202-3002 32nd Ave, Vernon BC Canada V1T 2L7 info@certifiedorganic.bc.ca

The second in our miniseries on GAP certification. Join us as a BC farmer takes us through her effort to become GAP certified—the process, the expense and the pain points.

Prefer to listen? Tune into the journey on the Organic BC podcast. New episodes and articles released weekly!

If you missed episode 1, you can check out the article here and the podcast here.

 

In Pursuit of GAP Certification

At the end of episode 1 of this series, we learned that North Okanagan farmer Emily Jubenvill had applied for GAP certification so she could maintain access to wholesale markets for the carrots she grows on her small-scale farm.

Our first conversation with Emily was in February of 2024, and towards the end of that chat she filled us in on where she was at in the process:

“I have submitted my initial application, which is really just our contact information to Eco-Cert for a GlobalGAP certification,” said Emily. “And I have had a half-day session on the farm with a food safety consultant to do an initial overview. Would we pass? What are going to be the major barriers to us passing this food safety certification?”

(To clarify, the consultant is not a formal part of the certification process. They’re essentially an advisor hired—and funded by the On-Farm Food Safety Program, in Emily’s case—to identify areas for improvement and what areas should be funded for infrastructural upgrades.)

“As part of [the walkthrough], they take the CanadaGAP audit list and they go through it with you,” Emily said.

After walking around the farm with the consultant for a few hours, here’s what Emily learned:

 

The Paperwork

The first thing identified was the need to develop standard operating procedures along with a record keeping checklist that will need to be integrated into staff training and existing record keeping processes.

And then there were questions like:

  • Do we clean the harvester before we start harvesting?
  • Do we clean the conveyors before we start washing?
  • Are we using a food-safe grease on our harvester so we don’t contaminate the food?
  • Will our old wooden apple bins result in splinters getting mixed in with the crop? Can we clean them? 

Regarding the apple bins, the consultant suggested adding a basic plastic liner to each bin to put a barrier between the crop and the poor quality of the bin. A cheap fix!

What might not be a cheap fix, however, is Emily’s wooden barrel washer. A new, modern food-safe version could run between $20,000 – $30,000—a tough pill to swallow for a new farm that’s still in the growth stage of business and trying to build up the infrastructure it needs just to operate.

“Maybe there’s something we can do to seal those wooden slots, or cover them with, or a cleaning procedure we can use to ensure we don’t have to replace our barrel washer,” said Emily. “The risk to these root crops from that wood is so low that it’s one of those situations where it’s not actually a massive food safety risk.”

But if you’re following the rules to the letter, it’s a risk. Unless, perhaps, you can dig in your heels and push back on the wooden slots—really show some evidence that the risk is sufficiently low.

“I want to prove how far we can push the not having to replace stuff with the newest state-of-the-art version,” said Emily. “And if there’s any solution available to us that doesn’t require us replacing equipment, I want to try that first and see what happens.”

 

The Packhouse

Emily’s current packhouse is a portion of the farm’s greenhouse, with dirt floors covered by landscape fabric.

“I thought it was going to be an issue, but the consultant said as long as you keep it clean it’s not an issue,” said Emily. “So sweep them, hose them down, whatever you need to do.”

Another issue is the lighting. While the greenhouse has great natural light, Emily installed patio lights to see better in the depths of winter. Those lights will need to be removed because they’re unprotected glass bulbs.

“That’s a very physical contamination,” Emily explained.

Removing the lights is a quick fix, or Emily could switch to non-breakable bulls.

 

The Critters

With an abundance of food, water and shelter, it’s no surprise that farms are a haven for rodents—and Shuswap Organics is no exception.

“They drive me crazy,” Emily said. “There’s a number of things that we’re already doing that we just need to tweak a little bit.”

For example, in the packhouse, all of the packaging is on pallets, but they’ve taken the extra step of raising those pallets up off the ground another 6 to 8 inches, which makes it so their rodent control dogs and cats can get under those spaces more easily.

“Previously, with the pallet on the ground, I found mice nests in pallets,” Emily said. “Now there’s none of that.”

Emily will also need to move the pallets away from the wall of the greenhouse to create “alleys” so inspectors can access the back areas more easily.

Another area for improvement is to ensure there’s 18 inches to three feet of empty space around the outside footprint of all buildings. While not a small job for established farms that have accumulated a lot of stuff, this practice reduces rat habitat (and also makes for a very tidy farm).

And then there’s the compost pile, which is a major rat habitat and food source. It’s currently too close to the packing area and will need to be moved down the field.

 

The Water

“We talked about water quite a bit,” said Emily. “Water quality has to be potable at the last point of use. Currently our water samples say that we have potable water that’s at the tap, where we attached our hoses to use for the barrel washer. We actually need to be taking our water samples from the nozzle at the barrel washer.”

“I was like, oh duh.”

If the water samples come back as non-potable at the barrel washer but potable at the tap, then Emily knows she needs to replace or clean her hoses.

 

So how’s it going now?

Originally, Emily had hoped to become GlobalGAP certified because she found a certification body that could do both her Canada Organic Regime (COR) and GlobalGAP certification at the same time, with appealing efficiencies in terms of time and cost. Same inspector, one day.

But, Emily learned that GlobalGAP requires some testing for chemical residues, with no leniency.

“Even though we’re organic, we would still have to test for at least four years, which is currently what I’m understanding,” said Emily. “That would take out the financial benefit of going with GlobalGAP versus CanadaGAP.”

“So yet again I’m on the fence between GlobalGap and CanadaGAP. I’m just going to keep looking at these long websites full of jargon and attempt to tease out exactly what makes the most sense for us.”

Interesting note: The food safety consultant did tell Emily to do CanadaGAP because it’s so much easier.

“I was dismissive,” Emily admitted. “It’s true CanadaGAP is more set up for you to just plug in your information. Whereas with GlobalGAP, my impression was you had to create a lot of the standard operating procedures and reporting, which makes it a lot more flexible to suit lots of different sizes and types of operations.”

“I think for me to be able to pull that off, I would have had to hire a food safety consultant under GlobalGAP to set me up. Whereas with CanadaGAP, you just have to sit down and get ‘er done.”

After much flip-flopping, Emily finally decided to go with CanadaGAP.

 

A1, A2, B and beyond? What level to get?

Within CanadaGAP, producers have the choice of choosing from a wealth of certification options, with one of the main differences being the audit cycle. A1 and A2 are the only options with four-year cycles—all others require annual on-site audits (and have higher costs).

“CanadaGAP doesn’t choose. I choose based on what my customers needs,” Emily explained. “If the customer we want to sell to says A1 or A2 is fine, that settles it. If they say, ‘No, you have to have the full blown,’ then we’d have to go that way.”

The difference between A1 and A2 is the audit schedule:

  • A1 (variable)
    • Year 1 on-site audit by 3rd party Certification Body (CB)
    • Could also be selected for random audit in Years 2, 3 and 4 of the cycle
    • If not selected for random audit, must complete sworn declaration and self-assessment each year
  • A2 (more structured)
    • Year 1 on-site audit by 3rd party Certification Body (CB)
    • No more than 4 years between on-site audits. If selected for a random audit, scheduled audit date will be extended to four years from the random audit date.
    • If not selected for random audit, must complete sworn declaration and self-assessment each year

“You still have to pay CanadaGAP a certification fee every year, but you’re not paying the audit fees every year, which overall makes it more affordable,” said Emily. “And simpler.”

So why wouldn’t everyone choose A1 or A2 over the other CanadaGAP options? Well, there are certain selling situations where A1 and A2 wouldn’t cut it. They don’t meet international benchmarking requirements, and also have a less rigorous approach with lower passing requirements.

But like Emily said before, if A1 or A2 is all your customer requires, then you’re all set– there’s no reason to pay for more expensive and in-depth CanadaGAP certifications.

 

Almost there…

After her walkthrough with the consultant and honing in on the best GAP certification option for her business, Emily began filling out the CanadaGAP forms and figuring out what recordkeeping processes she needs to update or change, and what physical changes she needs to make on the farm to comply with the requirements.

While juggling planting, she took on more “required” projects around the farm, like creating a locked cupboard for agricultural chemicals.

“That one was interesting because we grow I think 15 different crops, and only two of them are being GAP certified. And we don’t use any agricultural chemicals on our carrots or beets,” Emily said. “So it was very confusing for me to be going through the GAP forms. Do I need to create this cupboard or not?”

(Spoiler: It turns out, no. Emily asked during her formal audit process and it’s only required if she’s using those chemicals for her GAP-certified crops—the carrots and beets).

“That’s a good lens for anybody who’s growing multiple crops but wants to get GAP certified for just one,” Emily explained. “Whatever the CanadaGAP guidebook is asking you, only apply it to that crop. And it’s not worded that way. It’s hard.”

 

Time for the formal inspection. How did it go?

Emily had her first CanadaGAP audit in September of 2024. Find out the results and hear all about it in part three of our series, coming soon.