GLOBALG.A.P. Product Handling Assurance Standard

1. What is the Produce Handling Assurance (PHA) standard?
  • PHA is a standalone food safety and traceability certification of post-harvest activities such as cooling, packing, repacking, handling, and storage of crops for human consumption.
  • PHA is an independent, third-party verification of safe and traceable handling practices.
  • PHA reduces exposure to food safety and product safety reputational risks.
2. What is the scope of PHA?
  • PHA covers all fruit and vegetables and combinable crops that are listed on the “GLOBALG.A.P. Product List,” as well as hop pre-process production.
  • PHA covers all preprocess activities under four major categories: cooling, packing, repacking, and storage/distribution. Examples and further explanation are below.
  • The PHA standard does  not cover processing activities that significantly transform crops from the original whole state, such as cooking, slicing, or juicing.

    YES, Covered by PHA
    Preprocess production such as:

    • Cleaning
    • Cold storage
    • Cooling
    • Drenching
    • Drying (natural, not dehydrator)
    • Fluming
    • Grading
    • Hulling
    • Hydrocooling
    • Labeling
    • Packing
    • Repacking
    • Rinsing
    • Shelling
    • Sorting
    • Staging
    • Storage
    • Storing
    • Threshing
    • Trimming (removing foliage, husks, roots, or stems)
    • Washing
    • Waxing
     

    NO, Not Covered by PHA
    Processing, or activities that significantly alter or transform the product from its harvested state, such as:

    • Addition of any ingredients
    • Cooking
    • Cutting
    • Dehydrator drying
    • Dicing
    • Freezing
    • Juicing
    • Milling
    • Mixed or bagged salads (including leafy vegetables)
    • Mixing
    • Modified atmosphere packing
    • Pasteurization
    • Peeling
    • Prepackaged ready-to-eat (RTE) foods
    • Pressing
    • Quick Freeze (IQF)
    • Roasting
    • Salting
    • Shredding
    • Slicing
    • Vacuum packing
3. Can an operation be certified to both Integrated Farm Assurance (IFA) (or Harmonized Produce Safety Standard, HPSS) and PHA at the same time?

PHA can be combined with GLOBALG.A.P. farm audits to provide a complete certification option for a producer with on-farm packing or other post-harvest activities.

4. Why was PHA developed?

Producers, post-harvest operations, and supply chain members have asked GLOBALG.A.P. for a standalone post-harvest certification for several years. PHA is a direct response to industry requests.

5. How was PHA developed?
  • Global stakeholders took part in the development, review, trials, and initial certification of the fit-for-purpose standard. PHA is a true representation of a multisector collaboration. That’s why we say, “Designed by industry – for industry.” We extend our sincere gratitude to the many folks who contributed to the development of and continue to collaborate on this standard. See contributors here.
  • PHA incorporates United States Food Safety Modernization Act (FSMA) requirements from both the Produce Safety Rule and the Preventive Controls for Human Food Rule, where applicable.
6. Who accepts PHA standards?

PHA is accepted by buyers and retailers globally who seek Global Food Safety Initiative (GFSI)-recognized certification for post-harvest handling. As PHA is a relatively new standard, we are educating the market on the many benefits of PHA and welcome questions so we can share its benefits and expand its market uptake. Please direct inquiries to standard_support@globalgap.org.

7. Is PHA available globally?

The PHA standard is available globally for open-shed operations and for closed-shed operations except for geographical Europe and Russia. Geographic availability of the PHA certification program has been determined based on expressed market need and consideration for suppliers needing to comply with FSMA requirements for the US market, which are core to PHA.

8. How was required audit length determined?

The audit length was determined in two-steps: by comparison to similar GFSI-recognized BIII standards and in compliance with any GFSI benchmarking requirements. Then GLOBALG.A.P. certification bodies (CBs) and operations undertook trial audits to ensure the duration of the audit works as both a standalone duration and in combination with IFA or HPSS inspections.

9. What are the auditor requirements compared with IFA?
  • In line with other current Good Manufacturing Practices (cGMP) standards, PHA auditors must have five years’ experience instead of the four required for IFA auditors.
  • PHA allows some flexibility in education to be more food-production focused rather than in-field requirements.
  • PHA requires additional cGMP specific training and training requirements in FSMA where it is applicable to the operation.
10. How were Major and Minor Musts determined?

All practices in the PHA are to ensure food safety, and Major Musts are in place wherever the requirement is required by GFSI.

11. How does scoring work?

The scoring is modeled after IFA so that it is familiar to our CBs and producers. All Major Musts are required to be 100% conformant, and Minor Musts meet 95% compliance.

12. How are unannounced audits different from IFA?
  • The PHA General Regulations require that 10% of unannounced audits are recertification inspections. IFA version 5.4-GFS recently adopted this same requirement, rather than requiring an additional 10% of audits. This lifts the audit burden from producers, operations, and CBs while still maintaining GLOBALG.A.P.’s high level of integrity.
  •  PHA has a shorter window for unannounced audits so that the audit takes place during the normal certification cycle.
  • PHA allows for the operation to indicate up to fifteen dates that they will not accept an unannounced inspection, such as holidays or other events.
13. How does PHA address Hazard Analysis and Critical Control Points (HACCPs), especially if there are no CCPs?

We believe that all hazards need to be identified and that all hazards must be assessed for their risk level through a risk assessment process, and that all hazards presenting risks must be mitigated through hazard control or preventive control procedures. We additionally agree with the majority of the food safety industry, which believes preprocessed whole commodities should not undergo a kill-step for microbial hazards. Therefore, by default and definition of CCPs, there are no CCPs for preprocess whole commodities. That said, there are some controls (e.g., water treatment or metal detection) that customers may require have a CCP. Therefore, we have included CCP requirements. All other mitigation practices relevant to cGMPs are included in the PHA checklist.

14. Does incoming product need to be GLOBALG.A.P. certified?

The PHA General Regulations stipulate that at least at one point in time in the certification cycle, the PHA certified operation must receive GLOBALG.A.P. certified products that are included in the PHA certification. Not all products received by the facility must come from a GLOBALG.A.P. certified source. That said, PHA includes robust approved supplier requirements so that all products must at least be produced under Good Agricultural Practices.

15. When is Chain of Custody (CoC) certification required?
  • CoC is a traceability and segregation standard that GLOBALG.A.P. operates to ensure supply chain transparency and GLOBALG.A.P. certified production on the farm level occurred for any products that maintain the GLOBALG.A.P. Number (GGN) or that make any other GLOBALG.A.P. certified claims. Elements of this standard are included in PHA so that PHA certified operations may make claims about certified producers and products.
  • If an operation is not using the GGN or making GLOBALG.A.P. claims about the certified farm or products, this section is not applicable during the PHA audit.
16. What kind of labeling is allowed?
  • Operations that are PHA certified may use their PHA-N (GLOBALG.A.P. Number for the PHA operation) on product.
  • Operations that are PHA certified and adhere to the CoC section may use the PHA-N and the origin GGN on product.
  • Operations may use the GLOBALG.A.P. trademark in business-to-business communication. However, business-to-consumer labeling with the GLOBALG.A.P. trademark is not yet allowed.
17. How do we handle US and other governmental regulations?

The PHA standard refers to legal and local legislation or regulations throughout the standard. Where PHA requirements are stricter than legislation or regulations, operations must meet the minimum PHA requirements to achieve certification. Where the legislation or regulations are more strict or more prescriptive than PHA, the producer must meet those legal requirements to achieve certification.

18. How does PHA address FSMA?
  • PHA was written after the publication of the Food Safety Modernization Act (FSMA) and both the Produce Safety Rule and Preventive Controls Rule. Therefore, there was ample time to understand the intention of these requirements and how they will be enforced by the Food and Drug Administration (FDA).
  • PHA incorporates all post-harvest requirements of the Produce Safety Rule and was submitted to the FDA under the FDA third-party alignment pilot.
  • PHA incorporates the Preventive Controls requirements under FDA’s enforcement discretion for facilities that handle, store, and pack raw agricultural commodities, including the cGMPs, preventive controls, and supplier approvals.
19. Is PHA an accredited standard?

GLOBALG.A.P. PHA scope approval requires ISO 17065 accreditation for CBs to carry out PHA audits.

20. How does PHA differ from the post-harvest handling section of IFA for on-farm packing?
  • The IFA Fruit and Vegetables (FV) section 5 control points cover on-farm harvest and post-harvest handling activities, such as activities in a packinghouse and/or cold storage.
    • IFA FV is recognized by GFSI as benchmarked for scope BIII (pre-process)
    • IFA FV 5 requires a robust risk assessment for microbiological, chemical, and physical hazards and for identifed hazards to be mitigated.
    • The IFA FV 5 control points and compliance criteria contains a comprehensive annex to support producers and facilities in development of the risk assessment.
  • At minimum, IFA FV 5 requires practices for hygiene, training, sanitary facilities, cleaning, water quality, transportation, physical hazards, temperature control, and post-harvest treatments.
  • PHA provides supportive and more detailed compliance criteria specific to post-harvest handling, much of which is included in the IFA Fruit and Vegetable Annex 5 as voluntary guidance to aid producers in building a risk assessment for post-harvest. PHA takes that guidance and puts it into practice.
  • More specifically, PHA goes above and beyond IFA in the following ways:
    • Directly includes HACCP, if applicable, along with the risk assessment, including flow diagram and HACCP team
    • Includes allergen training
    • Includes customer requirements and specifications
    • Includes supplier approval, which is now included in IFA v5.4-GFS
    • Expands the foreign materials category by addressing physical and chemical hazards in detail
    • Requires food safety personal protective equipment (PPE) to be stored appropriately and designated storage for worker belongings
    • Has a higher level of detail for restroom and sanitary facilities requirements
    • Introduces non-retaliatory food safety violations requirement
    • Ensures suitable design, construction, and layout of facilities, buildings, operations, and equipment
    • Provides robust details for properly maintaining equipment, including coolers, ventilation, lighting, and other sources of potential contamination
    • Provides details for the maintenance of grounds program
    • Includes details for preventive maintenance of equipment and vehicles and procedures for temporary repairs
    • Requires more details to be provided for post-harvest water delivery systems, not only final rinse water
    • Assigns more responsibility to the operations regarding water treatments for reused water
    • Makes explicit the requirement for maintenance of sewage disposal systems
    • Requires more details for cleaning procedures and frequency as well as records requirements
    • Requires proper tool identification
    • Makes preoperational checks mandatory
    • Provides more details for microbiological testing, including an annex to support operations to make decisions about environmental monitoring
    • Defines more specific criteria regarding food contact surfaces
    • Includes robust pest control requirements, including spacing and location and verification of records
    • Includes additional requirements specific to storage, including cold and iced storage
    • Adds specificity to calibrations and incorporates foreign material devices