Growers Beware: Adopt GAPs or Else
By Richard F Stier and Nancy E Nagle, Ph D
The emphasis on food safety has Led to the adoption of the Hazard Analysis & Critical Control Points (HACCP) system by the food processing industry and food regulatory agencies throughout the world Codex Alimentarius, the international standard- setting body aimed at developing guidelines for food trade, has also adopted HACCP as part of its Code of Food Hygiene. In fact, if one talks to delegates to the Codex Committee on Food Hygiene, you will learn that HACCP literally “sailed” through the committee. Adoption of the system took only a few years, which is incredible when one understands that Codex Alimentarius is an organization in which change may take decades.
HACCP is a system that was developed to assure the safety of processed foods. However, this left a great deal of the food supply “uncovered”; specifically, the fresh fruit and vegetable business. Why do we say uncovered? HACCP is a system in which a food processor will identify potential hazards and build controls into the process to eliminate, reduce or control the hazard. With fresh produce, this is not realistic because it is literally impossible to eliminate or control all potential hazards. Processes designed to destroy or control most pathogens would render the fresh product unsaleable in most cases. Understanding this, representatives from industry, government and academia took steps to remedy this deficiency by developing Good Agricultural Practices (GAPs). The GAPs are a logical extension of HACCP into the fresh produce industry that utilize HACCP principles and prerequisite programs to reduce the potential of product contamination and thereby assure safety. Let’s take a look at the evolution of GAPs.
EVOLUTION OF GAPs
Good agricultural practices continue to evolve throughout the world. In the U.S., the Western Growers Association, the International Fresh-cut Produce Association, California Strawberry Commission, United Fresh Fruit & Vegetable Association, government agencies and the food industry have been and remain active in their efforts to develop training tools and other documentation to assure that growers produce foods that are free from foodborne hazards. The U.S. Food and Drug Administration’s (FDA) Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables, released on Oct. 26, 1998, addresses microbiological food safety. Chemical hazards are not ignored and are addressed in other documents.
In Europe, industry and government are following a similar path. The EUREPGAP certification protocols define “best practices” for global production of horticultural products. The key word here is “global.” As denizens of developed nations continue to demand fresh foods year-round, they must turn more and more to less developed nations to supply these products. But the demands do not stop at the foodstuffs themselves. These same people (and their governments) also demand that the produce that crosses international boundaries be safe and wholesome. The key to assuring that the produce that enters the world market is the development and implementation of GAPs.
These protocols are science-based systems designed to assure to a high degree of confidence that produce is safe. As one reads over guidelines that have been developed, it is easy to see that there is also what people once called “common sense” in these guidelines. The common sense practices have simply been codified. Adoption of GAPs, which may also be applied to fruits and vegetables destined for processing or to those used as ingredients, is seen as a burden by many Third World countries producing these export items. There are many in these nations who also perceive GAPs to be unfair barriers to trade that have been foisted upon them by the more affluent nations. This perception is way off the mark. The adoption of GAPs will not only help less-developed nations to build their businesses, but protect those businesses once the practices are established. One only needs to look at Guatemala and its raspberries to see how failure to uniformly adopt procedures hurts a whole nation. Of course, there are those who feel that the EUREPGAP protocols are inappropriate because they include issues such as child labor and humane animal treatment, which certainly are not food safety issues.
As an example of how adoption of GAPs can help build and maintain business, let’s look at the recent efforts in Belgium. To assure that the nation is able to meet the quality and safety demands of their customers, the Belgian Federation of Vegetable Trading and Processing Companies has established a “Quality and Food Safety System.” This system addresses the whole food chain (farmers, contractors, traders, processors and distributors) and integrates existing recordkeeping programs that have been implemented as part of HACCP or International Standards Organization (ISO) 9000. A nonprofit center, Centrum voor Kwaliteitscontrole (CKC) was created to monitor the system. The CKC seeks accreditation from the Belgian Food Safety Agency and EUREPGAP accepted in the future.
MICROBIOLOGICAL AND CHEMICAL SAFETY OF FRESH PRODUCE
Microbiological food safety was the driving force behind the development of GAPs. A review of past literature reveals that there have been an increasing number of foodborne outbreaks associated with fresh produce in recent years. In some of these, such as the tragic event involving radish sprouts in Sasaki, Japan, there were deaths. A similar review of the literature in five or 10 years should help document whether the implementation of GAPs has made a difference.
Pesticide issues have received significant attention for many years. Assuring microbiological safety of produce, whether it is destined for the fresh market or elsewhere, is a task that requires company-wide commitment, along with continued focus on chemical hazards. In fact, potential chemical contamination from pesticides may be an even greater concern when buying produce from Third World nations. The amount of pesticide on a product may not be enough to cause illness, but it can surely result in a product being denied entry to a country or exit from an importing nation. For example, there are many countries that have established export authorities whose main mission is to test products destined for export. Without a certificate from this state-run laboratory, the product cannot move forward. This places a burden on growers, but as has been emphasized time and again, does little to assure food safety. Development, implementation and adherence to a program is what will assure safety, not random sampling.
This mentality was underscored at the Codex Coordinating Committee Meeting in Cairo, Egypt, in January 2001. The delegates initiated a movement to develop sampling procedures and guidelines to assure food safety. After a rather lengthy discussion, Dr. Alan Randall from the Food and Agriculture Association in Rome took the floor and explained that the Codex Committee on Food Hygiene has adopted HACCP as the best tool for assuring food safety and that testing was not the way to go. The bottom line is that there are inherent biases throughout the world when it comes to a systematic and proactive approach to food safety employing HACCP or GAPs.
As noted earlier, there is a push the world over to assure food safety. The United Fresh Fruit and Vegetable Association has a working group that has been developing a document entitled, “Food Safety Questionnaire for Fresh Fruits and Vegetables.” This document is now being reviewed and should be released in Fall 2001. The questionnaire uses the FDA’s Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables as the basis for designing questions, and also incorporates questions that emphasize chemical safety. The stated objective of the questionnaire is to “assess how or if food safety issues are addressed in the production and distribution of fruits and vegetables.” The document emphasizes that there are no right or wrong answers. It is designed to be user-friendly and to help the grower or packer better understand potential risks and where they need to do more work. It is very similar to the “EUREPGAP Protocol for Fresh Fruits and Vegetables.” The big difference is that the EUREPGAP protocols are mandatory rules that must be followed if an operation wishes to be certified.
The human element is the most difficult of all to control. Growers can provide proper facilities, conduct what they feel are adequate worker education programs and pay their workers a fair wage, but the bottom line is that the large majority of the workers in fields or packing houses are at the lower end of the economic and education spectrum. All too often, they see the work as simply a job, and are not aware of (or may not care about) the consequences of their actions. This is why worker education programs must not only address basic hygiene issues, but also must ensure that the practices taught are shown to be relevant to the workers’ jobs and lives. For example, consultants have been successful in teaching food safety and hygiene to the predominantly female agricultural work force in Egypt. They found that the women were eager to learn methods that would help them keep their own families safe.
There have also been considerable research efforts expended throughout the world to develop methods that will help minimize the potential for microbial contamination of fresh produce. Researchers have looked at the effects of antimicrobial agents, such as chlorine compounds and ozone, temperature, electrochemically activated water (ECA), simple washing, organic acids and others, toward this end. The bottom line is that none of these methods will provide a 100% guarantee that you will be able to remove all the potential pathogens. A recent report by the Institute of Food Technologists (IFT) expert panel on cut produce emphasized another concern in this area. The panel concluded that there really is no single method that can be used to evaluate the efficacy of antimicrobial treatments. They did, however, establish basic guidelines for evaluating these products and procedures.
THE EMPHASIS ON CERTIFICATION
The Europeans place a greater emphasis on certification than do North Americans. ISO, HACCP and GAP certification programs and certifying agencies are much more prominent on the European side of the Atlantic. The EUREPGAP Protocols are the guidelines that growers, distributors and packing houses must meet if they wish to be certified. When one reads over the EUREPGAP Protocols, there are both required and encouraged (recommended) practices. They do not specify exactly how the requirements are to be achieved, however. Therefore, the producer has a certain leeway in meeting the goals.
EUREPGAP is in the process of evaluating certifying agencies from around the world. The vast majority of these are European firms, but the U.S. is represented by Scientific Certification Systems (SCS) of Oakland, CA, and Primus Labs of Santa’ Maria, CA. Both of these operations have actively worked with growers and packers in California and Mexico, and have assisted in the development of programs to enhance the safety of produce. Eric Engbeck of SCS commented, “We have applied for and will follow the yellow brick road to EUREP accreditation. The arrangements with EUREP are complicated, but it is the only game in town if your produce shipper is selling to Europe.
Certification is a process that has its pros and cons. Obviously, any company that has made the effort to be certified has exhibited a certain amount of discipline. They have met the requirements of the certifying agency, which for GAPs include the development of programs and documentation of these activities. Areas in which programs need to be in place include site history, fertilizer usage, water sources, irrigation, chemical use and storage, crop protection, harvesting, post-harvest handling and treatments, waste, worker health, safety and education and environmental issues. The ultimate goal is consumer health and, therefore, customer satisfaction. On the other hand, certifying agencies and the companies that they certify must avoid falling into the trap of thinking that GAPs and their maintenance is an exercise in recordkeeping. GAPs, like HACCP, is a system to assure the production of safe foods. If the program goes from a quality/safety system to one in which the documents take precedence, the program will be compromised. This is precisely what has happened with ISO 9000, and it is one of the reasons that ISO 9000 2001 has incorporated customer satisfaction into the new programs.
THE PROACTIVE APPROACH IS GOOD BUSINESS
There are certain areas in which certification will be mandatory for people to do business. Certification is also a means whereby growers and packers can demonstrate their commitment to the production and distribution of safe foods. The certificate, then, becomes a marketing tool that allows them to enter markets previously out of reach.
Adoption of GAPs has another benefit that all persons involved in the food business need to understand: The law requires that the foods you distribute are safe and wholesome. It is good business to do everything in your power to achieve this goal. Failure to adopt and follow what are acknowledged as “best practices” can have a significant and adverse economic affect on your business in the event of a food safety problem. Look at two of the more high-profile outbreaks over the past few years: Sara Lee’s cooked meat products and Odwalla’s juice. Products manufactured by each company were implicated as being the causative agent in an outbreak, but because these companies failed to follow best practices (due diligence), their penalties were much greater. The potential costs of failing to “do it right” can be high.
The world is becoming a smaller place with each passing day. The Internet allows instantaneous communication and provides scientists, regulators and members of the industry with updates of what is going on throughout the world as they happen; events that are both good and bad. This shrinking world market also has led to the development of a global economy in which foods from all over the world may be found anywhere in the world at any given time. A walk through the produce section will reveal kiwis from New Zealand, raspberries from Guatemala and green beans from central Africa. Any food that is traded in this global economy must adhere to one basic criteria, however. It must be safe and wholesome. If it is not, that product and the nation producing that product will suffer. Adoption of GAPs will not only help assure that the food is safe, but will help food-producing nations to protect and build their businesses. GAPs are an investment in the future.
Richard F Stier is the director, technical services for the Agricultural Led Export Business project based in Cairo, Egypt. He has international experience in food safety, food plant sanitation, quality systems, process optimization, GMP compliance and food microbiology. He has worked with a wide range of processing systems and products, including canning, freezing, dehydration, deep-fat frying, aseptic systems and seafood processing. Prior to joining this project, he worked as an independent consulting food scientist, which allowed him to work with clients in Europe, Asia, Africa, Mexico and throughout the U.S. As director of quality assurance for Dole Packaged Foods North American operations, he was responsible for building programs targeted at ensuring the quality of Dole value-added products packed in the U.S. and with the National Food Processor’s Association, where he served manager of the microbiology section for the Western laboratory.
He is an active member of the Institute of Food Technologists (IFT), AOCS, IAFP, and the NCAACC. He also serves as a contributing editor to Sosland Publishing’s “Baking & Snack” magazine and is a regular contributor to Food Safety and Security, a publication based in the U.K. He recently served as the councilor representative to the Institute of Food Technologists Executive Committee, where he has helped IFT develop its international programs. He is now a member of the IFT’s Committee on Global Interests.
Nancy E. Nagle, Ph.D., is currently the president of Nagle Resources, a food safety consulting firm and the food safety advisor to the California Strawberry Commission. She lectures in the Department of Nutrition and Food Science at San Jose State University. Her clients include growers, shippers and processors of fresh produce products. She was the vice president of research & development for Dole Fresh Vegetables, Inc., after sewing six years as the director of product development for the Dole Food Co., Inc. Her prior experience includes a position as corporate director of research for the Orval Kent Food Co., Inc., a major manufacturer of prepared salads and several research positions with Hunt-Wesson Foods, Inc.
She was a member of the National Advisory Committee on Microbiological Criteria for Foods from 1998-2000. She is an active member of the Institute of Food Technologists, chair of NCIFT past chair of the IFT Fruit and Vegetable Products division, and a former president of the American Oil Chemists Society, Southwest Chapter. Nagle also serves on the Fruit and Vegetable Quality and Safety Professional Development Group of The International Association for Food Protection (IAFP). She serves on the Advisory Council to the Texas A&M University Institute of Food Science & Engineering She has served on a number of NFPA committees, the board of directors for the International Fresh-cut Produce Association, is currently a member of the IFPA Technical Committee, and on the Produce Microbiology Committee for United Fresh Fruit & Vegetable Association. She has also been an adjunct professor and serves on the Industry Advisory Committee for Chapman University, Food Science Department.
1. U.S. Department of Health and Human Services, Food and Drug Administration. Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables. Oct. 26, 1998. (www.fda.gov).
2. EUREP. EUREPGAP Protocol for Fresh Fruits and Vegetables. March 2001. (www.eurep.orgfindex-efp.htm).
3. U.S. Department of Agriculture. “Belgium/Luxemborg Sanitary/Phytosanitary/Food Safety Quality and Traceability Concerns Spread to Vegetable Producers Chain.” Foreign Agricultural Services GAIN Report #BE1025. June 29, 2001. 4. Codex Alimentarius. Codex Coordinating Committee Meeting, Near East Meeting, Shepheard Hotel, Cairo, Egypt. January 30-February 1, 2001.
5. United Fresh Fruit and Vegetable Association. Food Safety Questionnaire for Fresh Fruits and Vegetables: 3rd Draft. Alexandria, VA. 2001.
6. Institute of Food Technologists Expert Panel. Standardization of a method to determine the efficacy of sanitizers in inactivating human pathogenic microorganisms on raw fruits and vegetables. Journal of Food Protection, (64)7, pp. 1079-1084. 2001.
7. Engbeck, E. Personal communication. 2001.
Interim Results of FDA’s Survey of Domestic Fresh Produce Released
In May 2000, the U.S. Food and Drug Administration (FDA) initiated a 1,000-sample survey focused on high-volume domestic produce that is generally consumed raw. The FDA Survey of Domestic Fresh Produce, as part of the government’s Produce Safety Initiative, is intended as a complement to the data on the incidence of microbial contamination gathered as part of the Imported Produce Sampling Assignment launched in 1999. Through this survey, the agency aims to detect the levels of pathogen contamination that might result from a failure to follow adequate Good Agricultural Practices (GAPs) and Good Manufacturing Practices (GMPs), not every incidence of low-level, sporadic contamination.
The stated objective of the domestic survey was to collect 125 samples of each of the following commodities from U.S. produce growers: cantaloupe, celery, cilantro, green onions, loose-leaf lettuce, parsley, strawberries and tomatoes, and to analyze each for the presence of Salmonella and E. coli 0157:H7. It was also determined that all samples (with the exception of strawberries due to the lack of a validated testing method) would be analyzed for the presence of Shigella.
The survey is scheduled for completion at the end of September 2001. Tables 1-3 represent an update of the results of the analyses performed by FDA through July 31, 2001. The overall results reported that of 767 samples analyzed thus far, 12 samples were noted as “violative,” with a violation rate of 1.6%.
Categories: Contamination Control: Chemical, Microbiological; Food Types: Produce; Regulatory: Audits/Certification/GFSI, HACCP; Supply Chain: Growers/GAPs; Testing and Analysis: Chemical, Methods