David Gombas of United Fresh emailed me a pdf of the first draft of the harmonized food safety standard this morning. I converted it to a Google document, available at this link. The document will also be posted to the United Fresh Web site.

The document is the work of the Produce GAPs Harmonization Initiative technical working group. Gombas stressed that the draft was a harmonization (blending) of 13 existing standards. “The next phase will be wordsmithing to ensure the standard is appropriate for the widest range of commodities, size operations, regions and production practices. It will also be worksmithed to ensure it is auditable,” he said in the email.

The next meeting of the GAP harmonization effort will be June 17-18 at Sysco headquarters in Houston. Gombas said he was seeking broad input for that meeting, and suggested the facilities could handle several hundred participants.

If you need to check with David about details of the Houston meeting, his email is dgombas@unitedfresh.org


Here is an excerpt from the standard about agricultural water:

2.6. Agricultural Water

2.6.1. Water System Description

2.6.1.1.A water system description shall be prepared.

2.6.1.2.Water sources and the production blocks they may serve shall be documented.

2.6.1.3.The description shall include one or more of the following: maps, photographs, drawings (hand drawings are acceptable) or other means to communicate the location of water source(s), permanent fixtures and the flow of the water system (including holding systems, reservoirs or any water captured for re-use).

2.6.1.4.Permanent fixtures include wells, gates, reservoirs, valves, returns and other above ground features that make up a complete irrigation system shall be documented in such a manner as to enable location in the field.

2.6.1.5.All local, state and federal regulations concerning water source shall be observed.

2.6.1.6.Water systems intended to convey untreated human or animal waste shall be separated from conveyances utilized to deliver agricultural water.

2.6.2. Water System Risk Assessment

2.6.2.1.An initial risk assessment shall be performed that takes into consideration the historical testing results of the water source, the characteristics of the crop, the stage of the crop, and the method of application.

2.6.2.2.A review or new assessment shall be conducted seasonally and any time there is a change made to the system or a situation occurs that could introduce an opportunity to contaminate the system.

2.6.2.3.The risk assessment shall address potential physical, chemical, and biological hazards and hazard control procedures for the water distribution system.

Produce GAPs Harmonized Food Safety Standard Page 6 of 31 DRAFT Version 5/13/2010

2.6.2.4.The risk assessment shall be used to develop a water management plan. In the event that the assessment identifies hazards or conditions likely to result in contamination, actions shall be taken to correct these conditions.

2.6.2.5.Corrective actions will be documented.

2.6.3. Water Management Plan

2.6.3.1.There shall be a water management plan to identify and mitigate risks associated with the water sy
stem on an ongoing basis.


2.6.3.2.The water management plan shall include the following: preventive controls, monitoring and verification procedures, corrective actions, and documentation.

2.6.3.3.Water testing shall be part of the water management plan.

2.6.3.4.As part of the monitoring and verification procedures for crops using water in the production of the crop, there shall be an SOP for ongoing water testing during the production and harvest season, which includes frequency of sampling, who is taking the samples, where sample is taken, how the sample is collected, type of test and criteria.

2.6.3.5.The frequency of testing and point of water sampling shall be determined based on the water source, its particular history, and the outcome of the risk assessment.

2.6.3.6.The monitoring and verification schedule shall be decided by the risk assessment, best practices within country of production, or applicable legislation.

2.6.3.7.As part of the water system plan, the water shall be tested prior to initial use. For water already in use, water sampling shall be conducted and a testing regime shall be established and in place. Water sampling should be done to establish the baseline for identifying control limits and action levels. If prior test results are available, they can be used to establish the baseline. If previous test results are not available, a testing regime shall be implemented to establish the baseline.

2.6.3.8.The testing regime shall be consistent with the water testing SOP. Subsequent tests may be necessary depending on the crop characteristics. For example, a crop that will undergo repeat foliar applications within its crop cycle would require additional samples to establish sufficient data.

2.6.3.9.Testing shall be performed and documented using established food safety risk criteria. The criteria shall be based on the results of the risk assessment or as defined in existing commodity specific guidance. When monitoring shows that the water meets the criteria for the intended use, then water from the source may be used. When monitoring shows that water does not meet established criteria or standards, the corrective actions noted in the water management plan shall be followed until the conditions have been mitigated and the non-conformity has been resolved.