11/2/2013 7:00 AM
By Dick Wanner Reporter
EPHRATA, Pa. — Chris High has been farming his 73 acres for 25 years. There are 77,000 broilers on the farm, and the cropland is planted to corn and soybeans. And there’s always been some kind of produce.
Two years ago, High and his wife, Dawn, decided to focus their produce business on Pennsylvania Simply Sweet onions.
They rented an acre and a half from a nearby farmer who has no livestock and had made no recent manure applications. There’s also a good well on the property.
The Highs could have grown onions on their 73 acres, but the couple were concerned about new safety regulations that embody a stew of abbreviations — FSMA, FDA, GAP, USFPA and the Harmonize inspection program.
The Food Safety Modernization Act, which was signed into law in 2011, includes regulations to guide the Food and Drug Administration in its Generally Accepted Procedures inspections.
The regulations are similar to the principles developed by the U.S. Fresh Produce Association in cooperation of the USDA for its Harmonize inspection program.
It’s called “Harmonize” because it replaced a hodgepodge of previous procedures that lent themselves to contradictions, conflicts and confusion.
“We used rented land without livestock because we did not want anything to get in the way of a GAP inspection,” Chris High said, “and the broilers could have been an issue.”
The FSMA regulations cover 600 pages of print and will not take effect until next year. The FDA is still fine-tuning the regulations and accepting comments until Nov. 15.
Anybody can comment by visiting fda.gov/Food/GuidanceRegulation/FSMA and clicking on the box that reads, “How to Comment on FSMA.”
When the regulations do take effect, High and his fellow members of the Lancaster County Vegetable Growers Association are ready.
The association is a farmer co-op organized initially to process and market mainly sweet onions and, more recently, to help its members deal with GAP requirements and inspections.
The co-op has about 80 members and represents some 100 acres of mostly sweet-onion production.
Most of the co-op members are Plain Sect growers who farm with horses and rely on family labor. High is mechanized and uses hired labor to harvest his crop.
High figures the co-op gives him and his neighbors a fighting chance at competing with Vidalia onion growers in Georgia, where one farmer might have 200 acres of crop and pays just one inspection fee.
High and his fellow co-op member each paid an independent auditor to perform their GAP safety inspections, but working as a group, they got a significant discount from what they would have paid as individuals.
The co-op also has a common processing facility and the ability to work as a group with one broker who moves their onions into the wholesale market.
Lancaster County probably has more than its share of roadside market stands, but High pointed out the near impossibility of selling his crop directly to consumers.
An acre-and-a-half yields about 80,000 onions, each of which has to be pulled from the soil and have its top cut off before it’s placed in a wagon to be taken to the packing shed.
He likes to confine his harvest to a four-day period, and needs 15 to 20 workers on each of those four days. His multifaceted farming business has a lot of parts, and glitches anywhere can complicate the whole works.
High’s confident that he — and his fellow co-op members — have helped minimize GAP inspection problems. And that is thanks in large measure to the work of Jeff Stoltzfus, an adult farmer educator with the Eastern Lancaster County School District in New Holland, and Peggy Fogarty-Harnish, who wears a couple of hats, one as a Penn State food safety educator and another as associate director of the Keystone Development Center, which works with farmers and their co-ops on business development.
Stoltzfus and Fogarty-Harnish have developed a template that helps farmers organize the information they need for a GAP audit.
The template is organized to follow the questions on an auditor’s form. Most of the Lancaster County clients who use the template are Plain Sect farmers who don’t use computers. So Stoltzfus and Fogarty-Harnish knew that it had to be a paper document with plenty of room for written comments.
While much of the information is repeated from farmer to farmer, some must be adapted to an individual operation. One farmer may have chickens, another dairy cows and another goats.
Each of these conditions will be addressed in an audit, and the farmer, with the help of the template, can tell the auditor his plans for dealing with his particular conditions.
Stolzfus and Fogarty-Harnish held a GAP workshop earlier this year in Hershey, Pa. Before the workshop began, just 13.5 percent of the 51 participants felt confident of their ability to write a food safety plan. After the workshop, their level of confidence had increased to 84 percent. The pair plan to offer more workshops.
Copies of the template can be obtained at extension.psu.edu/food/safety/farm/how-do-i-write-a-food-safety-plan/template-harmonized-food-safety-plan/view.
Fogarty-Harnish said that as of Oct. 16, some 930 copies of the template had been downloaded.
A dozen of the participants in the Hershey conference were Plain Sect growers who sell their crops to Four Seasons Produce in Ephrata.
David Hahn, Four Seasons’ director of procurement, had begun working with the growers in December of last year in an effort to get them all GAP certified for the 2013 season.
Hahn and a co-worker had piled their growers into a pair of Chevy Suburbans for the drive to Hershey.
Government is certainly a huge presence in food safety and GAP audits, but the real driving force is the marketplace, according to Hahn.
Four Seasons sells to retailers in an area that stretches from Boston to Richmond, Va., and west to Ohio. Most, but not all, of the retailers who buy from Four Seasons now want GAP certified commodities.
Which is why “we have moved fully to sourcing all our commodities from GAP certified growers,” Hahn said. “But I didn’t feel right saying to our guys, You need to be GAP certified this year, now go do it.’ I wanted them to see that we’re not just asking them to do it, we’re going to help them.”
The growers’ big concern, Hahn said, was that they would spend money to meet GAP specifications and then Four Seasons would hit the auctions when supplies were abundant and prices went down.
GAP can be expensive. Some of Four Seasons’ growers had to update packing sheds or even build new ones. Toilet facilities and handwashing stations are GAP requirements.
Irrigation water has to be tested. And horses in the field are a definite issue. If a horse does what horses do, the area where it relieved itself is marked off, and that crop is not harvested. It’s part of GAP.
Hahn reassured the growers that if they made the effort and investment to produce to GAP specs, then Four Seasons would take their crops. From Hahn’s perspective, it was a successful first season. All the growers were audited and he wasn’t aware of any problems.
He said he was confident the growers were doing a good job, and that confidence was reinforced when the FDA showed up at Four Seasons for an unannounced inspection two months ago.
“They pulled three bins of local cantaloupes,” Hahn said. “They swab-tested the cantaloupes, both the tops and the bottoms that were on the ground. Every one of them passed. And they were from horse farms. I’m proud of that.”
Hahn said the work that Stoltzfus and Fogarty-Harnish had done with the growers helped allay their concerns about the challenges of GAP certification. And he said the template was an important part of that work.
One man who’s seen a lot of those templates is Stanley Hess, who conducts audits on behalf of Equicert, a private Illinois company that was started in 2010 to help primarily horse-powered farmers deal with GAP audits.
Hess, who works out of Myerstown, Pa., said the template was helpful as he audited individual farmers, both the ones who grow for Four Seasons and the Lancaster County Vegetable Growers Association.
Audits can be quite time-consuming and expensive at the usual $100-an-hour rate farmers may pay if they contract individually for the work. The co-op struck a deal with Hess for $100 per farm.
Another keen observer of all things food is Jay Howes, Pennsylvania deputy secretary of agriculture. Howes said the state is keeping a close watch on the development of the new regulations.
Before the comment period ends on Nov. 15, Howes said, the department plans to ask the FDA to issue a set of preliminary regulations with time for another round of comments.
A good source of information about the issue is the transcript of a Penn State webinar from last year, which can be found at extension.psu.edu/food/safety/farm/gaps/frequently-asked-questions-on-the-usda-audit/view.
Dick Wanner can be reached at rwanner.eph<\@>lnpnews.com or 717-419-4703.