Distribution: FM, FPM, HQ, SPM 

Originating Office: Office of the Chief

File Instructions: File in Directive Binder 

 United States Department of Agriculture 

 Agricultural Marketing Service 

 Fruit and Vegetable Programs 

 Fresh Products Branch Directive 

FPB 702

06/08/09 

UNANNOUNCED VERIFICATION REVIEW FOR GOOD 

AGRICULTURAL PRACTICES & GOOD HANDLING PRACTICES 

(GAP&GHP) AUDIT VERIFICATION PROGRAM 

I. Purpose To outline & formalize the policy for conducting unannounced GAP&GHP 

Reviews. 

II. Background Effective October 1, 2007, several changes to the GAP&GHP program were 

announced. The principal change is the inclusion of an unannounced review 

requirement. This requirement is specifically mentioned in Exhibit A of Fresh 

Products Branch (FPB) Directive 625, which the client/auditee signs prior to 

the start of any audits. 

 III. Definitions Initial Audit – The annual announced audit that verifies farm/facilities 

compliance with the requirements of the USDA Voluntary GAP&GHP Audit 

Verification Program. 

Follow-up Audit – The audit conducted if either the farm/facility’s initial or 

unannounced surveillance review does not meet the minimum passing score or 

receives an automatic unsatisfactory. The follow-up audit will measure the 

effectiveness of the corrective actions taken by the company. The follow-up 

audit is a separate review and cannot be used to satisfy the unannounced 

surveillance review requirement. 

Unannounced Surveillance Review – The part of an audit that is conducted at 

some point after the auditee has successfully passed an initial or follow-up 

audit. It is used to verify that a farm/facility is still in conformance with the 

requirements of the USDA GAP&GHP Program and the auditee’s food safety 

plan. The unannounced surveillance review 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 surveillance review will generally verify 

conformance through observation but at times may also require review of 

documentation. Unannounced surveillance reviews shall cover all the scopes 

originally covered on the initial audit except as stated for “Farm Review.” 
FPB 702 

06/08/09 

Page 2 

III. Policy 

In Operation - A farm is considered “in operation" when fruits or vegetables 

are being grown, handled or harvested and activities such as thinning fruit, 

picking, harvesting, or field packing occur. It does not include activities such 

as pruning which occur when the fruits or vegetables are dormant or ground 

preparation such as plowing, discing or planting. A facility is “in operation" 

when any fruit or vegetable handling activity occurs such as sorting, packing, 

repacking, storing or transporting. The number of days in operation shall 

include the day of the initial (or follow-up) audit and all days the farm/facility 

is (or intends to be) in operation during the following twelve-month period. 

Scheduling 

After the auditee has successfully completed the initial audit, or if necessary 

the follow-up audit, the lead auditor shall schedule the unannounced 

surveillance review(s). The lead auditor, with the area supervisor’s approval, 

may alter the scheduled time when there are operational or activity changes in 

the facility or auditing service. The lead auditor shall take into consideration 

how much time remains in the growing season or how long the packing facility 

will be operating when scheduling the unannounced surveillance review(s). 

When the initial audit occurs late in the season, the unannounced surveillance 

review(s) may be scheduled for the following season, although it is highly 

recommended that the unannounced surveillance review(s) be performed in the 

same growing season as the initial audit. Auditors will need to verify the time 

the auditee is in operation by questioning the auditee and reviewing records. 

Unannounced surveillance review(s) can occur anytime as long as there is 

sufficient activity at the farm/facility to audit and may be made at the same 

time the auditor is visiting a farm/facility to perform initial or follow-up 

surveillance review covering other scopes. 

The number of unannounced surveillance review(s) is determined by the length 

of time the farm/facility is in operation following the initial audit for a 

particular scope or part. 

The lead auditor shall use the guidelines listed below to schedule the number 

of unannounced surveillance review(s). If unable to meet these guidelines, the 

Federal Program Manager/Federal Supervisor (FPM/FS) or Audit Program 

Coordinator (APC) shall be consulted for approval of a variation. The number 

of unannounced surveillance review(s) may be increased if the farm/facility is 

certified for various products that use similar production and handling 

procedures when not all the listed products are present at the time of the initial 

or follow-up audit. When water is used in the harvesting, packing or handling 

of any listed products the auditor should schedule at least one (initial audit or 

unannounced surveillance review) to verify the farm’s/facility’s good handling 

practices regarding water use are being met. 
FPB 702 

06/08/09 

Page 3 

Guidelines For Part One - Farm Review of the audit program 

Unless there are multiple commodities grown on the same piece of land during 

the same production season, unannounced surveillance review(s) are not 

required for production areas (gardens, fields or orchards) for Part One of the 

audit. However, an unannounced surveillance review(s) may be performed if 

there is a specific reason to suspect the farm’s food safety program is not in 

compliance with their plan.

 Guidelines For Parts Two through Six 

1. For a farm/facility that is in operation for 30 days or less - A 

farm/facility may be subjected to an unannounced surveillance review 

if there is a specific reason to suspect that their food safety program is 

not in conformance with their plan.

2. For a farm/facility that is in operation from 31 to 90 days - A 

minimum of one (1) unannounced surveillance review shall be 

conducted. In most cases this should be sufficient to verify continued 

conformance with their plan. However, if a company is certifying 

multiple commodities or there is a specific reason to suspect that the 

food safety program is not in conformance, a second unannounced 

review shall be conducted.

3. For a farm/facility that is in operation for greater than 90 days – A 

minimum of two (2) unannounced surveillance reviews shall be 

conducted. In most cases this will be sufficient to verify continued 

conformance to their plan. However, if a company is certifying 

multiple commodities or if there is a specific reason to suspect that the 

food safety program is not in conformance, the third review shall be 

conducted. 

Documentation 

The auditor should use a copy of the original checklist and scoresheet when 

performing an unannounced surveillance review(s). Only the parts (scopes) 

audited in the Initial Audit shall be reviewed during the verification review. 

The auditor may ask to review pertinent company documentation, policies and 

SOP’s, especially those documents needed to substantiate observations. The 

auditor shall observe behavior referred to in the “General” section and other 

appropriate sections and shall make notes in the “comments” area of the 

checklist if points are not awarded. 
FPB 702 

06/08/09 

Page 4 

When a facility passes an unannounced surveillance review, the date shall be 

recorded on the scoresheet and the scoresheet forwarded to the appropriate 

FPM/FS or FPB APC for review. 

If it appears that the company may fail the audit, point values shall be 

determined for all questions. When a farm/facility receives a failing score due 

to total score or an automatic unsatisfactory condition, the auditor must follow 

procedures for documenting nonconformities and corrective actions in 

accordance with FPB policy and instructions for the GAP&GHP Audit 

Verification Program, including notification of the FPM/FS and APC. The 

scoresheet shall be sent through normal channels to the FPB APC. 

The farm/facility shall be removed from the USDA GAP&GHP website until a 

follow-up audit is conducted and the farm/facility receives a passing score. 

When the farm/facility passes the follow-up audit, their information will again 

be posted on the USDA GAP&GHP website. 

Leanne L. Skelton 

Branch Chief