United States 

Department of 

Agriculture 

Agricultural 

Marketing 

Service 

Fruit and 

Vegetable 

Programs 

Fresh 

Products 

Branch 

April 2011 

Good Agricultural Practices 

and 

Good Handling Practices 

Audit Verification Program 

User’s Guide 
 

 

 

 

 

 

 

 

 

 

 

Audit User’s Guide for 

GAP & GHP 

This User’s Guide is specifically developed and designed by the United States 

Department of Agriculture, Agricultural Marketing Service, Fresh Products Branch to 

provide information about the USDA Good Agricultural Practices & Good Handling 

Practices (GAP&GHP) Audit Verification Program. 

This User’s Guide does not establish any substantial rule not legally authorized by 

official Branch Policy. 

Questions about this User’s Guide can be directed to the Fresh Products Branch’s Audit 

Management Section in Washington DC. 

April 2011 

****This publication may be duplicated without authorization from USDA. **** 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

TABLE OF CONTENTS 

GENERAL INFORMATION ............................................................................................ 1 

BACKGROUND........................................................................................................... 1 

AUDITORS.................................................................................................................. 2 

DEVELOPMENT OF A FOOD SAFETY PROGRAM ..................................................... 2 

PREPARING FOR AN AUDIT ........................................................................................ 3 

INTERNAL AUDIT ....................................................................................................... 4 

DOCUMENTATION..................................................................................................... 4 

D=DOCUMENT ........................................................................................................... 4 

P=POLICY.................................................................................................................. 5 

R=RECORDS.............................................................................................................. 5 

SCHEDULING AN AUDIT .............................................................................................. 5 

PARTICIPATION AGREEMENT.................................................................................. 5 

THE AUDIT ..................................................................................................................... 5 

INITIAL AUDIT............................................................................................................. 6 

FOLLOW-UP AUDIT.................................................................................................... 6 

UNANNOUNCED VERIFICATION VISIT..................................................................... 6 

PART 1- FARM REVIEW ............................................................................................... 7 

PARTS 2 THROUGH 6 OF THE GAP&GHP AUDIT............................................................ 7 

PEFORMING AN AUDIT FOR A DIVERSIFIED FARMING OPERATION.................... 7 

NON-CONFORMITY AND CORRECTIVE ACTION POLICY......................................... 8 

AUDIT SCOPES ............................................................................................................. 9 

GENERAL QUESTIONS................................................................................................. 9 

FOOD SAFETY PLAN ............................................................................................... 10 

TRACEABILITY ......................................................................................................... 10 

RECALL PROGRAM ................................................................................................. 10 

WORKER HEALTH AND HYGIENE .......................................................................... 11 

PESTICIDE/CHEMICAL USE .................................................................................... 12 

FARM REVIEW............................................................................................................. 12 

WATER USE ............................................................................................................. 12 

SOIL AMENDMENTS ................................................................................................ 13 

ANIMALS/WILDLIFE/LIVESTOCK ............................................................................ 14 

LAND USE & LAND USE HISTORY........................................................................... 14 

FIELD HARVEST & FIELD PACKING ACTIVITIES..................................................... 15 

PRE-HARVEST ASSESSMENT................................................................................ 15 

FIELD SANITATION UNITS....................................................................................... 16 

HARVESTING CONTAINERS & EQUIPMENT.......................................................... 16 

WATER USE ............................................................................................................. 17 

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TRANSPORTATION OF PRODUCE ......................................................................... 17 

EMERGENCY CLEAN-UP PROCEDURES............................................................... 17 

HOUSE PACKING FACILITY....................................................................................... 17 

WATER USE IN PACKING FACILITY........................................................................ 18 

TREATMENT OF PROCESSING WATER................................................................. 18 

SANITATION PROGRAM/GENERAL HOUSEKEEPING .......................................... 19 

WORKER HEALTH AND HYGEINE .......................................................................... 19 

CONTAINERS........................................................................................................... 20 

PEST CONTROL....................................................................................................... 20 

STORAGE AND TRANSPORTATION ......................................................................... 20 

MECHANICAL EQUIPMENT ..................................................................................... 21 

ICE AND REFRIGERATION...................................................................................... 21 

TRANSPORTATION AND LOADING ........................................................................ 21 

WHOLESALE DISTRIBUTION CENTER/ TERMINAL WAREHOUSE ........................ 21 

RECEIVING............................................................................................................... 22 

SANITATION PROGRAM/GENERAL HOUSEKEEPING .......................................... 22 

WATER USE IN PACKING FACILITY........................................................................ 23 

TREATMENT OF PROCESSING WATER................................................................. 23 

STORAGE FACILITY/TEMPERATURE CONTROL .................................................. 23 

CONTAINERS ........................................................................................................... 24 

MECHANICAL EQUIPMENT ..................................................................................... 24 

PREVENTIVE FOOD DEFENSE PROCEDURES ........................................................ 24 

FOOD DEFENSE PLAN ............................................................................................ 24 

PERSONNEL ............................................................................................................ 24 

FACILITY PROCEDURES......................................................................................... 25 

KEY/ENTRANCE ACCOUNTABILITY....................................................................... 26 

DELIVERIES ............................................................................................................. 26 

SEPARATION OF PRODUCTS................................................................................. 26 

ALLERGENS ............................................................................................................. 27 

USDA GAP&GHP PROGRAM AUDIT SCORING........................................................ 27 

AUTOMATIC UNSATISFACTORY CONDTION ........................................................ 27 

POST AUDIT ACTIVITIES............................................................................................ 28 

APPEALS, COMPLAINTS & DISPUTES ..................................................................... 28 

ADDITIONAL RESOURCES ........................................................................................ 29 

APPENDIX I – FV-237A AUDIT REQUEST ................................................................. 30 

APPENDIX II – FV-651 PARTICIPANT AGREEMENT ................................................ 31 

APPENDIX III – CORRECTIVE ACTION REPORT...................................................... 33 

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GENERAL INFORMATION 

This User’s Guide is intended to provide guidance to the fresh fruit and vegetable 

industry on the requirements of the USDA Good Agricultural Practices and Good 

Handling Practices Audit Verification Program (GAP&GHP) and prepare for a 

successful audit. This Guide does not address every specific question on the USDA 

GAP&GHP audit checklist, but covers all the major topic areas of the audit. 

USDA AMS and state departments of agriculture who work with USDA AMS 

through cooperative agreements also conduct commodity specific audits for the leafy 

greens, tomato and mushroom industries. These audits fall under the general 

guidelines of the USDA GAP&GHP program. Each commodity specific audit has its 

own set of specific requirements and audit checklists. Please refer to the USDA 

GAP&GHP website at www.ams.usda.gov\gapghp for links to these commodity specific 

audit programs. 

BACKGROUND 

In October 1998, the U.S. Food and Drug Administration (FDA) issued a 

guidance document for the fresh fruit and vegetable industry which provided general 

guidelines for reducing the risk of contamination of fresh produce by microbial 

organisms. The document, “Guide to Minimize Microbial Food Safety Hazards for Fresh 

Fruits and Vegetables,” (The FDA Guide) provides information about high risk areas for 

contamination and how to avoid or minimize such contamination. Shortly after the 

release of The FDA Guide, many wholesale and foodservice buyers of fresh fruits and 

vegetables began requiring their suppliers to undergo 3rd party audits which provided 

assurances they were following good agricultural practices (GAP) and good handling 

practices (GHP). 

In response to numerous requests from the fruit and vegetable industry, the 

USDA Agricultural Marketing Service (AMS) in cooperation with the Association of Fruit 

and Vegetable Inspection and Standardization Agencies (AFVISA) developed an audit 

based program to verify conformance to The FDA Guide. In August 2001, USDA AMS 

approved and conducted a pilot project for the GAP&GHP audit, and in January 2002, 

USDA AMS formally implemented the USDA Good Agricultural Practices & Good 

Handling Practices (GAP&GHP) audit verification program. It is offered to the fruit and 

vegetable industry and assesses an operation’s efforts to minimize the risk of 

contamination of fresh fruits, vegetables and nuts by microbial pathogens. The program 

does not guarantee the product is free from microbial contamination, but verifies the 

participant has taken proactive measures to reduce the risk of contamination by 

adhering to generally recognized best practices. The responsibility for product safety 

and the continued observance of best practices rests with the operation producing and 

handling the fresh product. 

Additional information and a copy of the current checklist can be found at 

www.ams.usda.gov/gapghp. 

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The USDA GAP&GHP audit verification program is a voluntary, user fee funded 

program. The USDA Agricultural Marketing Service operates under the Agricultural 

Marketing Act of 1946 [7 U.S.C. 1621], and offers voluntary, user fee funded programs 

which assists in the strategic marketing of agricultural commodities. The U.S. Food and 

Drug Administration is the federal agency with regulatory authority for fresh fruits and 

vegetables. 

AUDITORS 

All auditors used to perform the USDA GAP&GHP audit are either federal 

employees of USDA AMS, or state department of agriculture employees who are 

specifically trained and licensed to perform audits on behalf of USDA AMS. Most 

auditors are fruit and vegetable inspectors who inspect and grade produce on a daily 

basis as well as perform audits. 

USDA AMS sets the minimum criteria for all AMS personnel used to conduct 

audits. The following bullets highlight the auditor requirements for the GAP&GHP 

program: 

• Auditors must have a minimum of three years work experience in the area of fruit 

and vegetable production, handling or marketing; or a Bachelors Degree in an 

agricultural related field; or a combination of work experience and education. 

• Auditors must demonstrate knowledge of the production, handling, distribution 

and marketing of fresh fruits and vegetables. 

• Auditors must undergo formal classroom training as well as on the job training. 

• Auditors are evaluated by program management before being licensed as an 

auditor. 

• Auditors must take yearly refresher training specific to the audit program they are 

licensed. 

• Auditors must take yearly ethics training. 

• Auditors must complete 80 hours of continual professional development every 

three years. 

• Auditors are evaluated on a yearly basis. 

USDA licensed auditors provide impartial, prompt third party services to the fruit 

and vegetable industry and have no financial interest in the products and services they 

are auditing. In order to remain impartial, auditors are prohibited from providing specific 

recommendations to operations on the development of their food safety plan or actions 

which need to be taken by the operation in order to be compliant with the USDA 

GAP&GHP program requirements. Auditors may answer general inquiries and refer 

inquiries to food safety experts such as cooperative extension specialists. 

DEVELOPMENT OF A FOOD SAFETY PROGRAM 

The development of a food safety program is recommended for any operation 

which produces or handles fresh fruits and vegetables, not just for operations who wish 

to participate in the USDA GAP&GHP audit verification program. 

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A food safety plan is a written document that covers all aspects of the growing 

and handling processes, and evaluates the potential sources of risk. The plan indicates 

what steps and procedures the operation will take to reduce the risks of contamination 

by chemical, physical, or microbial hazards. 

To assist operations in the development of a food safety plan the FDA and the 

fruit and vegetable industry have developed commodity specific guidance documents 

which outline the best practices of the specific commodity. The FDA has released four 

commodity specific guidance documents for leafy greens, melons, tomatoes and fresh 

cut fruits and vegetables. Trade and commodity associations have developed their own 

set of guidance documents including watermelons, strawberries, mushrooms, leafy 

greens, tomatoes, and green onions. Other guidance documents are currently in 

development. 

Many university Cooperative Extension programs across the country have 

developed templates or examples of produce specific food safety plans to assist their 

constituents develop food safety plans. Operations should contact their state Extension 

Service program or visit the National GAPs Program website for further information at 

http://www.gaps.cornell.edu. 

For operations wishing to participate in the USDA GAP&GHP program, the first 

step in preparing for an audit should be the development and implementation of a food 

safety program. The produce food safety program should be written by the operation 

and shall define specific, measurable steps taken by the operation to reduce the risk of 

microbial, physical and chemical hazards from contaminating the product. A wellwritten plan will detail all aspects of the growing and handing processes and shall also 

outline the corrective actions the operation will take if it is suspected or known product 

has become contaminated. Typically the food safety program takes the form of a 

manual to facilitate the easy dissemination and recording of the operations food safety 

plan. The food safety plan needs to incorporate the USDA GAP&GHP audit verification 

program requirements and applicable policies. The following points are key items to 

consider: 

• The operation must create a food safety program that accurately reflects their 

operation. 

• The operation shall develop Standard Operating Procedures (SOPs) which 

outline the policies and procedures for the operation. 

• The operation must designate a person that oversees the food safety program. 

• The produce food safety program must be implemented and followed. 

• The operation must determine what to document and keep records for. The 

operation must also keep all documents and records current. 

• The operation shall document corrective actions taken which verifies adherence 

to their food safety plan. 

PREPARING FOR AN AUDIT 

For farming operations/packinghouses wishing to participate in the USDA 

GAP&GHP program, the operation should implement their produce food safety program 

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as close to the beginning of the growing season as possible. Starting early in the 

season allows the operation to make any necessary changes to their policies and 

procedures, as well as accumulate documents and records verifying their food safety 

program. Additionally, once the growing season starts, operations may not have the 

time and/or resources available to develop and implement a viable food safety program. 

Wholesale distribution centers/terminal warehouses/commercial storage facilities 

may implement their food safety program at any point during the year. These 

operations should take into consideration the time it will take to accumulate documents 

and records verifying their food safety program before scheduling an audit. 

INTERNAL AUDIT 

Although not a requirement of the program, it is recommended that the operation 

conduct a self or internal audit prior to scheduling an official USDA audit. A self or 

internal audit allows the operation to find areas of improvement and take corrective 

actions before the actual audit. Some Cooperative Extension programs will work with 

their growers and assist in performing an internal audit of the operation. 

Operations can utilize the USDA GAP&GHP audit checklist to perform the 

internal audit which is available on the USDA GAP&GHP website or by contacting the 

local inspection office. 

DOCUMENTATION 

An important component of any audit based program is the review of documents 

and records. Since the auditor is not at the operation on a daily basis, documents and 

records are necessary to verify policies and procedures are in place, and certain tasks 

have been completed throughout the year. 

The operation shall keep records as necessary to document adherence to their 

food safety program, USDA GAP&GHP program requirements, and local, state and 

federal regulations. The operation’s food safety plan shall address what documents and 

records shall be maintained and the policies and procedures for managing the 

documents. 

For the purposes of the USDA GAP&GHP program, the audit checklist defines 

when documents are required and what type of documentation is necessary. These are 

defined in the last column of the audit checklist as a D, P, or an R. Operations may 

decide to keep additional documentation than is required by the USDA GAP&GHP 

program, but at a minimum, those questions on the audit checklist which are identified 

with a D, P or R require documentation. 

D=Document 

Any question designated with a D requires a combination of written standard 

operating procedures outlining company policies and procedures, records of actions 

taken, and/or other documents which may be necessary to support the food safety plan. 

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P=Policy 

Any question designated with a P requires a written policy or procedure to 

appear in the operation’s food safety plan. 

R=Records 

Any question designated with a R requires a record which shows a process has 

been completed or record an action taken. 

SCHEDULING AN AUDIT 

An operation shall initiate the scheduling of the audit at least two weeks in 

advance of their anticipated audit date by contacting the local USDA inspection office. 

The USDA does not automatically contact operations who have participated in previous 

years to schedule its yearly announced audit. It is the operation’s responsibility to 

schedule the audit. 

A list of USDA inspection offices is available on the USDA GAP&GHP website or 

by calling the Fresh Products Branch at 800-560-7956, Extension 5. In addition, audits 

may be requested using the FV-237A form, located in the appendix of this User’s Guide, 

and faxing to the local USDA inspection office. When contacting the local inspection 

office, be prepared with a list of anticipated dates the operation is available for an audit. 

All services are offered on a first come, first served basis. Once an auditor is assigned, 

he/she will contact you to make arrangements for the audit. Be prepared to provide the 

auditor with a point of contact, the contact’s information, physical location/address of the 

audit site and other information necessary for the audit. If the operation has a large 

non-English speaking workforce, the auditor may ask the operation to provide a 

translator in order to communicate with the workers during the audit if he/she does not 

speak the language of the workforce. 

PARTICIPATION AGREEMENT 

The auditor will provide the operation with USDA form FV-651, the Participation 

Agreement. An example of the FV-651 form is in the appendix of this guide. The 

Participation Agreement outlines the expectations of the operation and the USDA in 

performing the GAP&GHP audit. Form FV-651 must be signed by a management 

representative of the operation and submitted to the auditor prior to the start of any 

audit. Without the form, no audit services can be provided. 

THE AUDIT 

The actual audit is broken down into four main areas: 

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• Opening Meeting - The lead auditor introduces the audit team, communicates the 

agenda of the audit, answers questions from the auditee, and explains the audit 

process so everyone knows what to expect during the audit. 

• Conducting the audit - The audit team will review documents and records, 

interview employees, witness processes and observe the operation to determine 

compliance to the operations food safety plan and the USDA GAP&GHP 

program requirements. 

• Team Caucus - After the audit team has finished evaluating the operation, the 

team will meet and discuss any findings, address any concerns among the team 

members, and finalize the audit. 

• Closing Meeting - The lead auditor will meet with the operation’s representatives 

and review the findings of the audit. The audit team will also answer any 

questions from the auditee and explain any observations. 

There are distinct types of audits which may be applicable to the operation during 

the year; the initial audit, the follow-up audit and the unannounced verification visit. 

INITIAL AUDIT 

The initial audit is the annual announced audit that verifies the farm/facilities 

compliance with the requirements of the USDA GAP&GHP audit verification program. 

A USDA GAP&GHP audit is valid for one year from the date of the initial audit. 

FOLLOW-UP AUDIT 

A follow-up audit is performed when either the farm/facility’s initial audit or 

unannounced verification visit does not meet the program requirements. If an operation 

does not meet program requirements, the auditor will create a corrective action report 

and the operation must address the non-conformities prior to the scheduling of a followup audit. For specific instructions, refer to the non-conformity and corrective policy 

section. 

• If the operation fails to meet program requirements due to an “automatic 

unsatisfactory” condition, the follow-up audit must consist of all scopes originally 

requested on the initial audit. 

• If the operation fails to meet program requirements because of a low score for 

one or more scopes, only those scopes which failed and the General Section 

must be completed on the follow-up audit. 

UNANNOUNCED VERIFICATION VISIT 

An important component of the USDA GAP&GHP audit is the use of 

unannounced verification visits. Unannounced verification visits are conducted at some 

point during the season after the operation has successfully passed an initial or followup audit. It is used to verify that a farm/facility is in consistent conformance with the 

requirements of its food safety plan and the USDA GAP&GHP program requirements. 

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The unannounced verification visit differs from the initial audit in that the auditee does 

not know specifically when the auditor will be on site to perform the audit. The 

unannounced review will generally verify conformance through observation but may 

also require a further review of documentation. 

USDA policy sets the following conditions for when and how many unannounced 

verification visits shall be conducted: 

Part 1- Farm Review 

For operation which only grow one commodity in a production area during a 

growing season such perennial crops, potatoes, onions, etc., no unannounced 

verification visits for the production area are required.* For those operations that grow 

multiple commodities during the growing season using the same crop production area, 

unannounced verification visits of the farm are required. 

Parts 2 through 6 of the GAP&GHP audit 

• For an operation which is in operation for 30 days or less, no unannounced 

verification visits are required.* 

• For an operation which is in operation for 31-90 days, a minimum of one 

unannounced verification visit shall be conducted.* 

• For an operation which is in operation for 90 days or more, a minimum of two 

unannounced verification visits shall be conducted.* 

*Note In all cases, the USDA reserves the right to conduct additional unannounced 

verification visits if there is specific reason to suspect the operation is not in 

compliance with the GAP&GHP program requirements or their own food safety 

program. 

PEFORMING AN AUDIT FOR A DIVERSIFIED FARMING OPERATION 

It is not a requirement to perform a separate audit for every separate commodity 

grown on the farm, however operations may choose to do so if they so desire. USDA 

AMS policy allows diversified farming operations to cover all the commodities grown on 

the farm under the same audit subject to the following conditions: 

• All commodities covered by the audit must be declared during the initial audit and 

cannot be added later in the season. The food safety plan must address the 

various risks associated with all the commodities being audited. For instance if a 

berry grower hand picks strawberries but mechanically harvests blueberries, the 

food safety plan shall address the potential risks and corrective actions 

associated with each of these activities. 

• The auditor must have the opportunity to observe the crop(s) being grown and 

harvested during the initial audit or subsequent unannounced verification visits. 

As an example, if the operation schedules an audit for August 1st , any crops 

which have been completely harvested prior to August 1st cannot be listed on the 

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audit. The auditor may not actually witness every commodity listed being 

harvested, but needs to have to opportunity to observe. 

• Operation would be subject to the appropriate number of unannounced 

verification visits determined by the length of the growing season for all the 

commodities produced. 

The following is an example of how performing a GAP&GHP audit for a 

diversified operation would work. ABC Fruit and Vegetable Growers Inc. produces a 

wide variety of fruits and vegetable including asparagus, strawberries, sweet peas, 

tomatoes, peppers, peaches, nectarines, apples, pears, potatoes, broccoli and 

cauliflower and wants a USDA GAP&GHP audit. The operation is in production from 

the start of the growing season on April 1st to approximately October 31st . 

• ABC Fruit and Vegetable Growers Inc would call and schedule their initial audit 

when the spring crops (asparagus, strawberries and sweet peas) are being 

harvested. However, they would declare all twelve of the commodities grown 

when scheduling the audit. 

• The auditor would perform the initial audit and cover the General Section and 

Part 1 Farm Review of the entire farming operation. The auditor would also 

perform Part 2 Field Harvesting and Field Packing Activities on the asparagus, 

strawberries and sweet peas. In addition because the operation is in production 

for more than 90 days, the auditor would inform the operation there will be two 

unannounced verification visits sometime during the rest of the growing season. 

The auditor would then schedule the first unannounced visit to coincide with the 

harvest of the tomatoes, peppers, and stone fruit, and the second unannounced 

visit to coincide with the harvest of the remaining commodities. 

NON-CONFORMITY AND CORRECTIVE ACTION POLICY 

A Corrective Action Report (CAR) is required for any GAP&GHP audit which fails 

due to non-conformities from a specific “automatic unsatisfactory” or because a 

particular scope fails to meet the minimum program requirements. 

The auditor will document the non-conformity(s) observed during the audit on the 

CAR form and submit it with the audit report at the closing meeting. If the operation 

wishes to continue in the GAP&GHP program, it must review the non-conformity(s) 

listed on the Corrective Action Report form and develop a plan to fix or address them. 

Corrective actions are typically taken in two steps, a short term corrective action and a 

long term corrective action (sometimes referred to as a root cause analysis). Short term 

corrective actions are taken to immediately address a deficiency. For example, if an 

auditor observes a restroom without any soap, toilet paper and paper towels, the 

operation’s short term corrective action is to stock the restroom with the appropriate 

supplies. A root cause analysis reviews the deficiency if it occurs frequently or requires 

long term investment. In the example above, if the auditor investigated why the 

restrooms were always out of supplies and found their food safety program didn’t 

designate someone to check the bathrooms on a regular basis and restock as needed. 

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Designating someone to handle the bathroom supplies would be a long term or root 

cause corrective action. 

Once the operation has reviewed and developed a corrective action for the nonconformities listed on the audit, it will submit the corrective actions to the auditor for 

review. The auditor will review the corrective actions and sign off on the Corrective 

Action Report if he/she feels the corrective actions listed will reasonably address the 

non-conformity. Ultimately the corrective actions will be verified during a follow-up audit 

or unannounced verification visit. 

AUDIT SCOPES 

The USDA GAP&GHP audit is divided into seven sections or scopes, each which 

covers a specific portion of the supply chain. The scopes of the audit are: 

• General Questions 

• Part 1 – Farm Review 

• Part 2 – Field Harvesting & Field Packing Activities 

• Part 3 – House Packing Facility 

• Part 4 – Storage & Transportation 

• Part 5 – (No Longer Used) 

• Part 6 – Wholesale Distribution Center/Terminal Warehouse 

• Part 7 – Preventative Food Defense Procedures 

USDA considers a good agricultural practices audit to consist of Part 1 Farm 

Review and Part 2 Field Harvest & Field Packing Activities and a good handling 

practices audit to consist of Part 3 House Packing Facility and Part 4 Storage & 

Transportation for pre farm gate operations or Part 6 Wholesale Distribution 

Center/Terminal Warehouse for post farm-gate operations. Part 7 Preventative Food 

Defense Procedures is an optional scope for those operations which need verification of 

food defense. 

The operation shall designate which scopes of the audit the auditor will perform 

when requesting the audit. 

GENERAL QUESTIONS 

The General Questions are a mandatory scope of every audit (except for a Part 7 

Food Security only audit) and cover overarching food safety issues which are applicable 

to any audit. In order to successfully pass the USDA GAP&GHP audit, the operation 

must meet the requirements of the General Questions portion of the audit. The 

following sections outline the major topics covered by the General Questions. 

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FOOD SAFETY PLAN 

USDA policy requires that an operation develop and implement a documented 

food safety program. The program must include a food safety manual which includes 

standard operating procedures (SOP’s), and/or documentation which outline the 

operation’s policies and work instructions for adhering to the food safety program. It 

may also contain information or references pertaining to self audits of the program or 

management reviews of the program. Other similar documentation may also be 

applicable and acceptable if it indicates that an established food safety program is in 

place. 

In addition, it is required that the operation has identified a specific person(s) to 

implement and oversee the food safety program. The person(s) need to be formally 

identified in the food safety plan, organizational chart, or similar documentation. 

TRACEABILITY 

The food safety program shall include a documented traceability program. A 

traceability program in its simplest form is the ability to know where product was 

received from (one step back) and where product was sent to (one step forward). The 

operation needs to develop and implement policies and procedures for a traceability 

program. There are commercially available traceability programs for the produce 

industry which can assist operations in implementing a traceability program. For further 

guidance operations can contact their trade/commodity associations, state horticultural 

associations or county extension agent. 

The Bioterrorism Act of 2002 requires certain handlers of foods to keep records 

which allow the handler to keep track of produce “one step forward” and “one step back” 

within the food chain. For producers, keeping records and uniquely identifying product 

moving out of the field to its next destination (packing house, storage cellars, end user, 

etc.) is an important component of a traceability program. For product moving in bulk 

from the field to a packing house or storage facility, records such as load tickets, field 

harvest records that move with the load or other similar records that identify where the 

product originated are examples of identification. For products that are field packed, the 

individual cartons or master containers should be clearly identified with the company 

information including company name and address and other identifying marks as 

outlined in the company’s traceability program. 

RECALL PROGRAM 

A recall program is defined as the ability to pull product from the marketplace 

once it has left the operation’s control. The operation needs to develop policies and 

procedures which allow it to recall product by working with their suppliers and 

customers to track the path the product takes from the farm to the consumer. A recall is 

a means to return marketed product to its origin or to remove it from the market place 

and have verifiable evidence that all product being recalled is accounted for. A “mock 

recall” is a practice exercise that is used to determine where product is shipped and 

whether or not it can be returned to the origin or removed from the marketing chain. 

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Operations must have some documented evidence of completing at least one mock 

recall prior to the audit. Documents must indicate the customers contacted, the amount 

of product remaining from the original shipment, and the disposition of product which 

could not be effectively recalled. 

The following is an example of a mock recall: 

• A packinghouse generated 5,000 cases of apples on January 15th from grower X 

lot 1234. The packinghouse labeled the apples with their name, address and a 

lot code of 11511. 

• The 5,000 cases of apples were shipped to five different retailers, each receiving 

1,000 cases. 

• The packinghouse initiates a recall of lot 11511. The individual(s) responsible for 

performing the mock recall contacts the five retailers who received apples from 

lot 11511 and informs them they are performing a mock recall. The 

packinghouse forwards a form to each retailer asking to supply an accounting of 

the number of cartons from lot 11511 still in their possession and the number of 

cartons sold. The form will contain instructions on where to send the form when 

completed and the timeframe when it must be sent back. The recall plan should 

outline the timeframe required to complete the mock audit. 

• The packinghouse summarizes the forms from the five retailers and determines 

the number of cartons still in the retailers control and the number that are not. 

In the event of an actual recall, the operation shall develop a procedure on how 

they want the product being recalled to be handled. Does the operation want it 

returned? Will the operation allow the buyer to dispose of it and submit proof the 

product has been dumped?, etc. This needs to be communicated to the buyer so they 

can effectively manage their inventory as well. 

WORKER HEALTH AND HYGIENE 

One of the primary risks associated with fruits and vegetables is the potential 

introduction of pathogens through poor worker health and hygienic practices. The 

General Questions section of the USDA audit covers, in great detail, areas which need 

to be addressed regarding worker health and hygiene. In addition, other scopes of the 

audit address worker health and hygiene issues related to those scopes such as an 

operation’s glove and jewelry policies, or location of portable sanitation units in the field. 

The operation’s food safety plan shall address worker health and hygiene issues 

and develop SOPs which address them. This should include a training program to 

educate workers on the operation’s SOPs. A solid training program is an essential 

component of a food safety program. Examples of SOPs include: 

• Ensuring potable water is available to all workers; 

• Ensuring all workers and visitors to the location are required to follow proper 

sanitation and hygiene practices; 

• Providing training on proper sanitation and hygiene practices to all staff; 

• Verifying employees and visitors are following good hygiene/sanitation practices; 

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• Confirming employees are washing their hands before beginning or returning to 

work; 

• Posting readily understandable signs that instruct employees to wash their 

hands before beginning or returning to work; 

• Servicing and cleaning all toilet/restroom/field sanitation facilities; and 

• Confining smoking and eating to designated areas separate from where product 

is handled. 

The General Questions section also requires the operation to develop a blood 

and bodily fluid policy, and a policy which addresses workers who report to work with 

symptoms of forborne illness. 

The USDA GAP&GHP audit requires that all sanitation facilities must be properly 

supplied with single use towels, toilet paper, and hand soap or anti-bacterial soap and 

potable water for hand washing. Hand sanitizers are not an acceptable substitute for 

hand washing and are not to be used as the sole method for hand cleaning. The 

number and placement of sanitation facilities must comply with all applicable local, state 

and federal regulations. At a minimum the Occupational Safety and Health 

Administration (OSHA) requires one bathroom per 20 employees. 

PESTICIDE/CHEMICAL USE 

The operation shall use all pesticides and other pre or post harvest materials in a 

manner consistent with prevailing regulations and the labeled instructions. This 

includes following state licensing requirements for pesticide applicators. 

FARM REVIEW 

The Farm Review scope of the USDA audit mainly addresses the crop 

production areas and adjacent lands, domestic and wild animals, as well as the inputs 

used to produce the crop such as water and soil amendments. 

WATER USE 

For the purposes of the USDA GAP&GHP program, water use is defined as 

either agricultural water used for irrigation, frost protection, fertigation, chemical 

application or other pre-harvest purposes, and post harvest water used on the product 

after it has been harvested. An example of post harvest water use is water used to 

wash the product, transport the product through the grading and packing line (dump 

tanks, flumes, etc.) or apply post harvest chemicals. Operations must have knowledge 

of the water quality used in order to determine whether or not the product is reasonably 

likely to become contaminated through the application of or submersion into water. 

For agricultural water, the USDA GAP&GHP program requires the operation 

perform a water quality risk assessment to determine if the water quality is appropriate 

for the crop(s) it’s being used on. The risk assessment should include the water quality, 

the type of irrigation method, and the crop being irrigated. The results of the risk 

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assessment shall be used to determine an action level where the operation determines 

water quality is not suitable for use without taking a corrective action. Water tests are 

required to be conducted on a scheduled frequency to verify water quality is meeting the 

operation’s action threshold as outlined in their SOPs. 

The USDA GAP&GHP program sets the following testing frequency: 

• Municipal water: Test results are acquired from the local water authority 

annually or tested by the operation at least annually. 

• Well water: Water is tested one time during the growing season. If fecal 

coliforms are present, the well is treated with a sanitizer to reduce pathogen 

levels and is retested. Wells are monitored to make sure casings are secure and 

well-maintained and that livestock and manure storage areas are excluded from 

the well recharge and pumping area. 

• Surface water: Water is tested three (3) times during the growing season – first 

at planting, second at peak use, third at or near harvest. 

There is not a national irrigation water standard which sets the minimum 

microbial levels allowable for irrigation water. However, there are many commodity 

specific guidelines available which give recommendations for water quality. These can 

serve as a reference source for an operation when determining specific thresholds for 

their irrigation water. For instance the CA & AZ Leafy Greens Marketing Agreements 

and the Food Safety Standard for the Tomato Supply Chain identify the microbial 

requirements of the EPA Recreational Water Standard as the threshold for irrigation 

water. 

For post harvest water applications, the USDA GAP&GHP program requires that 

the water used meet the microbial requirements of the US EPA Drinking Water 

Standard. Any post harvest water use which does not meet this standard will result in 

an “automatic unsatisfactory” assessment on the audit. 

SOIL AMENDMENTS 

Animal manure and biosolids represent a significant source of potential 

contamination. However, properly treated manure or biosolids can be an effective and 

safe fertilizer. Raw animal manure or raw biosolids used as a fertilizer or enters water 

sources through runoff may contain pathogens of public health significance that can 

contaminate produce. 

The operation shall conduct a risk assessment to determine if and when raw 

manure or biosolids are appropriate to use. The type of crop and growing conditions 

are all factors in the risk assessment. For example, raw manure applied to a newly 

planted orchard is less of a risk than raw manure applied to a vegetable crop grown on 

the ground. The USDA GAP&GHP Program requirements state that if raw manure is 

used, it must be applied at least 2 weeks prior to planting and a minimum of 120 days 

prior to harvest. There are also several commodity specific guidance documents which 

are more restrictive than the USDA GAP&GHP program and either do not allow the use 

of raw manure or have a one year restriction on the application of raw manure. 

Operations shall check to see what the commodity specific recommendations and 

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prevailing regulations are for their commodities regarding the use of manure and 

biosolids. 

Animal manure or biosolids which are composted require a documented 

composting process be developed and available for review. If purchasing composed 

manure, has documentation from the composter listing the process used and test 

results showing the process effectively controlled the pathogens of concern should be 

maintained. If an operation has questions regarding proper composting procedures, 

contact the Cooperative Extension Service in your state. Most all Extension Services 

have developed proper composting procedures and have this type of information readily 

available. 

ANIMALS/WILDLIFE/LIVESTOCK 

Animals pose a potential source of contamination for fruit and vegetable crops. 

Domestic animals which can be controlled such as livestock or pets need to be 

excluded from entering crop production areas in order to reduce the potential for 

contamination. However, when farm service animals (horses, oxen, and mules) are 

used, an operation shall address potential sources of contamination through a risk 

assessment and documented SOP’s to control hazards caused by these animals and 

remediation steps which will be taken if they cause contamination. 

The USDA GAP&GHP program requires operations to monitor for the presence 

or signs of animals. Based on the results of the monitoring, if necessary take measures 

to reduce the opportunity for animals from entering the crop production areas. This 

does not mean total exclusion; farming operations are never going to be able to 

completely exclude wild animals from entering crop production areas. However, every 

effort should be made to limit the access to the production areas. When needed, 

measures should be taken to reduce the entry into crop production areas by wild 

animals. This can be accomplished many ways, including such items as noise cannons 

or scare balloons to scare away birds and migratory water fowl, or fencing /other 

barriers or deterrents which limit wildlife access. 

Operations shall also consider any local, state or federal regulations when 

developing mitigation strategies for wild animals. Regulations may limit the options for 

controlling wild animals. Co-management strategies which balance food safety 

concerns with wildlife control and not just remove riparian areas, grass buffer strips and 

other conservation practices should also be considered. Operations can contact the 

local Natural Resources & Conservation Service or their local county extension agent 

for more information on co-management. 

LAND USE & LAND USE HISTORY 

The operation must consider the crop production areas and adjacent land use 

through a documented land use risk assessment. Any risks reasonably likely to cause 

chemical, physical or microbiological contamination of the produce which are identified 

by the risk assessment must be addressed and the crop production area tested to 

validate the hazard has been addressed. While adjacent lands may not be the property 

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of the operation, the effects they have on the crop production areas needs to be 

evaluated and mitigation strategies put in place to minimize the impact of the hazard on 

the ground. For example, if the adjacent ground is uphill houses a concentrated animal 

feeding operation, proactive steps to minimize the opportunity for runoff to flow through 

the crop production area must be taken. 

Flooding which is caused by the overflow of a body of water shall be documented 

and if it occurs in season, an assessment is performed to determine if the flooding 

contaminated the product. The operation should consider testing the product and/or 

soils before harvesting if sources of contamination are located in the general vicinity of 

the crop production areas. 

The land use risk assessment shall also consider the location of the operation’s 

sewage treatment/septic system or nearby municipal/commercial sewage treatment 

facilities. The operation shall also verify their sewage treatment/septic system is 

functioning properly and does not lead to a contamination risk. 

FIELD HARVEST & FIELD PACKING ACTIVITIES 

The Field Harvest and Field Packing Activities section of the audit covers the 

harvesting of commodities in either the field or greenhouse operations. It also covers 

the packing of such commodities for shipment when it occurs directly in the field or 

greenhouse and is not sent to a packinghouse for further sorting or grading. The 

emphasis on this scope is the harvesting activities, and the containers and equipment 

which are used to pack the product. Employee health and hygiene are also an 

important component of field harvest and field packing and are covered in the General 

Questions section of the audit. 

USDA policy only allows an auditor to perform this scope of the audit when 

commodities are actively being harvested and there is activity in the crop production 

area. It is not a requirement that the auditor observe every commodity listed on the 

audit being harvested, however the food safety plan shall address all the commodities 

being harvested, and the different risks associated with different harvesting methods. 

(i.e. mechanically harvested vs. hand harvested). Records for all commodities 

harvested are maintained for traceability. 

PRE-HARVEST ASSESSMENT 

The farm operation must have completed a pre-harvest assessment on each 

production area prior to harvesting any crop being certified by the audit. The 

assessment may include statements which address known risk that are applicable to 

the operation such as: 

• Are toilet and wash facilities properly located? 

• Is potable water available for workers? 

• Are harvest containers available, clean, well located and protected? 

• Is harvest equipment available and in good condition? 

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• Is there evidence of unauthorized entry in the crop area and if so, has it been 

investigated? 

• Is there evidence of domestic or wild animal crop damage? 

• Is there evidence of physical contamination in the crop area? 

• Are fuel and chemicals which might contaminate crop areas isolated? 

• If areas are contaminated are they isolated for “no-harvest”? 

• Are there any other notable sources of biological or physical contamination such 

as dump sites, manure, burning debris, water that may affect food safety? 

• Is transportation equipment clean and available? 

The assessment may include other information as determined by the operation. 

FIELD SANITATION UNITS 

The number and placement of sanitation facilities must comply with all applicable 

local, state and federal regulations. Operations shall also have a documented 

emergency clean-up procedure in case contamination occurs. The procedure should 

include what will be done to contain the spill and to prevent additional contamination, 

what will be done to clean up the spill and what will be done with contaminated product. 

HARVESTING CONTAINERS & EQUIPMENT 

The farming operation shall keep harvest containers (picking buckets, baskets, 

bulk bins, etc.) as clean as practicable to prevent cross-contamination of fresh produce. 

These are some key areas to consider which are covered in the GAP&GHP audit: 

• Harvest containers used repeatedly during a harvest should be cleaned on a 

scheduled basis as outlined in the food safety plan. 

• If the farming operation stores harvest containers outside, proactive steps shall 

be taken to minimize harboring rodents and other pests in the harvesting 

containers. 

• Harvesting containers stored outside should be cleaned and sanitized before 

being used to haul fresh produce. 

• Operations shall also instruct workers to only use harvesting containers for their 

intended purpose, and not to use them for collecting trash or transporting 

personal items unless they are designated for that use. 

• Final packing containers used in field pack operations shall be protected from 

sources of contamination. 

• Only new or sanitized containers are used for packing the product. 

• Operation shall repair or discard damaged harvesting containers. 

• Harvesting equipment and machinery which comes in contact with the product is 

in good repair. 

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• Light bulbs and glass on harvesting equipment are protected and the operation 

has an SOP in place to address glass or plastic breakage on the equipment 

during harvest. 

WATER USE 

See the water use discussion in the Farm Review section. 

TRANSPORTATION OF PRODUCE 

Products that are transported in bulk from the field or from storage for further 

packing may be contaminated during this time. Steps should be taken to reduce the 

possible contamination by other vehicles on the roads, overhead contamination from 

overpasses, from birds or other means. Using tarps, enclosed trailers or other means to 

cover loads are examples of good practices. Products being moved in enclosed 

containers (boxes, cartons, etc.) would be considered covered if they are completely 

enclosed. 

EMERGENCY CLEAN-UP PROCEDURES 

The operation shall have a documented emergency clean-up procedure in the 

event accidental contamination occurs from glass/plastic breakage, chemicals, 

petroleum, or pesticides contaminating the crop. The procedure should include what 

will be done to contain the spill and to prevent additional contamination. As well as 

what will be done to clean it up and what will be done with contaminated product. 

HOUSE PACKING FACILITY 

This scope covers packinghouses located on or near crop production areas. 

This scope is not intended for repack operations or distribution operations which may 

custom pack product for retail or foodservice customers. These types of operations 

should use the Part 6 Wholesale Distribution Center/Terminal Warehouse section of the 

USDA GAP&GHP audit. 

The main focuses of the House Packing Facility section of the audit are, water, 

the packing equipment, general housekeeping, worker health and personal hygiene, 

containers used for packing, and pest control. This scope of the audit can only be 

performed when the packinghouse is actively handling product. If the audit covers more 

than one commodity, it is not necessary to see every commodity being packed unless 

there are major differences in the packing process such as dry run product vs. product 

which uses a water flume, etc. 

. 

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WATER USE IN PACKING FACILITY 

Source water used in the packing of fresh fruits and vegetables must meet the 

requirements of the EPA Drinking Water Standard. Also water used to make ice used in 

the packinghouse must meet these requirements. 

Municipal water supplies are regulated by law and are required to meet these 

requirements. However well water and surface water is subject to various 

uncontrollable influences and may or may not meet these requirements. The operation 

must provide documentation verifying the source water meets the EPA Drinking Water 

Standard requirements. 

For commodities which are susceptible to water infiltration such as product with a 

stem scar; special attention needs to be given to the water temperature in the dump 

tank and flumes vs. the temperature of the product. Research has shown that a 

susceptible commodity which is placed in water colder than the pulp temperature of the 

commodity have a greater chance of internalizing the water and thus carrying any 

contamination into the product. Operations should refer to commodity specific 

recommendations or their state extension food safety specialist for more information 

regarding water infiltration. 

TREATMENT OF PROCESSING WATER 

Water used during the post-harvest handling of fruits and vegetables often 

involves a high degree of water-to-produce contact, and if untreated, may serve as a 

source of contamination or cross-contamination. Re-use of processing water may result 

in the build-up of microbial loads, including undesirable pathogens. Operations shall 

consider practices which will ensure and maintain water quality. Such practices may 

include: 

• Monitoring of sanitation chemicals used to prevent cross contamination (i.e. 

chlorine and pH). 

• Perform periodic water sampling and microbial testing. 

• Change water as necessary to maintain sanitary conditions. 

• Consider developing SOPs (standard operating procedures or sanitary operating 

plans), including water change schedules. 

• For all processes that use water: clean and sanitize water contact surfaces, such 

as dump tanks, flumes, wash tanks, and hydro coolers, as often as necessary to 

ensure appropriate water quality. 

• Install backflow devices and legal air gaps, as needed, to prevent contamination 

of clean water with potentially contaminated water (such as between potable 

water fill lines and dump tank drain lines). 

• Routinely inspect and maintain equipment designed to assist in maintaining 

water quality, such as chlorine injectors, filtration systems, and backflow devices, 

to ensure efficient operation. 

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SANITATION PROGRAM/GENERAL HOUSEKEEPING 

Operations with poor sanitation in the packing environment may significantly 

increase the risk of contaminating fresh produce and water used on produce. 

Pathogenic microorganisms may be found on the floors and in the drains in the packing 

facility and on the surfaces of sorting, grading, and packing equipment. Any of these 

surfaces could be a potential source of microbial contamination. 

Operations shall employ good sanitation practices as a standard operating 

procedure to maintain control throughout the packing operation. Packing areas should 

be cleaned minimally at the end of each day. As necessary, clean and sanitize the 

washing, grading, sorting, and the packing lines to reduce the potential for microbial 

contamination of fresh produce. The operation shall develop and implement a general 

sanitation schedule which addresses the cleaning and sanitizing of the packinghouse 

operation including: 

• Food contact surfaces 

• Pipes, ducts, fans, and ceilings which are over product flow zones 

• Catwalks over food contact surfaces 

Ice making facilities may be located on the site of the operation or may be 

contracted out and supplied by another operation. In either case, the facility must 

provide records that indicate there is a regular schedule to sanitize the ice production 

and storage facility and any means of transportation to reduce the microbial population. 

This would include augers, conveyors and shovels used to transport the ice from one 

part of the facility to another. 

The operation shall use food grade approved lubricants in areas where 

lubricating agents may come into contact with produce. 

The operation shall have a procedure which identifies how product that spilled or 

comes in contact with the floor is handled. Spilled product that comes in contact with 

the floor can become contaminated and should not be used without considering a 

corrective action such as washing /sanitizing or disposing of the product. Commodity 

specific guidelines offer recommendations regarding the handling of spilled product and 

should be incorporated into the operation’s food safety program. 

WORKER HEALTH AND HYGEINE 

The questions in the General Section portion of the audit related to health and 

hygiene are applicable to the House Packing Facility section of the audit as well. In 

addition, the House Packing Facility has several questions related to worker health and 

hygiene which are specific to these types of operations. 

The operation shall evaluate and develop a hair/beard net policy which is 

appropriate for the facility. Hair nets and beard nets are worn in order to keep stray hair 

from entering the food and food containers being packed. In addition, wearing of 

hairnets when the hair is very long reduces the risk of catching hair in machinery. 

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The operation shall evaluate and develop a jewelry policy. Jewelry can be both a 

physical safety and a food safety hazard. Jewelry may fall into the food item or the 

container or may get caught on machinery and injure the worker. 

The operation shall state the hairnet and jewelry policy in the food safety plan 

even if the policy states that no hairnets or restrictions on jewelry are required. 

CONTAINERS 

Operations should develop policies and procedures outlining only the use of new 

or sanitized containers which are clean and in good condition when packing the product. 

Policies and procedures shall require pallets and packing containers are properly stored 

to reduce the risk of contamination from pests, rodents, dirt, water, etc. Operation shall 

outline a sanitation schedule for reusable plastic containers used to pack product. 

PEST CONTROL 

All packing and storage facilities shall establish a pest control program to reduce 

the risk of contamination by rodents and other animals, including pets. This program 

shall include regular and frequent monitoring to accurately assess the program's 

effectiveness. The pest control program can be either performed by an employee 

trained to perform pest control or a contracted pest control company. 

The operation must maintain a pest control log which records inspection dates, 

inspection reports, and procedures implemented to eliminate pest infestations. If using 

a contracted company, they generally supply the records of activity. All traps and bait 

stations will be marked and flagged by numbers or some type of coding system and 

recorded on a map which shows the location of such bait stations and traps. 

All bait stations containing poison attractants must be located outside the facility. 

Traps or other non-poison methods should be the only control program located within a 

structure. 

STORAGE AND TRANSPORTATION 

This scope covers storage and transportation facilities located on or near crop 

production areas. This would include storage and transportation areas co-located with 

a packinghouse or stand alone storage facilities used on or near farms such as potato 

storage sheds or controlled atmosphere facilities. This scope is not intended for repack 

operations or distribution operations which may custom pack product for retail or 

foodservice customers. These types of operations should use the Part 6 Wholesale 

Distribution Center/Terminal Warehouse section of the USDA GAP&GHP audit. 

The topics of worker health and hygiene, water quality, general sanitation & 

housekeeping and pest control are addressed in the House Packing section of this 

User’s Guide (pages 17-20) and are applicable to this section of the audit as well. 

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MECHANICAL EQUIPMENT 

Any equipment used in the storage facility shall be clean and properly maintained 

to prevent leaking fluids that could potentially contaminate the product. Loose or broken 

parts must be repaired to prevent foreign objects from contaminating the product. Any 

equipment or portions of equipment that directly touches raw product must be 

maintained so as to not contaminate the product. 

ICE AND REFRIGERATION 

The operation shall use water which meets the EPA Drinking Water Standards 

when making ice used for cooling or which comes in contact with the product. Ice or 

cold water (hydro-cooling) is often used by some commodity packers to reduce product 

temperature. The operation shall provide records which verify the source water used to 

make ice meets these requirements, including any ice which is purchased from an 

outside vendor. 

The operation shall develop and implement a procedure for monitoring climate 

controlled rooms for temperature and keeping a record of temperatures. Climate control 

systems must be working and thermometers used in cold storage areas and for 

determining product temperatures should be regularly checked for accuracy and 

operators must maintain records to validate this procedure. 

TRANSPORTATION AND LOADING 

The operation shall develop an SOP which outlines the procedures for inspecting 

transportation conveyances for cleanliness, odors, and debris before the loading with 

product. The SOP should also include policies for not loading produce with potentially 

contaminating products such as raw meat or chemicals and policies to ensure adequate 

transport temperatures and should develop a written policy for transporters and 

conveyances to maintain specified transit temperatures. Records documenting 

adherence to the SOPs shall be maintained. 

WHOLESALE DISTRIBUTION CENTER/ TERMINAL 

WAREHOUSE 

Even though the “Guide to Minimize Microbial Food Safety Hazards for Fresh 

Fruit and Vegetables” is typically applied to farming operations, it is applicable 

throughout the marketing chain. Organizations and personnel within the wholesale 

distribution chain are just as responsible for food safety as organizations and personnel 

at the farm level. Part 6 of the USDA GAP&GHP audit focuses specifically on the 

wholesale end of the food distribution chain, and utilizes many of the same principles 

applied to packinghouses and storage & transportation facilities. 

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RECEIVING 

Operations shall develop a formally approved supplier program for all incoming 

products which includes verification the supplier has undergone a 3rd party GAP&GHP 

audit. 

The operation shall develop an SOP which outlines the procedures to verify 

incoming conveyances are checked for cleanliness, objectionable odors, and other 

potentially contaminating factors prior to accepting a load. The SOP shall also address 

procedures for monitoring the temperature of incoming loads and verify they meet any 

temperature requirements specified on the bill of lading or other requirements. The 

operation shall also have a policy on how to handle loads which do not meet the 

temperature requirements. 

SANITATION PROGRAM/GENERAL HOUSEKEEPING 

Operations with poor sanitation in the packing environment may significantly 

increase the risk of contaminating fresh produce and water used on produce. 

Pathogenic microorganisms may be found on the floors and in the drains in the packing 

facility and on the surfaces of sorting, grading, and packing equipment. Without good 

sanitation practices, any of these surfaces could be a potential source of microbial 

contamination. 

Operations shall employ good sanitation practices as a standard operating 

procedure to maintain control throughout the packing operation. Packing areas should 

be cleaned at the end of each day. As necessary, clean and sanitize the washing, 

grading, sorting, and the packing lines to reduce the potential for microbial 

contamination of fresh produce. The operation shall develop and implement a general 

sanitation schedule which addresses the cleaning and sanitizing of the packinghouse 

operation including: 

• Food contact surfaces 

• Pipes, ducts, fans, and ceilings which are over product flow zones 

• Catwalks over food contact surfaces 

Ice making facilities may be located on the site of the operation or may be 

contracted out and supplied by another operation. In either case, the facility must 

provide records that indicate there is a regular schedule to sanitize the ice production 

and storage facility as well as any means of transportation to reduce the microbial 

population. This would include augers, conveyors and shovels used to transport the ice 

from one part of the facility to another. 

The operation shall use food grade approved lubricants in areas where 

lubricating agents may come into contact with produce. 

The operation shall have a procedure which identifies how product that spilled or 

comes in contact with the floor is handled. Spilled product that comes in contact with 

the floor can become contaminated and should not be used without considering a 

corrective action such as washing/sanitizing or disposing of the product. 

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WATER USE IN PACKING FACILITY 

Source water used in the packing of fresh fruits and vegetables must meet the 

requirements of the EPA Drinking Water Standard. Water used to make ice used in the 

packinghouse must also meet these requirements. 

Municipal water supplies are regulated by law and are required to meet these 

requirements. However, well water and surface water is subject to various 

uncontrollable influences and may or may not meet these requirements. The operation 

must provide documentation verifying the source water meets the EPA Drinking Water 

Standard requirements. 

For commodities which are susceptible to water infiltration such as produce with 

a stem scar, special attention needs to be given to the water temperature in the dump 

tank and flumes vs. the temperature of the product. Research has shown that a 

susceptible commodity which is placed in water colder than the pulp temperature of the 

commodity have a greater chance of internalizing the water and thus carrying any 

contamination into the product. Operations should refer to commodity specific 

recommendations or their state extension food safety specialist for more information 

regarding water infiltration. 

TREATMENT OF PROCESSING WATER 

If applicable to the facility the operation shall verify that water used for processing 

is treated and monitored including: 

• Monitoring of sanitation chemicals used to prevent cross contamination (i.e. 

chlorine and pH). 

• Perform periodic water sampling and microbial testing. 

• Change water as necessary to maintain sanitary conditions. 

• Consider developing SOPs (standard operating procedures or sanitary operating 

plans), including water change schedules. 

• For all processes that use water: clean and sanitize water contact surfaces, such 

as dump tanks, flumes, wash tanks, and hydro coolers, as often as necessary to 

ensure the safety of produce. 

• Install backflow devices and legal air gaps, as needed, to prevent contamination 

of clean water with potentially contaminated water (such as between potable 

water fill lines and dump tank drain lines). 

• Routinely inspect and maintain equipment designed to assist in maintaining 

water quality, such as chlorine injectors, filtration systems, and backflow devices, 

to ensure efficient operation. 

STORAGE FACILITY/TEMPERATURE CONTROL 

The operation shall have procedures in place to verify the refrigeration systems 

are working properly and are monitoring the temperatures of climate controlled rooms. 

The operation must have temperature recording logs available for review. 

Thermometers used in cold storage areas and for determining product temperatures 

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should be regularly checked for accuracy and operators must maintain records to 

validate this procedure. 

CONTAINERS 

Operations should develop policies and procedures outlining only the use of new 

or sanitized containers which are clean and in good condition when packing the product. 

Policies and procedures shall require pallets and packing containers are properly stored 

to reduce the risk of contamination from pests, rodents, dirt, water, etc. Operation shall 

outline a sanitation schedule for reusable plastic containers used to pack product. 

MECHANICAL EQUIPMENT 

Any equipment used in the storage facility shall be clean and properly maintained 

to prevent leaking fluids that could potentially contaminate the product. Also loose or 

broken parts must be repaired to prevent foreign objects from contaminating the 

product. Any equipment or portions of equipment that directly touches raw product 

must be maintained so as to not contaminate the product. 

PREVENTIVE FOOD DEFENSE PROCEDURES 

This section of the USDA GAP&GHP audit covers an operations food defense 

program. Food Defense is the protection of the food supply by intentional

contamination by biological, chemical, or physical means by an aggressor. In contrast, 

the previous sections of the USDA GAP&GHP audit dealt with food safety which is the 

protection of food products from unintentional contamination from biological, chemical, 

or physical means. 

FOOD DEFENSE PLAN 

The operation shall develop and implement a documented food defense plan. 

Similar to a food safety plan, a food defense plan includes a company Food Defense 

Manual, containing the company’s published SOP’s and/or documentation. It will also 

contain information or references pertaining to internal or self audits of the program. 

Other similar documentation may also be applicable and acceptable if it indicates that a 

formally established program is in place. 

The Food Defense plan shall indicate that there is a person in the operation that 

has implemented and will oversee the food defense program. 

PERSONNEL 

Each company should designate a contact person who is responsible for 

overseeing the plan. This person should be the point of contact for employees to point 

out potential security problems or issues. This person can also designate another 

person (for example, a shift supervisor) who can be the contact person for employees. 

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Food defense training shall be provided for all employees and should cover 

potential threats and vulnerabilities of the food supply and how they apply to the 

produce industry. Training should include who employees should contact if they 

observe a potential food defense issue. Records showing training instructions and 

training documents that each employee has signed should be available. 

The food security plan should address access procedures to identify who has 

admittance to sensitive areas of the facility. This includes verifying the identity of 

visitors to the facility and the purpose for the visit. Check in procedures can vary from a 

formal sign in/sign out procedure in enclosed facilities to visitors checking in with the 

owner/manager (or designated person) of a small operation. 

The operation should determine if any staff should have limited access to certain 

areas of the operation. The food security plan should address those jobs and the 

details of how staff will be limited to areas of the operation that are related to their job 

function, and to general access areas (break rooms, locker rooms, etc.). This type of 

scenario usually applies to larger packing house facilities or wholesale warehouses. In 

the case of small operations that only have a limited number of employees who perform 

all functions, this may not apply. Limiting access to packing/storage areas by 

unauthorized personnel is one of the most important procedures that can be 

implemented to reduce the risk of intentional contamination. 

Visitors should be accompanied by an employee. A facility may designate 

exceptions to this for frequent visitors to the facility such as USDA inspectors, health 

department inspectors, the pest control contractor, etc., provided a documented list of 

exempted people is maintained. 

All vehicles should be subject to inspection to look for any obvious sources of 

contamination. Documentation that vehicles entering the facility are being searched or 

that vehicles are subject to search should be available for review. 

A policy should be in place that prohibits workers from bringing personal items 

into the production, handling, or storage areas. This reduces the possibility of an insider 

from contaminating product. Many packing facilities will allow workers to bring water to 

the packing line. This is an acceptable practice as long as the water is supplied by the 

facility and is not brought from outside sources. 

Employees should not be allowed to loiter around the grounds and facility after 

their work hours, especially in sensitive areas of the operation. A work schedule 

outlining employee’s hours and area the employee is assigned to work should be 

available to all management. 

FACILITY PROCEDURES 

The Operation shall develop procedures for the following areas: 

• Procedure for controlling all items which identify a person as an employee of the 

company and requiring those items to be returned to the company upon 

completion of employment. If an employee does not turn over these items, there 

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is a procedure in place for management/security to be notified that the employee 

is not allowed access to the facility. 

• Policy or Procedure to limit access to the company’s computer network so that 

sensitive information is only accessed by authorized personnel. 

• Policy or procedure for verifying the employment eligibility of all new hires in 

accordance with the Immigration and Nationality Act. In addition, the operation 

should outline what level of background checks will be performed. This can be a 

procedure as simple as a reference check, or more detailed such as a credit 

check for financial personnel. Operations that employ farm workers through an 

outside contractor should stipulate in their contract that the contractor perform a 

minimum level of background checks as well. 

• Procedure for scheduled checks of the operation. On a farm, critical areas such 

as the storage barns, pesticide storage areas, and any product storage areas 

should be checked routinely. For packing sheds and wholesale warehouses that 

have a more permanent structure, the entire facility should be routinely checked. 

Including development of a checklist to verify the points of entry into buildings, 

either on the farm or packing house/wholesale warehouse. 

KEY/ENTRANCE ACCOUNTABILITY 

There shall be an accountability log showing who is in possession of any keys to 

enter the facility. Lost keys are documented on the accountability log, and steps are 

taken if keys to sensitive areas such as chemical storage areas are reported lost or 

stolen. These steps may include changing the lock or adding additional security 

measures. 

DELIVERIES 

The operation shall develop a policy which outlines delivery schedules and the 

policy for rejecting loads. The policy should include a list of criteria for why the product 

doesn’t meet specified requirements as well as food safety requirements such as 

evidence of container tampering, evidence of suspicious foreign objects, etc. The 

receiving department/facility shall never accept incoming product that is from an 

unknown source. All deliveries should be listed on the delivery schedule, and only 

deliveries from that schedule should be accepted. The policy should address returned 

product and outline the returned product should be inspected for obvious signs of 

tampering or intentional contamination. 

SEPARATION OF PRODUCTS 

USDA Commodity Procurement purchases require that all domestic products be 

segregated from any foreign product. Additionally, because foreign product has the 

potential to be targeted for intentional contamination and shipped to the United States, it 

should be kept segregated from domestic product. 

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ALLERGENS 

Products that are known allergens, such as peanuts should be segregated for 

several reasons. First to avoid inadvertent cross contamination with other products, and 

secondly to minimize the potential for an insider to simply “reach across the aisle” and 

purposely contaminate other product stored in the same area. 

USDA GAP&GHP PROGRAM AUDIT SCORING 

The USDA GAP&GHP audit utilizes a scoring system. Each question is given a 

score of 5, 10 or 15 points and is weighted depending on the relative risk associated 

with the question. There are no partial points given for any question, each question is 

either given the total points assigned to the question or zero points. 

The USDA GAP&GHP Program requirements state that a minimum of 80% must 

be scored on each scope of the audit conducted in order to “pass” the audit. In addition 

no “automatic unsatisfactory” conditions can be present. 

AUTOMATIC UNSATISFACTORY CONDTION 

In addition to the scoring guideline shown above, there are a set of overarching 

conditions, which if observed, will result in the issuance of an “automatic unsatisfactory” 

score on the audit. These conditions are: 

• An immediate food safety risk is present when produce is grown, processed, 

packed or held under conditions that promote or cause the produce to become 

contaminated. 

• The presence or evidence of rodents, an excessive amount of insects or other 

pests in the production area during packing, processing or storage. 

• Observation of employee practices (personal or hygienic) that jeopardize or may 

jeopardize the safety of the produce. 

• Falsification of records. 

• Answering of Questions P1 or P2 as “NO”. 

Commodity specific audits performed by USDA auditors follow the same general 

guidelines as outlined above for automatic unsatisfactory conditions; however, they may 

refer to them in different terms such as “major deficiency” or “flagrant violation”. Refer 

to the commodity specific audit programs for the policies regarding these conditions. 

In addition, if an immediate food safety risk which results in product 

contamination, the auditor may be required to report the operation to the applicable 

state Public Health Agency or the Food and Drug Administration. 

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POST AUDIT ACTIVITIES 

Once an operation has successfully met the requirements of the USDA 

GAP&GHP program, it will receive a USDA certificate and have their information listed 

on the USDA website. The certificate is good for one year from the date of the initial 

audit, and the operations information will remain on the USDA website for one year 

unless the operation fails an unannounced verification audit. 

APPEALS, COMPLAINTS & DISPUTES 

Operations have the ability to appeal, dispute or lodge a complaint if they so 

desire. Operations with issues regarding an audit or auditor(s), should refer to the 

following list for assistance with the process. 

• APPEAL: A formal complaint contesting the results or findings of the audit 

brought before the Branch by applicants or other parties. 

• COMPLAINT: Discontent or unhappiness about a situation, interpretation, or 

performance of an audit, auditor(s), and/or policy brought before the Branch by 

applicants or other parties. 

• DISPUTE: Disagreement or argument about a situation, interpretation or 

performance of an audit, auditor(s), and/or policy brought before the Branch by 

applicants or other parties. 

If an operation decides to appeal or dispute an audit, there are certain steps 

that must be followed. The formal request for an appeal must be in writing on 

company letterhead from the company or person requesting the appeal. Information 

included in the request should be the date of the audit, location (if different from 

corporate office), sections on the original audit being appealed, and the specific 

item(s) being under dispute. Appeals, complaints and Disputes must be submitted 

to the Fresh Products Branch within three calendar days from the date the audit was 

performed. 

All GAP/GHP audit appeals are performed by the Audit Review Board (ARB), 

who meet as needed to review all GAP&GHP audit appeals. The ARB has the 

authority to sustain or reverse the appeal. The results of the appeal will be provided 

by the ARB to all parties in the appeal process within 14 calendar days. Copies of 

the appeal results become part of the audit record. 

Complaints regarding auditors shall be directed to the auditor’s supervisor. 

Complaints regarding Branch policies and procedures shall be directed to the Audit 

Management Section. 

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Additional Resources 

Establishing, implementing, and maintaining an effective food safety plan 

involves the evaluation of many processes. The USDA GAP&GHP website 

www.ams.usda.gov\gapghp provides links to many resources. State and Federal 

Agencies, University and Cooperative Extension Programs, Trade and Commodity 

Associations offer additional guidance for food safety planning. 

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APPENDIX I – FV-237A AUDIT REQUEST 

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APPENDIX II – FV-651 PARTICIPANT AGREEMENT 

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APPENDIX III – CORRECTIVE ACTION REPORT 

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