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This episode is part three of a miniseries about Good Agricultural Practices (GAP), a food safety certification designed for participants in the fresh fruit and veggie supply chain. Increasingly, food distributors and grocery stores are requiring their suppliers to hold GAP certification.

This requirement has concerned many small-scale fruit and veggie growers, who believe that GAP certification was designed with a bias toward large-scale farming systems. They argue that GAP is too expensive and too inflexible to the alternate ways that diversified, small-scale farms operate. The result, they argue, is that the requirement of GAP certification by retailers and distributors represents an unfair barrier to their participation in those markets.

Access to wholesale markets is important to Emily Jubenvill, a diversified small-scale farmer in the North Okanagan. In 2024, she applied for GAP certification in order to preserve her relationship with a few grocery stores in her region.

In this series, we track Emily’s effort to obtain GAP certification and talk to a couple of other small-scale farmers who obtained GAP, as we try to either confirm or disprove the concerns about GAP outlined above.

Prefer to listen? Check out this episode, and past episodes, on the Organic BC Podcast.


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, Shuswap Organics.

In episode 2, Emily took us through the process of applying for GAP certification and some of the changes she had to make on her farm.

And now, we finally reveal if Emily passed her first GAP audit:

“At the end of August, we had our GAP inspection,” Emily said. “And we passed!”

“My overall impression of the whole program is that it’s straightforward. It’s not difficult and complex. It’s achievable for small farms when specific types of crops like carrots or beets or potatoes are being certified at the A1 or A2 level.”

 

Looking back

“Like so many things in my life, I built it up to be more difficult than it actually was,” said Emily. “Is CanadaGAP more recordkeeping and paperwork for your farm? Yes. Is it outrageous and too difficult to achieve? Definitely not. It’s achievable even for a small farm, with a little bit of extra effort.”

From improved systems and new habits for staff, Emily found that so much of the certification was common sense and was mostly organizational and cleaning supply related. Even recordkeeping, which is often something farmers are hung up on, has its benefits.

“Yes, it’s more recordkeeping than you’re used to, but it ultimately, it makes you a better grower and it’s the kind of recordkeeping you want to run a business anyway.”

 

How much did an audit cost?

Emily estimates the audit process ran about $2000, with $600 covering the CanadaGAP fees and the remainder going to the auditor.

On top of that, Emily needed to tackle a few required upgrades, but nothing major: six hundred dollars on little investments like bin liners, colour-coded scrub brushes and brooms, mousetraps, bins for organizing, a second first-aid kit, and basic handwashing and no-smoking signage.

Even the wooden barrel washer that Emily was worried about didn’t present an issue.

“We have a standard cleaning procedure that we use every time we use the barrel washer, where we give those wooden slats a scrub,” said Emily. “And that was enough. [The auditor] visually inspected it and saw us using it and cleaning it.”

(The carrots also get a final spray with potable water when they come out of the barrel washer, so that could also have played a role in not needing to upgrade to a new $20,000 – $30,000 piece of equipment.)

Even employee training doesn’t require a lot of resources. Emily said she only spent a couple of hours over the course of a season on new training.

“It’s very doable,” she said. “The hardest part about staff training for me personally has been the ongoing reminders. Before you get on the harvester, make sure you wash your hands. Even though we’ve done the training and everything, we still have to remember and make sure it happens.”

 

Is there potential for farms to get together and collaborate?

One of Emily’s goals with this project is to learn more about the possibility of her farm obtaining GAP certification for wash and pack, and then buying “dirty” produce from a network of other farms, who would only need to have GAP certification through to the end of harvest. This would reduce certification costs for the supplier farms and get more local carrots on the shelves of stores year-round.

“I’ve heard it’s what other farms do in other parts of Canada, that this option exists,” said Emily. “And then I’ve talked to other people and they’re like, ‘No, their wash pack would still have to get certified.’”

So, the feasibility is still to be determined.

That said, Emily has shown that the CanadaGAP certification process isn’t prohibitive if one or two crops are being certified. All farms in this scenario could become CanadaGAP certified right through, representing a duplication but not a hindrance.

“Still, this is the kind of thing that would allow a small-scale farm to diversify,” said Emily. “They’re still going to the farmers’ market, but they create this new channel to sell one or two crops into wholesale markets that are now requiring GAP.”

 

On-Farm Food Safety Grants

Over the last 10 years or so, funding has been set up to help farmers address all the new food safety requirements. One of these programs is the On-Farm Food Safety Program:

It’s a fairly easy process and done through the Investment Agriculture Foundation (IAF) portal.

“The questions are all, ‘Why do you need food safety improvements on your farm?’” said Emily. “If you can articulate that, you’ll be good.”

“Any time I’ve referenced a food safety consultant it was via this On-Farm Food Safety Program. We got some partial funding to hire them.”

The consultant wasn’t required to pursue GAP, and Emily feels she could have figured out the process on her own. But, she said, it gave her the confidence that the certification was worth pursuing.

“It’s very abstract,” Emily said. “His feedback and the conversations we had over those four hours were really helpful for me being like, we can do this. We can pass this. And a lot of things we were worried about, he was able to say, ‘That shouldn’t be a problem. You can just show that you can wash this.’”

Even without funding, you could hire your own food safety consultant to come to your farm for a couple of hours, go through the GAP audit checklist, and give you the information you need.

“I don’t know that you have to spend a whole $1,000 bucks and do a 4-5 hour visit. That’s the exact kind of expense that a small-scale farmer typically shies away from.”

 

What about skipping GAP altogether and creating your own on-farm food safety plan?

Technically, it’s not that you have to get GAP—it’s that you have to meet certain food safety requirements laid out in the Safe Food for Canadians Act. For grocery stores and other buyers, it’s easier, cheaper and less risky to require suppliers to hold GAP certification than it is to independently document that each of their suppliers is satisfying Canada’s food safety regulations.

Some buyers might be flexible and accept independent plans, but Emily says the certification process is simple and offers peace of mind.

“All of those boxes are checked,” she said. “There’s nothing that you have to figure out yourself.”

 

Back to the original problem

Growers have been grumbling about food safety legislation for over 10 or 15 years, dismissing it as unnecessary and expensive bureaucracy, and biased against small-scale farmers.

While those thoughts shouldn’t be completely dismissed, Emily’s experience has shown that CanadaGAP certification is achievable, affordable and actually improves the safety of the food growing on your farm. And, it ensures access important wholesale opportunities.

“I would recommend to people that if you do want to do it, take it as a winter project to first go through the manual,” suggested Emily. “Then, make your to-do list of things you need to update or change on the farm.


Now you’ve heard the whole story of Emily’s pursuit of GAP certification—but we’re not done!

Emily’s summary of her experience will no doubt be useful to other farmers who have been ambivalent about GAP certification. But that story really only represents one data point. So in late 2024, Organic BC podcast host Jordan Marr interviewed a couple of other small-scale farmers who pursued and obtained GAP certification for the same reasons that Emily did.

In the next episode of the Organic BC podcast, you’re going to hear from them! That will technically wrap up this miniseries, except for one more short episode in which Emily spends a few minutes describing some changes she made to her carrot production in order to be able to sell her carrots at the lower prices required by wholesale buyers.