FSC 8915 

METRIC 

A-A-20192C 

May 21, 2021 

SUPERSEDING

A-A-20192B 

January 8, 2010 

COMMERCIAL ITEM DESCRIPTION

RADISHES, FRESH, READY-TO-EAT OR READY-TO-USE 

The U.S. Department of Agriculture (USDA) has authorized

the use of this Commercial Item Description (CID).

1. SCOPE. This CID covers ready-to-eat or ready-to-use, fresh radishes (radishes), packed in 

commercially acceptable containers, suitable for use by Federal, State, local governments, and 

other interested parties. Please note: This document does not guarantee purchase of this 

item by USDA.1

2. PURCHASER NOTES.

2.1 Purchasers must specify the following:

• Color(s), type(s), purpose(s) and agricultural practice(s) required of radishes (Sec. 3). 

• When analytical requirements are different than specified (Sec. 7.1).

• When compliance with analytical requirements must be verified (Sec. 7.2). 

• Manufacturer’s/distributor’s certification (Sec. 10.4) or USDA certification (Sec. 10.5).

2.2 Purchasers may specify the following:

• Good Agricultural Practices (GAP) Audit (Sec. 10.1). 

• Food Defense (Sec. 10.2) and Manufacturer’s Quality Assurance (Sec. 10.3). Purchaser 

must specify 10.4 or 10.5. In addition, purchaser may specify 10.1 or one of the following 

combinations: 10.2 with 10.3.1, 10.2 with 10.3.2, 10.3 with 10.3.1, or 10.3 with 10.3.2.

• Packaging requirements other than commercial (Sec. 11).

3. CLASSIFICATION. The radishes must conform to the following list which must be 

specified in the solicitation, contract, or purchase order.

1 USDA purchase specifications are available at: https://www.ams.usda.gov/selling-food/product-specs.
A-A-20192C 

2 

Colors, types, purposes and agricultural practices.

2

Color I - Red

Color II - White

Color III - Other (as specified by the purchaser)

Type A - Topped 

Type B - Bunched 

Type C - Trimmed

Type D - Other (as specified by the purchaser)

Purpose 1 - Ready-to-Eat

Purpose 2 - Ready-to-Use

Agricultural practice a - Conventional 

Agricultural practice b - Organic 

4. MANUFACTURER’S/DISTRIBUTOR’S NOTES. Manufacturer’s/distributor’s 

products must meet the requirements of the:

• Processing guidelines (Sec. 5).

• Salient characteristics (Sec. 6).

• Analytical requirements: as specified by the purchaser (Sec. 7).

• Manufacturer’s/distributor’s product assurance (Sec. 8).

• Regulatory requirements (Sec. 9). 

• Quality assurance provisions: as specified by the purchaser (Sec. 10). 

• Packaging requirements other than commercial: as specified by the purchaser (Sec. 11).

5. PROCESSING GUIDELINES.

5.1 Processing. The radishes must be minimally processed in accordance with Current Good 

Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food

(21 Code of Federal Regulations (CFR) Part 117). 

5.2 Food defense. The radishes must be processed and transported in accordance with 

Mitigation Strategies to Protect Food Against Intentional Adulteration (21 CFR Part 121). This 

regulation identifies the kinds of preventive measures food manufacturers, processors, or 

handlers may take to minimize the risk that food under their control will be subject to tampering 

or other malicious, criminal, or terrorist actions. The implementation of enhanced food defense

preventive measures provides for the security of a plant’s production processes and includes the 

2 Not all options are available from every manufacturer. Check with the manufacturer/distributor for availability. 
A-A-20192C 

3 

storage and transportation of pre-production raw materials, other ingredients, and postproduction finished product. 

5.3 Organic ingredients. When organic radishes are specified in the solicitation, contract, or 

purchase order, the radishes must be produced, handled, and labeled in accordance with the 

USDA organic regulations by an operation that is certified organic in accordance with the 

requirements of the National Organic Program (7 CFR Part 205). A Certificate of Organic 

Production or Handling must be provided to verify that the product was processed and handled in 

accordance with the USDA organic regulations. 

5.4 Temperature. The radishes must be kept under refrigeration to maintain quality. Unless 

otherwise recommended, preparation, storage, and delivery temperatures greater than 0°C (32°F) 

but not more than 5°C (41°F) are recommended. 

5.5 Shelf life. Once the radishes are packaged, the remaining shelf life must be at least 7 days 

for bunched radishes and 10 days for topped and trimmed radishes when stored at 5°C (41°F).

6. SALIENT CHARACTERISTICS.

6.1 Definitions. 

6.1.1 Topped. Radish tops are cut back not more than 0.953 centimeters (cm) (3/8 inches (in)).

6.1.2 Bunched. Radish tops are full length and tied in bunches. 

6.1.3 Trimmed. Radish tops and bottoms are cut back not more than 0.953 cm (3/8 in).

6.1.4 Ready-to-Eat. Product is intended for consumption by the public and to be consumed 

directly from the container without washing or other preparation.

6.1.5 Ready-to-Use. Product is intended for consumption by the public and to be consumed 

after additional processing such as but not limited to washing or cooking by the end user.

6.2 Labeling. All ingredients must be declared by their common or usual name in descending 

order of predominance by weight (21 CFR §101.4) unless exempted by 21 CFR §101.100. 
A-A-20192C 

4 

6.3 Ingredients.

6.3.1 Raw ingredients. The radishes must be U.S. No. 1 Grade of the U.S. Standards for 

Grades of Radishes.

3

6.3.2 Additional processing ingredients. When used, all additional ingredients must meet the 

standards specified in the Food Chemicals Codex (FCC) or, in the absence of FCC specification 

at a minimum, meet the specifications for quality set by the U.S. Pharmacopeia (USP)-National 

Formulary. The additional ingredients must be approved food additives (21 CFR Part 170) or 

meet Generally Recognized as Safe (GRAS) requirements (21 CFR Parts 182 and 184) for those 

uses by Food and Drug Administration (FDA). 

6.4 Finished product.

6.4.1 Flavor and aroma. The radishes of any color must possess good normal characteristic 

flavor and aroma. The radishes must be free from objectionable flavors and odors of any kind.

6.4.2 Color. The radishes must possess good exterior characteristic color of its variety. The

radishes must be well formed and free from any flesh discoloration.

6.4.3 Texture. The radishes must be crisp and firm, but not tough, fibrous, or mushy. The 

radishes must possess a practically uniform texture.

6.4.4 Defects. The radishes must be free from defects which materially affects their appearance 

or edibility. Presence of any decay, off-color, off-odor, damage caused by freezing, growth 

cracks or air cracks, cuts, pithiness, disease, insects, or other means and foreign material 

including but not limited to (soil, sand, grit, metal, glass, wood, paint, or insect parts) must be 

cause for rejection of the lot.

7. ANALYTICAL REQUIREMENTS.

7.1 Analytical and microbiological requirements. Unless otherwise specified in the 

solicitation, contract or purchase order, the following analytical and microbiological 

requirements for the radishes must conform to those in Table I: 

3

 U.S. Standards for Grades of Radishes are available at: https://www.ams.usda.gov/grades-standards/radish-grades-and-standards
A-A-20192C 

5 

TABLE I. Analytical and microbiological requirements

Test Requirement

Salmonella Must be negative 

Escherichia coli Less than 10 Colony Forming Units (CFU) 

per gram (g) or Most Probable Number

(MPN) per g4 

Staphylococcus aureus Less than 10 CFU per g or MPN per g4

7.2 Analytical verification. Purchaser must specify manufacturer’s/distributor’s certification 

(Sec. 10.4) or USDA certification (Sec. 10.5).

7.3 USDA verification procedures. When USDA certification (Sec. 10.5) is specified in the 

solicitation, contract, or purchase order, analytical testing must be performed as follows.

7.3.1 Product verification sampling. When USDA verification of analytical requirements is 

specified in the solicitation, contract, or purchase order, analytical testing must be performed on 

subsamples of packages randomly selected from the lot. The number of subsamples must be 

based on USDA inspection service sampling procedures and plans (7 CFR §52.38). The contents 

of each will be used to create a composite sample that will be used in the analytical testing. 

7.3.2 Analytical testing and reporting. When specified in the solicitation, contract, or 

purchase order, the analyses must be made in accordance with the following methods from the 

Association of Official Analytical Collaboration (AOAC) International Official Methods of 

Analysis (OMA) or as specified in Table II. Any result not conforming to the analytical 

requirements may be cause for rejection of the lot.

4 Findings indicate zero colonies (CFU) per plate or zero tubes producing gas for MPN.
A-A-20192C 

6 

TABLE II. Analytical and microbiological testing and reporting

Test Method Reported as

Salmonella AOAC 2013.09, 2003.09, 2004.03, 

996.08, 967.25, 967.27 or Section C-7 

of BAM Ch 55

Must be reported as 

positive or negative

Escherichia coli AOAC 992.30, 966.24, 991.14, 

2000.15, 2011.17 

Must be reported to the 

nearest CFU per g or the 

nearest MPN per g 

Staphylococcus aureus AOAC 987.09, 2003.07, 2007.06 Must be reported to the 

nearest CFU per g or the 

nearest MPN per g 

8. MANUFACTURER’S/DISTRIBUTOR’S PRODUCT ASSURANCE. The 

manufacturer/distributor must certify that the radishes provided meet the salient characteristics of 

this CID, conform to their own specifications, standards, and quality assurance practices, and be 

the same radishes offered for sale in the commercial market. The purchaser reserves the right to 

require proof of conformance. 

9. REGULATORY REQUIREMENTS. The delivered radishes must comply with all 

applicable Federal, State, and local mandatory requirements and regulations relating to the 

preparation, packaging, labeling, storage, distribution, and sale of the radishes in the commercial 

marketplace. Delivered radishes must comply with all applicable provisions of the Federal Food, 

Drug, and Cosmetic (FD&C) Act, the Fair Packaging and Labeling Act, Food Allergen Labeling 

and Consumer Protection Act (FALCPA), and regulations promulgated thereunder. The allergen 

statement must be provided in a format which complies with FALCPA for any product which 

contains wheat, fish, milk, soy, tree nuts, eggs, peanuts, sesame, and Crustacean shellfish or 

those in effect on the date of the solicitation, contract, or purchase order. When the radishes are 

used for the Child Nutrition Programs, the radishes must comply with all applicable provisions 

of those programs.

5

 8th Edition, FDA Bacteriological Analytical Manual (BAM) or the FDA BAM Online is available at: https://www.fda.gov/food/laboratorymethods-food/bacteriological-analytical-manual-bam
A-A-20192C 

7 

10. QUALITY ASSURANCE PROVISIONS. Purchaser must specify 10.4 or 10.5. 

Purchaser may specify one of the following combinations: 10.2 with 10.3.1, 10.2 with 10.3.2, 

10.3 with 10.3.1, or 10.3 with 10.3.2. 

10.1 GAP audit verification program. When required in the solicitation, contract, or purchase 

order, a GAP audit must be conducted by USDA, Agricultural Marketing Service (AMS). A 

GAP audit must be performed at the site where the radishes are grown and at the packing house 

where the radishes are packed. The audit program consists of one initial audit, and at least one 

unannounced audit depending on how long the facility is in operation during a growing season. 

The purpose of the GAP Audit Program is to demonstrate that the participating company is 

adhering to generally recognized GAP principles. 

10.2 Food defense. When required in the solicitation, contract, or purchase order, a Food 

Defense Systems Survey (FDSS) or audit must be conducted by USDA, AMS, Specialty Crops 

Program (SCP), Specialty Crops Inspection (SCI) Division. Food defense requirements include 

a documented and operational food defense plan that provides for the security of a plant’s 

production processes and includes the storage and transportation of pre-production raw materials 

and other ingredients and post-production finished product. The plan must address the following 

areas: (1) food security plan management; (2) outside and inside security of the production and 

storage facilities; (3) processing, including all raw material sources; (4) shipping and receiving; 

(5) storage; (6) water and ice supply; (7) mail handling; (8) personnel security; and 

(9) transportation, shipping, and receiving. 

10.2.1 FDSS. When required in the solicitation, contract, or purchase order, a FDSS must be 

conducted by USDA, AMS, SCP, SCI Division. The FDSS verifies that operators of food 

establishments have implemented measures to minimize the risk of tampering or other criminal 

actions against the food under their control. An AMS FDSS verifies the participating company’s 

adherence to Mitigation Strategies to Protect Food Against Intentional Adulteration (21 CFR 

Part 121). 

10.2.2 Food defense section of the Plant Systems Audit (PSA). When required in the 

solicitation, contract, or purchase order, a food defense audit will be conducted as part of the 

PSA. The audit will be conducted by USDA, AMS, SCP, SCI Division auditors. This verifies 

that operators of food establishments have implemented measures to minimize the risk of 

tampering or other criminal actions against the food under their control. The food defense 

section of the PSA verifies the participating company’s adherence to Mitigation Strategies to 

Protect Food Against Intentional Adulteration (21 CFR Part 121). 

10.3 Manufacturer’s quality assurance. When required in the solicitation, contract, or 

purchase order, the product manufacturer will be required to provide evidence, by certificate that 

the manufacturing plant has undertaken one of the following quality assurance measures within 

12 months prior to providing a bid or no later than 10 business days from the date of the 
A-A-20192C 

8 

awarding of the contract. Failure to provide this documentation within the proper time frame 

may result in the contract being terminated for cause.

10.3.1 Plant survey. A plant survey conducted by USDA, AMS is required within 12 months 

prior to the date of the awarding of the contract. The plant survey audit verifies that, at the time 

of the survey, the manufacturer produces products in a clean, sanitary environment in accordance 

with Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive 

Controls for Human Food (21 CFR Part 117). 

10.3.2 PSA. A PSA conducted by USDA, AMS is required within 12 months prior to the date 

of the awarding of the contract. The PSA verifies the manufacturer’s capability to produce 

products in a clean, sanitary environment in accordance with Current Good Manufacturing 

Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food (21 CFR 

Part 117) and verifies that the manufacturer has in place an internal quality assurance program

that meets or exceeds USDA requirements. 

10.4 Manufacturer’s/distributor’s certification. When required in the solicitation, contract, 

or purchase order, the manufacturer/distributor must certify that the radishes delivered meet or 

exceed the requirements of this CID. The manufacturer/distributor must certify via a Certificate 

of Conformance or other adequate documentation (as specified by the purchaser) that the

radishes meet the analytical requirements specified in Sec. 7 of this CID.

10.5 USDA certification. When required in the solicitation, contract, or purchase order that 

product quality and acceptability or both be determined, the USDA, AMS, SCP, SCI Division 

inspectors, must be the certifying program. SCI Division inspectors must certify the quality and 

acceptability of the radishes in accordance with SCI Division procedures, which include 

selecting random samples of radishes, evaluating the samples for conformance with the salient 

characteristics and analytical requirements of this CID and other contractual requirements, and 

documenting the findings on official SCI Division score sheets and/or certificates. In addition, 

when required in the solicitation, contract, or purchase order, SCI Division inspectors will 

examine the radishes for conformance to the Standards for Condition of Food Containers (7 CFR 

Part 42) in effect on the date of the solicitation.

11. PACKAGING. Preservation, packaging, packing, labeling, and case marking must be 

commercial unless otherwise specified in the solicitation, contract, or purchase order.

12. USDA INSPECTION NOTES. When Sec. 10.5 is specified in the solicitation, contract, 

or purchase order, USDA certification must include evaluation of the quality and condition 

of samples of radishes and compliance with requirements in the following areas:

• Processing guidelines (Sec. 5).

• Salient characteristics (Sec. 6).
A-A-20192C 

9 

• Analytical requirements when specified in the solicitation, contract, or purchase order 

(Sec. 7). When USDA analytical testing is specified, SCI Division inspection personnel must 

select samples and submit them to the USDA, AMS, Science and Technology Program 

(S&T) laboratory for analysis.

• Packaging requirements (Sec. 11).

13. REFERENCE NOTES.

13.1 USDA services.

13.1.1 USDA certification. For USDA certification information contact: National Program 

Mission Support, SCI Division, SCP, AMS, USDA, via E-mail: 

SCIinspectionoperations@usda.gov.

13.1.2 USDA FDSS, plant survey, and PSA. For a USDA FDSS, plant survey, and PSA 

contact the Chief, Auditing Services Branch, SCI Division, SCP, AMS, USDA, Room 1566 

South Building, STOP 0247, 1400 Independence Avenue, SW, Washington, DC 20250-

0247, telephone (202) 720-5021, fax (866) 230-9168, or via E-mail: SCAudits@usda.gov.

13.1.3 Analytical testing and technical information. For USDA technical information on 

analytical testing, contact the Laboratory Approval and Testing Division, S&P, AMS, USDA, 

STOP 0272, 1400 Independence Avenue, SW, Washington, DC 20250-0272, telephone 

(202) 690-4089 or via E-mail: LATD@usda.gov. Samples for specified USDA analytical 

testing should be sent to the USDA, AMS, S&TP laboratory for analysis at: USDA, AMS, 

S&T, National Science Laboratory, 801 Summit Crossing Place, Suite B, Gastonia, NC 

28054.

13.2 Sources of documents. 

13.2.1 Sources of information for nongovernmental documents are as follows:

Copies of the AOAC International OMA may be obtained from: AOAC International, 2275 

Research Boulevard, Suite 300, Rockville, MD 20850-3250, telephone (301) 924-7077. 

Internet address: http://www.aoac.org for nonmembers and http://www.eoma.aoac.org for 

members and AOAC OMA subscribers.

Copies of the Food Chemicals Codex and U.S. Pharmacopeia may be purchased from: United 

States Pharmacopeia Convention, 12601 Twinbrook Parkway, Rockville, MD 20877, 

telephone (800) 227-8772 or (301) 881-0666, Fax (301) 816-8148 or on the Internet at: 

http://www.usp.org. 
A-A-20192C 

10 

13.2.2 Sources of information for governmental documents are as follows:

Applicable provisions of the Standards for Condition of Food Containers are contained in 7 CFR 

Part 42, the National Organic Program are contained in 7 CFR Part 205, the Fair Packaging and 

Labeling Act are contained in 16 CFR Parts 500 to 503, and the Federal Food, Drug, and 

Cosmetic Act are contained in 21 CFR Parts 1 to 199. These documents may be purchased from: 

Superintendent of Documents, New Orders, P.O. Box 979050, St. Louis, MO 63197-9000. 

Credit card (Visa, MasterCard, Discover/NOVUS, and American Express) purchases may 

be made by calling the Superintendent of Documents at (866) 512-1800, (202) 512-1800. 

These documents may also be obtained free of charge on the Internet at: 

http://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR. 

Copies of U.S. standards and inspection instructions for fruits, vegetables, and other specialty 

products may be obtained from: USDA, AMS, SCP, SCI Division, 100 Riverside Parkway, 

Suite 101, Fredericksburg, VA 22406-1016, telephone (650) 552-9073, fax (650) 552-9147, 

or via E-mail: FVSupplyDepot@usda.gov or on the Internet at:

http://www.ams.usda.gov/grades-standards and http://www.ams.usda.gov/gradesstandards/how-purchase-equipment-and-visual-aids. 

Copies of the FDA Bacteriological Analytical Manual (BAM) are available online from: FDA, 

Center of Food Safety and Applied Nutrition (CFSAN) on the Internet at: 

https://www.fda.gov/food/laboratory-methods-food/bacteriological-analytical-manual-bam.

Copies of this CID and the Standards for Condition of Food Containers (7 CFR Part 42) are 

available from: Director, SCI Division, SCP, AMS, USDA, Room 1536 South Building, 

STOP 0240, 1400 Independence Avenue, SW, Washington, DC 20250-0240, via E-mail: 

CIDS@usda.gov or on the Internet at: http://www.ams.usda.gov/grades-standards/cids

and https://www.gpo.gov/fdsys/pkg/CFR-2019-title7-vol2/pdf/CFR-2019-title7-vol2-

part42.pdf. 
A-A-20192C 

11 

CIVIL AGENCY COORDINATING ACTIVITY:

DOJ - BOP

HHS - FDA

USDA - SCP

VA - OSS

PREPARING ACTIVITY:

USDA - SCP

Non-Discrimination Policy: In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations 

and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited 

from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, 

disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation 

for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and 

complaint filing deadlines vary by program or incident. 

Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American 

Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA 

through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. 

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at How to 

File a Program Discrimination Complaint and at any USDA office or write a letter addressed to USDA and provide in the letter all of the 

information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to 

USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, 

Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov. 

USDA is an equal opportunity provider, employer, and lender.