Agricultural Marketing Service, Specialty Crops Program, Specialty Crops Inspection Division

Good Agricultural Practices (GAP) Audit Program Scope

(April 2020)

SCI Division Inspection Series

Page 1 of 4

GOOD AGRICULTURAL PRACTICES (GAP) AUDIT PROGRAM SCOPE

Purpose

This document defines the scope of the U.S. Department of Agriculture (USDA) GAP audit

program, including the types of audit services offered under the USDA GAP audit program, and 

the types of commodities and operations that may be covered under the program. 

USDA GAP Audit Services

USDA GAP audit services include both process and system audits. 

Our process audits are the USDA Good Agricultural Practices and Good Handling Practices 

(GAP&GHP), Produce GAPs Harmonized, Harmonized GAP Plus+, Tomato Food Safety Audit 

Protocol, Mushroom GAP, California Leafy Green Marketing Agreement (LGMA), Arizona 

LGMA, and California Cantaloupe Advisory Board audits. Information about each of these 

programs, including their respective standards, checklists, and other guidance, is posted at: 

www.ams.usda.gov/gapghp. 

The USDA system audit is GroupGAP, which is a certification option for any group of production 

locations and secondary activity locations that agree to operate under a shared quality management 

system and seek certification under one of the USDA GAP audit services. Information about 

GroupGAP is posted at: https://www.ams.usda.gov/services/auditing/groupgap. 

Commodities

Fresh specialty crops may be audited using USDA GAP&GHP, Produce GAPs Harmonized, and 

the Harmonized GAP Plus+ audits.

Section 101 of the Specialty Crops Competitiveness Act of 2004 (7 U.S.C. 1621 note), as amended 

under section 10010 of the Agricultural Act of 2014, Public Law 113-79 (the Farm Bill), defines 

specialty crops as “fruits and vegetables, tree nuts, dried fruits, horticulture, and nursery crops 

(including floriculture).” To be considered a specialty crop, eligible plants must be cultivated or 

managed, and used by people for food, medicinal purposes, and/or aesthetic gratification. USDA’s 

detailed definition of specialty crops (pdf) is posted at: 

https://www.ams.usda.gov/services/grants/scbgp/specialty-crop.
SCI Division Inspection Series GAP Audit Program Scope

Effective Date: April 2020 Page 2 of 4

The following are lists of crops that may be or are not covered by USDA GAP audit services. 

These lists are not exhaustive lists – they are representative of products that have previously been 

requested for audits. To request an audit for crops not covered by the specialty crops definition or 

in the lists below, please contact the USDA Specialty Crops Inspection Division (SCI) Audit 

Services Branch at 202-720-5021 or SCAudits@usda.gov. 

Crops/processes, in addition to those included in under the specialty crop definition, that may be

covered by USDA GAP audit services include:

• Culinary herbs

• Dried beans

• Edamame

• Edible flowers

• Fresh tea leaves

• Harvested maple sap

• Hops

• Microgreens

• Pea tendrils

• Plants

• Tendrils

• Shoots

• Wheat grass

Crops that are not covered by USDA GAP audit services include:

• Algae

• Forage and grain products

• Mint oil and other similarly produced 

oils

• Medicinal herbs

• Sea asparagus

• Seaweed

• Sprouts

Fresh Cut Produce

A USDA GAP&GHP part 6 audit may be used for the storage, transport, and distribution of freshcut produce that is already packed. Fresh specialty crops that are processed into fresh-cut product 

fall under Food and Drug Administration (FDA) regulations for Good Manufacturing Processes 

(GMPs). The USDA Plant Systems Audits (PSA) would be the appropriate audit protocol to use 

for the processing of fresh cut produce. For more information about the PSA audit service, please 

contact the SCI Audit Services Branch at 202-720-5021 or SCAudits@usda.gov.

Mushrooms

The Mushroom GAP, USDA GAP&GHP, and Harmonized audits can be used to audit all species 

of mushrooms grown in enclosed facilities. Wild mushrooms are not covered by USDA GAP 

audit services.

Sprouted Seeds: Sprouts, Shoots, and Microgreens

Sprouted seeds are foods obtained from the germination of seeds, and include sprouts, shoots, and 

microgreens. 

• Sprouts are sprouted seeds obtained from the germination of seeds. They have cotyledons

(or seed leaves) that are un- or under-developed. True leaves have not begun to emerge. 

The final product is intended to be eaten whole, including the seed. Sprouts are not

covered by USDA GAP audit services.
SCI Division Inspection Series GAP Audit Program Scope

Effective Date: April 2020 Page 3 of 4

• Shoots and microgreens are sprouted seeds obtained from germination with true leaves that 

have emerged. The shoots and leaves are “harvested” for use. “Harvested” shoots and 

microgreens do not include the seed teguments or the roots. Shoots and microgreens may 

be sold as an entire plant, but the entire plant is not intended for consumption as roots are 

not consumed. Shoots and microgreens may be covered by USDA GAP audit services.

Types of Operations

Fresh specialty crop production operations may grow, harvest, pack, store/hold, transport, and 

distribute product prior to any processing. Conventional, organic, greenhouse, aeroponic, and 

hydroponic production may be covered by USDA GAP audit services.

U-pick Operations may be covered by USDA GAP audit services.

The following guidance outlines the various USDA audits and the types of the operations for 

which they are applicable: 

Type of Audit Available for: NOT Available for:

USDA Produce 

GAPs Harmonized 

Food Safety

Standard - Post 

Harvest Audit

USDA Harmonized 

GAPs Plus+ - Post 

Harvest Audit

 On-farm packinghouses for 

fresh fruits, vegetables, and 

other specialty crops

 Packinghouses for fresh fruits, 

vegetables, and other specialty 

crops

 Wholesale distribution centers 

and terminal warehouses 

distributing Raw Agricultural 

Commodities (RACs), 

including operations that 

distribute fresh-cut produce 1, 2

 Repack operations1

× Fresh-cut processing 

operations2

× Fresh-cut repack operations2

Type of Audit Available for: NOT Available for:

USDA GAP&GHP 

Audit -Part 6

 Wholesale distribution centers

and terminal warehouses

distributing RACs, including 

operations that distribute freshcut produce2

 Repack operations

× Packinghouses, 

× Fresh-cut processing 

operations2

× Fresh-cut repack operations2

1 These operations are not covered by the scope of recognition for GFSI technical equivalency. 

2 For fresh-cut produce, it is important that only operations that distribute fresh-cut produce are audited using USDA GAP audit services. When 

fresh specialty crops are processed into fresh-cut product, this process falls under the FDA regulation for GMPs. If an auditee would like to be 

audited for the processing of fresh-cut produce, the USDA Plant Systems Audits (PSA) would be the appropriate audit protocol to use (for more 

information about the PSA audit service, please contact Audit Services Branch at 202-720-5021 or SCAudits@usda.gov.
SCI Division Inspection Series GAP Audit Program Scope

Effective Date: April 2020 Page 4 of 4

USDA Harmonized GAP Plus+ Audit Service

The USDA Harmonized GAP Plus+ audit service aligns with the Technical Equivalency 

requirements of the Global Food Safety Initiative’s (GFSI) Benchmarking Requirements Version 

7.1 Part III- B1 Farming of Plants and D, Preprocessing of Plant Products. The scope of GFSI’s 

recognition of the USDA Harmonized GAP Plus+ audit is restricted to the farming of fruits, 

vegetables, and other specialty crop in the United States of America and its territories and 

possessions, and excludes grains and pulses. 

“SCI moving forward in the 21st Century using technology, innovation, and old-fashioned hard work”

Non-Discrimination Policy: In accordance with Federal civil rights law and U.S. Department of 

Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and 

employees, and institutions participating in or administering USDA programs are prohibited from 

discriminating based on race, color, national origin, religion, sex, gender identity (including gender 

expression), sexual orientation, disability, age, marital status, family/parental status, income 

derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil 

rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all 

programs). Remedies and complaint filing deadlines vary by program or incident.

Persons with disabilities who require alternative means of communication for program information 

(e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible 

Agency or USDA's TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA 

through the Federal Relay Service at (800) 877-8339. Additionally, program information may be 

made available in languages other than English.

To file a program discrimination complaint, complete the USDA Program Discrimination 

Complaint Form, AD-3027, found online at How to File a Program Discrimination Complaint and 

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

information requested in the form. To request a copy of the complaint form, call (866) 632-9992. 

Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, 

Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, 

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

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