The Ruminant: Audio Candy for Farmers, Gardeners and Food Lovers - GAP Certification: A Barrier & an Opportunity

Episode Date: January 17, 2025

Hey everyone! This is Jordan with some bonus listening for you. As you may know, I’m the producer and host of The Organic BC Podcast, and over there, I’ve been busy producing a miniseries about whether GAP certification is a viable option for small-scale farmers who want to gain, preserve, or expand access to wholesale marketing channels. You’re about to hear episode one of that series, exactly as it dropped on The Organic BC podcast feed. If you like it, you can go find the organic BC podcast and listen to episode two right now, and episodes three through five will drop over the next few weeks. One quick additional note is that I produced this series about GAP certification under a paid contract, but I was not paid to cross-post what you’re about to hear on my other two podcasts, Farming in British Columbia and The Ruminant. I’m posting episode one of the series here because I think it’s good and because the topic is relevant to a lot of my listeners.

Hey everyone, this is Jordan with some bonus listening for you. As you may know, I'm the producer and host of the Organic British Columbia podcast. And over there, I've been busy producing a mini-series about whether GAP certification is a viable option for small-scale farmers who want to gain, preserve, or expand access to wholesale marketing channels in Canada. You're about to hear episode one of that series, exactly as it dropped on the Organic BC podcast feed. If you like it, you can go and find episode two on the Organic BC podcast right now, and episodes three through five will drop over the

next few weeks. One quick additional note is that I produced this series about gap certification under a paid contract with Organic BC, but I was not paid to cross post what you're about to hear on my other two podcasts, Farming in British Columbia and The Ruminant. I'm posting episode one of the series here because I think it's good and because the topic is relevant to a lot of you. Okay, enjoy. For about as long as I've been a small scale farmer, which is around 14 years, I've been exposed to, and at times involved in, what I've been calling the GAP discourse. GAP, or Good Agricultural Practices, is a program that certifies the food safety practices of

farmers and other participants in the fruit and vegetable supply chain. So why has there been a gap discourse among small and medium-scale farmers in Canada? Well, it starts with a piece of federal legislation called the Safe Food for Canadians Act. The Act, which became law in 2012 and took effect in 2019, was a modernization of food safety rules in Canada. It set out new requirements for food safety, traceability, and labeling for operators who sell food destined for grocery store shelves. Now, nowhere in the Safe Food for Canadians Act does it say that a farmer has to have GAP certification to sell their food to a distributor or grocery store. But here's the thing. If you obtain GAP certification, you have met all of the requirements of Safe Food for Canadians.

you have met all of the requirements of safe food for Canadians. Distributors and grocery stores know this, and so for them, it is 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. So what's the problem here? We all want safe food, right? Well, the problem, and the reason there has been

a gap discourse among small-scale farmers over the last 12 years or so, was summed up quite well by Brody Irvine, a buyer for an organic food distributor called Discovery Organics, when I interviewed him in 2021 about the gap discourse. The Canada gap is pretty robust and great, but it's very much focused, or at least historically has been written and focused on monocrop conventional farming, which doesn't have a lot of flexibility or even understanding in terms of organic production methods. And certainly when you're looking at small farms, who maybe are growing 40 to 50 different types of crops in one year, that there was just this really kind of like you know round peg square hole thing or you know the the growers that i talked to were ahead of this

because they were they had these you know some retail supply relationships were coming into a ton of just really challenging and friction with canada gap and and it was also becoming really expensive a lot of of the requirements around food safety in the Canada Gap standard were requiring these small farms to put in very expensive infrastructure upgrades. Yeah. So, I mean, that is ultimately my main concern is that in the race to become compliant with these new food safety standards, it is going to become unprofitable or untenable for some small farmers or medium scale farmers to keep up, to be able to still survive. It's inhibitive and a little bit scary. And I think it's counterintuitive to the intention,

and a little bit scary. And I think it's counterintuitive to the intention, which, you know, we want a food safe plan. We want safety within our food supply chain in Canada, but we certainly don't want it to come at the expense of a small to medium sized farm. So to sum up the GAP discourse in a word, exclusion. Small and medium scale farmers have been talking about GAP, worrying about GAAP, cursing out GAAP, because of a perception, or maybe the reality, that GAAP requirements unfairly exclude them from retail supply chains because it's too expensive and unaccommodating to the systems typical of smaller, diversified farms. Meanwhile, access to retail supply chains for small, diversified farms is something that some food security advocates believe is really important for building diversity and resiliency in our regional food systems.

And that's where this mini-series from the Organic BC podcast begins. This is the Organic BC podcast and I'm Jordan Marr. In the next few episodes, you're going to learn about the effort of a North Okanagan mixed veggie grower, Emily Jubinville, to preserve her access to retail supply chains for her carrots and beets. The writing is on the wall for Emily. If she wants to continue selling root vegetables to distributors and retailers, she's going to need to have GAP certification. So she went through the process of getting GAP, and we documented it. In this episode, Emily will explain why access to the retail supply chain is important for her small,

diversified organic veggie farm, and she'll go into more detail than I just have about the discourse around GAP certification among small and medium-scale farmers. In future episodes, Emily's going to take us through her effort to obtain GAP certification, the process, the expense, and the pain points. She'll also take us on a small tangent about how she's modified her carrot production to be able to sell more carrots for a lower price to retail stores. And at some point, of course, you'll find out if Emily gets her GAP certification. And we'll also hear from a couple other small scale farmers about their experience with GAP. That was a mouthful, but we got through it together. And now with that preface behind us, we can head out to Grinrod. It's March of 2024,

and I'm in Emily's living room to talk to her about her project. I want to, I just want to start with like your relationship to GAP certification and Safe Food for Canadians leading up to this project. So maybe just give me a summary in terms of what your farm is and does. So our farm, Shuswap Organics, and we just started a new home delivery business called Nature Delivered. We're currently at six acres of certified organic mixed vegetable production. During COVID, we stopped going to farmer's markets, and then shortly after that, we had a baby, so we also stopped doing CSA. So we were only doing wholesale to restaurants, stores, and institutions.

And that made our lives as farmers and new parents just way more manageable. Thank you, COVID. Yeah. And one of the things that we've noticed is that there are opportunities available even for small and medium-sized growers to get into some of the bigger markets,

wholesale markets, and gap certification is required. Okay, can I stop you there? So talk about stores you were selling into at that time, before we get into then realizing there was this other level of sales that you wanted to consider. So what store like give me some examples of stores when you say stores and whether they did they require were they were they asking you questions about either either gap or food safe for canadian yeah so um as a small grower most of the stores that we were were selling into are independent or were independent but nature's fair is a great example local independent chain that three-ish, four-ish years ago was bought by a big corporate conglomerate.

I want to say Bilo, but I'm not. It was Patterson. Patterson. Patterson Group. So now they're part of Patterson Group. And there was uncertainty in the beginning of that process as to whether Patterson's rules around gap would apply to all of their growers because Nature's Fair as an independent prior to that was not requiring gap. Right.

So save on foods. You weren't getting anything there without gap is what you're saying. And then there was like it was ambiguous about whether this would start applying. Yeah. Yeah. So Nature's fair had lots of conversations with all of their growers and said you know we're gonna we're gap is not imminent and it's a potential risk is how is how we took the information we were receiving so that began

our interest into gap and then other potential customers like Interior Health were identified, but Gap would be required. And I think the even further background to this is that I really love the North Okanagan, and I think it's a beautiful place to farm, and I think it has a really lovely farming community, and I want the farmers that are here to thrive and i want to attract more new farmers to this area and we have a pretty small population of purchasers so like the farmers markets are pretty saturated it's not it's not an easy win for a new farmer to come in and just start going to the farmer's market and be successful. So we need to grow the pie for everybody in order to make room for new farmers to come in, as well as just help make existing farms here thrive more. And so access to new markets is

really important. And I'm really curious about about is there a potential if we're either working together or as individual farms to sell into some of these, like a Savon, for example, that needs gap and has a whole bunch of barriers to the typical small to medium scale farmer. But if we're working together, can we get into those markets and help build access essentially to a new market that helps our farms do well and thrive? You made the point that like you can't be as efficient and as price competitive with California carrots because of the massive difference in economies of scale essentially, right? But what you have that those carrots don't is like you, you have a flavor that over time customers in these stores can, can realize and be willing to pay a bit more for that makes sense when it's a certain retail environment. Right.

But your vision is to, is to sell a lot of carrots and even work with other farms to sell carrots you mentioned the potential of like selling into a health institution as an example at some point your carrots are going to end up in a store where you really can't over time build up they just they're not going to label the carrots that way necessarily right they're going to be pooled with other carrots interior health like in a health institution i would say is kind of similar in that respect. It's not like interior health is going to start, you know, labeling the carrots as they go out on the plates or whatever. So doesn't that still place some kind of limit? Like if, if you're, if your selling point is flavor, beautiful carrots, tasty carrots,

like how do you ultimately, are you going to hit a wall as far as like how you know i i haven't asked you how big the price difference is with with the commodity carrots but are there any concerns there or i think of course there's a wall to hit and i think we're along from what we have heard from the people who are currently buying from us we're a long ways from that. Like we can grow more. And there are like, will we get GAP certified? Can we get other growers to get GAP certified? There's a bunch of those solutions will take years to realize as well. So this is not something that's just going to happen overnight. So this is not something that's just going to happen overnight.

And I would hope that during that transition time, more people are trying our carrots and loving them. And so the market is also growing. And then the other piece of it is right now we're only selling carrots for a few months of the year. There's all the other months of the year that if we had enough storage those sales could continue to happen which increases how much we can sell so yes there of course there's going to be a wall eventually but not not anytime soon but i don't think it's anytime soon okay in that case i want you so like the point of this conversation is we're going to talk about gap as a requirement slash barrier to realizing some goals some selling some sales goals of yours right and your and colleagues paint a picture for me then

like um before we get to that barrier which is coming very soon what i just want to get a better understanding if you if you think about a year or two or three out from now, and you've managed to start working with colleagues farms around here to pool carrots that are going essentially through your wash station and your sales channel. Let's not consider a health institution. Let's just talk about the potential for retail grocery sales. Where, just paint it for me, where are these carrots going and in what kind of scale? So for carrots, I can see carrots on the shelves at local store chains like Nature's Fair, not just from October to February, but year round consistently. Uh, and in all of their stores. Because they've got, they must have between six and 12 stores in the interior. Yeah. Yeah, for sure. Okay. So you,

and there's interest in those going to the coast stores too. Right. Which is a whole other thing, but there's lots of potential just with that one chain of stores. To be, to be possibly, it's within the realm of possibility that you and a group of growers become their primary supplier of carrots year round. Yeah, could be for sure. Or like, or one of two. There's another large BC grower

that they like to get carrots from. Yeah, yeah. And so the potential there is that could Nature's Fair have no Californian carrots because they have access to BC carrots year round. Okay. Wouldn't that be fantastic? And that's, in that case,

you don't necessarily, are you distributing to one of a central warehouse that they take care of the rest? Or in that case, are you distributing to individual stores still? That is up for determination. So I think that depends on the volumes that are going out to stores and a whole bunch of different factors so it if if it was centralized it would actually

be i believe associated grocer because nature's fair is now part of the pattison group yeah and associated grocer is their pattison warehouse right. So then that would be us selling to Associated Grocer and then Nature's Fair getting their product via them. I don't love that model at this moment in time because it means that all of our product is going to the coast, to the main warehouse, and then it's coming back up here. And it undercuts or reduces the potential

to build the uh like the popularity of flavor of your you know your carrots yeah so right now we're able to distribute to uh the okanagan stores and nature's fair does some of that distribution for us like their their trucks will go if we deliver to Vernon, they have a truck that would take things out to Kamloops because they're already doing that trip. Sure. But we would do Vernon and Kelowna, for example.

Okay. And then I think you mentioned you could tell it, paint a different picture if we talk about Beats. Yeah. So Beats, the opportunity there is to begin a relationship with Discovery Organics, which is one of, if not the biggest organic wholesaler distributor in bc and uh that's an exciting

opportunity because it's a larger volume of beets those would in this example be going down to the coast and then distributed distributed from there um i think most likely to lower mainland cost end customers versus coming back up to the okanagan and beets are a great crop because they're a lot easier to grow than carrots for most farmers and they're easy to grade, easy to, they store well. They have all those great attributes, and Discovery, you know, would take them in bulk, so we're not even having to package them in tiny, like, retail-ready bags. They're being packed in bulk on pallets to go out to them. Okay, so thank you for painting those pictures. Whether you realize that picture for Nature's Fair or Discovery or even a health institution like Interior Health, you mentioned earlier, all are going to be requiring GAP certification. So why has that traditionally been another challenge for small scale, especially diversified small scale farms first of all money it's another

cost and it's not an insignificant cost it's at least two thousand dollars to do the inspection and certification process annually and then there's the headache of more record keeping so some farmers are really good at record keeping, and some are not. And you must be to be able to achieve GAP certification. And you have to train your employees. Everyone has to be on the same page around the basics of food safety. around the basics of food safety. There has been, I believe, mixed messages around how state-of-the-art your facility needs to be in order to achieve GAP certification. And my hope in doing this project is that we can show that a very rudimentary

is that we can show that a very rudimentary pack house facility and infrastructure is enough, as long as you're using it the right way and that you're doing the record keeping that you need to do to get GAP certified. You don't need to have stainless steel, everything, concrete floors everywhere. You can do it on a more rudimentary scale. Okay, so it sounds like you're saying there's flexibility, or another way to put it is that it's kind of outcome-based, that there are food safety outcomes you need to realize, but it's not as rigid in terms of how you reach those outcomes as some people assume? Yes, and I also expect in this process

that I'll have to be able to articulate to an inspector why what we have is good enough. Okay. So I will have to be fairly fluent in food safety and be able to defend my choices. So, okay. A couple things to cover though. So like I'll circle back to infrastructure. couple things to cover though so like um i'll circle back to infrastructure but you know a two thousand dollar annual expense is um is a drop in the bucket if you're a 30 acre farm with two crops right uh i think what you were implying there is that when you're a small scale say a

three acre diversified mixed farm so that say say you're only going to grow a quarter acre of carrots to go to work with emily emily's farm and send through their system suddenly like you know that that becomes a more substantial expense and therefore a bit of a barrier to being able to participate in a wholesale system that um that requires it on other hand, though, is that such a problem? I mean, the wholesale system just isn't really set up to work with farmers who want to grow a quarter acre of carrots and sell to them. Totally.

So we have to do the math. And maybe a quarter acre isn't enough, but maybe the money that you can make on a half acre makes it make sense. And I think each farm, it's going to be different. The other piece about GAP certification is that you don't have to get every crop you grow on your farm GAP certified. You can choose to just pick one. Yeah. And that really helps with the administrative burden and it can help limit the

cost because it simplifies the inspection process so an inspection for one crop takes a lot longer than an inspection for 15 to 30 crops and it only makes sense to have gap certification on a crop that needs it because you're growing enough of it to sell into a save-on or something like that that requires it. I have talked to certifying bodies that have said, you know, if you have several farms in an area that are all getting certified with us and it's all the same crop so that those inspections are all happening at the same time there could be uh discounts or efficiencies that we're able to pass on to the growers by coordinating okay so we're inspections we're not quite there yet so the other thing i want to ask you though is like just infrastructure so as you pointed out that it's maybe not as

economically challenging as some assume to have the right infrastructure to right but i had i have heard stories that you know there can be 20 30 40 000 investments required right like depending on the farm i if you disagree tell me but but i just want to like am am I, is that true? Like in some cases, are farmers facing if they want to get into GAP certification, are they facing upgrades to their washing and packing infrastructure that might require investments like that? Definitely possible. And I haven't done it. I haven't been through the process where an inspector has said, or a certification body has said, you must change this.

The biggest threat or possibility on our farm is probably our barrel washer because the slats are wood. Yeah. Wood is bad from a food safety perspective. For harboring microorganisms? Yeah. is bad from a food safety perspective for harboring microorganisms exactly yeah i would love to say that you know we're washing carrots beets and potatoes that that's those are the crops that are coming in contact with that wood those are all very low risk for passing on bad bacteria to an end customer it would be really nice if the food safety

certification world acknowledged the inherent risk in each crop i don't know that they do so if you were washing salad mix in a wooden barrel i think that that would have a potentially higher end risk to the end consumer than a potato that's going to get cooked anyways yeah so if we had to replace our barrel washer because it has wooden slots that probably would be 20 or 30 thousand dollars okay and i don't know that we i think at that point i don't know that we would make the decision to continue on with Gap because that's a large investment. Okay, so because what I'm trying to establish is you have a goal or a vision to get a bunch of local small-scale farms working together to grow carrots so that you can pool your carrots and sell them wholesale, right?

What I think I'm hearing, though, is that for each of those farms to separately get their own gap certification in order to participate is is going to be a barrier for for some or lots of those farms i i think it would be a big barrier i think even yes i think it would be a barrier because the the volumes that we're talking about from these supplier farms don't warrant the potential investment or changes to their established systems. Yeah, makes sense. Okay, so in that case, please share your idea to get around this challenge. What have you proposed as a solution that represents a tweak to allow you guys to to make this happen so based on

what we've heard from other from other growers in canada we've been trying to work with this food safety certifying body to inspect our supplier farms just to harvest and then that dirty crop that they've harvested, those beets, they're being sold to our farm. And the wash line, packing, all of that food safety certification, all of it happens on our farm. So the supplier farms only need to handle food safety in the field to harvest. And then from that point on, the responsibility to get those crops washed, packed, et cetera,

safely is in our hands. Right. So presumably, or what you're working with as a theory is that that should reduce the cost of participating for those other farms because it's a simpler, it's just a simpler approach to achieving GAP certification because what they they're not if you're correct what they're not going to have happen is a gap inspector come and say you need to put a twenty thousand dollar upgrade into your wash station because it's irrelevant because they're getting harvested like apples get harvested into bins and brought to you and it's only your system that needs that approval. Yes. That's the hope. And it reduces the amount

of time the inspector is at their farm, which is also a cost savings. So no infrastructure upgrades for their wash pack line and a shorter inspection time. And most of the food safety components in the field, like to get us to harvest, align pretty well with organic standards and record keeping. So it shouldn't represent a huge shift in an administrative burden of record keeping or practices that they're using in the field. Okay, so I mean, this has kind of turned into a project or experiment, hasn't it? Like you have a little bit of funding to help you explore if this is viable? Yeah. So the project piece of this is it feels like it's a great idea

and it's hard to convince farmers that it is worthwhile. And because I haven't been GAP certified, I can't say for certain that this will work and that we can achieve food safety certification without putting in a state-of-the-art facility. So the project is this year our farm getting food safety certified for carrots and beets and being able to document that process so it's helpful for other farms who may want to be suppliers or who are in other parts of the province and are juggling with these issues as well. Just a real attempt to demystify the process and break it down into

like almost farmer hacks. You don't need a stainless steel table. You can keep using your 20-year-old wooden table that you love as long as you put a piece of plastic over it. That makes it a wipeable, sanitizable surface. Easy. So figuring out those pieces. The funding, there is some funding coming from Sacha Investments which is a an organization

that is we should ask Kira how to explain it I can like literally if I use this I can fade you out and have Kira's voice fade in Excellent Kira's going to explain what Sacha is My name is Kira

Gerling I'm the Chief Real Estate Investment Officer for Satcha Investments Limited. It's basically kind of like a family bank or a private bank that is based in the United States, but has allocated some of its capital towards what they call impact investing in British Columbia and Alberta. But what Shoe Swap Organics is doing is very aligned with our ambition to support regenerative organic farming. So the way that Emily is growing her produce is aligned. And we are trying to work with her and some of the other food producers that she swap organic aggregates with to scale their farmland. We understand that in order for their produce to get distributed beyond the provincial borders and through a larger distribution network that's primarily driven by a distribution facility down here in the lower mainland called Discovery Organic, they need to have Canada Gap certification. So we don't know if it's a barrier or not yet. If Canada Gap certification is a barrier for small-scale farmers,

then our work is going to look one way. It's going to look like advocating at the provincial and the federal regulatory level to say this certification scheme is anti-competitive for small to medium scale farm enterprises, right? That could be channel one. So if we find that it really is a barrier and it's insurmountable for small scale farm producers, we're going to have a certain, our conversation is going to be more around advocacy and policy change with legislators and regulators. If it's not a barrier, then our conversation is going to look different, isn't it? We're going to then go to farmers and say, hey, here's a real world example.

It wasn't as bad as we thought it was going to be. Here's what you need. And here are some supports and some enablers. And as you say, a blueprint or a roadmap for how you can get through this. And coupled with that, here's the value proposition for why getting Canada Gap certified might help you stabilize and expand your farm enterprise in a way that you hadn't maybe considered before. So Satcha is interested in developing in growers, organic and regenerative growers, increasing the land that they're growing on and increasing production in the area. So they're interested in helping us develop this new market opportunity so we can grow more food. And then we've also applied for funding through the BC On-Farm Food Safety Grant.

So SACHA is going to help cover our certification costs this year and any infrastructural changes that we may need to make would be funded through the on-farm food safety grant program okay okay so step one is certify this farm because you don't you can't make any commitments to these other growers until you confirm that you can you can do it here with within a certain budget. Yeah. Okay. So, and we're going to document this process this year. And then safe to assume then if that is successful, then you could start work,

like teasing the concept or idea of other farms starting to try and get certified to harvest, essentially harvest and shipping, I guess, to you. But yeah. Yeah. Okay. So Emily, it seems to me you're right. You really kind of do need to really understand what the rules are so that, because I get the sense and I want you to confirm, you probably intend to where you feel confident, push back when you have, probably intend to where you feel confident push back when you have when you're getting inspected to be able to say well why like ideally if you know line by line what's required of you to sell carrots in nature's fair in the in the safe food for canadians legislation then you can feel

confident saying well no i this piece of plastic over my table is fine because xyz i know that currently how we sell carrots only in bc i am currently meeting the legislative requirements if i start selling outside of bc then i would need a cfia license or sorry a safe food for canadians license and I believe that there is a way to prove that I'm meeting all of the food safety criteria without having to use Canada Gap or Global Gap. However, I have been told it's just too much work and it's actually easier. The buyers are telling you this.

The buyers say it's too... Actually, a food safety consultant told me that. Right. They said it's just too much work. You'd have to write... You'd have to essentially reinvent the wheel. Yeah. Their perspective was that Canada Gap specifically and Global Gap to a degree were developed

essentially as like a really big checklist. So you don't have to dive into making everything from scratch however canada gap covers everything like the whole all the crops it's it's scaled to a very large farm so i do want to look into that a little bit more and see if is it simpler to develop our own food safety plan? Or I'm not actually sure what it would look like. But it also would still need to be verified. We would still have to hire someone to check it and to make sure that we're doing what we say we're doing on paper. But isn't it also going to require you to ask for a form of concession from some of your buyers?

Because the buyers are the ones saying, yes, we acknowledge that you have shown, you have a plan that shows you're meeting the rules and therefore covers our butts, but we don't care. We have just decided it's gap or nothing. Isn't that not the case for some buyers? And for example, the Patterson group, they may say like, good job and we need gap because

that's what we've said we need to have. Because they want simplicity. Yeah. Simplicity. It's just a checkmark for all their suppliers. We haven't asked because I don't know, I don't even know yet if it's possible that that option of developing our own plan and getting it verified somehow is feasible. Okay.

So you've just summarized this whole vision, this project, right? You know, we're talking in early, approaching mid-March of 2024. What has happened so far? Like what has actually happened? How far into this process are you? What actually happened

on the next episode of the Organic BC podcast? Thanks for listening, everyone. I'm Jordan Marr and the intro and outro music for this podcast was composed by Matt Eccle. Thanks, Matt.