GroupGAP Webinar
November 12, 2015
Questions and Answers
This review of the questions and answers from the webinar is designed to provide information and answer questions about the process about the USDA AMS Specialty Crops Program’s GroupGAP. The information and data are presented as resources for individuals as well as for public and private entities with an interest in the GroupGAP initiative, and intended for informational purposes only.
Q: Who is GroupGAP for?
GroupGAP is for producers of any size. While we focused our efforts during the pilot phase of the program on smaller producers, the GroupGAP concept is applicable to all growers. In reviewing the attendee list of today’s webinar, I see growers of all sizes in attendance, from small, local growers to larger producers who sell nationally and internationally.
Q: What is the cost of participating in the GroupGAP program?
There are several different sets of costs you will need to consider if you are looking to form a group. The first is the start-up cost associated with forming and implementing a group if you are not already an established group. The second set is the certification costs, which will vary depending on the size and scope of your individual group. We charge the SCI audit rate, as published in the Federal Register, which currently is $92 per hour. Certification charges will include the time it takes to review and approve your application, and conduct the on-farm verification audits as well as the QMS audit of the group.
Q: What will it take to implement a QMS? Will I need to hire new staff?
A quality management system (QMS) is a collection of business processes focused on achieving a quality policy and quality objectives to meet your customer’s requirements. A QMS addresses your group’s organizational structure, policies, procedures, and processes, and the resources you need to implement a group certification process. GroupGAP does not require that a group hire new staff to develop and manage a QMS, but you may choose to do that. During the pilot phase of GroupGAP, several groups developed and implemented their own QMS; others hired a contractor specifically to handle this task.
Q: How many audits will this program mean for a group per season? Will this increase or decrease
USDA’s presence on the farms in a group?
GroupGAP certification has two layers of audits. The first includes internal audits of all group members conducted by the group’s internal auditor. The second layer of audits is the formal GroupGAP certification audit conducted by USDA. This audit focuses primarily on the Group as a whole to determine if it has fully implemented its QMS, conducted the internal audits, and taken corrective actions on any non-conformances. As part of USDA’s audit of the group, we conduct onsite audits on a randomly selected percentage of growers.
Q: Who is considered a group?
There is no legal definition of a group, so we have some leeway in defining a group for purposes of GroupGAP certification. For our purposes, any group of producers and/or supply chain partners who come together to implement a shared food safety program can be considered a group. A GroupGAP group must have a central entity that takes responsibility for the group’s QMS and must be established in such a way to ensure effective management of the group.
Q: How many certificates will be issued?
A certificate will be issued to the group, with the option of issuing certificates to each group member as a member of the group.
Q: Will each certified participant be listed on the USDA GAP website?
Yes. The group itself will be listed as a certified entity and each grower within the group will be listed as certified as part of the larger group. The grower’s listing may show up as: Tomatoes-R-US Food Hub/ABC Farms.
Q: If we already have people who work on educating farmers, can they be used as internal auditors?
Yes. However, they will need to meet the USDA internal auditor requirements including completing USDA-specific training, which is the same training our Federal and Federal-state auditors must complete.
Q: What are the education/training requirements for internal auditors?
Internal auditors must hold high school diploma, have 3 years of post-high school education and/or work experience in an agricultural field, and successfully complete a basic auditor training course and whatever auditor training course is required for the food safety audit program selected.
Q: Can international groups be audited under the GroupGAP program?
For at least 2016, we are going to restrict participation in the GroupGAP Program to domestic groups. We will be looking at ways to include international groups moving forward, but not during the first year. If you represent a group of international producers, please let us know your interest in the program for 2017 and beyond so we can incorporate those locations into our discussions for coming years.
Q: Are there geographical limitations on a group?
No. Group participants can be geographically apart so long as a group can maintain control of participants, assure adherence to the group QMS, and complete internal and unannounced audits.
Q: If one farm fails an audit does the whole group fail?
That depends. Because this is a QMS-based program, the group needs to have a system for monitoring producers and product that are not in compliance. If there are systems in place to exclude product that does not meet the group’s requirements and the group can demonstrate that the system works, then the entire group does not fail. However, if a grower or growers had poor practices that cause an immediate food safety issue that affects the entire group, then a single grower could cause the entire group to fail.
Q: Which of the USDA GAP audits is the GroupGAP program based on?
Groups can choose to certify against any current USDA GAP audit (e.g., GAP&GHP, harmonized, or mGAP), including adding optional scopes such as food defense or the global markets addendum.
Q: How do I apply for GroupGAP?
We will begin accepting applications on April 3, 2016. Please check the GroupGAP webpage at http://www.ams.usda.gov/services/auditing/groupgap for additional information.
Q: Will my buyers accept GroupGAP as a GAP audit?
There are many different buyers in the marketplace who have specific requirements for their suppliers so a “one-size-fits-all” audit program isn’t necessarily possible. We do, however, regularly work with the retail and foodservice community to promote the various food safety audit-based programs offered by USDA, including the GroupGAP program. The take-home message for this question is that you will need to check with your buyers to determine if they will accept USDA GroupGAP.
Q: Is GroupGAP a Global Food Safety Initiative benchmarked scheme?
At this time, USDA is not recognized by the Global Food Safety Initiative (GFSI). We are working with GFSI to explore options that would allow USDA to be recognized in some way.
Q: Will GroupGAP audit reports be available as live data or PDF?
At this time, reports are issued as PDF documents to the groups. We are looking at options to provide live data in the future.
Q: October 3rd, 2016 launch? Did he mean April?
Yes, the launch date will be April 3, 2016.
Q: I may have missed it but is the definition of small grower - as defined by FSMA?
The definition for a small farm within the Food Safety Modernization Act rules can be found on the Food and Drug Administration’s website at: http://www.fda.gov/food/guidanceregulation/fsma/ucm334114.htm
Q: Have I missed the typical size of what a small or medium grower would be?
The definition for a small, medium, or large farm within the Food Safety Modernization Act rules can be found on the Food and Drug Administration’s website at: http://www.fda.gov/food/guidanceregulation/fsma/ucm334114.htm.
Q: Is GroupGAP currently or will it be accepted by large retailers like Wal-Mart, Costco, Kroger, etc.?
We regularly work with the retail and foodservice community to promote the various food safety audit-based programs offered by USDA, including the GroupGAP program. You will, however, need to check with your buyers to determine if they will accept USDA GroupGAP.
Q: Is it equivalent to GFSI standards?
USDA is not recognized by the Global Food Safety Initiative (GFSI), but we are working with GFSI to explore options that would allow for USDA to be recognized in some way.
Q: What are the savings between group certification and having the cost of a QMS?
We do not have any specific data to answer this question.
Q: Is the program set up so that individual farms within the group are audited at random and the
entire group result is based on the results of those random audits. Bottom line is that group
succeeds or fails based on the results of a few?
No. Under GroupGAP, there are two layers of audits. First, every grower in the group is audited internally to verify they are meeting the food safety requirements prescribed by the group. Internal auditors are employees or contractors of the group itself, and must meet strict USDA auditor criteria and complete training provided by USDA. The second layer of audits is a complete system review of the group carried out by a USDA auditor who reviews the group’s implementation of and adherence to its QMS and the internal audits. As part of the system review, a USDA auditor will randomly perform audits on a percentage of growers to ensure the internal audit process and the integrity of the program.
Q: Can an industry organized under a R&P program be considered a grower group?
We have tried to be as flexible as we can with the definition of a group, so we don’t see why an R&P program couldn’t potentially be a group. Any interested R&P program should check with its Board and the R&P Program to see if it is a fit for that specific Board.
Q: So let me get this right... If we participate GroupGAP we will be in compliance with FSMA?
AMS is engaged with the Food and Drug Administration’s (FDA) on a joint GAP review project that is reviewing the alignment of the USDA GAP program to the regulations under FSMA. We have committed to FDA and the industry that the USDA GAP program will be aligned with the rule and, at a minimum, meet the requirements of FSMA. In many cases, the USDA GAP requirements may be a bit more stringent than what is in the rule; the GAP program also takes into consideration industry best practices and the requirements of buyers.
Q: Does it really save money? Including admin costs, we are budgeting about 1,000/grower minimum
(when no financial assistance is available), which is similar to 3rd party audits
As with any business, there are economies of scale in regards to a return on investment. A smaller group may take longer to recoup its costs; a larger group might recoup its costs more quickly.
Q: In other words, after hiring a QMS coordinator, do the savings of a group GAP audit make sense?
It is an individual business decision for a group to consider when deciding whether or not to undergo group certification. For some groups, the savings could be significant. It’s important to keep in mind that there are other benefits to GroupGAP that are not just financial.
Q: Are GroupGAP requirements FSMA compliant?
AMS and FDA worked closely together as the Produce Safety Rule was being developed. An AMS employee served on a 3-year detail with FDA to help develop the rule. AMS is committed to ensuring its programs are in alignment with the FSMA requirements. Now that the major FSMA rules are final, we will continue to work with FDA through the joint AMS/FDA GAP review process to ensure our program is in alignment.
Q: What is the cost structure for GroupGAP? Does it increase based on the group, acreage, number of
facilities?
There are several different sets of costs you will need to consider if you are looking to form a group. The first is the start-up cost associated with forming and implementing a group if you are not already an established group. The second is the certification costs, which will vary depending on the size and scope of your individual group. We charge the SCI audit rate as published in the Federal Register, which is currently $92 per hour. The certification charges will include the time it takes to review and approve your application, and conduct the on-farm verification audits as well as the QMS audit of the group.
Q: What are the specific education/experience requirements for internal auditors?
Internal auditors must hold high school diploma, have 3 years of post-high school education and/or work experience in an agricultural field, and successfully complete a basic auditor training course and whatever auditor training course is required for the food safety audit program selected.
Q: Does a group of growers have to grow the same product to get certification?
No, it is up to the group to determine what they would like covered under their GroupGAP certification.
Q: Can Group Leaders also be Internal Auditors?
Yes, so long as they meet the internal auditor requirements. Internal auditors must hold high school diploma, have 3 years of post-high school education and/or work experience in an agricultural field, and successfully complete a basic auditor training course and whatever auditor training course is required for the food safety audit program selected.
Q: Do you envision this program ultimately eliminating the need for the Tester amendment?
The Tester Amendment is a section of the Food Safety Modernization Act that provides for exemptions to the Act for certain producers. The USDA GAP Program, including GroupGAP, is a voluntary, user fee funded program that is primarily used for market access by providing certification that a grower or grower group has implemented a food safety program to a specific food safety standard. Growers may be exempt from meeting the requirements of FSMA under the Tester Amendment, but still need to undergo a GAP/on-farm food safety audit to meet marketplace demands.
Q: So will the internal auditor be an employee of the farm? Or can it be a consultant hired by the
group?
This person is under the responsibility of the group, but doesn’t necessarily need to be an employee. You may choose to hire a contractor for that function.
Q: What is actually meant by “internal”? Can it be a contractor?
This person is under the responsibility of the group, but doesn’t necessarily need to be an employee. You may choose to hire a contractor for that function.
Q: When do you foresee putting protocols in place to allow third party auditors to conduct GroupGAP
audits?
Certification issued by USDA under the GAP Program, including GroupGAP, will be conducted only by USDA employees or state department of agriculture employees licensed by USDA to provide these services.
Q: Do you foresee setting a minimum standard for this program in the future? Or are growers going
to be audited to their own quality/food safety standards?
A group must choose a food safety standard that is one of the USDA approved audit standards listed on the USDA website (www.ams.usda.gov/gapghp).
Q: How do food safety standards get recognized?
A group must choose a food safety standard that is one of the USDA-approved audit standards listed on the USDA website (www.ams.usda.gov/gapghp).
Q: 1) When will the audit be revised to meet FSMA? 2) Will USDA GAP/GHP seek GFSI-benchmarking
in the future? If so, when? More and more customers are asking for GFSI-level certification and
this is a roadblock for creating a USDA GroupGAP program
AMS and the Food and Drug Administration are currently engaged in a joint GAP review project to ensure alignment of the GAP program to the FSMA requirements. USDA recognized the increased demand for producers to be audited against one of the GFSI benchmarked standards and is currently in discussions with GFSI to determine if there is a way for USDA to become recognized.
Q: How would a group auditor get USDA ISO auditor training?
Internal auditors may get ISO training from any accredited ISO training provider. Internal auditors do not need to get their ISO training from USDA.
Q: Are GroupGAP standards compliant with 'Harmonized GAP' for overseas acceptance?
A group can choose to use the Harmonized GAP Standard as part of their GroupGAP program.
Q: What is the cost for the application fee?
The application fee has not yet been finalized. When it is, it will be posted on the GroupGAP web page at http://www.ams.usda.gov/services/auditing/groupgap.
Q: You say this applies to small and mid-sized growers. Is that a requirement for membership in a
group? If so what defines small and large?
GroupGAP is for producers of any size. While we focused our efforts during the pilot phase of the program on smaller producers, the GroupGAP concept is applicable to all growers. In reviewing the attendee list of today’s webinar, I see growers of all sizes in attendance, from small, local growers to larger producers who sell nationally and internationally.