THE DIFFERENCE BETWEEN GLOBAL GAP IFA 5.2, V5.3, & V5.4

As the retail market demands changed, the Global Food Safety Initiative had to update its benchmarking requirements to align with new food industry trends and information. In February 2020, the GFSI then released the new benchmarking requirements under GFSI V7.2. To maintain its GFSI recognition, Global G.A.P – a certification standard for farm production – had an obligation to update its certification standard to accommodate producers that cater to international markets requiring GFSI certification.

In reaction to this chain of events, and to ensure that producers requiring a GFSI recognized certification scheme had an option. Global GAP then revised the Integrated Farm Assurance (IFA) standard V5.3 to ensure the new requirements align to the Global Food Safety Initiative (GFSI) version 7.2 benchmarking requirements. Global GAP then published v5.3. on 21 February 2020 as an optional standard to maintain its GFSI compliance. I.F.A. v.5.3 GFS only became obligatory on 21 May 2020. Consequently, all certificates issued under I.F.A. v5.2 after 20 May 2020 were no longer GFSI recognized. Therefore, all producers whose market requires GFSI benchmarking while in possession of I.F.A. v5.2 had to apply for I.F.A. v5.3 G.F.S. to maintain their GFSI recognition. Before the new GFSI version 7.2 was released, it is worth noting that GLOBAL G.A.P I.F.A. v5.2 was compliant with Global Food Safety Initiative (GFSI) v7.1.  Subsequently, I.F.A. v5.4 G.F.S. was published on 15 July 2020.

Let us now look at what were the significant amendments

2. 
   

   F.A. v5.2 Significant amendments

   
   

Many of the amendments instituted on I.F.A. v5.2 were simply adjustments from minor must to major must requirements under the following scopes and sub scopes: Fruit and Vegetables, (F.V.) Livestock Base (L.B.); Aquaculture (A.Q.); Flowers and Ornamentals (F.O.); Plant Propagation Material (P.P.M.); Combined Crops (CC); and Hop (H.O.) module.

The newly introduced Control Point and Compliance Criteria (CPCC) under Food Fraud Mitigation was clause AF 17.1 which compels producers to implement a documented procedure for non-conforming products. Non-conforming products can be simply defined as those products or materials that do not meet the specified requirements which potentially could lead to either withdrawal or recall of the product. Such products need to be identified, segregated, quarantined, or disposed of according to the nature of their non-conformities.

3. 
   

   F.A. v5.3 Significant amendments

   
   

Only two new changes were instituted on CPCC under Propagation Material and Supply of Inputs of Hops sub-scope. Clause HO 1.3.1 addresses the use of approved and unapproved suppliers where unapproved suppliers are used, a selection criteria and assessment must be clearly documented. For example, an organization could choose to utilize unapproved suppliers in a case of an emergency provided that the supplier possesses an equivalent Food Safety Management System (FSMS) such as FSSC 22000.

Clause HO 4.4.6 under Handling and Packaging Areas states that a risk-based environmental monitoring program must be carried out where applicable. The program must be accompanied by a written procedure and documented results like water testing. Environmental monitoring, air testing in particular is of paramount importance for establishments that employ Modified Atmosphere Packaging (MAP) and controlled atmosphere.

Under Part II in relation to Quality Management Systems rules, Option 1 with multisite and option two group producers with high-risk products such as fresh herbs (parsley, thyme, chive, mint, etc.), leafy greens, lettuce, romaine, spinach, arugula, or rocket, berries, and cantaloupe melons (spanspek) were obligated to an annual inspection.

Measures have been imposed on management concerning Quality Management review of food safety. Such meetings were required to be documented and kept on record to be produced when Certification Bodies request them during audits. Furthermore, members of management are obligated to conduct a documented annual review where food safety, the effectiveness of the QMS, and internal and external issues affecting the QMS are discussed.

In addition, under general regulations, Part 3, certification bodies are now required to have a system in place to assess the auditing skills of their auditors.

4. 
   

   F.A. v5.4 Significant amendments

   
   

Notable adjustments were introduced more especially on the Control Point and Compliance Criteria (CPCC) of All Farm base (A.F.), Crops Base (C.B.) Fruit and Vegetables (F.V.) modules and Aquaculture (A.Q.) scope. These changes involved amending the minor must requirements to major must; in addition to that, several new Control Points were added to the CPCC. Furthermore, Part 1 of General Rules section 5.2.3 contains added requirements concerning producer groups having unannounced inspections for 20% of their producers. In addition, it is now a requirement that 25% of members in a producer group shall be randomly selected.

In the AF module, changes were instituted under the following clauses AF 1.2.3, AF 1.2.4, AF 2.2., AF 2.5, AF 3.5, AF 4.2.3, AF 13.5, AF 17.1, AF 17.2, AF 17.4.

Looking at each clause respectively, it is noted that AF 1.2.3 emphasizes the construction of facilities, equipment, and feeding systems to facilitate good hygiene, in other words, they need to be easy to clean to prevent cross-contamination.

AF 1.2.4 makes it a major must requirement for producers to possess a compulsory program of a site inspection to promote food safety through maintenance of equipment and the site itself. AF 2.5 requires continuous improvement from self-assessment and site inspection implementation to be documented. Examples of continuous improvements include resource management plans.

AF 3.5 addresses appropriate storage of cleaning chemicals to reduce the risk of food contamination. It is important to store cleaning chemicals in a secure and lockable storeroom that is only accessible to designated individuals.

AF 4.2.3 outlines a need to identify employees whose activities impact food safety (such as chemical spraying staff) to be identified by means of their job functions and responsibilities.

Under Traceability and Segregation CPCC, clause AF 13.5 requires an annual traceability test to be conducted. Food and Drug Administration defines traceability as the ability to follow the movement of a food product and its ingredients through all steps in the supply chain, both backward and forward. Clause AF 13.5 also indicates the permissibility of traceability to be included in recall and withdrawal procedures.

AF 17.1 stipulates mandatory requirements for all outsourced products, materials, and services that have effects on food safety to conform with specified requirements or specifications. Examples of complying with specified requirements could include the need for packaging materials to be food grade, in certain circumstances, a Certificate of Analysis (COA) could be expected to accompany the food products. For all product input,

AF 17.2 requires an establishment, implementation, and maintenance of written specifications as well as a review process of the specified requirements. Both products and inputs or ingredients that affect food safety are required to have a written specification document for product conformity.

AF 17.4 declares a product release to possess a documented procedure that complies with a criterion for product releases such as MRL compliance.

Then under crop base, the following changes have been introduced:

CB 5.5.2 found under efficient water use on-farm, mandates the farm management to formulate a water management plan by identifying water sources and measures to utilize water efficiently within the previous 12 months. The plan must contain relevant maps to identify the water source, the need for maintenance of irrigation equipment, and necessary staff training to manage the site where applicable.

Then lastly, under Fruits and Vegetables, the following changes were introduced:

FV 5.3.2 was introduced as a new control point under Water Quality which requires completion of a risk assessment based on physical and chemical pollutants of water utilized on pre-harvest activities such as irrigation, product washing, and spraying.

Under CPCC of Temperature, Humidity, and Compressed Gasses, FV 5.5.2 makes it clear that compressed gasses that potentially can impact food safety must be monitored, stored safely, and handled with precautious to reduce food safety incidents. Most compressed gasses are utilized in a Modified Atmosphere Packaging (MAP) which employs a combination of Nitrogen, Carbon dioxide, and Oxygen to prolong the shelf life of the product. It is then becoming a requirement to test compressed gasses at a frequency determined by the product’s risk assessment.

FV 5.9.1 Institutes a demand for an environmental program monitoring to be established, implemented, and maintained to prevent, eliminate or reduce risks of food contamination. Regular water testing for microbial organisms is deemed sufficient to comply with the requirement although other pathogenic testing methods like swabbing can be supplemented on to the environmental monitoring program.

The final new clause added under Stock and Finished Product Management CPCC is FV 5.11.1 which addresses compliance with the First in First Out (FIFO) procedure which requires all finished products, work in progress, and other materials to be released to customers according to their shelf life order.

Table 1: The table below depicts a summary I.F.A. v5.4 G.F.S. FV sub-scope changes.

Module	New CPCCs Major Must	Minor Must to Major Must change	Added wording	CPCC Removed	CPCC moved to a different section
AF	10	7	4	0	0
CB	1	17	3	1	0
FV	4	8	5	0	1
Total	15	32	12	1	1

Table 2: Summary of I.F.A. v5.4 GFS AQ sub-scope changes

Module	New CPCCs Major Must	Minor Must to Major Must changes	Added wording	CPCC Removed	CPCC moved to a different section
AF	10	7	4	0	0
AQ	1	2	0	0	0
Total	11	9	4	0	0

Table 3: Summary of I.F.A. v5.2; v5.3 G.F.S. & v5.4 G.F.S. changes

	V5.2	V5.3 GFS	V5.4 GFS
Released	1 February 2019	21 February 2020	15 July 2020
GFSI compliance	Non-GFSI recognized	GFSI recognized	GFSI
GFSI version	N/A	V7.2	V2020
Scopes	FV, LB, AQ, FO, PPM, CC, HO	FV, AQ & HO	AF, FV, CB & AQ
Validity	Valid	Valid	Valid

Conclusion

Although Global G.A.P. I.F.A. v.5.3 and v5.4 has replaced v5.2 concerning GFSI compliance, it is essential to note that v5.2 is still functional and valid for those producers not seeking to meet GFSI requirements. All three versions remain operational until the release of v6 anticipated in the first quarter of 2022.