4
ALBA Case Study: ALBA’s GroupGAP Food Safety Program BACKGROUND: The Agriculture and Land-Based Training Association (ALBA) is a 501(c)3 non-profit organization. Its mission is to create economic opportunity for limited-resource and aspiring organic farmers through land-based education in the heart of the Salinas Valley. Each year ALBA trains 35 aspiring farmers in the Farmer Education Course and help grows the farm-businesses of an additional 40 participants in the Organic Farm Incubator. The majority of our participants are current or former farm workers. Incubator participants grow an array of vegetable crops and berries at ALBA’s training facility, which includes 90 farmable acres, a classroom, mechanic’s shop, and a produce cooler. Since its founding in 2001, ALBA has trained more than 450 participants and over 150 have farmed at ALBA or gone on to be successful independent farmers. 2006 Produce contaminated with E. Coli 0157:H7 makes national headlines 2011 FSMA passed into law 2015 Produce Safety Rule finalized 2010 Launches food safety program 2011 First group of ALBA farmers achieve 3rd-party food safety certification 2011 -2012 ALBA Organics reaches peak sales 2012 Requires all of its farmers to obtain 3rd-party food safety certification 2013 Pilots GroupGAP certification program 2015 Fully adopts GroupGAP for food hub and farmers in years 1-3 2018 Requires all of its tenant farmers to participate in GroupGAP In 2006 produce contaminated with E. Coli 0157:H7 originating from San Benito county resulted in three deaths. Food safety scrutiny began to dramatically increase both regionally and nationally. Trade organizations, certification companies and the USDA began to develop auditing schemes, as buyers increasingly required food safety plans and third-party audits of growing and handling practices. The Food Safety Modernization Act (FSMA) was signed into law in 2011 and was the first major overhaul of our nation’s food safety practices since 1938. As part of FSMA’s Produce Safety Rule, there are new regulations for farms that grow fresh produce and for facilities that process food for people to eat. One of the end results of this legislation is that most all farmers are, or will be, legally required to have 3rd- party food safety certification. From 2005-2016, ALBA’s food hub (ALBA Organics) provided produce cooling, aggregation, marketing and distribution services. At its peak in 2012, the food hub sold over $5,000,000. The peak sales and growth of ALBA Organics coincided with the rapid changes in the food safety landscape. ALBA Organics’ customers included large retailers, such as Trader Joe’s and Whole Foods, as well as other prominent wholesale buyers. ALBA began developing a food safety program in 2010. In 2011, ALBA helped its first group of farmers achieve Good Agricultural Practices (GAPs) certification through a third-party. By 2012, ALBA required all of its incubator farmers, and farmer vendors to the food hub, to achieve 3rd-party food safety certification. When ALBA launched its food safety program, farmers were responsible for covering the costs of the third-party audits, which were generally around $800-$1,000/each. ALBA found grant funds to cover technical assistance, workshops, and the development of food safety plans. This was a big investment for both farmers and the organization. Certainly, food safety has been the largest regulatory hurdle to farmer development in ALBA’s recent history.

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Page 1: Case Study: ALBA’s GroupGAP Food Safety Programngfn.org/resources/ngfn-database/ALBA_GGAP Cast... · such as Trader Joe’s and Whole Foods, as well as other prominent wholesale

ALBA

This material is based upon work that is supported by the National Institute of Food and Agriculture, U.S. Department of Agriculture, under award number 2015-38640-23779 through the Western Sustainable Agriculture Research and Education program under subaward number 150893-0001-205. USDA is an equal opportunity employer and service provider.”

Case Study:ALBA’s GroupGAP Food Safety Program

BACKGROUND: The Agriculture and Land-BasedTraining Association (ALBA) is a 501(c)3 non-profit organization. Its mission is to create economic opportunity for limited-resource and aspiring organic farmers through land-based education in the heart of the Salinas Valley. Each year ALBA trains 35 aspiring farmers in the Farmer Education Course and help grows the farm-businesses of an additional 40 participants

in the Organic Farm Incubator. The majority of our participants are current or former farm workers. Incubator participants grow an array of vegetable crops and berries at ALBA’s training facility, which includes 90 farmable acres, a classroom, mechanic’s shop, and a produce cooler. Since its founding in 2001, ALBA has trained more than 450 participants and over 150 have farmed at ALBA or gone on to be successful independent farmers.

GroupGAP RESOURCESALBA

web: www.albafarmers.org | office phone: (831) 758-1469primary contact: Nathan Harkleroad, Program Director | e-mail: [email protected]

Wallace Center at Winrock Internationalweb: www.wallacecenter.org | phone: (703) 685-8699

primary contact: Will Gray, Senior Program Associate | e-mail: [email protected]

USDA AMS GroupGAP Programweb: www.ams.usda.gov/services/auditing/groupgap | phone: (202) 720-5021

primary contact: Audrey Draper, Audit Programs Coordinator | e-mail: [email protected]

2006Produce contaminated with E. Coli 0157:H7 makes national headlines

2011FSMA passed into law

2015Produce Safety Rule finalized

2010Launches food safety program

2011First group of ALBA farmers achieve

3rd-party food safety

certification

2011-2012ALBA Organics

reaches peak sales

2012Requires all of

its farmers to obtain 3rd-party

food safety certification

2013Pilots

GroupGAP certification program

2015Fully adopts

GroupGAP for food hub and farmers in

years 1-3

2018Requires all

of its tenant farmers to participate in

GroupGAP

In 2006 produce contaminated with E. Coli 0157:H7 originating from San Benito county resulted in three deaths. Food safety scrutiny began to dramatically increase both regionally and nationally. Trade organizations, certification companies and the USDA began to develop auditing schemes, as buyers increasingly required food safety plans and third-party audits of growing and handling practices. The Food Safety Modernization Act (FSMA) was signed into law in 2011 and was the first major overhaul of our nation’s food safety practices since 1938. As part of FSMA’s Produce Safety Rule, there are new regulations for farms that grow fresh produce and for facilities that process food for people to eat. One of the end results of this legislation is that most all farmers are, or will be, legally required to have 3rd-party food safety certification.

From 2005-2016, ALBA’s food hub (ALBA Organics) provided produce cooling, aggregation, marketing and distribution services. At its peak in 2012, the food hub sold over $5,000,000. The peak sales and growth of ALBA Organics coincided with the rapid changes in the food safety landscape. ALBA Organics’ customers included large retailers, such as Trader Joe’s and Whole Foods, as well as other prominent wholesale buyers. ALBA began developing a food safety program in 2010. In 2011, ALBA helped its first group of farmers achieve Good Agricultural Practices (GAPs) certification through a third-party. By 2012, ALBA required all of its incubator farmers, and farmer vendors to the food hub, to achieve 3rd-party food safety certification. When ALBA launched its food safety program, farmers were responsible for covering the costs of the third-party audits, which were generally around $800-$1,000/each. ALBA found grant funds to cover technical assistance, workshops, and the development of food safety plans. This was a big investment for both farmers and the organization.

Certainly, food safety has been the largest regulatory hurdle to farmer development in ALBA’s recent history.

Page 2: Case Study: ALBA’s GroupGAP Food Safety Programngfn.org/resources/ngfn-database/ALBA_GGAP Cast... · such as Trader Joe’s and Whole Foods, as well as other prominent wholesale

Table 1. Costs for GroupGAP food safety program at ALBACost Category 2017 Actuals

(covered 100% by ALBA)

2018 Farmer Cost Share

Notes

Quality Management System Audit $3,000 %50 Charged by AMS

Quality Management System Administration

$2,000 0% Staff member + consultant time

External Audits $4,200 100% Performed by CA Dept. of Food and Agriculture

Internal audits $15,600 50% Staff member and consultant time; 1 scheduled and 2 unannounced audits per farmer

Additional technical assistance $6,500 0% Staff member + consultant time

Required workshops $2,080 0% Workshops: Orientation to GroupGAP and Basic GAPs and Symptoms of Food-borne Illness; several others added in 2018

2017 actuals = $33,380; est. $1,669/participant

Based on 2017 actuals and cost share projections, farmers pay flat rate of $300 in year 1; $500 in years 2-4; $700 in years 5+

Sharing the food safety costs with farmers was an essential move towards sustaining ALBA’s food safety program. The 2018 GroupGAP fee to farmers is significantly less than what farmers would be paying for independent food safety certification, which could easily run $2,000+ for the development of an individual or custom food safety plan, mock audit and third-party audit. With the cost share in place, ALBA anticipates approximately $15,000 in revenue from farmers to cover food safety costs for 2018. ALBA will re-evaluate the costs and fees to farmers each year.

GroupGAP is a USDA farm food safety program that provides the entire specialty crops industry the opportunity to supply and buy fruits, vegetables, and related products that are certified as being produced using GAPs. This allows small to middle-sized farmers, food hubs, cooperatives and marketing organizations to band together and pool resources to achieve USDA GAP certification. This includes sharing the costs of training and certification. GroupGAP includes options for both USDA GAP & GHP, and Harmonized GAP certifications.

In 2013, ALBA was selected along with 5 other organizations to pilot a GroupGAP food safety certification program. An organization wishing to implement a GroupGAP program must develop a Quality Management System (QMS) that is audited, annually, by the USDA’s Agricultural Marketing Service. A QMS is a formalized system that documents processes, procedures, and responsibilities for achieving quality policies and objectives.

LESSONS LEARNED ANDBEST MANAGEMENT PRACTICES:

• Cross-training is important. Food safety is rapidly evolving into a technical regulatory arena. Turnover of key food safety staff can leave an organization scrambling to ‘plug holes’ in the system. There is a need to train and retain multiple internal auditors.

• Budget for consultants and professional development. Most organizations will benefit from outside consultation. Performing audits, developing a QMS, and deciphering the complexities of food safety are not for the newly initiated. Over time, an organization can develop internal staff capacity and decrease reliance on outside assistance. Food safety professional development is expensive with some courses running thousands of dollars, requiring travel and taking a week to complete.

• Develop relationships. ALBA participates in the GroupGAP Community of Practice organized by - the Wallace Center at Winrock International. This allows ALBA to learn directly from other practitioners and stay up to date on GroupGAP program changes. The USDA AMS is also an important relationship, as they administer the GroupGAP program.

• Develop a culture of food safety. This is especially important in the context of the GroupGAP. Staff implementing the food safety program need complete buy-in from management to be effective. All staff within the organization need to participate in the food safety program and take it seriously.

• Increase the number of participants in the group. To a point, the more farmers that participate, the more cost-effective the program can become for individual farmers. This is achieved by spreading out hard costs for the program (like the QMS audit, workshops), as well as the external audits costs. With a large enough group, farmers may be able to pay for the full cost of the program at a competitive rate.

• Communicate clearly with farmers. It is important that participants understand how GroupGAP fits into the larger picture of food safety, such as federal regulations, and the potential to open markets. They need to know what their commitment is under the program and what they should expect from the organization. It is important to develop and bring this language into a GroupGAP consent form and use it consistently in all farmer interactions.

BENEFITS OF GROUPGAP FOR ALBA:• Decreased farmer food safety costs. This is important for an organization such as ALBA that strives to reduce the start-up costs for its beginning farmers and is working with a population with limited resources.

• Standardization of food safety practices for farmers in the incubator. This puts ALBA, its participants, and potential buyers on the same page with regard to food safety. Also, it provides internal controls and a standard level of professionalism.

• Technical assistance and workshops under GroupGAP fit neatly into the standard workshop and technical assistance structure of ALBA’s programs. This type of farmer assistance can often be funded through grants and is another way to help lower the costs to farmer participants.

• Partnership with farmers. Due to the cost share, both farmers and ALBA are incentivized to be efficient and find ways to reduce costs. This creates a sense of ‘being in it together’.

CHALLENGES OF GROUPGAP FOR ALBA:• Organizational costs. Large and sometimes unanticipated costs associated with the food safety program are on ALBA, such as qualified staff, consultant time, and QMS administration. For example, in 2018 we expect to do a major update of the QMS. This will have associated costs but will hopefully pay off down the road with a more efficient system.

• Increased staff resources. Given the cross-cutting nature of the QMS, most ALBA management and staff have been drawn into food safety as part of their work responsibilities. This redirects resources away from other parts of ALBA’s training program. Many staff are required to take lengthy and expensive trainings to be qualified to assist with the management of the group.

A QMS helps coordinate and direct an organization’s activities to meet customer and regulatory requirements and improve its effectiveness and efficiency on a continuous basis. One of the main ways the GroupGAP saves money on certification costs is that only a subset of farmers receive an external audit (usually by state departments of agriculture); however, the organization managing the group must develop a system and allocate resources for providing internal audits, as well as managing the QMS.

After completing the pilot, ALBA fully adopted GroupGAP in 2015 as a system for managing food safety for farmers years 1-3 in the incubator, as well as the food hub. In 2018, to increase the number of participants and ease of management, ALBA required all of its 40 farmer participants to participate in the GroupGAP program as a condition of the incubator and a new fee and cost-share structure was implemented (see Table 1).

Page 3: Case Study: ALBA’s GroupGAP Food Safety Programngfn.org/resources/ngfn-database/ALBA_GGAP Cast... · such as Trader Joe’s and Whole Foods, as well as other prominent wholesale

Table 1. Costs for GroupGAP food safety program at ALBACost Category 2017 Actuals

(covered 100% by ALBA)

2018 Farmer Cost Share

Notes

Quality Management System Audit $3,000 %50 Charged by AMS

Quality Management System Administration

$2,000 0% Staff member + consultant time

External Audits $4,200 100% Performed by CA Dept. of Food and Agriculture

Internal audits $15,600 50% Staff member and consultant time; 1 scheduled and 2 unannounced audits per farmer

Additional technical assistance $6,500 0% Staff member + consultant time

Required workshops $2,080 0% Workshops: Orientation to GroupGAP and Basic GAPs and Symptoms of Food-borne Illness; several others added in 2018

2017 actuals = $33,380; est. $1,669/participant

Based on 2017 actuals and cost share projections, farmers pay flat rate of $300 in year 1; $500 in years 2-4; $700 in years 5+

Sharing the food safety costs with farmers was an essential move towards sustaining ALBA’s food safety program. The 2018 GroupGAP fee to farmers is significantly less than what farmers would be paying for independent food safety certification, which could easily run $2,000+ for the development of an individual or custom food safety plan, mock audit and third-party audit. With the cost share in place, ALBA anticipates approximately $15,000 in revenue from farmers to cover food safety costs for 2018. ALBA will re-evaluate the costs and fees to farmers each year.

GroupGAP is a USDA farm food safety program that provides the entire specialty crops industry the opportunity to supply and buy fruits, vegetables, and related products that are certified as being produced using GAPs. This allows small to middle-sized farmers, food hubs, cooperatives and marketing organizations to band together and pool resources to achieve USDA GAP certification. This includes sharing the costs of training and certification. GroupGAP includes options for both USDA GAP & GHP, and Harmonized GAP certifications.

In 2013, ALBA was selected along with 5 other organizations to pilot a GroupGAP food safety certification program. An organization wishing to implement a GroupGAP program must develop a Quality Management System (QMS) that is audited, annually, by the USDA’s Agricultural Marketing Service. A QMS is a formalized system that documents processes, procedures, and responsibilities for achieving quality policies and objectives.

LESSONS LEARNED ANDBEST MANAGEMENT PRACTICES:

• Cross-training is important. Food safety is rapidly evolving into a technical regulatory arena. Turnover of key food safety staff can leave an organization scrambling to ‘plug holes’ in the system. There is a need to train and retain multiple internal auditors.

• Budget for consultants and professional development. Most organizations will benefit from outside consultation. Performing audits, developing a QMS, and deciphering the complexities of food safety are not for the newly initiated. Over time, an organization can develop internal staff capacity and decrease reliance on outside assistance. Food safety professional development is expensive with some courses running thousands of dollars, requiring travel and taking a week to complete.

• Develop relationships. ALBA participates in the GroupGAP Community of Practice organized by - the Wallace Center at Winrock International. This allows ALBA to learn directly from other practitioners and stay up to date on GroupGAP program changes. The USDA AMS is also an important relationship, as they administer the GroupGAP program.

• Develop a culture of food safety. This is especially important in the context of the GroupGAP. Staff implementing the food safety program need complete buy-in from management to be effective. All staff within the organization need to participate in the food safety program and take it seriously.

• Increase the number of participants in the group. To a point, the more farmers that participate, the more cost-effective the program can become for individual farmers. This is achieved by spreading out hard costs for the program (like the QMS audit, workshops), as well as the external audits costs. With a large enough group, farmers may be able to pay for the full cost of the program at a competitive rate.

• Communicate clearly with farmers. It is important that participants understand how GroupGAP fits into the larger picture of food safety, such as federal regulations, and the potential to open markets. They need to know what their commitment is under the program and what they should expect from the organization. It is important to develop and bring this language into a GroupGAP consent form and use it consistently in all farmer interactions.

BENEFITS OF GROUPGAP FOR ALBA:• Decreased farmer food safety costs. This is important for an organization such as ALBA that strives to reduce the start-up costs for its beginning farmers and is working with a population with limited resources.

• Standardization of food safety practices for farmers in the incubator. This puts ALBA, its participants, and potential buyers on the same page with regard to food safety. Also, it provides internal controls and a standard level of professionalism.

• Technical assistance and workshops under GroupGAP fit neatly into the standard workshop and technical assistance structure of ALBA’s programs. This type of farmer assistance can often be funded through grants and is another way to help lower the costs to farmer participants.

• Partnership with farmers. Due to the cost share, both farmers and ALBA are incentivized to be efficient and find ways to reduce costs. This creates a sense of ‘being in it together’.

CHALLENGES OF GROUPGAP FOR ALBA:• Organizational costs. Large and sometimes unanticipated costs associated with the food safety program are on ALBA, such as qualified staff, consultant time, and QMS administration. For example, in 2018 we expect to do a major update of the QMS. This will have associated costs but will hopefully pay off down the road with a more efficient system.

• Increased staff resources. Given the cross-cutting nature of the QMS, most ALBA management and staff have been drawn into food safety as part of their work responsibilities. This redirects resources away from other parts of ALBA’s training program. Many staff are required to take lengthy and expensive trainings to be qualified to assist with the management of the group.

A QMS helps coordinate and direct an organization’s activities to meet customer and regulatory requirements and improve its effectiveness and efficiency on a continuous basis. One of the main ways the GroupGAP saves money on certification costs is that only a subset of farmers receive an external audit (usually by state departments of agriculture); however, the organization managing the group must develop a system and allocate resources for providing internal audits, as well as managing the QMS.

After completing the pilot, ALBA fully adopted GroupGAP in 2015 as a system for managing food safety for farmers years 1-3 in the incubator, as well as the food hub. In 2018, to increase the number of participants and ease of management, ALBA required all of its 40 farmer participants to participate in the GroupGAP program as a condition of the incubator and a new fee and cost-share structure was implemented (see Table 1).

Page 4: Case Study: ALBA’s GroupGAP Food Safety Programngfn.org/resources/ngfn-database/ALBA_GGAP Cast... · such as Trader Joe’s and Whole Foods, as well as other prominent wholesale

ALBA

This material is based upon work that is supported by the National Institute of Food and Agriculture, U.S. Department of Agriculture, under award number 2015-38640-23779 through the Western Sustainable Agriculture Research and Education program under subaward number 150893-0001-205. USDA is an equal opportunity employer and service provider.”

Case Study:ALBA’s GroupGAP Food Safety Program

BACKGROUND: The Agriculture and Land-Based Training Association (ALBA) is a 501(c)3 non-profit organization. Its mission is to create economic opportunity for limited-resource and aspiring organic farmers through land-based education in the heart of the Salinas Valley. Each year ALBA trains 35 aspiring farmers in the Farmer Education Course and help grows the farm-businesses of an additional 40 participants

in the Organic Farm Incubator. The majority of our participants are current or former farm workers. Incubator participants grow an array of vegetable crops and berries at ALBA’s training facility, which includes 90 farmable acres, a classroom, mechanic’s shop, and a produce cooler. Since its founding in 2001, ALBA has trained more than 450 participants and over 150 have farmed at ALBA or gone on to be successful independent farmers.

GroupGAP RESOURCESALBA

web: www.albafarmers.org | office phone: (831) 758-1469primary contact: Nathan Harkleroad, Program Director | e-mail: [email protected]

Wallace Center at Winrock Internationalweb: www.wallacecenter.org | phone: (703) 685-8699

primary contact: Will Gray, Senior Program Associate | e-mail: [email protected]

USDA AMS GroupGAP Programweb: www.ams.usda.gov/services/auditing/groupgap | phone: (202) 720-5021

primary contact: Audrey Draper, Audit Programs Coordinator | e-mail: [email protected]

2006Produce contaminated with E. Coli 0157:H7 makes national headlines

2011FSMA passed into law

2015Produce Safety Rule finalized

2010Launches food safety program

2011First group of ALBA farmers achieve

3rd-part food safety

certification

2011 -2012

ALBA Organics

reaches peak sales

2012Requires all of

its farmers to obtain 3rd-party

food safety certification

2013Pilots

GroupGAP certification program

2015Fully adopts

GroupGAP for food hub and farmers in

years 1-3

2018Requires all

of its tenant farmers to participate in

GroupGAP

In 2006 produce contaminated with E. Coli 0157:H7 originating from San Benito county resulted in three deaths. Food safety scrutiny began to dramatically increase both regionally and nationally. Trade organizations, certification companies and the USDA began to develop auditing schemes, as buyers increasingly required food safety plans and third-party audits of growing and handling practices. The Food Safety Modernization Act (FSMA) was signed into law in 2011 and was the first major overhaul of our nation’s food safety practices since 1938. As part of FSMA’s Produce Safety Rule, there are new regulations for farms that grow fresh produce and for facilities that process food for people to eat. One of the end results of this legislation is that most all farmers are, or will be, legally required to have 3rd-party food safety certification.

From 2005-2016, ALBA’s food hub (ALBA Organics) provided produce cooling, aggregation, marketing and distribution services. At its peak in 2012, the food hub sold over $5,000,000. The peak sales and growth of ALBA Organics coincided with the rapid changes in the food safety landscape. ALBA Organics’ customers included large retailers, such as Trader Joe’s and Whole Foods, as well as other prominent wholesale buyers. ALBA began developing a food safety program in 2010. In 2011, ALBA helped its first group of farmers achieve Good Agricultural Practices (GAPs) certification through a third-party. By 2012, ALBA required all of its incubator farmers, and farmer vendors to the food hub, to achieve 3rd-party food safety certification. When ALBA launched its food safety program, farmers were responsible for covering the costs of the third-party audits, which were generally around $800-$1,000/each. ALBA found grant funds to cover technical assistance, workshops, and the development of food safety plans. This was a big investment for both farmers and the organization.

Certainly, food safety has been the largest regulatory hurdle to farmer development in ALBA’s recent history.