Farm to School Legal Toolkit - Food and Beverage Law Clinic, Elisabeth Haub School of Law

A. Good Agricultural Practices (GAP)/Good Handling Practices (GHP) Certification GAP and GHP are voluntary audits that verify that fruits and vegetables are produced, packed, handled, and stored using practices that minimize the risks of microbial food safety hazards.

GAP stands for Good Agricultural Practices while GHP stands for Good Handling Practices. Being GAP/GHP certified guarantees a school that a producer follows at least the minimum number of food safety practices mandated by the certification.

There is no law requiring that farms selling to schools be GAP/GHP certificated, but many school districts require it. A farmer should contact the school district to determine if that particular school district requires GAP/GHP certification.

A farm seeking to become GAP/GHP certified will have to complete a Request for Audit Service.

The completed form must then be sent to the closest auditing facility from the list of Local Specialty Crops Inspection Division audit offices. A representative will conduct an initial audit of the farm to determine if its practices meet the standards. A certification is valid for one year from the date of the initial audit. The auditor may also conduct an unannounced verification visit at some point after this initial audit. If the initial audit or the unannounced verification visit demonstrate that the farm is not meeting the program requirements, a follow up audit may be conducted.

Generally, a GAP/GHP audit will be conducted pursuant to the USDA Good Agricultural Practices Good Handling Practices Audit Verification Checklist. The auditor uses this audit checklist to score the food safety performance of the farm. This checklist is broken down into different sections which each cover a certain portion of the supply chain. In order to receive the certification, the applicant must obtain at least 80% of the available points in each applicable section. For example, if the farm has potable water available to all workers the farm will receive 10 points in the “general questions” section of the checklist. Compliant farms will receive a USDA certificate and have its name listed on USDA’s website.

A full breakdown of the requirements for each section is beyond the scope of these materials, but some basic information concerning the requirements for GAP/GHP is provided below. For more information refer to the USDA Good Agricultural Practices Good Handling Practices Audit Verification Checklist.

The applicable questionnaire sections differ for GAP and GHP audits because they cover different portions of the supply chain. However, both GAP and GHP audits contain a “general questions” section which addresses overarching food safety issues. To comply with this section, the farm must have a food safety program, a traceability program, and a recall program. A food safety manual is required as part of the food safety program. This manual must explain the 8