University of Maryland Extension

Comparison of GAP and PSR Certification Requirements

Maryland growers who already voluntarily comply with the requirements of a Good Agricultural Practices (GAP) program often ask what more they will have to do under the Food Safety Modernization Act’s Produce Safety Rule (PSR). They might wonder if they are already satisfying the legal obligations and want to know how to prove compliance to inspectors.


The comparison table below is meant to provide an overview and help producers understand the general similarities and differences between GAP and PSR requirements so they can assess what steps they might need to take to bring their operation into compliance with Federal and State laws.


The main recommendations to help with FSMA PSR compliance for producers already GAP certified are:

  • Have the food safety officer/manager or other employee attend a grower training course (events link);
  • Develop a food safety training program for farm employees;
  • Inspect your water distribution system and learn more about your water quality through periodic testing;
  • Evaluate compost/soil amendment techniques and use to satisfy FDA microbial standards;
  • Identify tools and equipment in your harvesting and packing which are food contact surfaces and develop a cleaning and sanitizing regime for those objects/surfaces.

Most GAP programs currently include some requirements that are not required under FSMA, including:

  • Documented Farm Food Safety Plan;
  • Designated food safety officer/manager— this person would ideally be the one attending the FDA-approved course;
  • Traceability records (except on-farm food processing activities that require traceability under the Preventive Controls Rules);
  • Pesticide residues testing (GlobalGap and GroupGAP);
  • Mock recall plan; and
  • Farm sewage treatment records.

Preview of PSR v GAP Table

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