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April 26, 2023 51 mins

In this episode we speak with Lisa Rhoden, Food Safety Director with NSEVP on the island of Oahu about The Food Safety Modernization Act (or FSMA), water testing, and NSEVPʻs Group GAP program. GAP stands for Good Agricultural Practices and Lisa facilitates a group certification process for Hawaiʻi ag producers on all the islands.

Brought to you by University of Hawaii College of Tropical Ag. and Human Resources, and the Seeds of Well-being (SOW) Project. This podcast is supported by the Farm and Ranch Stress Assistance Network (FRSAN) grant from the U.S. Department of Agriculture, National Institute of Food and Agriculture and Hawaii Department of Agriculture.

Resources:
- North Shore EVP
- NSEVP GroupGAP Intro video
- HeavyConnect App
Water Testing by Island
- Hawaii: Aileen Yeh (ayeh@hawaii.rr.com)
- Oahu: Ming Yi Wang at Hawaii Agriculture Research Center (mwang@harc-hspa.com)
- Maui: Aimee Greenwood (agreenwd888@gmail.com)
- Kauai: Lisa Rhoden (lisa@nsevp.org) or Carl Berg (cberg@pixi.com)
Lisaʻs contact information: lisa@nsevp.org
UH AgConnect Program

Find out more about us:

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Transcript

Episode Transcript

Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Jim (00:00):
The views information or opinions expressed in this
episode are solely those ofindividuals involved, and do not
necessarily represent those ofthe University of Hawaii College
of Tropical Agriculture andHuman Resources, our funders, or
any of the organizationsaffiliated with this project.
Welcome to a Seeds of Wellbeing"Experts in the Field" podcast

(00:27):
featuring people working intheir fields of expertise to
provide support for agricultureproducers in Hawaii, in the
United States, and in some casesaround the world. These podcasts
were made possible by a grantfrom the University of Hawaii
College of Tropical Agricultureand Human Resources, also known
as CTAHR. And the Seeds ofWellbeing or SOW project and is

(00:47):
supported by a grant from the USDepartment of Agriculture,
National Institute of Food andAgriculture, and the Hawaii
Department of Agriculture.
What's North Shore EVP?

Lisa Rhoden (00:57):
We are, well, it stands for North Shore Economic
Vitality Partnership, and we area nonprofit, originated on the
North Shore of Oahu, really tolook at economic opportunities
for the region. And primarilythe work that we're doing right
now is food safety workstatewide, but we remain

(01:17):
committed, of course to theNorth Shore as well and the
economic partnerships andprojects that we can come up
with for that area.

Jim (01:25):
That's North Shore of Oahu.
Yes, yes. Okay.
In this episode, we speak withLisa Rhoden, Food Safety
Director with the North ShoreEVP on the island of Oahu, about
the Food Safety ModernizationAct or FISMA, water testing, and
NSEVP's group GAP program. GAPstands for good agricultural
practices and Lisa facilitates agroup certification process for

(01:48):
Hawaii ag producers on all theislands. Please note that when
Lisa refers to working withKevin at NSEVP, she's referring
to Kevin Kelly, who is thepresident. Now let's hear more
about the group GAP program.
Keeping the country country iswhat I heard you say. Can you
talk a little bit about thatphrase?

Lisa Rhoden (02:08):
Yeah. Kevin was actually involved pretty heavily
in that organization. And whatthey were really concerned with
at the time was the fact thatthere was a lot of development
pressure on the North Shore andthey were looking at how do we
sort of tamp that down a littlebit? And it seemed, I think,
like there was a lot ofdefensive maneuvering, and they

(02:30):
really felt like we really needto go on the offense. And how do
we convince people to preservegreen space on the North Shore
and really look at what are thejobs that we can create and
enhance on the north shore forfolks who live there. And that's
where the study came, theclusters of opportunity study
came from, it's on our websiteas well, but basically it boiled

(02:52):
down to looking at what were thebiggest economic drivers in the
region. And it turned out thatthere was, of course, tourism,
but also agriculture. And then acategory of jobs that were more
like remote type jobs, thingsthat you could do anywhere and
just happen to be folks wereliving on the North Shore and
doing those jobs. So really, asa nonprofit, we're looking for

(03:14):
ways to increase economicopportunities in Hawaii,
particularly on the North Shoreof Oahu. And food safety is just
the tool that we're using at themoment to really move some of
that forward.

Jim (03:25):
So I first noticed the work of North Nhore EVP a few years
back and the phrase group GAPwas was what caught my
attention. I know, GAP standsfor good agricultural practices.
And I remember a couple yearsago, maybe you did a
presentation about group GAP,which I think at that time was a

(03:46):
new concept, certainly new tome. And so is that when you came
on board with North Shore EVP,is that your role? And are you
folks kind of spearheading groupGAP throughout the islands? And
just talk a little bit aboutthat if you would.

Lisa Rhoden (03:59):
Yeah, that is I came on board in, I want to say
2016 or so, and Kevin hadapproached me earlier in 2016, I
had been introduced to him by amutual friend who said, "Hey,
there's somebody here who Ithink thinks very similarly to
you." And I had expressed, I hadbeen managing an ag park at the

(04:21):
time and Kunia and I hadexpressed to this mutual
acquaintance of ours that, "Youknow, gosh, I've got all these
small farmers, but they've gotnowhere to put all their
products and they're not foodsafety certified." And that
conversation came about becauseone of them one of the farmers
had said "Oh, thinking aboutcalling Whole Foods and see if
they'll come out and look at myfarm and want to buy my product"

(04:43):
and I was looking at their farmand I was like, "Oh my god,
please do not call Whole Foods.
They do not want to see this"because it was just sort of a
typical small farm operating ona shoestring, very disorganized
looking, but they had not thebest practices in place, and I
knew that we could do better.
And so I had mentioned this toour mutual acquaintance, who

(05:05):
then put me in touch with Kevinand Kevin came out and we
actually walked around the farmsand toured that area. And I
said, you know, I really feellike one, these guys need to get
food safety certified to helpthem get into these markets,
like Whole Foods. And two, wereally need a hub, a big hub to
take product. And that's whereKevin was, at the same time,
unbeknownst to me, but involvedon the North Shore. So a few

(05:28):
months later, he called me upagain, and he said, I'm, I'm
going to submit a grant and I'mgoing to try to get funding and
I want to do this, you know, Iwant to do this hub, and I want
to help farmers get food safetycertified and group GAP is the
way to do it. And I had alsofound out about group GAP at a
similar time and I thought thesame thing. It's a perfect fit
for small farmers. And so westarted talking more regularly.

(05:52):
He finally got word he hadgotten the grant, he created a
job description I interviewedfor the job, and here I am
working with Kevin, and for usit's been a I guess a couple of
years now, what is it 2023, soalmost seven years we've been
working together. And we just wejust think very similarly, and
we see a lot of the samepotential for these for this

(06:14):
program and for our farmers herein the state.

Jim (06:17):
I think Kevin, and remind me Kevin, he's president of
North Shore EVP, is he one ofthe founders?

Lisa Rhoden (06:23):
Yes, he is yes.

Jim (06:24):
Great. Have you been focusing a lot on food hubs and
food coops? Has that been whatwhat have you been targeting as
part of the group GAP and yourwork that you've seen as most
successful or has the potentialto help the most?

Lisa Rhoden (06:39):
Yeah, initially, we were focused on food hubs and,
and food safety for smallfarmers. And it, we spent some
time trying to find a great sitefor a mid scale size food hub.
We spent some time trying tofind great partners for it. And
we just, we just really weren'tfinding the right, all the right

(07:03):
things coming together at theright time. Space, location
partners, etc. At the same time,we were working on this food
safety certification and groupGAP establishing the group which
took some time. And over thelast couple of years, a lot of
food hubs have popped up orgrown particularly on Oahu, but

(07:24):
across the state. And thathappened, you know, really, it
was exponential during COVID.
The food hubs suddenly becamereally the place where all of
this food was being aggregated.
And so for us now I think we'rewe're interested now in helping
food hubs if they want and needto get food safety certified at
whatever point that's going toneed to happen for them. We want

(07:46):
to help them with that. Wereally put a lot more energy
though lately into gettingbetter at food safety
certification for farmers. Wehave grown in terms of the
number of farmers that we'veserviced. Our first two cohorts
we had a lot of farmers inthere, but we did not see see
succession, or success incertification on those guys. And

(08:10):
we reevaluated and we looked at"Well, what's what's the
problem? Where are we failing?"and it turned out to be record
keeping, and so that was the bigone anyway. And so we looked at
how do we make this easier? Andthat's when we were looking for
a digital record keeping app. Wefound Heavy Connect, got in
touch with those guys, did apilot program with three farmers

(08:31):
using Heavy Connect, and we'vesaw tremendous success. And we
thought this is it, this is thisis going to fix this record
keeping issue. Since then, we'vehad a lot more success on the
record keeping side which hascontributed to more farmers
getting certified. We also havedone a little bit more diligence
in looking at the farms thatwe're inviting to join our

(08:53):
program and looking for farmsthat want to grow, want to have
a market that's opened up andhave the infrastructure to be
successful in this program. Andnot just you know, do they have
a bathroom and things like that,but are they regular
communicators? Can I reach outto them and they're gonna get
back to me within a few days, ifnot sooner? Are they, do they

(09:15):
know their processes? Do theyhave set processes or are they
still growing and they haven'tquite figured out what they're
doing yet? So that's been a bigpiece. I think we've seen more
success because we've justreally focused down on that food
safety certification part of theprogram. Also we are part of a
monthly community of practicecall with food safety, quality

(09:37):
and folks around the country.
And that's been really helpfultoo, because we've been able to
learn a little bit about whatgoes on in other places. And I
think we have this sense inHawaii that we're so different.
And things that work in otherplaces aren't ever going to work
here but I have found that atleast in this sphere, we're
wrong. There are so manysimilarities with the small

(09:58):
farmers in Mississippi andGeorgia and all these places, I
can reach out to any of thosefolks in the group GAP community
of practice and say, "Oh mygosh, here's what I'm dealing
with. Do you have any experiencewith this?" And almost always
somebody says "Yes" or "Oh, I'min that same place right now."
So we really have benefited fromthat. And our farmers have
benefited from that.

Jim (10:20):
A couple of things that I was thought it asked you about
is water testing. It sounds likeas a regular need and it sounds
like you have access toresources that can do water
testing on all the islands.
That's true

Lisa Rhoden (10:32):
Yes. A few years ago, Stevie Whelan at the Hawaii
Ag Research Center, she receiveda grant, I think, from the Farm
Bureau. And she was able topurchase some water quality
testing supplies, and she gotenough that they ended up on
every island. So Maui, maybe notMolokai, but Maui, the Big

(10:54):
Island here on Kauai and Oahu.
And the idea behind it at thetime was that the FISMA water
quality standards, we thought,were going to be finalized and
farmers were going to have to doall this testing. I think at the
time, it was something like 20tests in a year to establish a
baseline. And we just thought,"Oh my gosh, what are we going
to do to help these guys? Wehave nowhere to send this other

(11:14):
than a few labs, which are goingto be inundated, and it's
expensive, and they're all onOahu. What are the neighbor
islands going to do?" So Steviegot a hold of this equipment,
got some folks trained to do it,and we've provided free water
quality sample testing tofarmers all across the state for
some time under this project.

(11:38):
It's a really quick method, it'sthe same, it's called the
Colilert method. It's it'sapproved for FISMA. And it's
essentially take a sample of thewater, it goes, you add media to
it goes into the incubator forabout 24 hours, and then you're
going to take a look at thecells in in the tray. And you're

(11:59):
going to look at how many ofthem turn color. One color for
total Coliform, one color forgeneric E. Coli. And it's just a
really great way to give farmersan idea of what their water
quality looks like at a givenpoint in time. I think if you
establish sort of a regulartesting schedule, you'll know,
you know, during the rainyseason, this is what my water
looks like during the dry seasonthis is what my water looks

(12:21):
like. It's just a great way agreat piece of information for
folks to know what it looks liketo know what to watch out for.
If you've got limited water andyou're having to bring water for
cleaning. If you've got kids onthe farm, you don't drink the
irrigation water, you know, it'snot for that kind of thing. But
you know, just to understandreally what it is. And we've had

(12:43):
some success here on Kauai intalking with some land managers
about ways that they could helpimprove the water quality. You
know, keeping animals away fromthe ditches if possible, where
possible, because that's a bigcontributor to poor water
quality. And we just want to beaware of it. You know, so many

(13:04):
of our farmers, that's it,surface water is what they have.
And we got it.

Jim (13:08):
And it can be certainly in short supply or in some parts of
the island way too much certaintimes of year, so yeah.
Understood. So you mentioned Ithink you mentioned a harmonized
GAP is the standard use inHawaii. And and that I think I
heard you say that it wassimilar to the Food Safety

(13:28):
matter... Let me try again...
it's similar to the Food SafetyModernization Act or FISMA
requirements. Is that true forHawaii? So are they pretty
close?

Lisa Rhoden (13:38):
They are. So back when GAP was established by USDA
in 2002. There was just GAP,which was essentially a
checklist. It was a very simpleaudit. And over time, they have
added different audit standards.
So there's a specific one fortomato production. There's one
from mushrooms. When FISMA wasintroduced, USDA kind of took a

(13:59):
look at the old GAP and thoughtit's not very robust, and now
we've got FISMA, which is veryrobust, so we need something to
sort of bridge that space. Andso they came up with what's
called a harmonized gap. Andit's essentially something that
covers everything that FISMAcovers, in some places, it's a
little bit more covers a littlebit more or is a little bit more

(14:22):
robust in its requirements. Andthe idea behind it was,
particularly for farms who maybehave a qualified exemption from
FISMA, but their buyers stillwant to see some verification.
And harmonized GAP or any anyGAP certification would suffice,
right? Your buyer wants to seethat you have a third party

(14:43):
audit. So harmonized GAP is moreclosely related to FISMA, closer
to FISMA requirements. And so afarmer then can say "Well, I
don't have to comply witheverything in FISMA but I've got
this harmonized GAAPcertification." As as they grow,
if they do have to comply witheverything in FISMA, they're
already in good shape, they'realready complying because

(15:04):
harmonized GAP is so synchronouswith FISMA. And there has been
some talk about folks who areharmonized, GAAP certified, as
FDA does begin doinginspections, if they see that
you're already harmonized GAPcertified, you're probably not
going to be on the short list ofFDA inspections because they

(15:26):
don't have to worry about you.
They know you've had a thirdparty audit, they know you're
following these compliancecriteria. It's the farms who
maybe don't have anything toshow that they may be like,
we're gonna go take a look atthis one.

Jim (15:40):
It's a really interesting program. As you know, again, as
I understand it, FISMA once youhit certain limits of of how
much revenue you generate, or towhom you're selling products,
and to get into certain markets,you have to have that
certification, follow thoserequirements, I think GAAP is
optional for now but potentiallyvaluable to hold up there as as

(16:02):
something that you can set youapart as a producer, and get you
ready for markets like we talkedabout. But I think the Seeds of
Wellbeing project, right, whichis why we're here, it's we
interviewed over 400 agproducers and affiliates on the
Hawaiian Islands and they have alot of stressors, right? I think

(16:23):
one of them is keeping up withpaperwork and certifications. So
I guess what would you share askind of a, a short sentence or
description to say when agproducers that are listening to
this might want to pay attentionto group GAP, GAP, FISMA? When

(16:43):
would I as a producer need tostart to really pay attention to
that and and make sure I'm incompliance?

Lisa Rhoden (16:49):
Sure. Well, I think if you're selling to any entity
that's beyond a direct toconsumer, if you're looking to
get into institutionalpurchasing, which is becoming a
big buzz, so you want to sell toschools or your local hospital
or something like that, youreally need to start to keep
records and be able to showthose buyers that you have food

(17:09):
safety practices in place anddocumentation of them. And as
far as group GAP goes, you know,when you start to when you start
to get to that point whereyou're growing, and you really
want to have a little bit moremarket access you or you need
certification, one of yourbuyers has said, "Hey, we're
going to start requiring this inthe next year or two." then I
would say reach out to us.
Because really, what we're hereto do is help alleviate that

(17:31):
administrative burden. We wantfarmers to farm and to farm
well, and all the documentationand stuff, we want to help you
with that so that you can payattention to what you do well,
and we will pay attention towhat we do well. I am not a
farmer but I can do a prettygood job of helping you with
documentation of your practices.
And that's really what we wantto provide. We want to make it

(17:53):
equitable for small farms, theydon't have food safety managers?
We want to help with that.

Jim (17:58):
Sounds great. Thanks for that summary. That's, that's
helpful. So I will take piecesfrom the longer course that you
were kind enough to provide tothe UH AgConnect course and
their cohort. I think there maybe a YouTube recording somewhere
that you've done in the past aswell, that you're okay with me

(18:19):
sharing that as well as the linkin the notes of the podcast. I
think I could offer that. Sopeople get the full version of
the overview of the program. Orwe could even use the one from
UH AgConnect is that if that'sokay with you. So let's, let's
try to come up with someresources that we could share in
the notes and people, yourwebsite, of course, and ways to

(18:40):
get a hold of you if they'reinterested.

Lisa Rhoden (18:42):
That sounds perfect. Yeah, we do have a
YouTube channel. We have somegroup GAP webinars on there, as
well as some publicly available,what we call, employee
trainings. So that's an areawhere sometimes farms aren't
really gonna have the time, orthey don't know how to train
their employees on some of thesepractices. So we have a whole
series up there. There'sprobably about nine or 10 videos

(19:04):
that they can watch to.

Jim (19:07):
When Lisa recently met the University of Hawaii's AgConnect
program about group GAP. Wedecided to record it and will
now share some excerpts from themeeting to highlight some of the
key points. We hope you findthis helpful.

Lisa Rhoden (19:19):
I'm going to talk a bit about a couple of things,
one little bit about ourprogram. So what are we doing?
Who are we? GAPs, history FISMAhistory, those are sort of
confusing terms for folks. Theydon't exactly mean the same
thing, but they're in the samespace. So cover a little bit
about that. Basics of FISMA.
People always want to know alittle bit about it and whether

(19:42):
or not they're exempt.
Differences between GAP andFISMA. What is GAP about? Why is
it useful? Why do we care aboutit? I'll talk a little bit about
general best practices on thefarm. Sort of overall things
that you should know about ifyou're growing food for
consumption. And thenspecifically, I'll talk about

(20:02):
group GAP and how it works. Howis it a little bit different
from what we call traditionalGAP or GAP that was around prior
to group GAP. To talk a littlebit about the history of GAP,
it's an acronym people use itall the time. It stands for good
agricultural practices. USDA GAPis the most popular food safety

(20:23):
certification available. Thereare other things out there you
can get. You may hear peopletalk about Primus, that is a
food safety audit that istypically required by Costco for
example. GFSI is another one,which is global food safety
standard. Global gap is anotherone. But USDA GAP is the most
commonly required one. It wasestablished in the early 2000s.

(20:48):
and it was again put in place byUSDA to allow a producer a way
to show verification of theirpractices that they were
preventing or trying to preventtrying to minimize the potential
for foodborne illness comingfrom their product. It is
voluntary. So GAP is what'scalled a buyer driven audit,

(21:12):
which means that you don't haveto do it but your buyer may say,
"I'm not going to buy from youunless you are food safety
certified in USDA GAP." So it isthe buyers choice. Whatever
audit scheme they wish to workin or have a farmer or supplier
do, that is their choice. So forthe farmer, it's not voluntary,

(21:35):
but if you're in a positionwhere you really want to sell to
a particular buyer who'srequiring it, then it kind of
goes into that gray area. It'snot, it's not required, but it
is required because you can'tsell to this buyer unless you
have it. So GAP is prettycommon. On the mainland,
particularly, it's very wellknown. FISMA, on the other hand,

(21:57):
newer a little bit moreconfusing. FISMA is an acronym
for the Food SafetyModernization Act. And it was
written because in the early2000s, right around the time
kind of GAP got introduced,there were a number of food
illness outbreaks that reallycaught the attention of the
nation because they were spreadout across the country, and they

(22:21):
were pretty bad. One of them hadto do with spinach, it was the
E. coli infection. It killed anumber of people. And other one
was cantaloupes. People haveprobably or you may remember if
you haven't heard of itrecently, but there was a big
one that was related to beefthat was Jack in the Box, I
think. That really set the stagefor people just start worrying

(22:43):
about this because a small, ayoung child died in that one. So
food safety became all of asudden something that everyone
was really paying attention toto the point that nationwide, it
became something that leaderswere looking at. And so FISMA
was starting to be written. Andthe idea was really to

(23:04):
strengthen the supply chain fromfarm to fork to prevent
foodborne illness as much aspossible. There are seven pieces
to FISMA legislation, there isthe Produce Safety Rule, which
covers farm operations, that'swhat most farms or farmers are
aware of. And that is whatestablishes the standards for
growing, harvesting, packing,holding any of the fruits and

(23:26):
vegetables that people eat,particularly the ones that are
eaten raw. If it's somethingthat is never eaten raw, it's
likely not covered under FISMA.
So we'll talk little bit aboutthat in a minute. Farms,
generally speaking, if you're ofa certain size, you're gonna
have to comply with some portionof FISMA. You may be eligible
for an exemption. There areexemptions, qualified exemptions

(23:50):
and a full exemption as well,depending on the size of your
farm. And by size, what we meanis income and where you're
selling your product and howmuch of it you're selling direct
to consumer. So basically, ifyou grow a product for human
consumption, if you wash it,pack it hold it any of those
things, any combination of thosethings, you are probably covered

(24:13):
under FISMA, especially if thatproduce is on the, not on the
rarely consumed raw list. So ifit's something that you might
eat raw like lettuce, tomatoes,etc. that's going to be covered
by FISMA. There are exemptionsand as I mentioned, one of them
has to do with income. So if youon your farm made less than, and

(24:34):
this is a little bit off,$25,000 a year in produce sales,
that would be adjusted forinflation, so it's probably a
little closer maybe to $28 or$29,000 now, but essentially,
that would mean that you're notyou don't have to comply. You
are exempt, fully exempt. Aqualified exemption is that you
are selling your product, morethen half of it 51%, directly to

(24:59):
a qualified end user, which is aconsumer, so directly to a
consumer to a restaurant orretail within 275 miles or in
the same state. So for Hawaii,most of our farms would fall
under this qualified exemption.
Most of our farms are sellingmore than half of their product

(25:23):
directly to a consumer or arestaurant or within the state.
So you really as a person, ifyou're worried about having to
comply with FISMA, in mostcases, you're probably going to
have a qualified exemption. Whatis GAP then? So we talk about
FISMA. We talk about GAP,they're not exactly the same
thing. And GAP again, goodagricultural practices, it is

(25:47):
voluntary, whereas FISMA is thelaw. So FISMA is not voluntary.
That's why it provides thatexemption for certain size
farms. For GAP it's really abouthow do you show that you are
doing all of these practices,best recommended practices? And
how do you show that you'vethought through the potential

(26:07):
contamination that might happenon your farm or around your
farm? How are you keeping yourproduct safe? It covers a lot of
different things. It's not justabout cleaning and sanitizing.
It's also about how did youtrain your workers? are you
monitoring regularly? And howare these things verified? So
keeping documentation is areally big key piece of GAP.

(26:31):
Because really, your practicesare going to be verified through
an audit process. And when anauditor comes to your farm,
they're just there for that oneday. They're going to watch what
you're doing, they're going tosee your processes. But in order
to really assess whether or notyou've been doing all of these
things all this time, theyreally need to see documentation

(26:52):
and that's where those recordscome in, that documentation that
shows "Yes, I regularly docleaning and sanitizing of my
harvest tools. I always log myharvest, I know exactly what I
got and where it's going." Sothis is how we verify that these
practices are being done byreviewing these records and
reviewing the procedures. ForGAP typically, an audit will be

(27:16):
done once a year by USDA.
They'll also be follow up auditsdone intermittently. So that's
kind of an opportunity for them.
Typically a shorter audit,they'll come out to the farm and
just check up on everything andmake sure that yes, you have
records for the last few monthssince they've been there. Yes,
you're still doing basically thesame procedures as you were
before. So why do we care aboutGAP? Why is it helpful? I like

(27:43):
to think of it as kind of likecar insurance. It protects you
in the event that somethinghappens. Now, of course, we hope
nothing happens, and for themost part, we don't see a lot of
evidence of that, particularlyin Hawaii. But that may just be
because we're not very good attracking it. So having that GAP

(28:04):
certification or following goodagricultural practices and
having records even if you'renot certified, it goes a long
way to showing someone, if youneed to, that you do have all of
these practices in place. It'salso important for buyers.
Buyers like to have someassurance, some verification
that you are following thesebest recommended practices. And

(28:27):
even better that you've had anaudit by a third party who has
come into your farm, seen whatyou're doing, and verify that
that's exactly what they areexpecting to see. For a buyer it
reduces their risk, right? Itreduces their concern and their
potential liability. And itgives you a market advantage,
particularly in Hawaii. Not thatmany farms are GAP certified or

(28:48):
have any food safetycertification. So it's a
branding opportunity to put thatout there to say "I have gone
through this process, the USDAhas come to my farm, they agree
that I am doing all the thingsI'm supposed to be doing." In
fact, if you go through the GAPprocess, and you get audited,
your farm would be listed on theUSDA website. So anyone can look

(29:08):
it up and see, yes, you meet thecompliance criteria for GAP. So
why do we care about it, though?
Why is it such a big deal? I getthat question a lot,
particularly from folks who say,"Well, you know, we don't see
food safety, illnesses comingfrom small farms in Hawaii. We
don't see that small farms causethese big problems." And I would

(29:29):
say for that one, I think that'snot necessarily the case. We
probably do have that happen. Wejust don't have a good way to
track it. People don't rememberthat they got sick. Maybe they
had bought, you know, somethingfrom a roadside stand. They
didn't wash it. They don't putthose two things together
necessarily. And most of thetime, we're not keeping good

(29:50):
enough documentation to knowanyway. It's also important to
remember that contaminationcomes from many places and it's
all often not something that'svisible or very easily seen. So
when we have things like curlykale, we've got tomatoes with
scarring or bruising, those arepotential for contamination to
get in there of some kind. If wedon't wash our kale, well we've

(30:14):
got little bit of stuff stuck inthere, maybe we've got a snail
in there we don't know about. Sothose are things that we just
need to keep in mind. As far aswhere can contamination come
from, sometimes it's just partof our environment. And we don't
know what the person who buysour product is going to do with
it, when they go home. We hopethat they're going to wash it
themselves but that's not alwaysthe case. Sometimes people buy

(30:36):
stuff, they put it straight inthe blender, they don't wash it,
they don't rinse it, they don'tdo anything with it, other than
eat it right away. So on thefarm side, we want to be sure
we're doing everything we can toprevent any potential illness
from happening. This iseveryone's favorite topic. No
one really likes to keep recordsand I get it. But if you don't
keep them, you really don't haveone any evidence that you've

(30:59):
been doing all of these bestpractices. And two, you don't
really have a way to show yourprogress. So I always recommend
to folks try to keep records asbest you can. Even if you're not
trying to get food safetycertified. There are a lot of
reasons why you want to keepthem aside from food safety. One
is that it's your commitment towhat you're doing, right. It's a

(31:22):
history of the work that you'vedone. It shows your inputs, it
shows your outcomes. So you havea really good set of documents
to show your progress, I havehad an operation tell me that
because of their record keeping,they were able to show donors
that they produce this much morefrom one year to the next and

(31:43):
they were able to hire this manyextra people. So understanding
that having that data can beuseful. It might be a grant that
you're applying for, it might bea donor that's looking into
investing in your operation, buthaving a clear set of data to
show this is what I've beendoing and this is where I've
come is really, really key. Sohowever you want to do your

(32:04):
records, doesn't really matterif it's on paper, you want to do
it digitally or Google Sheets isa great way to do it. Whatever
it is, just keep records, setyourself up with some kind of
system that works for you thatyou feel comfortable with, and
then try to do your best tocomplete them every single day.
Lately, over the last couple ofyears in our program, we have

(32:27):
been using a product calledHeavy Connect and it is a
digital record keeping system.
We love it. I like to call itthe glitter and unicorns of
record keeping. It's a digitalsystem. It's not the only one
out there but it's one that isspecific to food safety so we
really like it for that reason.
And it's just wonderful becausebasically it goes on your mobile

(32:50):
device, so on your phone or onan iPad. We put all of the
records in here for our group,it has templates as well. So if
there's a record that you don'tfeel like producing yourself,
you can use the template, butessentially, it's a very simple
way to go through and identifywhat you did in a day. So why
all this care about food safety?

(33:16):
Why do we care about gettingcertified? Well, the big reason
to us and I mentioned thisearlier is, you know, we were
looking at how do we boost aghow do we have a more thriving
ag production in our state. Andwe know that we import a ton of

(33:37):
our food 85 to 90% by mostaccounts, and yet the state had
a goal to double local foodproduction by 2020. That was
back in 2016. We're now twoyears, three years past that. In
the last couple of years, thestate has actually mandated that
institutional purchasing boostup and start buying a lot more

(33:58):
local product. So how are wegoing to make this happen?
Because we haven't had thisopportunity to do it yet. We've
got a lot of small farms, butthey're not selling into these
markets. And again, that isbecause in many cases they don't
have food safety documentation.
They're not food safetycertified. These larger markets
just won't or can't take theirproduct. So if we look at how do

(34:19):
we make ag a thriving industryhere in Hawaii, one of the ways
to do it is help these smallfarms get certified so that they
can start to fill in thesemarkets, these gaps that we
have. Institutional markets,bigger buyers like HFA and Y,
Hata, and ChefZone. We have theproduction capacity to do this.

(34:42):
We have a ton of small farms inthis state. We're just not
really helping them get to wherethey need to be. So for
Northshore EVP this is our biggoal. This is what we realize
this is how we help small farmsby enabling them to compete more
successfully in the marketplace.
One thing that we want to do islevel the playing field. Big

(35:03):
farms, they have farm foodsafety managers, they have the
capacity to hire someone to justdo that farm food safety work.
So that's what we want to do, wewant to be that for small
farmers. That allows them thento get that food safety
certification, compete moreequitably with the bigger guys.
We also want still to work onhelping folks achieve an

(35:28):
aggregation or food hubfacility. Midsize food hubs,
midsize aggregation facilities,that's a place where a lot of
small farmers can hurry up theirproduct. And then a retailer can
be assured that they're going toget what they need, in the
consistency that they need, thequality that they need. So by
putting all these small farmstogether and their product

(35:50):
together in one place, we startto address those concerns that
these bigger buyers have withsmall farms. And that is, namely
that they're inconsistent, thequality isn't there, or they
just don't have enough, right.
So by huiing, together, bysetting up these mid scale
aggregation facilities, weaddress that issue. We address
that concern that the big guyshave. And then we're also
working on that food safetycertification or documentation

(36:11):
that the buyer requires. Soagain, we're addressing all of
these issues. And that's goingto help these small guys be able
to compete more successfullywith the big guys that are out
there. So this is where groupGAP comes in group GAP is a
little bit different. It was aresponse by USDA from smaller
growers who said, "I want to getGAP certified but it's out of my

(36:36):
reach. I don't have a person tomanage it. It's too expensive.
It's too hard." All of thesethings that that small growers
said. And so USDA was like,"Okay, how do we make this
happen for smaller farms?" Sothey came up with the idea of
group GAP. It is a USDA program.
There are specific requirementsthat a group has to follow to

(36:59):
become an authorized group GAPgroup and to stay a group GAP
group. Our group here in Hawaii,we work under the harmonized GAP
standard. So that is thestandard that is synchronous,
essentially with FISMA. Sobasically, that means that FISMA
requirements and harmonized GAPrequirements are very, very

(37:19):
similar. In many cases, they'resimilar or the same. In a few
cases, harmonized GAPrequirements are a little bit
more robust than FISMA. Butgroup GAP allows a group of
farms, even food hubs, marketingorganizations, it allows them
all to work together under onesystem to get that

(37:40):
certification. So essentially,all of the farms are working
together. They're all kind offollowing the same practices or
similar practices, following thesame procedures, and then the
group will be audited together.
So if one farm doesn't do well,that's okay. They basically have
their corrective actions thatthey need to take care of.

(38:02):
Everybody else is going to getcertified. We started looking at
this as a way to help smallfarmers in Hawaii. We saw that
it was a really good fit and westarted working on our group
procedures, got authorized byUSDA in January of 2020. In
March of last year, about a yearago, we actually merged with

(38:23):
another big group GAP group onthe mainland and it's
administered by Fresh Systems.
This is a really big group,that's about seven different
states that are involved. Andthey have a number of group GAP
groups within those states. Butit comes up to about 60 farms.

(38:44):
This is a good opportunity forus, for a couple of reasons. We
wanted to merge with thembecause USDA didn't see any
reason why we couldn't do that.
There was no specificrequirement that it had to be
regional. And so we thought,well, if we do this, we've got
all of this technical expertisefrom folks on the mainland who
have group GAP groups. We'vealso got a much larger pool of

(39:06):
farms so when it comes tolooking at how many farms in the
group will be audited, we've gota much bigger pool that reduces
the number of farms in our groupthat would be audited every
year. And it's just a reallygreat way to share, right? There
are a lot of similarities withrural farms on the mainland and
rural farms in Hawaii, more thanI would have expected. But we

(39:28):
started working with this groupand we started to see that they
had a lot of the same challengesthat we have. So there's really
a lot of power in that tobrainstorm, to work together, to
ask for advice, and we found itto be really helpful. So the way
that group GAP and regular GAPwork or are different? Regular

(39:48):
GAP, the way that it had beenprior to group GAP coming along,
a farm would prepare for thataudit, do all of their record
key thing, right, their farmfood safety plan, all of the
documentation that they need,they're gathering on their own,
and then they have an audit ontheir own. They pay for that
audit. So the audit cost goes tothe farmer. And typically, as I

(40:12):
mentioned, you're going to havea follow up audit in that year
as well. Under group GAP, it's alittle bit different structure.
The farms, all the farms in thegroup work under what's called a
QMS, a quality management systemthat's managed by an entity or
group manager. So in our case,that is Fresh Systems. Fresh
Systems manages our qualitymanagement system, they have set

(40:34):
the procedures and they makesure that we're all following
them. We prepare our farms fortheir audit together. So all of
the Hawaii farms work togetherwith us, with Northshore EVP. We
work individually with eachfarm. We also do classes, we
help them write their farm foodsafety plan, we go through the
risk assessments and we helpthem start their record keeping.

(40:56):
Once in the year, each farm inour group is going to have an
internal audit and what's calledan unannounced audit. So two
audits a year done by us. Thatgives us a really good sense of
where are you? Are you ready forthe USDA audit? Are there some
things that we're not quitefeeling compliant on we're going
to work on? And when it comestime for the actual USDA audits,

(41:20):
we're going to submit all of ourfarms to USDA together along
with all the other farms in thatbig huge Fresh Systems group.
USDA will say okay, you've got,let's say about 50 Farms, we're
going to audit the square rootnumber of that, which would be
about seven. So all across thoseseven states, seven farms out of

(41:41):
those are going to be audited,give or take. The USDA will look
at all of our internal auditrecords so they know which farms
are in our group, they knowwho's doing well, they know if
there's somebody who's got somecorrective actions, and they're
going to choose which farms theywant to come see. Once they do
that they do those audits,again, if everybody passes, the

(42:01):
whole group gets certified. Ifthere are some farms that didn't
pass, that's okay, they do theircorrective actions, the whole
rest of the group getscertified. Once those farms who
have their corrective actionstake care of those and they
receive a follow up audit, theywill get their certification as
well. One of the biggestbenefits to this is that every

(42:21):
single farm in our group pays aflat fee, they pay that into
basically the kitty, and we paythe audit costs out of that. So
every year if you're in groupGAP, you know what your costs
are going to be. versus regularGAP, you do that on your own,
you don't exactly know how muchit's going to cost because you
don't know how many hours theaudit is going to take. And then

(42:43):
that is the bill that's going tocome to you. And then to provide
I guess, a little extrarobustness, the entity that
manages the procedures, FreshSystems, they get an audit every
year by USDA too. So USDA isreally checking on overall the
procedures of this group, howdoes this work? Is that working?

(43:04):
Are they meeting therequirements? And then they're
also going to look at all of thefarms as well in the group in
one way or another.
So for our program here inHawaii, again, we are we are
working with Fresh Systems, theythey manage the administrative
side of it. On the ground herein Hawaii, the way that we do

(43:26):
this is that we hold arecruitment period. So once a
year, anyone can apply. We willtake those applications and we
will go and meet with the farmand kind of take a look at what
does it look like? How arethings set up? Is it organized?
Is there anything missing?
Infrastructure? Do you have abathroom? Do you have a place to

(43:47):
wash hands? What are youproducing? Where are you
selling? That will help usdetermine if the farm is ready
to enter into this program. Ifwe have a farm, for example,
that doesn't have a workingbathroom, that's going to be a
point of concern where we'regoing to say, "Well, you need to
get that before we can startworking with you because not
having a bathroom is notacceptable, we're not going to

(44:09):
be able to get you certifiedwithout that." Once we get our
group going, we do grouptraining and one on one
training. Our group training isin the form of classes that we
start off with going through theentire harmonized GAP audit, so
we understand what's in thereand what's required. And then
once that is done, we begin towork with every individual farm,
preparing their risk assessment,their documentation. And overall

(44:34):
this really is just a bignetwork of farmers who are kind
of all thinking the same thing.
"We want to open up our markets.
We want to get food safetycertified." And we do those
internal audits twice a year aswell. So you will get visits
from us to come out and we willdo those audits with you and
give you a sense of you know,how good are you doing in terms

(44:54):
of being compliant with the USDAstandard? We kind of break our
work down into what we calltiers. So in the first tier,
that's kind of the basics. We'relooking at your record keeping,
we're gonna go over food safety,basics and culture and we're
going to talk abouttraceability, because that's a
really key piece ofunderstanding, being able to
trace documentation wise whereyour product went, and what did

(45:17):
it what happened to it when itwas still on the farm. Then we
move into what we call tier two,that's risk assessments. So we
kind of look at where are allthe possible places on your farm
that contamination could comefrom and what do you have set up
to do about it? In most cases,this is a pretty rigorous
meeting. But it's also a meetingwhere we find that most farmers

(45:39):
already have a lot of proceduresin place, they're just not
written down. So we take thaton, we write that down, and we
use that information to write afarm food safety plan. At the
same time, we're going to begathering the other
documentation that we wouldneed. So water quality results,
if you have any pesticides beingused on the farm, you're going

(45:59):
to need WPS trainings, we makesure that you get that. Any of
the documentation that'srequired outside of your farm
food safety plan. And then thelast tier essentially is, if you
want to get an audit, you'regoing to be preparing for that
audit. So if you are chosen, wewill attend the audit with you.
Otherwise, we're going to bedoing your internal audits and

(46:22):
submitting those reports toUSDA, if they don't see any
problem with it, and you passthose, you're going to get your
certification. So what we'redoing is we're auditing the
procedures at a farm withrespect to those particular
products. So as an example, ifyou are growing cucumbers, leafy

(46:42):
greens, herbs, swiss chard, thatkind of stuff and let's say
tomatoes, and you want to getcertified all of those products,
we would come out, we would lookat your procedures, and we're
going to look at the harvestprocedure for all of those
things. Now, for leafy greens,if your procedure for lettuce,

(47:04):
swiss chard, kale is all thesame, we don't need to see every
single one of those thingsharvested, we would just look at
one of them, because you'reusing the same procedure for
everything. But your tomatoprocedure is different, that's
going to be looked at. If yourcucumber procedure is different,
we're gonna look at that too.
Then, if you go somewhere else,so let's say you you open up a

(47:26):
second farm, then you could getthat farm certified as well. And
same thing, we're going to comeout and look at the procedures
on that farm. Every every farmsite, every crop is going to be
reviewed. And that's every year.
So you're gonna have thatreview, you're gonna have to
maintain your records, all ofthat, you know, every single
year is the same process. Whenyou introduce a new crop that's

(47:47):
going to be audited as well. Soif you say, oh, now I'm gonna
grow pumpkins, I'm gonna addthat, same same thing. We're
gonna come out and we're gonnabe like, "Alright, I want to see
your pumpkin harvest. Let me seeyour whole procedure here. What
do you do?" If you move and youlike you give up your farm and
you go somewhere else, thenyou're not, there's no more
certification until youestablish something at a new
place.

Jim (48:09):
We thank Lisa for sharing details of the group GAP program
and to the AgConnect cohort fortheir willingness to share
excerpts from their reviewsession in our podcasts. As
described. GAP certification,while not mandatory, can open up
opportunities for selling intocertain markets like schools.
And since the process to get GAPcertified may seem like a
burden, or even overwhelming toa small scale farmer, this

(48:32):
Northshore EVP group GAP programcan make it much easier and can
also help ensure that ourlocally produced food is
following these food safetystandards.

Lisa Rhoden (48:41):
I just wanted to talk a minute about what what do
we see as a successful programbecause really, we can do this
kind of stuff all day but weneed to have a measure, right?
What's our measure of success?
What we really want to see isthat this program is serving
farmers. That we're gettingfolks certified and helping them
open up their new markets. So wewant to see farmers who want to

(49:02):
work with us, farmers who arededicated really to to growing
their markets, farmers who arelooking for food safety
certification, or at least foodsafety documentation, folks who
really want to maybe increasetheir production or at least be
producing and have consistentmarkets to sell it into.
Ideally, we'd also like to seethat this helps a farmer reduce

(49:25):
their post harvest work. Becauseif your food safety certified,
you can move your product overto someone, some distributor,
there's a lot less work for youto do in terms of getting it out
to a farmers market or someother place where that's a lot
more work on your end. And ofcourse, we want folks who want
to be a part of a network,because that's really how this
works. It's a community andwe're really trying to sort of

(49:48):
elevate that for farmers inHawaii that you have a place to
go to, to ask questions, to gethelp, to help you grow bigger
and be more successful andaccess new markets. So ideally,
that's what success looks liketo us and, you know, at the at
the apex of this we have localfood everywhere because it's

(50:08):
widely available and we have alot of farmers who are certified
and able to get it out there.

Jim (50:16):
The intention of this podcast series is to create a
safe space for respectful andinclusive dialogue. With people
from across a broad and diversespectrum involved in growing and
making accessible the food weshare together. The diversity of
voices, perspectives andexperiences can serve to deepen
mutual understanding, to sparkcreative problem solving, and

(50:37):
provide insight into thecomplexities of our agricultural
system. If you, our listeners,have experiences with Hawaii
agricultural ecosystems, fromsmall holder farms to large even
including multinationalagricultural industrial
companies, or anywhere inbetween, and you would like to
share your story, please contactus. We welcome your voices and

(50:59):
perspectives
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