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  • From: KAKerby AT aol.com
  • To: market-farming AT lists.ibiblio.org
  • Subject: [Market-farming] GAP summary (long)
  • Date: Mon, 15 Mar 2010 12:31:09 EDT

Good morning all.  I've held off writing up my GAP thoughts because I wanted to talk to a variety of other growers first, to see what their impressions were in addition to my own.  What I found was that grower impressions were all over the map.  Before I get into those reactions, here is a very general summary of what I learned:

Top Bad Guys: E coli, salmonella and listeria.  But Campylobacter is in there too.  If growers have a program that adequately control E coli and listeria, the other two are probably adequately controlled as well.  E coli has become something of the poster child for this whole thing because it is so pervasive in the environment, is so adaptable to various conditions, and its toxicity is so variable, ranging from beneficial to deadly.  Any warm-blooded animal can produce any of the variants, from beneficial to deadly, simultaneously, and without showing outward signs of illness.  So the presence of one form of E coli is sufficient to be concerned about the presence of more toxic forms.  Salmonella is the most common form of mild to moderate sicknesses by number, but listeria is the biggest single killer.  Campylobacter is a distant fourth, but is still significant from both a public health and economic impact standpoint.
 
Manuring/Harvest separation times: The standing 90 day separation for above-ground crops and 120 day separation for root crops stands, for now.  But strong research results are coming in that indicate that separation time should be increased to 200 days where possible because E coli continues to live in soil for much longer than anyone expected.  This seems to be the case regardless of how the soil is managed.  The vast majority of manuring issues with E coli can be dealt with by manuring the beds or fields in fall rather than springtime.  One of the specific things I asked during that second workshop was whether E coli survival rates had been tested in certified organic ground; those results are being compiled now but seem to be fairly consistent with previous results that E coli can remain viable in soil up to 200 days after application.  Also, the carrot/onion study I cited before was only one of a whole body of research, all of which show that E coli (and the others) are very persistent in a wide variety of environments, and very potent once ingested.

Irrigation: overhead irrigation is being strongly discouraged wherever possible, because one of the greatest contamination risks comes from contaminated water being sprayed on crops.  Drip irrigation is the hands-down recommendation for most applications where scale allows, but any form of irrigation which keeps water on the ground is recommended over irrigation wheel, pivot systems and similar.  In terms of sheer contamination potential, irrigation water is the greater threat than actual manure application, simply because water can carry contamination to untreated fields where manures are not otherwise present.
 
Employees: employee movements in the field remains the #1 source of contamination.  Of those movements, failure to wash hands is the single most common form of employee-caused contamination.  Many farms face greater GAP challenges on the employee front than they do on the manuring front, because all levels of the operation - pre-planting cultivation, planting, in-row weeding, harvesting, processing and packing - can involve the potential for contamination to spread from where it is to where it shouldn't be, particularly from the restroom to the fields.
 
Equipment management: the general rule of thumb is that existing cleaning methods for equipment is fine IF that cleaning addresses any pockets, crevices, nooks/crannies and other corners where dirt or contamination can otherwise build up.  Harvest crates were a huge topic, because they are handled so often, commonly stored fairly dirty, and come into direct contact with ready-to-eat fresh produce.  Ventilation was also important because any contamination there spreads aerosolized bacteria throughout the rest of the operation.
 
Composting: the recommended method for composting remains the certified organic protocols, which are not expected to change. 
 
Documentation: there are no universal documentation requirements, but the more specific the documentation is already in place (or can be put into place) the less impact the grower will suffer during any particular contamination issue.  For instance, one recent contamination issue found contamination occurred from one grower whose produce went to two wholesalers.  One wholesaler kept impeccable records and was able to identify the boxes containing that grower's produce from the suspect date range, and pull just those boxes out of circulation.  The other wholesaler didn't keep such good records and that produce had been mixed in with other growers' product.  Everything that had come in during that date range was therefore suspect and had to be pulled out of distribution.  Growers were told during the session that if they couldn't make any other changes to their practices, invest time in their recordkkeeping to help minimize the impact if a contamination event ever did occur.  Records like "this field manured on this day, planted or cultivated or harvested with X crop by Y employee, packed in box #x to #y by Z employee, shipped such-and-such date" is the type of documentation they're looking for.  In most instances, records kept for certified organic operations are sufficient with very little tweaking.
 
GAP recommendations versus certified organic standards: any grower who is already certified organic is already 95% of the way to meeting GAP standards.  A review and refinement of cleaning practices and employee habits would probably provide the other 5%.  Certified growers are also already meeting the bulk of the record-keeping recommendations as noted above.
 
Now, for grower/market manager/public reactions: Some growers I know got disgusted very quickly, and didn't attend the second session.  Several of the growers I talked to considered GAP just one more thing they knew was coming down the pike.  One attendee was the farm manager for one of our larger operations in the area, and she had worked at other on-farm processing facilities, one of which suffered a listeria contamination that had shut down the operation.  She seemed eager to get her employees started on these new guidelines.  Her biggest worry was trying to make management understand this was not optional for liability reasons, even though they were still only guidelines.  Other growers didn't fret too much about these changes either because their procedures were already very close to what was being recommended, and/or they operated without manures and/or employees.  Oddly, the certified organic growers were the most annoyed even though they were already the closest to meeting the new recommendations.  And finally, a number of growers I have spoken to expressed concerns that this was just another piece of the "Monsanto taking over the world" machinery.  While I am not privy to Monsanto's diabolical plans, I came away from these sessions feeling like that particular response was an over-reaction, and perhaps even an unfortunate and damaging over-simplification, for what is a much more complicated and very-long-running topic. 
 
Perhaps the most telling part for me came a few days ago, when an email was sent to area growers from a local farmer's market manager.  She said that she had already been contacted by an number of market customers, asking if it was still safe to buy from vendors at the market, because of food safety concerns.  Some of those customers specifically asked if the market had a GAP requirement in place for the vendors who sold there.  That particular market manager has asked for a special vendors meeting where that topic will be discussed, and hopefully a strategy formulated that everyone can buy into (literally or figuratively), to help reassure buyers that the market is selling safe produce.  As was predicted in class, any sort of regulatory legislation is probably secondary to the buying public's demands for some kind of food safety accounting system.
 
My own farming system relies very little on employees so I only have myself to train in that regard, but we rely heavily on manure and compost.  I asked myself several times if, having learned what I learned in class, I would consider making these recommended changes on my own without any outside pressures from regulatory bodies or customers.  I have to say that, given what I've learned, I would already be putting these changes in place anywhere/everywhere they apply to my operation. 
 
Also, from a historical perspective, there is a lot of precedent for any new set of guidelines or recommendations to be met with much gnashing of teeth and predictions of "the end of things as we know them".  Yet that doom never materializes.  The meat and dairy sectors have already gone through this process, and small scale producers have weathered that transition in both sectors.  Some would argue that small scale processors were given a leg up if they could meet the initial costs, because they were then able to compete more effectively in the more lucrative retail marketplace.  I firmly believe this is going to be the same result for GAP produce recommendations. 
 
Bottom line, the marketplace will continue to demand tighter growing, processing and packing conditions of produce growers, whether those demands are justified or not.  When I got that email from the farmers market manager, I realized two things - first, if there is some diabolical plot, that's now a moot point because the public has already reached a point of deciding they need this for their own protection.  As a grower, I can either meet that requirement, or not sell to them.  And that pool of "buyers who don't care" is shrinking every day.  Secondly, if I am angered or frustrated or further taxed as a result of all this, it would seem the best application of my limited energies would be to first meet the requirements so I can at least continue to sell, but then also ramp up my educational efforts to help demystify this magical thing we do called growing.  Only when people are well educated about the real risks, and real benefits, will they collectively decide that our methods are better than any other approach.  So, at the end of the day, that's what I'm going to do.
Kathryn Kerby
Frog Chorus Farm
Snohomish, WA



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