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On-farm Food Safety and Access to Larger Markets

Group GAP and Food Safety Modernization Act


On-farm food safety is on the mind of those looking to support the success of small and mid-sized, sustainable producers.  We dig into two cutting edge issues:

More and more wholesale and institutional buyers are requiring on-farm food safety certification, making these markets extremely difficult to participate in for smaller farmers due to the expense of GAP auditing. The Wallace Center is working with USDA to identify and run several pilots at food hubs of a group GAP approach. Instead of the current "one farm, one audit" protocol, participants in a group GAP audit have their shared food safety system audited, and are audited as one body. This method opens markets to producers who would otherwise be priced out.

The Food and Drug Administration just released two proposed rules outlining new standards for produce safety and preventive controls for food processing and manufacturing.  These two rules, along with existing food safety regimes, create a maze of challenges for the development and growth of local and regional food systems.  Learn about the new proposed rules, models for addressing food safety, and how to get involved in supporting sustainable food systems and safe food!



Presentation Slides

Download the slides (PDF)

Questions and Answers

Q: Is the $25,000 minimum an aggregate or $25,000 per year?

A: The $25,000 is per year but it is based on the average annual monetary value of food sold in the previous three year period.

Q: Also, is the income threshold for ALL farm income or just income from veggie sales?

A: The threshold is for all food sales, but there are questions around how a farm that does processing would meet the thresholds -- still an area that needs clarifying.

Q: Is that $25K just in produce or all food items, for example, beef and pork sales as well as produce?

A: It is for all food items

Q: Do you know why they switched from a 4 month/120 day interval (GAPs standard) to a 9 month interval between application of raw manure and harvest? Will NSAC be commenting on this?

A: This is an area that we are looking more into and NSAC will be commenting on this issue.  It is in contradiction with organic program regulations

Q: We sell produce, jam from our fruits, and oil from our olives. Is the $25,000 just for the produce or would jam and oil be included? 

A: The jam and oil would be included in the 25K

Q: How can we become a pilot project?

A: Please contact me ->

Q: Are there particular concerns when working with Amish Farmers?

A: Of course, but the Good Natured Family Farms pilot (report at ) included Amish farmers.

Q: There is an exemption for Sell 51% or more directly to a consumer or retail food establishment in the same state or within a 275-mile radius. This seems to imply that 51% must be sold to a SINGLE customer or retail establishment. I am understanding this correctly?

A: No -- it does not need to be to a single customer or retail food establishment.

Q: What about honey?

A: In the draft proposed rule, honey is considered low risk and so if it is done by a very small or small business, then it would be exempt from the preventive control rule requirements if the facility is not doing high-risk activities

Q: Do I have your permission to share this Webinar with our proposed co-op group?

A: Yes, please share with them and whoever else you think might benefit from this webinar!

Q: Where can we find that list of activities that Ariane just mentioned? 

A: Those lists are currently in the proposed rules and we will provide that info on our website in the next couple of weeks.

Q: We've seen problems with large processing but have there been as many docuented problems from small farms/markets?

A: No, there have not been as many documented problems from small farms and markets


Presenter Bios

Ariane Lotti

Ariane Lotti

Ariane Lotti serves as the Assistant Policy Director for the National Sustainable Agriculture Coalition (NSAC). She has served as the Policy Director for the Organic Farming Research Foundation (OFRF), and Policy Associate for OFRF and NSAC.  She is a published author, and has worked on and conducted research on organic and conventional farms in the US and Europe.  Ariane coordinates NSAC’s policy campaigns, serves as a liaison between the grassroots and policy staff, and staffs several program areas, including organic and food safety issues.  She holds a B.A. and a Master of Environmental Management from Yale University.

Steve Warshawer

Steve WarshawerSteve Warshawer has represented the National Good Food Network’s food safety interests for over 3 years. His unique perspective of being an active farmer and rancher for over 35 years, multi-farm biodynamic CSA founder and manager, and food hub staff at La Montanita in New Mexico allows him to deeply understand food safety certification from many perspectives. He also participates in the landmark United Fresh Produce sponsored GAP Harmonization effort, and is an active member of NSAC's food safety task force, recently expanded to become the "food system integrity committee". He has worked on’s online food safety plan tool, and serves as coordinator of the Beef Industry Improvement Initiative of New Mexico and as a member of the National Advisory Committee on Meat and Poultry Inspection.

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