Microgreen Manager

A Comprehensive Guide to the GAP Certification for Microgreen Farmers

Nov 30th, 2024

Introduction

“You need to be GAP certified to work with us.” “I’m preparing for my GAP audit.” “GAP is required to sell to bigger buyers like distributors.” Do any of these sound familiar? What is GAP? How do you get GAP certified? Why should you pursue a GAP certification? This article is your comprehensive guide to what GAP is and why you may or may not want to pursue it.

GAP stands for Good Agricultural Practices, and it’s a voluntary food safety program. The US Department of Agriculture (USDA) oversees the program and issues the certifications. Voluntary means you’re not required to take part. The GAP program was created to verify that fresh fruits and vegetables are produced, packed, handled, and stored according to food safety practices that minimize the risks of microbial hazards. As your microgreen farm grows, though, you'll want to sell to bigger buyers, like grocery stores, schools, and distributors. These buyers are increasingly requiring a GAP certification from their suppliers. They want to know that the food they wholesale to their customers can be trusted as safe, and a third-party GAP audit proves that.

Disclaimer: This article is not meant to be a how-to guide for actually preparing for your GAP audit. GAP preparation takes months. You will need to study the GAP standards, assess where you are today, and then chip away at the improvements.

Too Long, Didn’t Read (TLDR)

GAP stands for Good Agricultural Practices, and it’s a voluntary food safety certification offered by the USDA. As you grow your microgreen farm, you'll seek bigger buyers, like grocery chains, schools, and distributors. Most of these client types will require your farm to be GAP-certified. A GAP certification shows buyers you follow strict food safety standards on your farm. There are different types of GAP with varying levels of strictness. These range from the entry-level GAP/GHP to the international gold standard GFSI. If you’re thinking about getting GAP certified, ask yourself the following question. “Do I want to be a full-time microgreen farmer?” If the answer is “No,” GAP likely isn’t the right choice. The types of buyers that require GAP will likely buy five- or six-figures of microgreens a year, which demands full-time work. After deciding to pursue GAP, find a partner organization. They can help you prepare your farm and your food safety plan. Expect to spend four to six months preparing for the audit. Expect to spend $1,000 - $2,000 on the audit costs before any cost-share programs.

History of GAP

GAP was developed in the 1990s and early 2000s in response to growing food safety concerns. GAP predates the 2011 Food Safety Modernization Act (FSMA) and Produce Safety Rule (PSR). We wrote about these mandatory federal regulations at length in our other article, "What’s Legally Required to Sell Microgreens...?" Many PSR rules come from GAP. Why is this important? First, it’s helpful to understand how and why mandatory (FSMA) and voluntary (GAP) programs come to be. Second, you can think of GAP as the stepping stone to FSMA. The article above says that farms with $500,000 in annual sales must follow FSMA rules. If you’re already GAP certified, you’re well on your way to meeting those requirements. I know $500,000 sounds like a lot, but bigger buyers can easily be worth $100,000 a year. My farm’s relationship with FreshPoint/Sysco earns us $120,000 annually.

What EXACTLY is GAP?

In short, GAP is a set of standards and practices to maintain proper food safety in your farm. GAP covers infrastructure, chemical safety, historic land use, water sources, employee training, pest prevention, record keeping, and much more. Here is a non-exhaustive list of categories GAP covers and the specific items they’ll ask you to address. The bullets in quotations are directly from the Harmonized GAP Audit Checklist.

Infrastructure
- Proper facilities and equipment that minimize contamination risks. Adequate drainage systems. Proper storage areas for chemicals and equipment.
- “(F 1.2) For indoor growing and field storage buildings, building shall be constructed and maintained in a manner that prevents contamination of produce.”
Behaviors & Practices
- Proper handwashing and personal hygiene protocols. Correct handling of produce during harvesting and packing. Implementation of cleaning and sanitization procedures.
- “(G 10.1) Operation shall have a policy for toilet, handwashing, hygiene, and health.”
- “(G 10.6) Toilet and wash stations shall be maintained in a clean and sanitary condition.”
Tools & Equipment:
- Use of appropriate materials, such as stainless steel. Proper maintenance and cleaning of equipment.
- “(F 10.2) Operation has a written policy regarding inspection of food contact containers prior to use.”
- “(F 11.4) Cloths, towels, or other cleaning materials that pose a risk of cross-contamination shall not be used to wipe produce, unless risk mitigation procedures are in place.”
Knowledge & Training:
- Understanding of food safety principles, including bacterial growth and chemical safety. Regular employee training on food safety practices. Awareness of potential hazards and mitigation strategies.
- “(G 4.1) All employees shall receive food safety training appropriate to their job responsibilities.”
Documentation & Record Keeping:
- Maintaining detailed records of food safety practices. Developing and implementing a comprehensive food safety plan. Conducting mock recalls and traceability exercises.
- “(G 3.1) Documentation shall be kept that demonstrates the food safety plan is being followed.”
- “(G 3.2) Documentation shall be readily available for inspection.”
- “(G 6.2) A trace back and trace forward exercise shall be performed at least annually.”
Water Management:
- Ensure the safety of water used for irrigation and post-harvest activities. Regular testing and monitoring of water sources. Identify potential risks to the health and safety of your water sources.
- “(F 2.3) Water systems shall not be cross-connected with human or animal waste systems.”
- “(F 1.3) Sewage or septic systems are maintained so as not to be a source of contamination.”
- “(F 4.2) Water testing shall be part of the water management plan, as directed by the water risk assessment and current industry standards or prevailing regulations for the commodities being grown.”
Soil & Land Management:
- Assessing and mitigating risks associated with land use history. Proper management and storage of soil amendments and fertilizers.
- “(F 6.3) If an alternative growing media, soil-less media, or substrate not of animal-origin is used, such as perlite, peat, or coconut fiber, it is appropriate for its intended use and stored and handled in a manner to minimize the risk of contamination.”
Animal & Pest Control:
- Implementing measures to prevent animal intrusion. Regularly checking and replacing traps when necessary.
- “(F 5.2) Operation routinely monitors for animal activity in and around the growing area during the growing season.”

These are just a few of the audit standards you must meet to earn your GAP certification. For the Harmonized GAP level certification, the General and Field sections of the standards span 37 pages. The auditor will visit your farm and review each of the 100+ standards one by one to ensure compliance. We'll talk more about the actual audit process later in the article.

GAP vs. GHP vs. GMP

Good Agricultural Practices (GAP), Good Handling Practices (GHP), and Good Manufacturing Practices (GMP) sound similar, but cover distinct areas of the food production system. GAP covers farm-level practices. GHP covers post-harvest handling. GMP covers food processing and manufacturing. Food processing means transforming the original “raw agricultural commodity (RAC)” from its “natural state” into something else. This would include processes like pasteurization, cooking, peeling, and blending. Peeling, for example, doesn’t sound like you’re “altering it from its natural state.” However, oranges don’t grow on trees without their skin, so peeling is a departure from the natural state. GMP isn’t relevant to microgreen farmers because most farmers sell the microgreens as-is. If you process your microgreens into a salt, dehydrated product, pesto, or anything else, you'll likely need a separate, GMP-certified facility. Ignoring GMP, that leaves us with GAP and GHP. You’ll often hear GHP and GAP mentioned together. When we look at the three sections of GAP, we see how they’re related. Not all three sections are required for all farms or all audit levels. For example, my farm, Piedmont Microgreens, only needed to follow Sections G and F. Section P would be GHP, even though the whole audit scheme is GAP. As a microgreen farm, you should only need to follow Sections G and F. If you wash your microgreens, though, you'll also need to follow Section P. This mainly applies when farmers wash and dry their sunflower shoots to remove seed hulls. Otherwise, your grow racks and harvest tables would be considered the “field.”

General Questions (G)
Field Operations & Harvesting (F)
Post-Harvest Operations (P)

GAP for Flowers

Many microgreen farmers eventually venture into edible flower production, so let’s touch on that real quick. Edible flowers are like microgreens; they're raw agricultural commodities (RAC). As long as you’re selling the flowers in their original, natural, unaltered state, they’re considered a RAC. When you apply for your audit, you’ll need to list the commodities you want audited for certification. If you grow flowers and microgreens, be sure to list both on your application. If you grow microgreens and flowers in the same facility, but only want to certify your microgreens, you'll have a tough time. Mixing GAP and non-GAP products in the same facility will require extra safeguards and procedures to prevent cross-contamination. I highly advise getting both audited and certified if you grow both. It should be just as easy to meet the standards for flowers as it is for microgreens.

Types of GAP

There are different types of GAP certifications to be aware of. Buyers that need GAP will require different types, depending on their customers' needs. We’ve mostly been talking about GAP and GHP, but through the lens of my personal experience. I never had my farm, Piedmont Microgreens, GAP certified. I chose to start with Harmonized GAP as our first certification, bypassing the entry-level audit. I did this to stand out and exceed the minimum standards for my farm. I’ll add that I’ve talked to many people about the severity of each audit type. Most people agree that GAP is approachable; it’s not too hard to meet the requirements. HGAP is significantly harder than GAP, requiring much more training and record keeping. HGAP+ is closer to HGAP than HGAP is to GAP. HGAP+ adds further training and record keeping to the HGAP standards. The Global Food Safety Initiative (GFSI) is another type of food safety certification, but it’s not offered by the USDA. GAP, GHP, HGAP, and HGAP+ are all USDA-accredited certifications. Being that they’re based on USDA standards, the certification is only recognized in the US. The Global Food Safety Initiative is, as the name implies, an international certification for food safety. GFSI is the gold standard for food safety certifications. Thankfully, HGAP+ is considered an equivalent certification to GFSI.

GAP/GHP is an entry-level certification focusing on general food safety practices.
HGAP aligns with FSMA requirements, offering more comprehensive coverage.
HGAP+ combines HGAP with GFSI standards, meeting higher market demands.
GFSI sets the benchmark for global food safety standards.

USDA GAP Service Tiers

Below are a few common wholesalers and distributors requiring some form of GAP to work together. Most national grocery chains want a GFSI-equivalent certification. Distributors and public schools, in my experience, only require entry-level GAP.

Buyer Type	Buyer	GAP Level Required
Grocery Store	Wegmans	HGAP+ or GFSI
Grocery Store	Trader Joe’s	HGAP+ or GFSI
Grocery Store	Whole Foods	GAP or GFSI
Grocery Store	Food Lion	Unknown
Grocery Store	Ingles	Unknown
Grocery Store	Publix	HGAP or GFSI (Pg. 38)
Grocery Store	Costco	HGAP+ or GFSI
Grocery Store	Aldi	HGAP+ or GFSI
Grocery Store	Albertsons	HGAP+ or GFSI
Grocery Store	Kroger	HGAP+ or GFSI
Public Schools	Public Schools	GAP
Distributor	Sysco or FreshPoint	GAP
Distributor	UNFI	HGAP+ or GFSI

Value of GAP

Buyers requiring GAP can be worth much more than those that don't. It’s often the bigger clients that want GAP, so you can expect them to spend more. How much more? Here is a comparison of our customers at Piedmont Microgreens. It shows those who require GAP and those who do not. It includes their annual purchasing volumes. As you can see, a single big buyer can be worth dozens of smaller buyers. A single big buyer can make your GAP certification worth it.

Customer Type	Annual Spend	Gap Required?	Comments
Restaurants	$4,000	No	Average of Our 50 Local Restaurants
Farmer’s Market	$50,000	No	One of the Best Markets in the Southeast
Local Food Co-Op	$5,000	No	Small Grocery Store
Distributor	$30,000	Yes
Distributor	$100,000	Yes
Public School System	$25,000	Yes	Likely to Grow in Value ea. Year

GAP Costs & Timeline

What does GAP cost, though? You should separate the costs of getting your GAP certification into explicit and implicit costs.

Explicit Costs

The two main explicit costs are both related to the audit services. You’ll pay a third-party auditing agency to perform the audit, and then you’ll pay the USDA to review the audit and grant the certification. The third-party auditor will likely be your state’s agriculture agency. For my farm, it was the NC Department of Agriculture & Consumer Services (NCDA&CS). The auditor charges $155.00/hour, up from $132.00/hour last year. The auditor will charge you for any time spent on the farm performing the audit, as well as travel time. If you visit the link below for auditors by state, you’ll see that most states have only 1-3 auditors. If you have an auditor located on the other side of the state, tough luck. You can expect to pay much more than someone located close to the auditor. Our audit, including drive time, took 7.5 hours, which amounts to ($155.00*7.5) $1,162.50 in direct audit costs. The auditor was at the farm for only 90 minutes. I can’t remember if the USDA fees are fixed or per hour, but you can expect to pay a few hundred dollars more for that portion. The screenshot below is directly from my company’s financial reports. You can see we paid $465.00 to the USDA and $262.50 to the NCDA&CS. We applied for and received $900.00 in cost share from the NCDA&CS, bringing the auditor's cost down from $1,162.50. Our total explicit audit costs were $727.50.

Billing Facts for Audit Services

Total Explicit Costs After $900 Cost-Share

Audit Reimbursement Form

Implicit Costs

The biggest implicit cost was the time spent preparing. I spent a few hundred hours preparing over the course of the six months from initiation to certification. We spent that time working with our CFSA consultant. We wrote and rewrote the food safety plan, trained employees, and attended the Produce Safety Alliance class. We were also remodeling our new commercial space concurrently with GAP preparation. This was hugely beneficial. It meant we could work with our CFSA consultant and general contractor (GC) to build a food-safe farm space. The time spent working with the architect and GC would be other implicit costs. We also had tons of small purchases. For example, a lockable chemical cabinet. We only use two chemicals on our farm, Ocean Solution as a fertilizer and Sanidate 5.0 as a sanitizer. I wouldn’t have thought to buy a lockable chemical cabinet, but GAP requires it. Finally, I spent countless hours creating signage and labels for the farm. For example, signs to keep the bathroom door closed at all times. Signs like this reinforced the behaviors and practices outlined in our food safety plan. The bucket of implicit costs could include many other items. For example, emailing the auditor, contacting customers about passing the audit, and applying for the cost share program.

Where to Start & What to Expect

That was a lot of information. So, where should you start?

Determine if you want to get GAP certified. Are you at a scale where you could fulfill orders from five- and six-figure customers? Are you operating out of a spare room in your home or a commercial space? You can meet entry-level GAP requirements in a basement, garage, or shipping container, but it will be easier in a dedicated warehouse. Do you want to continue scaling your farm? GAP has both implicit and explicit costs to earn and keep the certification. Are you prepared to keep up with those costs and demands? A good litmus test for determining if you should pursue GAP is whether or not you want to be a full-time microgreen farmer. If not, I wouldn’t bother with GAP. There are enough customers out there that don’t require GAP to fulfill your part-time hours as a farmer.
Contact your local Cooperative Extension Office for help. Cooperative Extension offices help home gardeners and farmers. They assist with growing food, finding grants, connecting with buyers, and solving production problems. Use your local office as a starting point for your GAP journey. They might not be the people to hold your hand through the process, but they should be able to point you to someone who can. If you're in NC or SC, I can't endorse the CFSA highly enough. For a measly $40.00 annual membership fee, you can request help preparing for GAP. They will give you a Food Safety Plan (FSP) template. A consultant will visit your farm to answer any questions. See the resources at the end of the article to learn more about CFSA.
Attend a Produce Safety Alliance (PSA) training. Entry-level GAP does not seem to require food safety-specific training. However, our HGAP certification required it. GAP will require you to identify a primary, on-site Food Safety Manager. My Farm Manager is actually the designated Food Safety Manager, and I’m the secondary or backup. If you recall from earlier, “(G 4.1) All employees shall receive food safety training appropriate to their job responsibilities.” If you'll be responsible for food safety at your farm, including training others on the topic, you should receive training. I attended the training with my Farm Manager because I would become the Food Safety Manager if she left the company. I need training on the same material to stand in for that role while I hire a replacement and have them trained.
Identify the closest audit services office. The USDA Agricultural Marketing Services (AMS) website provides a list by state - Link. Send them an email letting them know you want to pursue a GAP audit. They’ll likely request the three forms below. As I said earlier, there are only 1-3 auditors per state, which means they could be booked months in advance. Be sure to start this process and request an audit date well before you need your GAP certification. We knew we’d be moving into our new commercial space in mid-April. We wanted a few weeks to adjust before the audit, so we requested an audit date of mid-May. We worked with CFSA from early January to prepare our FSP and audit materials. I would plan for the whole process to take six months. That's six months from finding a partner, like CFSA, and asking for their help, to getting your USDA certification.
Submit Form SC-430, which sets your farm up with a billing account with the USDA. You can complete this a few months before your requested or expected audit date. You can see from the screenshots below that I submitted SC-430 on 1.4.24, but our audit wasn’t until 5.21.24.
Determine the type of audit you want, and submit Form SC-237A. SC-237A is your request for audit services form. This is where you ask for a specific audit date and audit type. We asked for our audit to be on a Monday because we knew that would be a very relaxed day of our week. You don’t want to host an auditor on a day you’re trying to harvest and deliver tons of product. You can see from the screenshot that SC-237A is where you select the exact audit services. We wanted the HGAP audit, but we specifically kept the scope to Field Operations & Harvesting. As I mentioned earlier, we don’t wash any of our microgreens, so we didn’t need to be audited for Post-Harvest. The General Questions (G) section is required for everyone, so it’s not listed.
Submit Form SC-651, which is your agreement to participate in the audit services. We had a few documents, including SC-651, mailed to us in advance of our audit. We didn’t submit this online. We signed the hard copy the auditor sent over, and the auditor reviewed it when they arrived.
The auditor only spent 1-1.5 hours at the farm reviewing our FSP, supporting documents, and the farm itself. The auditor will also want to watch you harvest. They do NOT want or need to see a full-blown harvest day. You just need to demonstrate how you harvest a single container of microgreens, and maybe a blend as well. If you plan on moving to a new facility, be sure to schedule the audit for at least a few weeks after you move in. Why? First, the buffer will give you time to create good habits. It will let you adjust your layout, tools, and anything else with poor food safety. Second, you need to show the auditor legitimate records. We must maintain over a dozen records to meet our HGAP standards. These include a visitor log, bathroom cleaning records, and pre-harvest checklists. Your auditor will want to see at least a few weeks of real records to demonstrate you’re following your FSP. I also have to mention, your GAP certification is site-specific, not farm-specific! Do NOT pursue a GAP certification for the first time if you think you'll relocate the farm soon. Your farm map, FSP, processes, and much more are related to how the farm operates under the current context. For example, let's say you currently operate out of a greenhouse on personal property in a rural area. You likely use well water for irrigation. If you plan on moving to a commercial warehouse in the city in a few months, you'll likely use municipal water. Pretty much everything in the FSP related to water and irrigation will change as a result. Save yourself the effort.
When your auditor finishes their audit, they’ll go over any mistakes. If none of the mistakes are critical, they’ll informally congratulate you on passing. The auditor will return to their office and submit their report to the USDA. A few weeks later, after paying all associated fees, you’ll receive your certificate in the mail. The link isn’t working, but you should be able to eventually see your farm on the list of USDA GAP-Certified Companies. You can search by state, location, company name, or commodity. With either the hard copy certificate or the database as proof, you can start negotiations with those big buyers. Congrats!
You’ll need to maintain your GAP certification every year. The implicit costs will largely be gone, but the explicit costs will be the same or more each year. Most cost-share programs only help for a few years. So, expect to pay full price eventually. Keep your records up to date, and expect a mid-year "surprise" audit.