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Harmonized GAP Plus+ 

Standard

A global market-access solution for the 

specialty crops industry

February 8, 2021
For Official Government Use Only.

The USDA Harmonized GAP Plus+ Standard is based on the Produce GAPs Harmonized Food Safety 

Standard developed by the GAPs Harmonization Initiative. Use of the Harmonized Food Safety 

Standard has been granted by the Secretariat of the GAPs Harmonization Initiative through a nonexclusive copyright license agreement which includes permission to insert additional audit 

requirements beyond those listed in the Harmonized Standard. Additional requirements are 

designated by any requirement number ending in a letter. (i.e. G-1.1a)

This issue of the United States Department of Agriculture’s Harmonized GAP Plus+ Standard

supersedes the previous issue which has been in effect since March 29, 2018.

A summary of changes is available on the AMS website:

https://www.ams.usda.gov/sites/default/files/media/SummaryofChangestotheHarmonizedStandard.pdf

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.
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Harmonized GAP Plus+ Standard

Section Page No.

Introduction................................................................................................................................... 1

Scopes of Audit.............................................................................................................................. 1

Standard Layout ........................................................................................................................... 1

General Questions (G).................................................................................................................. 3

G-1: Management Responsibility .................................................................................................. 3

G-2: Food Safety Plan or Risk Assessment................................................................................... 5

G-3: Documentation & Recordkeeping ......................................................................................... 8

G-4: Worker Education and Training ............................................................................................ 9

G-5: Sampling and Testing .......................................................................................................... 11

G-6: Traceability.......................................................................................................................... 13

G-7: Recall Program .................................................................................................................... 15

G-8: Corrective Actions and Food Safety Incidents.................................................................... 16

G-9: Self-Audits........................................................................................................................... 18

G-10: Worker Health/Hygiene and Toilet/Handwashing Facilities............................................. 19

G-11: Waste Management ........................................................................................................... 27

G-12: Food Defense..................................................................................................................... 28

G-13: Food Fraud......................................................................................................................... 30

Field Operations and Harvesting (F) ........................................................................................ 31

Field Production............................................................................................................................ 31

F-1: Field History and Assessment........................................................................................ 31

F-2: Agricultural Chemicals /Plant Protection Products........................................................ 34

F-3: Water System Description.............................................................................................. 39

F-4: Water System Risk Assessment..................................................................................... 40

F-5: Water Management Plan ................................................................................................ 41

F-6: Animal Control............................................................................................................... 44

F-7: Soil Amendments........................................................................................................... 45

F-8: Vehicles, Equipment, Tools and Utensils...................................................................... 46

Harvesting..................................................................................................................................... 51

F-9: Preharvest Assessment................................................................................................... 51

F-10: Water/Ice Used in the Harvesting and Post-Harvest Operations ................................. 52

F-11: Containers, Bins and Packaging Materials................................................................... 54

F-12: Field Packaging and Handling ..................................................................................... 56

F-13: Post-Harvest Handling and Storage (Field Prior to Storage or Packinghouse)............ 59
iii

F-14: Equipment Sanitation and Maintenance....................................................................... 60

Post-Harvest Operations (P)...................................................................................................... 61

P-1: Produce Sourcing ................................................................................................................. 61

P-2: Agricultural Chemicals ........................................................................................................ 62

P-3: Facility.................................................................................................................................. 64

P-4: Pest and Animal Control ...................................................................................................... 68

P-5: Equipment, Tools and Utensils ............................................................................................ 70

P-6: Maintenance and Sanitation ................................................................................................. 73

P-7: Post-Harvest Water/Ice ........................................................................................................ 79

P-8: Containers, Bins and Packaging........................................................................................... 84

P-9: Storage.................................................................................................................................. 87

P-10: Transportation (Packinghouse to Customer)...................................................................... 91

Logo Use (L) ................................................................................................................................ 93

L-1: Food Safety Plan or Quality Manual.................................................................................... 93

L-2: Traceability and Recall Programs......................................................................................... 94

L-3: Approved Suppliers.............................................................................................................. 95

L-4: GAP & GHP Logo Approved Use....................................................................................... 96

Tomato Audit Protocol Open-field Production and Harvesting ............................................ 97

TOF-1: Management Responsibility............................................................................................ 97

TOF-2: Self Audits ...................................................................................................................... 98

TOF-3: Field History and Pre-harvest Assessments.................................................................... 99

TOF-4: Workers Health/Hygiene and Toilet/Handwashing Facilities ...................................... 101

TOF-5: Pesticides....................................................................................................................... 103

TOF-6: Water Used in Growing Activities................................................................................ 104

TOF-7: Soil Amendments.......................................................................................................... 106

TOF-8: Sanitizing Agents Used During Harvest....................................................................... 107

TOF-9: Product Containers........................................................................................................ 108

TOF-10: Field Packing of Tomatoes......................................................................................... 109

Tomato Audit Protocol Packinghouse .................................................................................... 110

TPH-1 Management Responsibility............................................................................................ 110

TPH-2: Raw Material Sourcing .................................................................................................. 111

TPH-3: Traceability .................................................................................................................... 112

TPH-4: Self Audits ..................................................................................................................... 113

TPH-5: Product Containers and Packaging Materials............................................................... 114

TPH-6: Packinghouse Condition and Equipment...................................................................... 116

A. General Building .......................................................................................................... 116

B. Facility and Equipment ................................................................................................ 117
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TPH-7: Worker Health/Hygiene and Toilet/Handwashing Facilities........................................ 118

TPH-8: Product Wash Water Management ............................................................................... 119

TPH-9: Quarantine or On-hold Materials.................................................................................. 122

TPH-10: Tomato Rerunning Processes...................................................................................... 123

TPH-11: Food Defense Awareness............................................................................................ 124

Tomato Audit Protocol Greenhouse........................................................................................ 125

TGH-1 Management Responsibility........................................................................................... 125

TGH-2: Recordkeeping and Traceability.................................................................................... 126

A. Greenhouse Packing..................................................................................................... 126

B. Packinghouse Packed Greenhouse Tomatoes.............................................................. 127

TGH-3: Self-Audit..................................................................................................................... 128

TGH-4: Greenhouse................................................................................................................... 129

TGH-5: Worker Health/Hygiene and Toilet/Handwashing Facilities....................................... 130

TGH-6: Pesticides...................................................................................................................... 131

TGH-7: Water Used in Growing Activities............................................................................... 132

TGH-8: Soil and Soil Amendments........................................................................................... 134

TGH-9: Sanitizing Agents Used During Harvest ...................................................................... 135

TGH-10: Product Wash Water Management............................................................................. 136

TGH-11: Product Containers and Packaging Materials............................................................. 139

Tomato Audit Protocol Repacking and Distribution ............................................................ 140

TPD-1 Management Responsibility............................................................................................ 140

TPD-2 Raw Material Sourcing ................................................................................................... 141

TPD-3 Traceability ..................................................................................................................... 142

TPD-4: Self Audits ..................................................................................................................... 143

TPD-5: Product Containers and Packaging Materials............................................................... 144

A. Bins, Gondolas, Totes .................................................................................................. 144

B. Primary Packing Boxes................................................................................................ 145

TPD-6: Packinghouse Condition and Equipment...................................................................... 147

A. General Building .......................................................................................................... 147

B. Facility and Equipment ................................................................................................ 148

TPD-7: Worker Health/Hygiene and Toilet/Handwashing Facilities........................................ 149

TPD-8: Product Wash Water Management ............................................................................... 150

TPD-9: Quarantine or On-hold Materials.................................................................................. 153

TPD-10: Food Defense Awareness............................................................................................ 154
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INTRODUCTION

The USDA Harmonized GAP Plus+ Standard is based on the Harmonization Initiative 

Harmonized Food Safety Standards located at: https://www.unitedfresh.org/food-safety/gapharmonization-initiative/. This standard was built on the concepts of risk identification, control 

and mitigation of risks, monitoring, verification, and documentation. These mirror the Codex 

Alimentarius Principles of HACCP (http://www.fao.org/docrep/005/y1579e/y1579e03.htm). 

Requirements of the USDA Harmonized GAP Plus+ Standard reference adherence to “current 

industry practices”, “regulatory requirements”, and “prevailing regulations” – these may include, 

but are not limited to, the Food and Drug Administration Produce and & Plant Products 

Guidance Documents

(https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Pro

ducePlantProducts/ucm187676.htm), the Food Safety Modernization Act (FSMA): Produce 

Safety Rule (https://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334114.htm), Codex 

Alimentarius Recommended International Code of Practice – General Principles of Food 

Hygiene (http://www.fao.org/3/a1552e/a1552e00.htm), and the WHO Guidelines on the Safe 

Use of Wastewater and Excreta in Agriculture

(http://www.who.int/water_sanitation_health/sanitation-waste/wastewater/wastewaterguidelines/en/). Additional requirements are included to align this standard with the Global Food 

Safety Initiative (GFSI) Guidance Document Version 2020, Part III, Scopes of Recognition BIFarming of Plants (other than grains and pulses), and BIII- Pre-Processing Handling of Plant 

Products.

SCOPES OF AUDIT

The Harmonized GAP Plus+ Audit is comprised of four scopes: General Questions, Field 

Operations and Harvesting, Post-Harvest Operations, and Logo Use. The General Questions 

scope is required to be completed for every audit. One or both of the Field Operations and 

Harvesting and/or Post-Harvest Scopes will be completed based on the type of operation being 

audited. The Logo Use scope must be completed for any Operation who intends to use the 

USDA GAP & GHP Logo on packaging or promotional materials. There are four optional 

scopes that are available for operations that produce, harvest, pack, store, distribute or repack 

tomatoes which provide verification of requirements specific to tomato operations. These are: 

Tomato Audit Protocol for Open-field Production and Harvesting, Packinghouse, Greenhouse, 

Repack and Distribution.

STANDARD LAYOUT

The standard has specified columns for the Requirement (Req. # and Requirement Description), 

Documentation (DOC), Mandatory (MAN), Procedure, Verification and Corrective Action.

Requirement: Is a specification of the conditions expected to be met by the auditee.

DOC: The auditing standards require verification of written policies, procedures and plans 

(WP); records (R); and risk assessment (A). To help auditors identify where documents (DOC) 
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are required, the Standard includes a DOC column that designates the type of documentation to 

verify WP, R, A, or a combination of these document types.

• Written Policies, Procedures, and/or Plans (WP) – A policy is high-level guidance that 

describes general goals and acceptable procedures for an organization. A procedure is a 

specified way to carry out an activity or process. A plan outlines actions that will be 

taken by an organization to mitigate risk. Policies, procedures and plans may be 

communicated orally or in writing. They are only required to be written if a WP is 

indicated in the DOC column in this standard. 

• Records (R) – A record is a document stating results achieved or providing evidence of 

activities performed. Records may include checklists, service records, billing forms, and 

water tests.

• Risk Assessment (A) – A risk assessment is a process to identify potential hazards on a 

farm and/or packinghouse as well as the likelihood the hazards will impact the safety of 

fruits and vegetables. Risk assessments should be documented in the manner which best 

represents the operation and the type of risk assessment required. This may include a 

combination of WP and/or R documents.

MAN: A ● in this column indicates a requirement that is mandatory and must either be assessed 

as compliant (C) or not applicable (N/A) in order to meet USDA Acceptance Criteria.

Procedure: Is a more detailed explanation of the conditions expected to be met by the auditee in 

order to meet the requirement.

Verification: Are the conditions verified by the auditor to determine if the auditee meets the 

requirement.

Corrective Actions: Are actions to be taken by the auditee if it is found that they do not meet the 

requirement.
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GENERAL QUESTIONS (G)

G-1: Management Responsibility

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-1.1 A food safety policy 

shall be in place. 

WP ● A written policy shall outline a 

commitment to food safety, in general 

terms, how it is implemented and how 

it is communicated to employees, and 

be signed by Senior Management. 

The auditor observes 

the food safety policy, 

observes that it is 

signed by Senior 

Management, and 

observes that it has 

been communicated to 

all employees in a 

manner that can be 

understood.

The Operation creates 

or revises the policy, or 

its communication to 

employees, to be in 

compliance.

G-1.1.a The food safety 

policy shall include 

measurable

objectives for 

meeting the safety 

needs of products.

WP A written policy shall include 

measurable objectives, each of which is 

defined and includes a plan to achieve 

it. The plan must include the timeline 

in which the objective will be 

accomplished, who is responsible for 

ensuring it is accomplished, and how 

the progress of completion will be 

documented and verified.

The auditor observes 

that the food safety 

policy contains 

measurable objectives 

and that the Operation 

is progressing toward 

their completion.

The Operation adds or 

revises its measurable 

objectives.

G-1.2 Management has 

designated 

individual(s) with 

roles, responsibilities 

and resources for 

food safety functions.

WP ● The Food Safety Plan shall designate 

who has the responsibility and 

authority for food safety, including a 

provision for the absence of key 

personnel. Twenty-four hour contact 

information shall be available for these 

individuals in case of food safety 

emergencies. These roles and 

responsibilities shall be communicated 

within the organization.

Auditor observes that 

the Food Safety Plan 

has identified 

individual(s) for key 

food safety activities. 

Auditor verifies that 

procedures include 

provisions for when 

the identified 

individual is not 

present.

Operation identifies 

individual(s) for key 

food safety activities in 

the Food Safety Plan. 

Operation identifies 

actions to be taken 

when the identified 

individual(s) are not 

present.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-1.2.a The Food Safety Plan 

outlines an 

organizational 

structure for at least 

those staff whose 

activities affect food 

safety. 

WP The Food Safety Plan defines and 

documents the job functions and 

responsibilities related to on farm 

activities of at least those staff whose 

activities affect food safety.

Auditor observes 

documentation of job 

functions and 

responsibilities related 

to on farm food safety 

activities.

The Operation creates 

or revises the 

documentation of job 

functions and 

responsibilities related 

to on farm food safety

activities.

G-1.3 There is a 

disciplinary policy 

for food safety 

violations.

There shall be a policy that establishes 

corrective actions for personnel who 

violate established food safety policies 

or procedures.

Auditor observes the 

policy and checks for 

examples of 

enforcement.

The Operation creates 

or revises the policy, or 

its communication to 

employees, to be in 

compliance.
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G-2: Food Safety Plan or Risk Assessment

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-2.1 There shall be a 

written Food Safety 

Plan. The plan shall 

cover the Operation. 

The Operation and 

products covered 

shall be defined.

WP ● The Food Safety Plan shall identify all 

locations of Operation covered by the 

plan and shall identify physical, 

chemical, and biological hazards 

reasonably likely to occur and hazard 

control procedures, including 

monitoring, verification and 

recordkeeping, for all provisions 

covered by this audit.

Auditor shall observe 

the Food Safety Plan 

and verify that the plan

has considered 

potential biological, 

chemical and physical 

hazards and has 

identified preventive 

controls for hazards 

that may reasonably 

affect food safety.

Operation develops or 

completes a Food 

Safety Plan for all 

locations of Operation.

G-2.2 The Food Safety Plan 

shall be reviewed at 

least annually.

R Operation shall be responsible for 

reviewing their Food Safety Plan at 

least annually, documenting the review 

procedure and revising the plan as 

necessary. Updated or revised on date 

shall be indicated.

Auditor reviews last 

Food Safety Plan 

review.

Operation reviews 

Food Safety Plan and 

documents review.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-2.2.a The Food Safety Plan 

shall be reviewed in 

the event of any 

change which may 

affect food safety.

R ● The documented Food Safety Plan 

review shall include evidence of 

management’s commitment to 

establish, implement, maintain, and 

continuously improve food safety and 

the organization’s food safety culture. 

Elements of a food safety culture 

include but are not limited to 

communication about food safety 

policies and responsibilities, training, 

Employee feedback on food safety 

related issues and performance 

measurement. Additionally, it shall 

ensure access to necessary resources to 

implement plan, including suitably 

qualified personnel. The plan must 

include a review of all supplier 

specifications. An Operation should be 

continuously reviewing their Food 

Safety Plan to identify any potential 

improvements.

Auditor shall review 

documentation for 

Food Safety Plan 

review in the event of 

any change which may 

affect food safety.

Operation conducts a 

review of the Food 

Safety Plan in the 

event of any change 

which may affect food 

safety, and provides 

documentation.

G-2.3 Operation has an 

Approved Supplier 

program for all 

incoming materials, 

including packaging.

R ● Operation has and maintains a current 

list of approved raw material suppliers

and service providers relevant to food 

safety. Approved Supplier program 

includes a procedure for accepting 

materials from alternate sources.

Auditor verifies a list 

of raw material 

suppliers is maintained 

and current. Auditor 

verifies that all 

materials received 

from alternate sources 

has followed 

established procedure.

Operation develops an 

Approved Supplier 

program and maintains 

current list. Operation 

develops a procedure 

for accepting materials 

from alternate sources. 

Operation ceases 

accepting or shipping 

materials from noncompliant suppliers.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-2.3.a Approved supplier 

program contains 

written procedures 

for the evaluation, 

approval, and 

continued monitoring 

of suppliers.

WP The Operation shall document the 

procedures for evaluation approval, and 

continued monitoring of suppliers. 

Results of evaluations, investigations, 

and follow up actions shall be recorded 

for each supplier.

Auditor verifies 

documentation for 

procedures for 

evaluation, approval, 

and continued 

monitoring of suppliers 

as well as records 

documenting these 

activities.

Operation develops 

procedure and/or 

records for the 

evaluation, approval 

and continued 

monitoring of 

suppliers.

G-2.3.b The Operation’s 

Approved Supplier 

program includes 

procedures for 

approving 

contractors.

R The Operation’s program includes the 

approval of any contractors and food 

safety related services utilized by the 

Operation to ensure that all 

specifications are met. The program 

includes a procedure for accepting 

services from alternate sources.

Auditor verifies that a 

list of contractors is 

maintained and 

current. Auditor 

verifies that any 

services received from 

alternate sources has 

followed established 

procedure.

Operation develops an 

Approved Supplier 

program and maintains 

current list. Operation 

develops a procedure 

for accepting services 

from alternate sources. 

Operation ceases 

utilizing services from 

non-compliant 

suppliers or 

contractors.

G-2.3.c Outsourced processes 

must be identified, 

documented, and 

monitored.

R Outsourced processes (i.e. pest control, 

sanitation unit maintenance, harvest 

crews, etc.) must be identified, 

documented, and monitored.

Auditor verifies that 

outsourced processes 

are documented and 

monitored. 

Operation identifies, 

documents and 

monitors outsourced 

processes.
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G-3: Documentation & Recordkeeping

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-3.1 Documentation shall 

be kept that 

demonstrates the 

food safety plan is 

being followed.

R ● Documents and records of procedures, 

standard operating procedures (SOPs) 

and policies shall be in place for 

meeting each of the food safety 

standards identified in the Food Safety 

Plan. Records comply with prevailing 

regulations.

Auditor reviews Food 

Safety Plan and 

verifies that all 

required 

documentation is

available.

Operation develops 

missing documentation 

or recordkeeping 

procedures.

G-3.2 Documentation shall 

be readily available 

for inspection.

● Documents and records may be 

maintained on-site or at an off-site 

location, or accessible electronically, 

and shall be available for inspection in 

a reasonable timeframe or as required 

by prevailing regulation. Records shall 

be protected to prevent unauthorized 

access or potential falsification.

Auditor verifies that 

required 

documentation can be 

accessed in a 

reasonable timeframe.

Operation defines in 

food safety plan where 

and how 

documentation is 

maintained and 

expected retrieval time.

G-3.3 Documentation shall 

be retained for a 

minimum period of 

two years, or as 

required by 

prevailing regulation.

R ● Document and record handling policy 

or procedures require that 

documentation required by the food 

safety plan shall be retained for a 

minimum of two years, or as required 

by prevailing regulation.

Auditor reviews 

document handling 

procedures and verifies 

that required 

documentation is 

available for at least 

two years, or as 

required by prevailing 

regulation.

Operation revises 

documentation 

procedures.

G-3.3.a Food Safety Plan 

documentation and 

records shall be 

securely stored and 

effectively 

controlled.

The Food Safety Plan, documentation, 

and any records required to 

demonstrate the implementation of 

food safety are securely stored and 

effectively controlled.

Auditor verifies that 

documentation and 

records are securely 

stored and effectively 

controlled.

Operation stores their 

documentation and 

records in a secure 

location and 

implements effective 

controls for these 

records.
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G-4: Worker Education and Training

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-4.1 All personnel shall 

receive food safety 

training, appropriate 

to their job 

responsibilities.

R ● All personnel shall receive training in 

the food safety policy and plan, food 

safety procedures, sanitation and 

personal hygiene appropriate to their 

job responsibilities. Personnel shall 

receive training at hire and refresher 

training at prescribed frequencies, and 

as needed. Documentation of training 

is available.

Auditor reviews 

program of required 

training and examines 

training records for 

evidence of 

compliance. 

Operation shall 

develop and deliver 

required training.

G-4.2 Personnel with 

supervisory food 

safety responsibilities 

shall receive training 

sufficient to their 

responsibilities.

● The individual designated for food 

safety responsibilities demonstrates 

knowledge of food safety principles. 

Food safety designate has completed at 

least one adequate food safety 

course/workshop, by job experience or 

as required by prevailing regulation.

Auditor reviews the 

evidence of the 

individual’s training 

relevant to produce 

food safety, such as a 

degree or course 

certificate or receipt, or 

attendance at a relevant 

food safety meeting, 

company training 

record, and/or auditor 

interview.

Individual must obtain 

demonstrable food 

safety training.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-4.3 Contracted personnel 

are held to the 

relevant food safety 

standards as they 

would be as 

employees.

R ● Operation shall have procedures and/or 

records to demonstrate that contracted 

personnel whose activities can affect 

food safety have been informed of and, 

to the extent that can be verified, are in 

compliance with the relevant 

requirements of this standard.

Auditor reviews 

Operation’s evidence 

that contracted 

personnel are trained to 

the same food safety 

requirements as 

employees would be 

and, if practical during 

the audit, observes 

contracted personnel 

for compliance.

Operation obtains 

evidence, trains or 

discontinues using 

contracted personnel.
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G-5: Sampling and Testing

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-5.1 Where laboratory 

analysis is required in 

the Food Safety Plan, 

testing shall be 

performed by a GLP 

laboratory using 

validated methods.

R Operation utilizes laboratories that 

have, at minimum, passed a Good 

Laboratory Practices (GLP) audit or 

participates in a Proficiency Testing 

program, and utilizes BAM, AOAC 

International or testing methods that 

have been validated for detecting or 

quantifying the target organism(s) or 

chemical(s).

Auditor reviews 

Operation’s evidence 

that only GLP 

laboratories and 

validated methods are 

used.

Operation discontinues 

using non-GLP 

laboratory and nonvalidated testing 

methods.

G-5.2 Where 

microbiological 

analysis is required in 

the Food Safety Plan, 

samples shall be 

collected in 

accordance with an 

established sampling 

procedure and 

prevailing 

regulations. 

WP Operation utilizes a written sampling 

protocol when collecting samples for

microbiological testing. 

Auditor observes that 

the Operation has a 

sampling protocol for 

each type of 

microbiological testing 

required in the 

Operation’s food safety 

plan.

Operation develops or 

obtains written 

sampling protocols for 

each type of 

microbiological testing 

required in their Food 

Safety Plan.

G-5.3 Testing, tests, results 

and actions taken 

must be documented.

R All results for microbiological testing,

including lab reports or certificates of 

analysis, required in the Operation’s 

food safety plan shall be recorded and 

the records maintained for two years or 

as required by prevailing regulation.

Auditor reviews 

Operation’s 

recordkeeping of 

microbiological test 

results.

Operation maintains 

for at least two years 

test records for all 

required 

microbiological tests.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-5.4 All required testing 

shall include test 

procedures and 

actions to be taken 

based on the results.

WP ● For all microbiological testing required 

by the food safety plan, Operation has 

a written testing procedure that 

includes test frequency, sampling, test 

procedures, responsibilities and actions 

to be taken based on results. If finished 

product is tested for pathogens or other 

adulterants, Operation’s procedures 

require that it shall not be distributed 

outside the Operation’s control until 

test results are obtained.

Auditor reviews the 

Operation’s 

microbiological testing 

procedures for 

completeness.

Operation revises 

testing procedures for 

completeness and to 

meet expectations of 

the food safety plan.
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G-6: Traceability

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-6.1 A documented 

traceability program 

shall be established.

WP,

R

● Records that enable reconciliation of 

product delivered to recipients (one 

step forward) shall be maintained 

except for direct to consumer sales. 

Records shall be maintained that link 

product with source of the produce or 

production inputs, e.g., soil 

amendments, fertilizers, 

seeds/transplants, agricultural 

chemicals, homemade preparations 

(one step backward). Records shall 

include the date of harvest, quantities, 

farm identification (field or block), 

transporter and non-transporter. 

Additional information may be 

included. Contents and retention of 

records shall be consistent with 

applicable regulations. If using 

reusable containers, procedures ensure 

that labels are accurate prior to 

packing.

Auditor reviews 

traceability program 

and verifies 

Operation’s ability to 

trace product 

accurately one step 

forward and one step 

back.

Operation establishes 

an effective traceability 

program.

G-6.1.a Packaging must 

include product 

identification.

Operation must include product 

identification on all packaging. The 

product identification at a minimum 

must include the name and address of 

the farm, packer, or distributor of the 

produce and meet the requirements of 

the prevailing regulation.

Auditor reviews the 

product identification 

on all packaging.

Operation establishes 

product identification 

on all packaging.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-6.1.b If product is intended 

for export, product 

meets labeling 

regulations of the 

country(ies) the 

product is being 

exported to. 

Product shall be labeled according to 

the applicable regulations in the 

country(ies) in which the product is 

intended to be sold, if known during 

production.

Auditor reviews 

Operation’s procedure 

for ensuring adherence 

to food labeling 

regulations in 

country(ies) of 

destination. If the 

country of destination 

is unknown during 

production, this item is 

not applicable.

Operation develops 

procedures, and diverts 

non-compliant product 

to a market in which 

the product meets 

standards.

G-6.2 A trace back and 

trace forward 

exercise shall be 

performed at least 

annually.

R The trace back and trace forward 

exercise shall achieve accurate 

traceability within 4 hrs. or as required 

by applicable regulations. Trace 

exercise shall achieve 100% 

reconciliation of product to recipients.

Auditor reviews 

records of most recent 

trace exercise. If no 

trace exercise was 

performed in the past 

year, the Operation 

will perform the 

exercise during the 

audit.

Operation performs 

exercise and/or 

improves traceability 

program to achieve 

accurate reconciliation.
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G-7: Recall Program

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-7.1 A documented recall 

program, including 

written procedures, 

shall be established.

WP,

R

● The recall program shall have a 

designated recall team. A mock recall 

exercise shall be performed at least 

annually at the Operation being 

audited. The mock recall shall include 

the trace back and trace forward 

exercise and shall be completed as 

stated in the program and in 

compliance to applicable regulations.

Auditor reviews 

records of most recent 

mock recall performed 

at the Operation.

Operation develops 

recall team, recall plan, 

and tests the plan for 

effectiveness.
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G-8: Corrective Actions and Food Safety Incidents

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-8.1 The Operation shall 

have documented 

corrective action 

procedures.

WP,

R

● A documented Corrective Action is 

required for an observation or audit 

that contains a non-conformance with 

food safety requirements. The 

responsibility, methods, and timelines 

to address Corrective Actions shall be 

documented and implemented.

Auditor reviews 

corrective action 

procedures and 

examines records for 

evidence of 

compliance. 

Operation develops 

and implements 

corrective actions 

procedures.

G-8.1.a Corrective action 

procedures shall 

include a procedure 

to evaluate 

complaints.

WP For the purpose of preventing 

recurrence, there shall be a documented 

corrective action procedure to evaluate 

food safety related complaints, and to 

investigate non-conformities. It shall 

include a plan to address the issue; a 

plan to prevent recurrence; and 

demonstration of the evidence of 

effectiveness. The time frame 

necessary for corrective action shall be 

documented. Objective evidence shall 

demonstrate that the procedure is 

effective.

Auditor shall verify the 

Operation has a 

procedure to evaluate 

complaints.

The Operation shall 

develop a procedure 

for evaluating 

complaints.

G-8.1.b Food safety incidents 

are recorded and 

assessed to determine 

severity and risk, and 

are addressed 

according to a 

documented food 

safety incident 

management 

procedure.

R A food safety incident management 

procedure shall be in place. Relevant 

staff shall be aware of their obligations 

in case of an incident. Incidents which 

could lead to unsafe or non-conforming 

product are recorded and assessed in a 

timely manner to establish their 

severity and consumer risk. Corrective 

actions are taken and documented.

Auditor verifies 

Operation has a food 

safety incident 

management 

procedure, that food 

safety incidents are 

recorded and assessed, 

and risk is addressed 

by the Operation 

accordingly.

A food safety incident 

management 

mechanism will be 

implemented. Staff is 

trained to record and 

assess the severity of 

risk and to respond 

accordingly.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-8.1.c The documented 

incident management 

procedure is 

reviewed, tested and 

verified at least once 

a year.

WP,

R

An annual review is conducted of the 

overall documented incident 

management procedure, including a 

review of records and corrective 

actions related to any food safety 

incidents that occurred. If there has 

been no food safety incident in the 

previous year, a mock incident 

management exercise has been 

conducted by the Operation to test the 

existing system. Any identified 

deficiencies in the incident 

management system have been 

corrected.

Auditors verify that the 

Operation has 

conducted an annual 

review of the 

Operation’s incident 

management 

procedure. Auditor 

will verify records.

Operation implements 

an incident 

management review 

procedure which is 

tested and verified 

annually. Training of 

personnel responsible 

for implementing the 

incident management 

procedure may need to 

occur.

G-8.2 Non-conforming 

product on hold for 

food safety is clearly 

identified and 

segregated from other 

products and 

packaging materials.

WP, 

R

● Operation has a written procedure to 

clearly identify and segregate on-hold, 

quarantined, and rejected product and 

materials when held for food safety 

reasons, to prevent commingling with 

other products or adulteration of 

products, production area, or packaging 

materials.

Auditor reviews 

procedure, reviews 

logs and observes all 

currently on-hold, 

quarantined, and 

rejected materials for 

compliance with 

procedure.

Non-compliances are 

corrected on site. If 

on-hold, quarantined or 

rejected materials are 

not segregated 

according to 

procedure, operation 

shall assess potential 

for product 

adulteration. 

Procedures are 

developed or revised. 

Retraining is 

performed.
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G-9: Self-Audits

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-9.1 The Operation shall 

have documented 

self-audit procedures.

R Internal audits will be conducted at a 

minimum annually by an assigned 

individual utilizing this standard to 

assist in the self-audit. All aspects of 

the Operation’s food safety plan will be 

audited and a written record of required 

corrective action will be documented.

Auditor reviews 

internal audit 

procedures and 

examines records for 

evidence of 

compliance. 

Operation develops 

and implements 

internal audit 

procedures.
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G-10: Worker Health/Hygiene and Toilet/Handwashing Facilities

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.1 Operation shall have 

a policy for toilet, 

handwashing, 

hygiene, and health.

WP ● Each Operation shall establish written 

policies for their specific operations, 

which shall be in compliance with 

prevailing regulations for Worker 

Health and Hygiene Practices.

Auditor ensures that 

policies for toilet, 

handwashing, hygiene 

and health exist.

Operation develops 

written policies 

covering toilets, 

handwashing, hygiene 

and health.

G-10.2 Employees and 

visitors shall be made 

aware of and follow 

all personal hygiene 

practices as 

designated by the 

Operation.

● Operation’s hygiene policies shall 

apply to all employees, contractors, 

visitors, buyers, product inspectors, 

auditors, and other personnel in the 

field. The Operation shall designate 

competent supervisory personnel to 

ensure compliance by all workers, 

visitors, and field personnel with the 

requirements in this section.

Auditor observes 

personnel in field for 

evidence of 

compliance. Auditor 

notes whether s/he was 

informed of the policy.

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

G-10.3 Toilet facilities and 

restrooms shall be 

designed, 

constructed, and 

located in a manner 

that minimizes the 

potential risk for 

product 

contamination and 

are directly 

accessible for 

servicing.

● Toilet and handwashing facilities are 

situated during operation and servicing, 

and maintained so as not to pose a 

hazard to the produce or other 

opportunity for contamination. 

Restrooms are located away from 

produce handling areas whenever 

possible. If in a building, restrooms 

should not open directly into product 

handling areas. Those that do open 

directly into produce handling areas 

should have additional measures in 

place to mitigate risk, such as a selfclosing mechanism, a maze-type 

entrance/exit, or distance.

Auditor visually 

verifies that toilet and 

handwashing facilities 

are not positioned, 

leaking or serviced in a 

manner that poses a 

risk of produce 

contamination.

Toilet or handwashing 

facility is replaced, 

repaired or 

repositioned to be 

compliant.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.4 Toilet facilities shall 

be of adequate 

number, easily 

accessible to 

employees and 

visitors and in 

compliance with 

applicable 

regulations.

● The Operation will have verification 

that the number of toilet facilities and 

their location relative to employees 

meets the more stringent of federal, 

state or local regulations. 

Auditor verifies that 

the number of 

available toilet 

facilities and their 

location is compliant 

with prevailing 

regulation for the 

number of employees.

Operation obtains a 

sufficient number of 

toilet facilities to be 

compliant.

G-10.5 The practice of 

disposing of used 

toilet tissue on the 

floor, in trash 

receptacles, or in 

boxes is prohibited

except in situations 

where waste systems 

are not capable of 

handling toilet paper.

● Operation shall instruct employees that 

used toilet tissue shall only be disposed 

of in the toilet. If toilet paper cannot be 

disposed of in the toilet, the use of 

toilet paper disposal containers is 

acceptable. Containers must be used 

only for toilet paper or other hygiene 

products and must be distinguishable 

from towel waste containers. 

Operation shall develop SOPs for the 

sanitary disposal of waste, ensuring 

adequate monitoring and cleaning 

frequencies to prevent unsanitary 

conditions.

Auditor observes 

restrooms for evidence 

of compliance.

Auditor observes 

evidence or existence 

of toilet paper disposal, 

if applicable.

Retraining is 

performed and 

documented. 
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.6 Toilet and wash 

stations shall be 

maintained in a clean 

and sanitary 

condition. 

R ● Toilet paper shall be available in toilet 

facility. Wash stations shall include 

hand wash facilities with water that 

meets the microbial standard for 

drinking water, hand soap, disposable 

towels or other hand drying device, 

towel disposal container, and a tank 

that captures used hand wash water for 

disposal. These stations shall be 

provided inside or adjacent to toilet 

facilities, and any location where 

product handling is taking place. If 

portable hand wash water tanks are 

used, they are cleaned and sanitized at 

a prescribed frequency and the water is 

changed at prescribed frequencies 

adequate to prevent unsanitary 

conditions. Restrooms shall include 

hand wash facilities with water that 

meets the microbial standard for 

drinking water, hand soap, disposable 

towels or other hand drying device, and 

towel disposal container. Gray water is 

plumbed or captured for disposal.

Auditor observes toilet 

and handwashing 

facilities for 

compliance. Auditor 

observes checklist or 

other evidence of a 

documented system for 

tracking cleaning of 

toilets and wash 

stations.

Toilet or handwashing 

facility is replaced, 

repaired or maintained 

to be compliant.

G-10.7 A response plan is in 

place for major spills 

or leaks of field 

sanitation units.

WP A written response plan is developed 

and implemented in the event of a 

major leak or spill.

Auditor verifies 

existence of the plan 

and interviews the 

responsible individual 

for knowledge.

Operation prepares or 

edits the plan or 

receives plan from 

contractors of 

sanitation units. The 

responsible individual 

is retrained.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.8 Personnel shall wash 

their hands at any 

time when their 

hands may be a 

source of 

contamination.

● Personnel shall wash their hands prior 

to start of work, after each visit to a 

toilet, after using a handkerchief/tissue, 

after handling contaminated material, 

after smoking, eating or drinking, after 

breaks and prior to returning to work, 

after touching animals or waste and at 

any other time when their hands may 

have become a source of 

contamination. Antiseptic hand rubs 

may not be used as a substitute for soap 

(or other effective surfactant) and 

water. Operation management 

reinforces importance of and 

compliance with handwashing policy.

Auditor observes 

personnel for evidence 

of compliance. If 

handwashing practices 

are observed to be 

compliant, auditor will 

judge management 

emphasis to be 

sufficient.

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

G-10.9 Signage requiring 

handwashing is 

posted.

Signage in applicable languages and/or 

pictures shall be provided adjacent to 

hand wash facilities requiring people to 

wash their hands after each toilet visit.

Auditor verifies that 

signage is present 

adjacent to all hand 

wash facilities and is in 

appropriate language 

or pictures to clearly 

communicate 

requirements to all 

employees.

Operation obtains and 

posts signage to be 

compliant.

G-10.10 Clothing, including 

footwear, shall be 

effectively 

maintained and worn 

so as to protect 

product from risk of 

contamination.

● Operation shall have a policy that 

employee clothing shall be clean at the 

start of the day and appropriate for the 

Operation. Clothing shall be replaced 

if it becomes reasonably likely to serve 

as a source of contamination of product 

or food contact surfaces.

Auditor reviews policy 

and observes 

compliance with 

Operation’s policy.

Operation develops or 

revises clothing policy. 

Retraining is 

performed and 

documented. 
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.11 If gloves are used, 

the Operation shall 

have a glove use 

policy.

● If rubber, disposable, cloth or other 

gloves are used in contact with product, 

the Operation shall have a glove use 

policy that specifies how and when 

gloves are to be used, cleaned, replaced 

and stored. Hands must be washed 

before putting on gloves. Policy shall 

be in compliance with current industry 

practices or regulatory requirements for 

that commodity.

If gloves are used, 

auditor observes glove 

use for compliance 

with the Operation’s 

policy and current 

industry practices or 

regulatory 

requirements. 

Operation develops or 

revises glove policy. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

G-10.12 If protective outer 

garments are worn in 

product handling 

areas, they shall be 

handled in a manner 

to protect against 

contamination.

When appropriate, 

racks and/or storage 

containers or 

designated storage 

area for protective 

clothing and tools 

used by employees 

shall be provided.

When employees wear protective outer 

garments, such as aprons and sleeves, 

the operation shall have a policy that 

employees shall wear suitable outer 

garments, not reasonably likely to 

serve as a source of contamination of 

product or food contact surfaces. The 

clothing shall not be left on product, 

work surfaces, equipment or packaging 

material but hung on racks or in 

designated areas. When appropriate, 

racks shall be available and located so 

as to avoid potential contamination. In 

addition, storage containers or 

designated storage areas shall be 

provided to ensure tools used by 

employees are properly stored prior to 

entering toilet facilities. Operation 

shall have a policy regarding whether 

protective clothing can be taken home.

If protective clothing is 

used, auditor observes 

use for compliance 

with the Operation’s 

policy and current 

industry practices or 

regulatory 

requirements. Auditor 

observes whether 

storage areas are 

designated, available 

and used.

Operation develops or 

revises protective 

clothing policy or 

procedures. Operation 

obtains and positions 

racks and storage 

containers as 

necessary. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.13 The wearing of 

jewelry, body 

piercings and other 

loose objects (e.g. 

false nails) shall be in 

compliance to 

company policy and 

applicable regulation.

Operation shall have a policy that 

personal effects such as jewelry, 

watches or other items shall not be 

worn or brought into fresh fruit and 

vegetable production areas if they pose 

a threat to the safety and suitability of 

the food. Policy shall be in compliance 

with current industry practices or 

regulatory requirements for that 

commodity. 

Auditor observes 

personnel in field for 

evidence of 

compliance.

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

G-10.14 The use of hair 

coverings shall be in 

compliance to 

company policy and 

applicable regulation.

The Operation shall have a policy that 

addresses use of hair coverings (e.g., 

hair nets, beard nets, caps), which is in 

compliance with prevailing regulation.

Auditor reviews the 

Operation’s policy and 

observes employees for 

compliance. 

Operation develops 

policy. Retraining is 

performed.

G-10.15 Employees’ personal 

belongings shall be 

stored in designated 

areas.

Operation shall have a policy for when 

and how employee’s personal 

belongings shall be stored so as not to 

be a source of product contamination. 

Auditor observes 

personnel in field for 

evidence of 

compliance.

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

G-10.16 Smoking, chewing, 

eating, drinking 

(other than water), 

chewing gum, 

spitting, urinating, 

defecating, and using

tobacco, shall be 

prohibited except in 

clearly designated 

areas.

● Operation shall have policy prohibiting 

smoking, eating, spitting, chewing gum 

or tobacco, or drinking (other than 

water) except in designated areas. 

Such areas shall be designated so as not 

to provide a source of contamination. 

Operation shall have policy prohibiting 

spitting, urinating or defecating in any 

production area.

Auditor observes 

personnel for evidence 

of compliance.

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.17 Operation shall have 

a written policy that 

break areas are 

located so as not to 

be a source of 

product 

contamination.

WP Break areas shall be designated and 

located away from food 

contact/handling zones and production 

equipment.

Auditor observes break 

areas for evidence of 

compliance with 

Operation policy.

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

G-10.18 Drinking water shall 

be available to all 

employees. 

R Drinking water, which meets drinking 

water standards, shall be easily 

accessible to field personnel and in 

compliance with applicable regulation. 

Bottled water or potable drinking water 

stations with single-use cups and a 

trash receptacle shall be available to all 

employees. 

Auditor observes 

evidence of drinking 

water accessibility and 

Operation’s evidence 

that water supplied to 

personnel meets 

drinking water 

standards. 

Operation makes 

drinking water 

available to employees, 

in compliance with 

prevailing regulation.

G-10.19 Workers and visitors 

who show signs of 

illness shall be 

excluded from direct 

contact with produce 

or food-contact 

surfaces.

WP ● Operation shall have a policy that 

restricts employees, contractors, 

visitors, buyers, product inspectors, 

auditors, and other personnel in the 

Operation who show signs of illness 

(e.g., vomiting, jaundice, diarrhea) 

from contact with product or food 

contact surfaces. Policy shall require 

that any person so affected 

immediately report illness or symptoms 

of illness to the management.

Auditor reviews policy 

and observes field 

personnel for evidence 

of compliance.

Operation develops 

and implements policy. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

G-10.20 Personnel with 

exposed cuts, sores or 

lesions shall not be 

engaged in handling 

product. 

● Minor cuts or abrasions on exposed 

parts of the body are acceptable if 

covered with a non-permeable 

covering, bandage or glove. Bandages 

on hands shall be covered with gloves 

in compliance with Operation’s glove 

policy.

Auditor observes 

personnel in field for 

evidence of 

compliance.

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.21 Operation shall have 

a blood and bodily 

fluids policy.

WP ● There shall be a written policy 

specifying the procedures for the 

handling/disposition of food or product 

contact surfaces that have been in 

contact with blood or other bodily 

fluids.

Auditor reviews policy 

and observes Operation 

for evidence of 

compliance.

Operation develops 

and implements policy. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

G-10.22 First aid kits shall be 

accessible to all 

personnel.

The kits shall be readily available in 

the vicinity of field work in the 

Operation and maintained in 

accordance with prevailing regulation. 

The kit materials shall be kept in a 

sanitary and usable condition.

Auditor observes that 

provisions exist for 

first aid kit to be 

readily available in 

vicinity of workers and 

is stocked in 

accordance with 

prevailing regulation.

Operation obtains and 

stocks a first aid kit 

and ensures it is readily 

accessible near field 

personnel.
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G-11: Waste Management

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-11.1 Operation has 

implemented a waste 

management plan.

Operation implements procedures for 

the control, storage and disposal of 

trash, litter, and waste in areas used for 

produce handling activities. Such 

procedures minimize the potential for 

trash, litter, or waste to attract or harbor 

pests and protect against contamination 

of produce, food contact surfaces, areas 

used for produce handling activities, 

water sources, and water distribution 

systems. Waste treatment and disposal 

systems operate so that they do not 

constitute a potential source of 

contamination in produce handling 

areas.

Auditor verifies the 

Operation has 

implemented a waste 

management plan.

Operation implements 

a waste management 

plan.

G-11.2 Trash shall not come 

in contact with 

produce.

● Trash handling and removal shall not 

pose a hazard of contamination of 

produce.

Auditor reviews trash 

handling procedures 

for field operation and

observes trash handling 

practices for evidence 

of compliance.

Operation revises 

procedures. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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G-12: Food Defense

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-12.1 Operation shall 

assess the potential 

for unauthorized 

access to growing 

and/or packing areas 

and its impact on 

food safety.

A ● Operation shall demonstrate an 

awareness of site security and, if 

deemed necessary for food safety, take 

reasonable measures to minimize the 

potential for unauthorized access to 

growing and/or packing areas.

Auditor interviews the 

responsible individual 

for awareness of site 

security, and security 

measures, if applicable.

Security assessment is 

performed.

G-12.2 Operation shall 

develop an 

emergency response 

plan.

WP, 

R

A response plan is in place in the event 

of a security event potentially 

impacting food safety. Action taken to 

reduce risk to product shall be 

documented by means of an incident 

report or other record of response.

Auditor interviews the 

responsible individual 

for knowledge of the 

emergency response 

plan and, if applicable, 

reviews incident 

response records.

Emergency response 

plan is developed.

G-12.3.a Initially and at least 

annually thereafter, 

the Operation shall 

evaluate and 

document the risks 

associated with 

security (food 

defense), including 

unintentional security 

risks.

A ● A review or new assessment shall be 

conducted seasonally and any time 

there is a change made to the system or 

a situation occurs that provides the 

opportunity for the intentional or 

unintentional introduction of a hazard. 

The risk assessment shall address 

potential physical, chemical, and 

biological hazards. 

Auditor reviews the 

risk assessment for 

completeness of 

consideration of 

potential hazards.

Operation develops or 

updates the risk 

assessment.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-12.3.b There shall be a 

written food defense 

plan to mitigate risks 

identified in the food 

defense risk 

assessment. 

WP, 

R

The food defense plan shall include the 

following: preventive controls, 

monitoring and verification procedures, 

corrective actions, and documentation. 

The plan shall be reviewed following 

any changes made to the food defense 

risk assessment and adjusted 

accordingly to incorporate such 

changes. Evidence of management 

commitment to the food defense plan 

shall be documented. Training and/or 

retraining of personnel having 

oversight or performance duties shall 

be documented.

Auditor reviews the 

food defense plan for 

accuracy and 

completeness relative 

to the risk assessment.

Operation develops or 

updates the food 

defense plan.
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G-13: Food Fraud

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-13.1.a The Operation shall 

initially and at least 

annually thereafter, 

evaluate and 

document the risks 

associated with food 

fraud.

A ● A review or new assessment shall be 

conducted seasonally and any time 

there is a change made to the system or 

a situation occurs that could provide an 

opportunity for the misrepresentation 

of product. 

Auditor reviews the 

risk assessment for 

completeness of 

consideration of 

potential hazards.

Operation develops or 

updates the risk 

assessment.

G-13.1.b There shall be a 

written food fraud 

plan to mitigate risks 

identified in the food 

fraud risk 

assessment. 

WP, 

R

The food fraud plan shall include the 

following: preventive controls, 

monitoring and verification procedures, 

corrective actions, and documentation. 

The plan shall be reviewed following 

any changes made to the food fraud 

risk assessment and adjusted 

accordingly to incorporate such 

changes. Evidence of management 

commitment to the food defense plan 

shall be documented. Training and/or 

retraining of personnel having 

oversight or performance duties shall 

be documented.

Auditor reviews the 

food fraud plan for 

accuracy and 

completeness relative 

to the risk assessment.

Operation develops or 

updates the food fraud 

plan.
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FIELD OPERATIONS AND HARVESTING (F)

Field Production

F-1: Field History and Assessment

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-1.1 The food safety plan 

shall, initially and at 

least annually 

thereafter, evaluate 

and document the 

risks associated with 

land use history and 

adjacent land use 

including equipment 

and structures.

A ● When land use history or adjacent land 

use indicates a possibility of physical, 

chemical or biological contamination, 

preventive controls shall be performed 

and documented to mitigate food safety 

risk. The assessment is re-performed, 

and documented, at least annually and 

upon significant events, for 

environmental conditions or risk 

awareness that has changed since the 

last assessment. The assessment shall 

address flooding and shall include 

indoor growing facilities and structures 

such as green houses and hydroponics.

Auditor reviews food 

safety plan to verify 

that risks associated 

with field history, 

adjacent land use and 

indoor growing 

facilities have been 

evaluated at least 

annually and 

preventive controls 

implemented for 

identified risks.

Operation evaluates 

and documents risks 

associated with land 

use history, adjacent 

land use, indoor

growing facilities and 

implements preventive 

controls for identified 

risks.

F-1.1.a Operation has 

performed and 

documented a risk 

assessment of each 

production area prior 

to the harvest of that 

location.

A ● A system shall be established to 

maintain the record of agricultural 

activities undertaken at each 

production unit and records shall be 

available to demonstrate that sites (on 

farm and adjacent sites) have been 

evaluated with regards to potential 

food safety hazards.

Auditors verify the 

Operation has 

performed and 

documented a risk 

assessment of each 

production area.

The Operation shall 

perform and document 

a risk assessment for 

each production area. 

Training of appropriate 

personnel may need to 

take place on 

conducting and 

recording this 

assessment.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-1.1.b Operation has 

identified control 

measures for all 

significant hazards 

identified during risk 

assessment.

WP ● Workers shall be trained on what the 

food safety hazards are and how to 

manage them. There shall be 

responsibilities assigned to maintain 

records on the food safety hazards and 

their management.

Auditor verifies that 

control measures for 

all significant hazards 

identified during the 

risk assessment are 

implemented.

Operation trains 

workers on the 

maintenance of the 

food safety hazards 

identified and how to 

manage and record the 

management of these 

hazards.

F-1.2 For indoor growing 

and field storage 

buildings, building 

shall be constructed 

and maintained in a 

manner that prevents 

contamination of 

produce. 

● Building and equipment structures and 

surfaces (floors, walls, ceilings, doors, 

frames, hatches, etc.) shall be 

constructed in a manner that facilitates 

cleaning and sanitation and does not 

serve as harborage for contaminants or 

pests. Chill and cold storage loading 

dock areas shall be appropriately 

sealed, drained and graded. Fixtures, 

ducts, pipes and overhead structures 

shall be installed and maintained so 

that drips and condensation do not 

contaminate produce, raw materials or 

food contact surfaces. Water from 

refrigeration drip pans shall be drained 

and disposed of away from product and 

product contact surfaces. Drip pans and 

drains shall be designed to assure 

condensate does not become a source 

of contamination. Air intakes shall not 

be located near potential sources of 

contamination.

Auditor observes 

building and 

equipment for 

evidence that the 

building can be 

cleaned and 

maintained to prevent 

product contamination. 

Building deficiencies 

are corrected. 

Affected product is 

evaluated for potential

contamination and 

disposition.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-1.3 Sewage or septic 

systems are 

maintained so as not 

to be a source of 

contamination.

● After a significant event (such as 

flooding or an earthquake) that could 

negatively impact a sewage or septic 

system, Operation takes appropriate 

steps to ensure that sewage and septic 

systems continue to operate in a 

manner that does not contaminate 

produce, food contact surfaces, areas 

used for produce handling, water 

sources, or water distribution systems.

If a significant event 

has occurred, Auditor 

reviews steps taken by 

Operation to verify 

sewage or septic 

system is not a source 

of contamination. 

Sewage or septic 

systems deficiencies 

are corrected. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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F-2: Agricultural Chemicals /Plant Protection Products

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-2.a The Operation has a 

current list of 

agricultural 

chemicals that are 

used and approved 

for the crops being 

grown.

R An agricultural chemical list is 

available for the commercial brand 

names and active ingredient 

composition or beneficial organisms of 

agricultural chemicals (including postharvest chemicals such as biocides, 

waxes and plant protection products), 

that are approved for crops being 

grown within the scope of the audit for 

the last 12 months.

Auditor shall verify the 

Operation’s list of 

agricultural chemicals 

that are used and 

approved for the crop 

being grown and for 

crops grown within the 

scope of the audit for 

the last twelve months.

Operation will keep a 

list of agricultural 

chemicals used and 

approved.

F-2.1 Use of agricultural 

chemicals shall 

comply with label 

directions and 

prevailing regulation.

R ● Agricultural chemicals, including postharvest chemicals such as biocides, 

waxes and plant protection products, 

must be registered for such use as 

required by prevailing regulation, and 

used in accordance with label 

directions including application rates, 

worker protection standards, personal 

protection equipment, container 

disposal, storage, and all requirements 

specified for the chemical or 

compound. Chemicals that are not 

registered pesticides may be permitted 

for food contact use if allowed under 

regulations of the prevailing agency.

Records of chemical agricultural use 

are maintained, and include crop date 

and location of application, chemical 

used, application rate and method, and 

preharvest interval.

Auditor reviews 

agricultural chemical 

use records for 

evidence of 

compliance with 

approved uses or label 

directions.

Operation develops 

and maintains 

agricultural chemical 

use records and 

maintains evidence of 

proper use of each 

chemical use. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-2.1.a Agricultural chemical 

records include the 

target organism(s) 

and justification for 

application.

R The name of the pest(s), disease(s) 

and/or weed(s) treated and justification 

for the application is documented in all 

agricultural chemical application 

records.

Auditors shall verify 

the Operation’s records 

for agricultural 

chemicals used for 

target organism(s) and 

justification for 

application.

Operation will keep 

agricultural chemical 

records which include 

the target organism(s) 

and justification for 

application. 

F-2.1.b Records of 

agricultural 

chemicals include the 

identity of the 

harvested crop, 

location, application 

dates, harvest dates,

treatment, product 

name, and dose rate.

R Records of agricultural chemical 

applications shall be available and 

include: crop type and/or variety, 

location, application date, harvest 

dates, dose rate (a.i./ha), application 

rate (l/ha), product trade name, active 

ingredient and method of application.

Auditors shall verify 

that records for postharvest biocides, 

waxes and plant 

protection products 

include the harvested 

crop, location, 

application dates,

harvest dates

treatment, product 

names, and dose rate.

Auditors shall verify 

that the dates 

demonstrate 

compliance with the 

labeled pre-harvest 

interval, if applicable.

Operation shall include 

the harvested crop, 

location, application 

dates, harvest dates, 

treatment, product 

name, and dose rate of 

post-harvest biocides, 

waxes and plant 

protection products in 

their records.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-2.1.c Use of biological 

controls shall comply 

with label directions 

and prevailing 

regulation.

R Only biological controls which are 

authorized for the cultivation of the 

specific crop will be used. Any 

biological control will be used 

according to the manufacturer’s 

direction.

Auditor reviews 

biological controls use 

records for evidence of 

compliance with 

approved uses or label 

directions.

Operation develops 

and maintains 

biological controls use 

records and maintains 

evidence of proper use 

of each biological 

control. Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

F-2.1.d Operation keeps 

records of 

agricultural chemical 

applications used on 

nursery stock, 

transplants and other 

propagation material 

produced on site. 

R Records shall be available of the use of 

agricultural chemicals on propagation 

materials

Auditor shall verify 

Operation’s records of 

agricultural chemical 

applications on 

propagation materials.

Operation keeps 

complete records of 

agricultural chemical 

applications on 

propagation materials.

F-2.2 If product is intended 

for export, 

agricultural chemical 

use, including postharvest chemicals, 

shall consider 

requirements in the 

intended country of 

destination.

The Operation shall have procedures, 

such as pre-harvest interval and 

application rate, sufficient to meet the 

MRL entry requirements of the 

country(ies) in which the product is 

intended to be traded, if known during 

production.

Auditor reviews 

Operation’s procedure 

for complying with 

agricultural chemical 

restrictions in countries 

of destination. If the 

country of destination 

is unknown during 

production, this item is 

not applicable.

Operation develops 

procedures, and diverts 

non-compliant product 

to a market in which 

the product meets 

standards.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-2.3 Agricultural 

chemicals shall be 

applied by trained, 

licensed or certified 

application 

personnel, as 

required by 

prevailing regulation.

R Operation maintains records 

demonstrating that all personnel 

responsible for chemical applications 

are trained and/or licensed, or 

supervised by licensed personnel, in 

compliance with prevailing regulation.

Auditor reviews 

records demonstrating 

that application 

personnel are licensed 

and/or trained in 

compliance with 

prevailing regulation.

Operation utilizes 

application personnel 

who are appropriately 

licensed and/or trained.

F-2.3.a Operator 

demonstrates 

knowledge of 

preparing and 

calculating 

agricultural chemical 

mixes. 

The responsible person must be able to 

calculate and prepare the required 

application mix according to the label 

instructions and to prevent over or 

under application.

Auditors shall verify 

agricultural chemical 

mixes are calculated 

properly. Responsible 

person(s) for applying 

agricultural chemicals 

should be interviewed.

Retraining of 

responsible persons 

may be needed. 

F-2.4 Water used with 

agricultural 

chemicals shall not 

be a potential source 

of product or field 

contamination.

R Water used to dilute or deliver 

agricultural chemicals shall be from a 

source in compliance with the Water 

System Risk Assessment and Water 

Management Plan, consistent with 

current industry practices or regulatory 

requirements for that commodity.

Auditor reviews the 

Water System Risk 

Assessment for 

evidence that water 

used with agricultural 

chemicals has been 

considered, and that 

agricultural chemical 

use policies are in 

compliance with the 

Water System Risk 

Assessment.

Operation revises the 

Water System Risk 

Assessment. 

Operation uses a water 

source in compliance 

with the Water System 

Risk Assessment. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-2.4.a Equipment used to 

apply agricultural 

chemicals shall be 

kept in good 

condition and 

calibrated annually to 

ensure accurate 

application. 

R The agricultural chemical application 

machinery has been verified for correct 

operation within the last 12 months and 

this is certified or documented either 

by participation in an official scheme 

(where it exists) or by having been 

carried out by appropriately trained 

and/or licensed (where required) 

personnel. 

Auditors shall verify 

the Operation’s records 

have been maintained 

within the last 12 

months to ensure 

accurate application of 

agricultural chemicals. 

Observation should be 

made that application 

equipment is in good 

condition if maintained 

by the Operation.

Equipment used for 

application of 

agricultural chemicals 

will be brought to a 

level of good condition 

and records of its 

annual maintenance 

will be maintained by 

the Operation.

F-2.5 Agricultural chemical 

disposal shall not be 

a source of product 

or field 

contamination.

R Operation shall have procedures for 

disposal of waste agricultural 

chemicals and for cleaning of 

application equipment that protects 

against contamination of product and 

growing areas.

Auditor reviews 

procedures and 

observes chemical 

handling records for 

evidence of 

compliance.

Operation develops 

and implements 

procedures. Steps are 

taken to mitigate any 

contamination events.

F-2.5.a Agricultural 

chemicals approved 

for use on the crops 

being grown are 

stored separately 

from agricultural 

chemicals used for 

other purposes.

R Only the agricultural chemicals 

currently in the approved agricultural 

chemicals list are kept in the storage 

area. Agricultural chemicals used for 

purposes other than application on 

crops within the rotation for the last 12 

months are clearly identified and stored 

separately within the chemical storage 

area.

Auditors shall verify 

that only chemicals 

approved for use on 

crops being grown by 

the Operation are 

stored in a designated 

storage area.

Operation will 

establish a designated 

storage for approved 

agricultural chemicals 

for use on the crops 

being grown separated 

from agricultural 

chemicals used for 

other purposes.
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F-3: Water System Description

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-3.1 A water system 

description shall be 

available for review.

WP ● Water sources and the production 

blocks they may serve shall be 

documented and current. The 

description shall include one or more 

of the following: maps, photographs, 

drawings (hand drawings are 

acceptable) or other means to 

communicate the location of water 

source(s), permanent fixtures and the 

flow of the water system (including 

holding systems, reservoirs or any 

water captured for re-use). Permanent 

fixtures include wells, gates, reservoirs, 

valves, returns and other above ground 

features that make up a complete 

irrigation system shall be documented 

in such a manner as to enable location 

in the field or in hydroponic, aeroponic 

or aquaponics operations.

Auditor reviews water 

system description or 

map, and verifies 

accuracy during 

inspection. 

Operation develops or 

corrects the water 

system description or 

map.

F-3.2 The water source 

shall be in 

compliance with 

prevailing 

regulations.

Water shall be sourced from a location 

and in a manner that is compliant with 

prevailing regulations.

Auditor determines 

whether the water 

source is compliant 

with regulations 

relevant for the 

intended use of the 

water.

Operation discontinues 

use of the source until 

compliant with 

regulations. Affected 

produce is evaluated 

for potential 

contamination and 

disposition.

F-3.3 Water systems shall 

not be crossconnected with 

human or animal 

waste systems.

● Water systems intended to convey 

untreated human or animal waste shall 

be separated from conveyances utilized 

to deliver water.

Auditor reviews water 

system for crossconnections with 

human or animal waste 

conveyances.

Operation discontinues 

use of the system until 

they are separated. 
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F-4: Water System Risk Assessment

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-4.1 An initial risk 

assessment shall be 

performed and 

documented that 

takes into 

consideration the 

historical testing 

results of the water 

source, the 

characteristics of the 

crop, the stage of the 

crop, and the method 

of application.

A ● A review or new assessment shall be 

conducted seasonally and any time 

there is a change made to the system or 

a situation occurs that could introduce 

an opportunity to contaminate the 

system. The risk assessment shall 

address potential physical, chemical, 

and biological hazards and hazard 

control procedures for the water 

distribution system.

Auditor reviews the 

risk assessment for 

completeness of 

consideration of 

potential hazards.

Operation develops or 

updates the risk 

assessment.
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F-5: Water Management Plan

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-5.1 There shall be a 

water management 

plan to mitigate risks 

associated with the 

water system on an 

ongoing basis. 

WP ● The water management plan shall 

include the following: preventive 

controls, monitoring and verification 

procedures, corrective actions, and 

documentation. The plan shall be 

reviewed following any changes made 

to the water system risk assessment 

and adjusted accordingly to incorporate 

such changes. Training and/or 

retraining of personnel having 

oversight or performance duties shall 

be documented.

Auditor reviews the 

water management 

plan for accuracy and 

completeness relative 

to the risk assessment.

Operation develops or 

updates the water 

management plan.

F-5.2 Water testing shall be 

part of the water 

management plan, as 

directed by the water 

risk assessment and 

current industry 

standards or 

prevailing regulations 

for the commodities 

being grown.

WP ● As required, there shall be a written 

procedure for water testing during the 

production and harvest season, which 

includes frequency of sampling, who is 

taking the samples, where sample is 

taken, how the sample is collected, 

type of test and acceptance criteria. If 

all water is sourced from a municipal 

source, the municipal testing shall 

suffice. The frequency of testing and 

point of water sampling shall be 

determined based on the risk 

assessment and current industry 

standards or prevailing regulations for 

commodities being produced.

Auditor verifies that a 

water testing program 

is in compliance with 

the risk assessment and 

current industry

standards or prevailing 

regulations and is 

included in the water 

management plan. 

Operation develops a 

testing program 

consistent with risks 

identified in the risk 

assessment and with 

current industry 

standards or prevailing 

regulations for the 

commodities being 

produced. 
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-5.3 The testing program 

shall be implemented 

consistent with the 

water management 

plan. 

R ● Testing shall be performed and 

documented according to procedures 

described in the water management 

plan. 

Auditor reviews testing 

records for compliance 

with the written plan.

Operation shall revise 

testing to be in 

compliance with the 

written plan. The

corrective actions 

noted in the water 

management plan shall 

be followed until the 

conditions have been 

mitigated and the nonconformity has been 

resolved.

F-5.4 If water is treated to 

meet microbiological 

criteria, the treatment 

is approved and 

effective for its 

intended use, and is 

appropriately 

monitored.

R ● Treatment is approved for its intended 

use (e.g., EPA-registered antimicrobial 

pesticide, or registration as required by 

the prevailing regulation of the country 

of use) and is delivered in a manner to 

ensure that the treated water is 

consistently safe and of adequate 

sanitary quality for its intended use 

and/or consistently meets the relevant 

microbial quality criteria. Treatment is 

monitored at a frequency adequate to 

ensure that the treated water is 

consistently safe and of adequate 

sanitary quality for its intended use 

and/or consistently meets the relevant 

microbial quality criteria.

Auditor verifies that 

water treatment is 

approved for its 

intended use, reviews 

documentation that it 

is used effectively to 

meet the intended 

microbiological 

criteria, and reviews 

monitoring records for 

compliance with the 

Operation’s 

established procedure 

and acceptance 

criteria.

Operation discontinues 

use of unapproved 

treatments, uses 

approved treatments in 

an effective manner, 

and monitors the 

treatment at an 

adequate frequency.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-5.5 If post-harvest 

handling is used to 

achieve microbial 

criteria, Operation 

has documentation 

supporting its use.

R ● If die-off or removal rates or other 

methods (e.g., commercial washing) 

are used to achieve microbial criteria 

of water used during growing, 

Operation has scientific data or 

information used to support its 

effectiveness. Documentation includes 

the specific time interval or log 

reduction applied, how the time 

interval or log reduction was 

determined, and the dates of 

corresponding activities such as the 

dates of last irrigation and harvest, the 

dates of harvest and end of storage, 

and/or the dates of activities such as 

commercial washing.

Auditor verifies 

documentation for 

completeness.

Operation obtains 

documentation on, or 

discontinues use of, 

unsupported methods, 

uses approved methods 

in an effective manner, 

and maintains required 

documentation.

F-5.6 If Operation uses an 

alternative approach 

to regulatory 

microbiological 

testing, Operation has 

scientific data or 

information to 

support the 

alternative.

R ● If Operation uses an alternative testing 

method, frequency or criteria to 

regulatory requirements, Operation has 

documentation supporting the 

alternative.

Auditor verifies 

documentation for 

completeness.

Operation obtains 

documentation on, or 

discontinues use of, the 

alternative.
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F-6: Animal Control

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-6.1 The Operation has a 

written risk 

assessment on animal 

activity in and around 

the production area.

A ● There shall be a written assessment of 

the growing fields and adjacent land, 

prior to each growing season, focusing 

on domestic and wild animal activity 

including grazing and feeding 

operations, noting crop characteristics, 

type and approximate number of 

animals, proximity to the growing 

field, water sources, and other relevant 

factors. 

Auditor reviews the 

written assessment to 

ensure it has been 

performed for this 

season and is 

complete.

Operation performs 

and documents the 

assessment.

F-6.2 The Operation 

routinely monitors 

for animal activity in 

and around the 

growing area during 

the growing season.

R There shall be scheduled monitoring of 

growing fields and adjacent land for 

evidence of animal activity. A 

frequency of monitoring and 

assessment shall be established based 

on production factors, such as the crop, 

geography, and other conditions.

Auditor reviews 

monitoring records to 

ensure the frequency 

of monitoring is 

consistent with the 

schedule.

Operation develops 

and implements a 

monitoring schedule.

F-6.3 Based on the risk 

assessment, there 

shall be measures to 

prevent or minimize 

the potential for 

contamination from 

animals, including 

domesticated animals 

used in farming 

operations. 

WP,

R

● The Operation shall have riskappropriate actions to prevent or

minimize the potential for 

contamination of produce with 

pathogens from animal feces, including 

from domesticated animals used in 

farming operations. There shall be a 

written record of any mitigation or 

corrective actions. Preventive 

measures and corrective actions shall 

comply with all local, state and federal 

regulations concerning animal control 

and natural resource conservation.

Auditor reviews 

preventive measures 

and corrective action 

plans.

Operation develops 

and implements riskappropriate corrective 

actions for animal 

intrusions reasonably 

likely to contaminate 

produce in the field.
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F-7: Soil Amendments

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-7.1 The food safety plan 

shall address soil 

amendment risk, 

preparation, use, and 

storage. 

A,

R

● If animal-based soil amendments or 

biosolids are used, records of 

composition, dates of treatment, 

methods utilized and application dates 

must be documented. Evidence of 

processing adequate to eliminate 

pathogens of human concern, such as 

letter of guarantee, certificate of 

analysis (COA) or any test results or 

verification data (e.g., time and 

temperature) demonstrating 

compliance with process or microbial 

standards, shall be documented. Such 

soil amendments must be produced, 

handled, stored and applied in 

accordance with applicable federal, 

state, or local regulations. 

Auditor reviews soil 

amendment records for 

completeness and 

evidence of 

compliance with 

prevailing regulations. 

If biosolids are used, it 

shall be noted.

Operation discontinues 

use of untreated, 

partially treated or 

undocumented animalbased soil amendments 

or biosolids. Operation 

develops and 

implements policies to 

obtain treatment 

information for all 

animal-based soil 

amendments. 

F-7.2 If a soil amendment 

containing raw or 

incompletely treated 

manure is used, it 

shall be used in a 

manner so as not to 

serve as a source of 

contamination of 

produce.

R ● If such a product is used, there shall be 

documentation of the composition, and 

time and method of application. Such 

use will be consistent with current 

industry practices or regulatory 

restrictions for that commodity. 

Untreated human waste shall not be 

used.

Auditor reviews 

records for any soil 

amendment use that 

may contain raw or 

incompletely treated 

manure.

Operation discontinues 

use, or develops and 

implements policies to 

safely use animalbased soil amendments 

that may contain raw 

or incompletely treated 

manure. Produce 

grown without such 

controls are either 

diverted to thermalprocessed products or 

destroyed.
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F-8: Vehicles, Equipment, Tools and Utensils

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-8.1 Equipment, vehicles, 

tools utensils and 

other items or 

materials used in 

farming operations 

that may contact 

produce are 

identified.

R Operation maintains a list of 

equipment, vehicles, tools, utensils and 

other items or materials that may pose 

a risk of produce contamination during 

normal use.

Auditor reviews the 

list for completeness.

Operation develops a 

list of equipment, 

vehicles, tools and 

utensils that may pose 

a risk of produce 

contamination during 

normal use.

F-8.2 Equipment, vehicles, 

tools and utensils 

used in farming 

operations which 

come into contact 

with product are in 

good repair, and are 

not a source of 

contamination of 

produce.

WP,

R

The Operation shall develop, 

implement, and schedule repair, 

cleaning, sanitizing, storage and 

handling procedures of all food contact 

surfaces to reduce and control the 

potential for contamination. Records 

must include the date and method of 

cleaning and sanitizing equipment. As 

necessary for food safety, vehicles and 

equipment shall be properly calibrated, 

operated, maintained, and used as 

intended. Equipment traffic flow is 

prevented from traveling through an 

untreated manure area into the 

harvesting field. These procedures 

shall be documented. Product contact 

tools, utensils and equipment shall be 

made of materials that can be cleaned 

and sanitized. Procedures include 

equipment and vehicles that are in the 

field infrequently. 

Auditor observes 

production and harvest 

vehicles, equipment, 

tools and utensils 

which may come into 

contact with produce 

for evidence of food 

safety risks. Auditor 

reviews maintenance, 

cleaning and sanitation 

records that 

demonstrate 

compliance with 

procedures.

Operation develops 

maintenance, cleaning 

and sanitation 

procedures for 

equipment, vehicles, 

tools and utensils that 

may pose a risk for 

produce 

contamination. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-8.2.a All equipment and 

instruments which 

have an effect on 

food safety shall be 

identified, adequately 

maintained and 

calibrated at a 

frequency sufficient 

to assure continuous 

accuracy.

R ● The Operation shall have a list of 

equipment and instruments that have 

an effect on food safety (e.g. 

thermometers, pH meters, scales, 

chemical application or monitoring 

devices). This equipment shall be 

adequately maintained and calibrated 

at a frequency sufficient to assure 

continuous accuracy. A record of 

calibration shall be maintained.

Auditor reviews 

equipment and 

instrument list and 

calibration records.

Operation develops a 

list of equipment and 

instruments. 

Calibration will be 

performed and 

recorded.

F-8.2.b Calibration of 

equipment is 

traceable to a 

recognized standard.

WP Calibration of measuring and 

monitoring equipment (thermometers, 

pH meters, scales, chemical application 

or monitoring devices) is performed 

using a recognized standard or method.

Auditor reviews the 

calibration procedures 

to determine if they 

follow a recognized 

standard or method.

Operation develops 

calibration procedures 

which are traceable to 

a recognized standard 

or method.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-8.2.c A cleaning and 

sanitation program 

for food contact 

surfaces shall be 

established, 

implemented and 

maintained. The 

program shall include 

measures for 

monitoring to verify

effectiveness.

WP, 

R

An implemented cleaning and 

sanitation program shall be established, 

including SOPs. Procedures must 

include frequency, approved cleaning 

and sanitizing agents, and methods of 

cleaning and sanitizing chemical use.

The SOP must justify the frequency of 

cleaning, demonstrate that the cleaning 

and sanitizing methods are effective on 

the surfaces that they are used on, are 

being used at appropriate 

concentrations as required by the label. 

Operation shall demonstrate 

effectiveness in minimizing the 

potential for cross contamination from

cleaning and sanitizing. Records of 

sanitizer chemical concentrations shall 

be maintained.

Auditor reviews the 

cleaning and sanitation 

program procedures 

and records for 

inclusiveness of 

frequency approval 

and proper use of 

cleaning and sanitizing 

agents, and methods of 

cleaning and sanitizing 

agent use. Auditor

reviews chemical 

records regarding use 

of approved chemicals 

used for cleaning and 

sanitizing.

Operation develops 

and implements

program procedures

for cleaning and 

sanitation. Operation 

identifies chemicals 

approved-for-use in the 

cleaning and sanitation 

program and 

establishes and 

maintains records of 

all cleaning and 

sanitizer 

concentrations. 

Retraining of cleaning 

and sanitation program 

policies and 

procedures are 

performed and 

documented.

F-8.3 Vehicles, equipment, 

tools and utensils 

shall be controlled so 

as not to be a source 

of chemical hazards.

WP Operation shall have a written 

procedure to address the spills and 

leaks (fuel, oil, hydraulic fluids) which 

might occur during equipment 

operation in the field.

Auditor observes 

production and harvest 

vehicles, equipment, 

tools and utensils 

which may come into 

contact with produce 

for evidence of food 

safety risks. 

Operation repairs leaks 

and cleans any food 

contact surfaces. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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F-8.4 Vehicles, equipment, 

tools and utensils 

shall be controlled so 

as not to be a source 

of physical hazards.

Operation has a glass and brittle plastic 

policy that addresses glass on 

production equipment and in growing 

area. Inspections performed in 

compliance with the policy shall be 

documented.

Auditor observes 

production and harvest 

vehicles, equipment, 

tools and utensils 

which may come into 

contact with produce 

for evidence of food 

safety risks and for 

compliance with the 

glass and brittle plastic 

policy.

Operation develops 

policy. Retraining is 

performed. Source of 

food safety risk is 

mitigated.

F-8.5 Cleaning and 

sanitizing procedures 

do not pose a risk of 

product 

contamination.

Equipment cleaning and sanitizing 

operations shall be conducted away 

from the product and other equipment 

to reduce the potential for 

contamination. Water used for 

cleaning and sanitizing shall meet the 

microbial standards for drinking water.

Auditor reviews 

cleaning and sanitizing 

procedures for steps to 

prevent contamination 

of produce, and 

observes Operation’s 

evidence of 

compliance.

Operation develops 

and implements 

procedures. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

F-8.6 Water tanks are 

cleaned at a sufficient 

frequency so as not 

to be a source of 

contamination.

WP ● There shall be a written procedure for 

cleaning water tanks, such as those 

used for dust control, the water from 

which may contact produce in the field.

Auditor reviews water 

tank cleaning 

procedures for steps to 

prevent contamination 

of produce, and 

observes Operation’s 

evidence of 

compliance.

Operation develops 

and implements 

procedures. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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F-8.7 All cleaning agents 

shall be approved for 

their intended use on 

food contact surfaces.

All chemicals used for cleaning or 

sanitizing of food contact equipment, 

tools, utensils, containers and other 

food contact surfaces shall be approved 

for that use, according to the chemical 

manufacturer or supplier and all 

federal, state and local requirements, 

and shall be used in a manner 

consistent with the approved use.

Auditor reviews 

cleaning and sanitizing 

chemicals purchasing 

practices or 

procedures, storage 

area, and use 

procedures to verify 

compliance.

Operation ceases use 

of unapproved 

chemicals. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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Harvesting

F-9: Preharvest Assessment

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-9.1 A preharvest risk 

assessment shall be 

performed.

A ● The Operation shall have a preharvest 

assessment procedure, which describes 

when the assessment is performed and 

that it includes an evaluation of 

conditions that may be reasonably 

likely to result in physical, chemical, or 

biological contamination of the 

produce, and demonstrates that the 

Operation is in compliance with the 

food safety plan. Results of the 

evaluation shall be documented.

Auditor reviews most 

recent preharvest 

assessment for 

completeness and 

consistency with the 

food safety plan.

Operation develops 

and implements a 

preharvest assessment 

procedure.
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F-10: Water/Ice Used in the Harvesting and Post-Harvest Operations

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-10.1 Operation has 

procedures for water 

used in contact with 

product or food 

contact surfaces.

WP, 

R

● Standard Operating Procedures 

(SOPs), including water-change 

schedules, shall be developed for all 

uses of water. Microbial and/or 

physical/ chemical (e.g., test strips) 

testing shall be performed, as 

appropriate to the specific Operation, 

to demonstrate that acceptance criteria 

have been met.

Auditor observes 

evidence of existence 

of water use SOPs.

Operation develops the 

SOPs. 

F-10.2 Water use SOPs 

address the microbial 

quality of water or 

ice that directly 

contacts the 

harvested crop or is 

used on food-contact 

surfaces.

R ● If water or ice directly contacts the 

harvested crop or is used on foodcontact surfaces, such as in the field, as 

the final wash step prior to consumer 

packaging, or as a cooling aid in a 

consumer package, Operation’s water 

use SOP requires that water or ice 

when applied meets the microbial 

standards for drinking water, as 

defined by prevailing regulation. 

Water may be treated (e.g., with 

chlorine) to achieve the microbial 

standards or to prevent crosscontamination. Ice and water shall be 

sourced/manufactured, transported, and 

stored under sanitary conditions. 

Special considerations or variances 

may be appropriate for some crops, e.g. 

cranberries and watercress, where 

deliberate flooding of the field is part 

of production and harvest practices.

Auditor reviews 

Operation’s policy 

regarding water quality 

and its transport, and 

observes evidence that 

water or ice that 

contacts harvested crop 

or food contact 

surfaces meets the 

microbial standards for 

drinking water.

Operation discontinues 

using water or ice that 

does not meet the 

microbial standards of 

drinking water. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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F-10.3 If water is re-used, 

SOPs address 

antimicrobial 

treatment.

R ● Operation’s water use SOPs require reused water to be treated using an 

approved antimicrobial to prevent it 

from becoming a source of 

contamination, according to prevailing 

regulation or industry specific 

standards for the commodity. 

Auditor reviews water 

use SOP for 

completeness, and 

observes water 

treatment records for 

adequacy and 

consistency of 

treatment.

Operation discontinues 

using re-used water 

that is not treated 

sufficiently to prevent 

contamination of the 

produce. Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

F-10.4 Water use SOPs 

address condition and 

maintenance of 

water-delivery 

system.

R ● The water-delivery system shall be 

maintained so as not to serve as a 

source of contamination of produce, 

water supplies or equipment with 

pathogens, or to create an unsanitary 

condition.

Auditor reviews the 

SOP for inclusion of 

condition and 

maintenance of waterdelivery system, and 

observes maintenance 

records for evidence of 

compliance.

Operation revises SOP 

and implements 

maintenance 

procedures.

F-10.5 If applicable to the 

specific commodity, 

water use SOPs 

address control of 

wash water 

temperature.

R For produce demonstrated as being 

susceptible to microbial infiltration 

from wash water, wash water 

temperature differentials during 

immersion shall be considered. 

If applicable to the 

commodity being 

washed, auditor 

reviews the SOP for 

inclusion of water

temperature control, 

and observes 

monitoring records for 

evidence of 

compliance.

Operation revises SOP 

to address and control 

wash water 

temperature.
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F-11: Containers, Bins and Packaging Materials

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-11.1 Operation has written 

policy regarding 

storage of harvesting 

containers.

WP Harvesting containers shall be stored in 

a manner so as not to serve as a source 

of contamination to the extent feasible 

and appropriate.

Auditor observes 

whether Operation has 

a policy regarding 

storage of harvesting 

containers used in the 

field. Auditor 

observes current 

practices for 

compliance with 

policy.

Operation develops the 

policy. Retraining is 

performed and 

documented. 

F-11.2 Operation has written 

policy regarding 

inspection of food 

contact containers 

prior to use.

WP Food-contact totes, bins, packing 

materials, other harvest containers, and 

pallets shall be visually inspected, 

clean, intact and free of any foreign 

materials prior to use. Containers shall 

be sufficiently maintained so as not to 

become a source of contamination.

Auditor observes 

whether Operation has 

a policy regarding 

inspection of food 

contact containers and 

observes current 

practices for 

compliance with 

policy.

Operation develops the 

policy. Retraining is 

performed and 

documented. 

F-11.3 Operation has written 

policy regarding 

acceptable harvesting 

containers.

WP The types and construction of harvest 

containers and packing materials shall 

be appropriate to the commodity being 

harvested and suited for their intended 

purpose.

Auditor observes 

whether Operation has 

a policy regarding 

what types of 

containers and packing 

materials are 

acceptable for use 

during harvest, and 

observes current 

practices for 

compliance with the 

policy.

Operation develops the 

policy. Retraining is 

performed and 

documented. 
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F-11.4 Operation has written 

policy prohibiting 

use of harvest 

containers for nonharvest purposes.

WP ● Food-contact totes, bins and other 

harvest containers designated for 

harvesting shall not be used for other 

purposes unless clearly marked or 

labeled for that purpose.

Auditor observes 

whether Operation has 

a policy prohibiting 

use of harvest 

containers for other 

uses unless otherwise 

labeled, and observes 

current practices for 

compliance with the 

policy.

Operation develops the 

policy. Retraining is 

performed and 

documented. 
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F-12: Field Packaging and Handling

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-12.1 Operation shall have 

a written policy that 

visibly contaminated, 

damaged or decayed 

produce is not 

harvested, or is 

culled. 

WP ● Employees are trained that only sound 

produce appropriate for the intended 

use is harvested, and that produce that 

has been visibly contaminated or 

otherwise damaged to an extent that it 

poses a microbial food safety hazard is 

not harvested or is culled. 

Auditor reviews 

written policy and 

evidence of employee 

training. Auditor 

inspects the harvest or 

sorting operation for 

evidence of 

compliance.

Operation develops the 

policy. Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

F-12.2 Product that contacts 

the ground shall not 

be harvested unless 

the product normally 

grows in contact with 

the ground.

WP ● Operation has considered and 

developed written policies regarding 

produce that comes in contact with the 

soil (e.g., drops) and to avoid, to the 

degree practicable, contact of cut 

surfaces of harvested produce with 

soil. Policy shall be consistent with 

industry standards or prevailing 

regulations.

Auditor reviews 

written policy and 

evidence of employee 

training. Auditor 

inspects the harvest or 

sorting operation for 

evidence of 

compliance.

Operation develops the 

policy. Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

F-12.3 Harvest procedures 

shall include 

measures to inspect 

for and remove 

physical hazards.

Operation shall have procedures to 

detect glass/plastic breakage and 

remove possible physical 

contamination such as glass, metal, 

rocks, or other hazardous items, during 

harvesting operations.

Auditor inspects the 

harvest or sorting 

operation for evidence 

of hazard control.

Operation develops the 

procedure. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

F-12.4 Cloths, towels, or 

other cleaning 

materials that pose a 

risk of crosscontamination shall 

not be used to wipe 

produce, unless risk 

mitigation procedures 

are in place.

Operations shall not use cloths or other 

cleaning materials to clean produce, 

unless there is a procedure to reduce 

risk of cross-contamination.

Auditor reviews 

whether Operation 

uses cloths or other 

produce cleaning 

materials and, if so, 

how Operation 

prevents crosscontamination between 

uses.

Operation ceases use 

of produce cleaning 

cloths, or develops 

procedure to prevent 

cross-contamination. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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F-12.5 Packaging materials 

shall be appropriate 

for their intended 

use.

● The product contact packaging shall be 

appropriate to the commodity being 

harvested and suited for its intended 

purpose.

Auditor observes 

evidence (e.g., 

information from 

supplier, customer 

specification, industry 

standards, prevailing 

regulation) that the 

packaging does not 

create an unsafe 

condition.

Operation discontinues 

use of the packaging 

until information can 

be obtained 

demonstrating safe 

use. Affected product 

is evaluated for 

potential 

contamination and 

disposition.

F-12.6 Packaging shall be 

stored in a manner 

that prevents 

contamination.

Packaging storage shall be designed to 

maintain packaging dry, clean and free 

from dirt or residues so it remains fit 

for the purpose. Particular care shall be 

taken to prevent packaging from 

becoming a harborage for rodents and 

other vermin. Packaging shall be stored 

separately from hazardous chemicals, 

toxic substances and other sources of 

contamination.

Auditor inspects 

packaging storage area 

for evidence of 

compliance. 

Operation designates a 

storage area and 

practices that reduce 

risk of contamination. 

Affected packaging is 

evaluated for potential 

contamination and 

disposition.

F-12.7 Operation has written 

policy regarding 

whether packaging 

materials are 

permitted in direct 

contact with the soil. 

WP If produce is packed in field, Operation 

has considered and developed written 

policies regarding placement of 

packaging materials directly on the 

soil, or whether a physical buffer (e.g., 

buffer bin or slip sheet) is required. 

Policy shall be consistent with industry 

standards.

Auditor observes 

whether Operation has 

a policy regarding 

placement of 

packaging materials 

used in the field in

direct contact with soil. 

Auditor observes 

current practices for 

compliance with 

policy.

Operation develops the 

policy. Retraining is 

performed and 

documented. 
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F-12.8.a The Operation has 

implemented a 

product release 

procedure. 

WP Operation follows product release 

written procedure to ensure that all 

potential hazards have been addressed 

prior to transport. Release records 

must be kept.

Auditor observes 

product release 

procedure is being 

followed and release 

records are kept.

Operation develops a 

written release 

procedure. Release 

records are kept.
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F-13: Post-Harvest Handling and Storage (Field Prior to Storage or Packinghouse)

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-13.1 Harvested produce is 

handled in a manner 

such that it is not 

likely to become 

contaminated.

● Operation has a policy, in compliance 

with current industry practices or 

regulatory requirements for that 

commodity, regarding handling, 

walking, stepping, or lying on 

harvested produce, food contact 

surfaces or packaging materials, or 

coming in contact with produce that 

has not been handled in compliance 

with these standards, or that may 

otherwise result in contamination.

Auditor reviews policy 

and produce handling 

practices for evidence 

of compliance.

Operation develops the 

policy. Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

F-13.1.a When product is field 

packed, collection, 

storage, and 

distribution points 

are maintained in a 

clean and hygienic 

condition.

Areas of collection/storage/distribution 

points shall be identifiable on farm 

during harvesting. There shall be 

visual evidence that these areas are 

kept clean. Where there is temporary 

storage on farm, rodent and other 

animal control measures shall be 

present.

Auditors shall verify 

through observation 

that when products are 

field packed, 

collection, storage and 

distribution points are 

maintained in a clean 

and hygienic 

condition.

Operation will 

implement practices 

that during field 

packing of produce 

that collection, storage 

and distribution points 

are maintained in a 

clean and hygienic 

condition.

F-13.2 Materials that come 

in contact with the 

produce shall be 

clean and in good 

repair.

● Operation has a policy that pallets, 

produce bins, totes and materials that 

come in contact with the produce or the 

containers during handling or storage 

shall be cleaned and, if practicable, 

sanitized sufficient so as not to be a 

source of contamination.

Auditor observes 

current practices for 

compliance with 

policy.

Operation develops the 

policy. Retraining is 

performed and 

documented. Affected 

materials are evaluated 

for potential 

contamination and 

disposition.
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F-14: Equipment Sanitation and Maintenance

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-14.1 The Operation shall 

have a policy, written 

procedures, and a 

checklist to verify 

cleanliness and 

functionality of 

shipping units (e.g., 

trailer).

WP,

R

● Shipping units shall be clean, 

functional and free of objectionable 

odors before loading, in compliance 

with current industry practices or 

regulatory requirements for that 

commodity. Refrigeration units, if 

used, must be in working order. 

Auditor reviews 

cleaning and 

inspection procedures 

and inspects produce 

transport vehicles for 

cleanliness.

Operation develops the 

policy. Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

F-14.2 Loading/unloading 

procedures and 

equipment shall 

minimize damage to 

and prevent 

contamination of 

produce.

Personnel responsible for the loading 

and unloading of produce shall take 

steps to minimize the potential of 

physical damage to produce, which can 

introduce and/or promote the growth of 

pathogens. Loading/unloading 

equipment shall be clean and well 

maintained and of suitable type to 

avoid contamination of the produce.

Auditor observes 

loading/unloading 

procedures for 

evidence of practices 

that result in excessive 

damage to produce.

Auditor observes 

loading/unloading 

equipment for 

suitability and 

condition.

Operation revises 

procedures. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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POST-HARVEST OPERATIONS (P)

P-1: Produce Sourcing

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-1.1 The Operation has a 

policy and takes 

affirmative steps to 

ensure that all fresh 

produce that are 

packed or stored in 

the Operation are 

grown following 

requirements in 

Field Operations 

and Harvesting

harmonized 

standard.

R The Operation requires all raw product 

suppliers to provide evidence of food 

safety/GAP programs and compliance. 

Such evidence must include sufficient 

documentation to demonstrate that the 

supplier complies with the 

requirements in Field Operations and 

Harvesting harmonized standard.

Auditor reviews policy 

and verifies that 

Operation’s evidence 

of supplier compliance 

with food safety/GAP 

programs is in 

compliance with the 

Operation’s policy.

Operation obtains 

required 

documentation. 

Operation ceases 

accepting or shipping 

product from nonapproved suppliers, 

until sufficient 

documentation 

demonstrating 

compliance is received 

by the Operation.
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P-2: Agricultural Chemicals

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-2.1 Use of agricultural 

chemicals shall 

comply with label 

directions and 

prevailing 

regulation.

R ● Agricultural chemicals applied postharvest (e.g., biocides, waxes and 

plant protection products) must be 

registered for such use as required by 

prevailing regulation, and used in 

accordance with label directions 

including application rates, worker 

protection standards, personal 

protection equipment, container 

disposal, storage, and all requirements 

specified for the chemical or 

compound. Chemicals that are not 

restricted pesticides may be permitted 

for food contact use if allowed under 

regulations of the prevailing agency.

Records of chemical use are 

maintained.

Auditor reviews postharvest agricultural 

chemical use records 

for evidence of 

compliance with 

approved uses or label 

directions.

Operation develops 

and maintains 

agricultural chemical 

use records and 

maintains evidence of 

proper use of each 

chemical use. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-2.2 If product is intended 

for export, pre- and 

post-harvest 

agricultural chemical 

use shall consider 

requirements in the 

intended country of 

destination.

The Operation shall have procedures, 

such as review of pre-harvest intervals 

and adjustment of post-harvest 

application rates, sufficient to meet the 

MRL entry requirements of the 

country(ies) in which the product is 

intended to be traded, if known during 

post-harvest handling.

Auditor reviews 

Operation’s procedure 

for complying with 

agricultural chemical 

restrictions in 

countries of 

destination. If the 

country of destination 

is unknown during 

post-harvest handling, 

this item is not 

applicable.

Operation develops 

procedures, and 

diverts non-compliant 

product to a market in 

which the product 

meets standards.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-2.3 Agricultural 

chemicals shall be 

applied by trained, 

licensed or certified 

application 

personnel, as 

required by 

prevailing 

regulation.

R Operation maintains records 

demonstrating that all personnel 

responsible for chemical applications 

are trained and/or licensed, or 

supervised by licensed personnel, in 

compliance with prevailing regulation.

Auditor reviews 

records demonstrating 

that application 

personnel are licensed 

and/or trained in 

compliance with 

prevailing regulation.

Operation utilizes 

application personnel 

who are appropriately 

licensed and/or 

trained.
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P-3: Facility

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-3.1 Operation has 

initially and at least 

annually thereafter, 

performed and 

documented a hazard 

analysis of the 

packinghouse, and 

has addressed all 

identified hazards.

A ● Records shall be available to 

demonstrate that the packinghouse has 

been evaluated with regards to 

potential food safety hazards 

associated with the packinghouse and 

the activities taking place within. 

Workers shall be trained on what the 

food safety hazards are and how to 

manage them.

Auditors verify the 

operation has 

performed and 

documented a hazard 

analysis of the 

packinghouse. Auditor 

verifies that control 

measures for all 

significant hazards 

identified during the 

analysis are 

implemented.

The Operation shall 

perform and document 

a hazard analysis for 

the packinghouse. 

Training of 

appropriate personnel 

may need to take place 

on conducting and 

recording this 

assessment. Operation 

trains workers on the 

maintenance of the 

food safety hazards 

identified and how to 

manage and record the 

management of these 

hazards.

P-3.1.a If microbiological 

hazards requiring a 

control are identified 

in the hazard 

analysis of the 

packinghouse a 

microbial 

environmental 

monitoring program 

shall be established.

WP, 

R

The operation has established an 

environmental monitoring program 

based on the risks identified in the 

hazard analysis. The program shall

address microbiological risks and

include procedures for sampling, 

testing and frequency. Acceptable 

results shall be clearly defined and 

include procedures for when 

unacceptable results have occurred. 

Records of environmental monitoring 

sampling, testing and any corrective 

actions shall be kept.

Auditor reviews the 

environmental 

monitoring program 

and records and 

observes current 

practices for 

compliance with 

policy.

Operation develops an 

environmental 

monitoring program. 

Retraining is 

performed and 

documented. Records 

of environmental 

monitoring and 

corrective actions are 

kept.
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P-3.2 Building shall be 

located, designed, 

constructed and 

maintained in a 

manner that prevents 

contamination of 

produce during 

handling, storage and 

cooling.

Product flow is designed to minimize 

risk of cross-contamination. Building 

and equipment structures and surfaces 

(floors, walls, ceilings, doors, frames, 

hatches, etc.) shall be constructed in a 

manner that facilitates cleaning and 

sanitation and does not serve as 

harborage for contaminants or pests.

Drop ceilings shall enable cleaning 

and monitoring for pest activity. Chill 

and cold storage loading dock areas 

shall be sealed, drained and graded, as 

appropriate for the operation. Fixtures, 

ducts, pipes and overhead structures 

shall be installed and maintained so 

that drips and condensation do not 

contaminate produce, raw materials or 

food contact surfaces. Drip pans and 

drains shall be designed to assure 

condensate does not become a source 

of contamination. Water from 

refrigeration drip pans shall be drained 

and disposed of away from product 

and product contact surfaces. Floors 

are designed to minimize and/or 

facilitate the removal of standing 

water. Air intakes shall not be located 

near potential sources of 

contamination.

Auditor observes 

building and 

equipment for 

evidence that the 

building can be 

cleaned and 

maintained to prevent 

product 

contamination. 

Building deficiencies 

are corrected. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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P-3.3 Adequate lighting 

shall be provided in 

all areas. 

Lighting in all areas shall be sufficient 

to enable cleaning, sanitation, repairs, 

etc. 

Auditor observes, 

directly or by other 

evidence, that 

sufficient lighting is 

provided to the worker 

to clearly see the task 

being performed.

Operation installs 

adequate, lighting.

P-3.4 Only essential glass 

and brittle plastic 

shall be present in 

the building. 

R Light bulbs, fixtures, windows, 

mirrors, skylights and other glass and 

brittle plastic in the building or in the 

product path entering or exiting the 

building shall be of the safety type, or 

shall be otherwise protected to prevent 

breakage. If glass or brittle plastic 

must be used, there shall be a written 

glass and brittle plastic control policy, 

including a glass and brittle plastic 

register.

Auditor observes glass 

and brittle plastic use 

in building, and glass 

and brittle plastic 

control policy and 

glass and brittle plastic 

register for 

compliance. 

Operation develops a 

glass and brittle plastic 

control policy or 

eliminates all glass 

and brittle plastic in 

the building.

P-3.5 Catwalks above 

product zones are 

protected to prevent 

produce or 

packaging 

contamination.

Where workers walk over product 

contact surfaces, those walkways are 

solid surface or have catch trays 

installed, are protected by kick plates, 

product covers or other barriers.

Auditor observes 

catwalks over product 

zones for evidence of 

protective measures.

Operation retrofits 

catwalks or product 

zones to protect 

against potential 

contamination. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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P-3.6 If applicable, 

Operation has a 

written Allergen 

Control Program.

A,

WP

● The Allergen Control Program lists 

the allergens in use or storage at the 

Operation specific to country 

regulations. If applicable, procedures 

address identification and segregation 

of allergens during storage and 

handling as based on a risk assessment 

conducted by the Operation.

Auditor reviews 

Allergen Control 

Program and inspects 

Operation for evidence 

of allergen use and 

storage.

Operation develops 

and implements an 

Allergen Control 

Program or eliminates 

allergens from the 

Operation.
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P-4: Pest and Animal Control

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-4.1 Operation has 

procedures to 

manage pests to the 

extent appropriate to 

the Operation. 

WP ● Operation has a written pest control 

program, performed by a trained pest 

control operator (or licensed where 

required by prevailing regulation). 

The written program includes policies 

and procedures applicable to that 

Operation, such as storage of outside 

equipment or other factors dealing 

with pest harborages, and maps of the 

location of pest traps outside and 

inside the Operation. Operation 

maintains a pest-control log that 

includes dates of inspection, 

inspection reports and steps taken to 

eliminate any problems. Applications 

of pesticides (e.g., insecticides, 

rodenticides) shall be performed in 

compliance with local, state, and 

federal pesticide regulations.

Auditor reviews pest 

control program, pest 

control operator’s 

credentials, and 

inspects Operation for 

pest activity.

Operation develops, 

documents and 

implements an 

effective pest control 

program.

P-4.2 Operation restricts 

animals from food 

handling areas.

● Domesticated animals are prohibited 

from pack house, cooling, and storage 

facilities unless procedures are in 

place for their safe presence. 

Procedures are in place to exclude 

wild and feral animals to the degree 

practical and to monitor for and

mitigate contamination from animal 

excreta.

Auditor looks for 

evidence of animals or 

animal activity.

Operation develops

and implements an 

effective animal 

control program.
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P-4.3 If used, pest control 

devices, including 

rodent traps and 

electrical flying 

insect devices, are 

located so as to not 

contaminate produce 

or food handling 

surfaces.

Only non-toxic traps and pest control 

devices are used inside the packing 

house or storage building.

Auditor reviews pest 

control program and 

placement of pest 

control devices.

Operation removes or 

repositions pest 

control devices to be 

compliant.
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P-5: Equipment, Tools and Utensils

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-5.1 All food contact 

equipment, tools and 

utensils are designed 

and made of 

materials that are 

easily cleaned and 

maintained.

WP ● The Operation shall develop, 

implement, and schedule repair, 

cleaning, sanitizing, storage and 

handling procedures of all food 

contact surfaces to reduce and control 

the potential for contamination. These 

procedures shall be documented. 

Product contact tools, utensils and 

equipment shall be made of materials 

that can be cleaned and sanitized. 

Seams between food contact surfaces 

are smooth and cleanable.

Auditor observes food 

contact surfaces for 

design and materials 

that can be easily 

cleaned and 

maintained. Auditor 

reviews cleaning, 

sanitizing, storage and 

handling procedures.

Operation develops 

and implements 

procedures. Operation 

replaces all noncompliant food contact 

equipment, tools and 

utensils.

P-5.2 Equipment is 

installed in a way 

that provides access 

for cleaning.

Cooling, packing and other food 

contact equipment is installed away 

from walls and otherwise positioned 

so as not to inhibit access for proper 

cleaning.

Auditor observes 

positioning of all food 

contact equipment for 

compliance.

Operation relocates 

the equipment to be 

compliant.

P-5.3 Equipment 

lubrication is 

managed so as not to 

contaminate food 

products.

Only food-grade lubricants are used 

on food processing and packaging 

equipment, or on any other equipment 

where incidental food contact may 

occur, unless the equipment 

manufacturer specifies only a nonfood grade lubricant. Lubricant leaks 

are fixed or catch pans are installed to 

prevent product contamination.

Auditor reviews 

purchase or 

maintenance records 

to verify all lubricants 

used are food grade. 

Auditor observes 

lubrication points to 

verify leaks are 

controlled.

Operation replaces 

non-food grade 

lubricants. Operation 

fixes lubricant leaks or 

installs catch pans. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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P-5.4 All instruments used 

to measure 

temperature, pH, 

antimicrobial levels 

and/or other 

important devices 

used to monitor 

requirements in this 

section shall be 

adequately 

maintained and 

calibrated at a 

frequency sufficient 

to assure continuous 

accuracy.

R ● Records shall be kept. If an ORP 

system is used, an independent 

measurement shall be used to verify 

compliance. Test methods or test 

strips used to monitor requirements 

shall be appropriate to their use, 

sufficiently sensitive to their intended 

purpose and available in adequate

numbers for their designated use.

Auditor reviews 

calibration and 

verification 

procedures and 

records.

Operation develops, 

documents and 

implements calibration 

and verification 

procedures and 

records.

P-5.4.a Calibration of 

equipment is 

traceable to a 

recognized standard.

WP Calibration of measuring and 

monitoring equipment (thermometers, 

pH meters, scales, chemical 

application or monitoring devices) is 

performed using a recognized standard 

or method. 

Auditor reviews the 

calibration procedures 

to determine if they 

follow a recognized 

standard or method.

Operation develops 

calibration procedures 

which are traceable to 

a recognized standard 

or method.
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P-5.5 Foreign material 

control devices are 

inspected and 

maintained. 

R If included in the Food Safety Plan, 

foreign material control devices shall 

be included as part of a Preventive 

Maintenance Schedule or other 

program and maintained to ensure 

effective operation. Calibration 

checks shall be performed according 

to written procedure or manufacturer’s 

recommendations.

Auditor inspects any 

foreign material 

control devices and 

maintenance and 

calibration check 

records for 

compliance.

Operation develops 

written procedures for 

inspection, calibration 

checks and 

maintenance of 

foreign material 

control devices. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-5.5.a Metal detection 

equipment, if 

utilized, shall be 

checked at a 

scheduled frequency 

as outlined in the 

operation’s food 

safety/HACCP plan 

using iron, non-iron 

and stainless steel 

testing wands.

R These systems should be frequently 

checked to ensure that they are 

working correctly (recorded). Foreign 

material issues should be documented 

and corrective actions implemented as 

written in the food safety program.

Auditors shall review 

equipment records to 

ensure frequency is 

according to 

established food safety

plan.

Procedure is 

developed and 

implemented at an 

established frequency. 

Training is performed 

and documented.
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P-6: Maintenance and Sanitation

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-6.1 A Preventive 

Maintenance and/or 

Master Cleaning 

Schedule, with 

related SOPs, shall 

be established.

WP,

R

● There is a written cleaning and 

sanitation schedule for all food and 

non-food contact surfaces including 

floors, drains, walls, ceilings and other 

surfaces that may pose a source of 

product contamination. Roof leaks 

shall be promptly identified, 

controlled and repaired. Operation has 

procedures for cleaning and sanitation 

of cooling equipment. Drip pans and 

drains shall be maintained to assure 

condensate does not become a source 

of contamination. If standing water 

exists, it is removed from floors and 

floors cleaned in a manner and at a 

frequency sufficient to prevent 

creation of a source of contamination.

Auditor reviews 

Preventive 

Maintenance and/or 

Master Cleaning 

Schedule observes 

building and 

equipment for 

evidence that the 

building is cleaned 

and maintained to 

prevent product 

contamination. 

Auditor reviews 

building maintenance 

records for evidence 

of repairs.

Operation develops a 

Preventive 

Maintenance and/or 

Master Cleaning 

Schedule, with related 

SOPs. Building 

deficiencies are 

corrected. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-6.2 Any temporary 

repairs on food 

contact surfaces are 

constructed of foodgrade material. 

Operation has a 

procedure to ensure 

that permanent 

repairs are 

implemented in a 

timely manner.

Operation has procedures to ensure 

temporary repairs are compliant with 

all food safety requirements, and do 

not create potential sources of 

chemical, microbiological or physical 

contamination. Permanent repairs are 

implemented as soon as practical; 

Operation establishes timelines and 

responsibilities for completion.

Auditor observes 

temporary repairs, if 

present, and 

Operation’s plans for 

timely completion.

Operation develops 

and implements a 

temporary repair 

procedure. Operation 

immediately fixes any 

non-compliant 

temporary repairs. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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P-6.3 All cleaning agents 

shall be approved for 

their intended use on 

food contact 

surfaces.

All chemicals used for cleaning or 

sanitizing of food contact equipment, 

tools, utensils, containers and other 

food contact surfaces shall be 

approved for that use, according to the 

chemical manufacturer or supplier and 

all federal, state and local 

requirements, and shall be used in a 

manner consistent with the approved 

use.

Auditor reviews 

cleaning and sanitizing 

chemicals purchasing 

practices or 

procedures, storage 

area, and use 

procedures to verify 

compliance.

Operation ceases use 

of unapproved 

chemicals. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-6.4 Cleaning equipment 

and tools are clean, 

in working order and 

stored properly away 

from product 

handling areas.

Equipment, utensils and tools used for 

cleaning or sanitizing, including food 

contact and non-food contact surfaces, 

are maintained in a manner sufficient 

to avoid becoming a source of produce 

contamination and are stored away 

from product handling areas.

Auditor reviews 

practices or 

procedures for use and 

storage of cleaning 

and sanitizing 

equipment, tools and 

utensils, and observes 

storage area for 

compliance.

Operation develops 

written procedures for 

maintaining and 

storing cleaning and 

sanitizing equipment, 

tools and utensils. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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P-6.5 Food contact 

surfaces shall be 

cleaned, sanitized 

and maintained 

according to the 

Food Safety Plan

R ● Prior to use, the lines used for 

washing, grading, sorting, or packing 

shall be cleaned and sanitized as 

appropriate per risk assessment or 

prevailing regulations. Records must 

include the date and method of 

cleaning and sanitizing equipment. 

When in use, the lines shall be 

maintained so as not to be a source of 

contamination with pathogens.

Auditor reviews 

cleaning and sanitizing 

procedures and 

records and observes

food contact surfaces 

to verify compliance.

Operation develops 

written cleaning and 

sanitizing procedures 

and records consistent 

with the Food Safety 

Plan. Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-6.5.a A cleaning and 

sanitation program 

for food contact 

surfaces shall be

established, 

implemented and 

maintained. The 

program shall 

include measures for 

monitoring to verify

effectiveness.

WP, 

R

An implemented cleaning and 

sanitation program shall be 

established, including SOPs.

Procedures must include frequency, 

approved cleaning and sanitizing 

agents, and methods of cleaning and 

sanitizing chemical use. The SOP 

must justify the frequency of cleaning, 

demonstrate that the cleaning and 

sanitizing methods are effective on the 

surfaces that they are used on, are 

being used at appropriate 

concentrations as required by the 

label. Operation shall demonstrate 

effectiveness in minimizing the 

potential for cross contamination from

cleaning and sanitizing. Records of 

sanitizer chemical concentrations shall 

be maintained.

Auditor reviews the 

cleaning and sanitation 

program procedures 

and records for 

inclusiveness of 

frequency approval 

and proper use of 

cleaning and sanitizing 

agents, and methods of 

cleaning and sanitizing 

agent use. Auditor 

reviews chemical 

records regarding use 

of approved chemicals 

used for cleaning and 

sanitizing.

Operation develops

and implements 

program procedures

for cleaning and 

sanitation. Operation 

identifies chemicals 

approved-for-use in 

the cleaning and 

sanitation program and 

establishes and 

maintains records of 

all cleaning and 

sanitizer 

concentrations. 

Retraining of cleaning 

and sanitation program 

policies and 

procedures is are 

performed and 

documented.
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P-6.6 Transporting 

equipment shall be 

maintained to 

prevent 

contamination of 

products being 

transported.

R Pallet jacks, carts, trolleys and 

forklifts, shall be maintained to 

prevent contamination of products 

being transported and are listed on the 

Preventive Maintenance and/or Master 

Cleaning Schedules. 

Auditor observes 

transporting 

equipment and 

reviews Schedules and 

records for evidence 

of compliance.

Operation develops 

and implements 

Preventive 

Maintenance and/or 

Master Cleaning 

Schedules.

P-6.7 Waste materials and 

their removal are 

managed to avoid 

contamination.

● Trash, leaves, trim, culls, wastewater 

and other waste materials are removed 

from the produce handling areas at a 

frequency sufficient to avoid 

becoming a source of produce 

contamination.

Auditor observes 

waste control 

procedures in produce 

handling areas.

Operation develops a 

written waste control 

procedure. 

Operational 

deficiencies are 

corrected. Retraining 

is performed and 

documented.

P-6.8 Outside garbage 

receptacles/

dumpsters are closed 

and located away 

from building 

entrances and the 

area around such 

sites is reasonably 

clean.

Waste containers and compactors are 

located away from produce handling 

areas, are closed or have lids (except 

for waste collection/cull trailers in 

active use), are emptied on a 

scheduled basis or as needed, and 

weeds and other pest harborage are 

minimized around the containers.

Auditor observes 

waste container 

location and 

management practices.

Operation relocates 

waste containers. 

Building deficiencies 

are corrected. 

Retraining is 

performed and 

documented. 
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P-6.9 The plant grounds 

are reasonably free 

of litter, waste culls, 

vegetation, debris 

and standing water.

Operation has procedures to maintain 

the grounds surrounding the building 

in a manner to minimize sources of 

contamination, such as litter, 

vegetation, waste culls, debris and 

standing water that may be pest 

attractants or harborages. Equipment 

and materials stored outside are stored 

away from the building perimeter. 

Outside storage areas are included in 

pest control program. Vegetation that 

does not serve as an attractant or 

harborage is permitted.

Auditor observes the 

grounds for 

compliance.

Operation removes the 

attractants and 

harborages, and 

develops procedure to 

maintain grounds in 

compliance.

P-6.10 Sewage or septic 

systems are 

maintained so as not 

to be a source of 

contamination.

● After a significant event (such as 

flooding or an earthquake) that could 

negatively impact a sewage or septic 

system, Operation takes appropriate 

steps to ensure that sewage and septic 

systems continue to operate in a 

manner that does not contaminate 

produce, food contact surfaces, areas 

used for produce handling, agricultural 

water sources, or agricultural water 

distribution systems.

If a significant event 

has occurred, auditor 

reviews steps taken by 

Operation to verify 

sewage or septic 

system is not a source 

of contamination. 

Sewage or septic 

systems deficiencies 

are corrected. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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P-6.11 The sewage disposal 

system is adequate 

for the process and 

maintained to 

prevent direct or 

indirect product 

contamination.

● The human waste and gray water 

sewage system has sufficient capacity 

to handle the Operation’s peak flows 

and not cause direct or indirect 

product contamination. Crossconnections with product contact 

water systems are prohibited. Floor 

drains are adequate, functional, free of 

obstruction, and are properly 

maintained and cleaned to prevent 

them from becoming sources of 

contamination.

Auditor observes 

Operation for evidence 

of compliance.

Operation suspends 

operation until sewage 

disposal system 

functions so as to 

prevent risk of product 

contamination. 

Affected product and 

product handling areas 

are evaluated for 

potential 

contamination and 

disposition.
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P-7: Post-Harvest Water/Ice

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-7.1 A water system 

description shall be 

prepared. 

R ● Water sources and the Operations they 

serve shall be documented and current. 

The description shall include one or 

more of the following: maps, 

photographs, drawings (hand drawings 

are acceptable) or other means to 

communicate the location of water 

source(s), permanent fixtures and the 

flow of the water system (including 

holding systems, reservoirs or any 

water captured for re-use). Permanent 

fixtures include wells, gates, 

reservoirs, valves, returns, backflow 

prevention and other above ground 

features that make up a complete 

water distribution system shall be 

documented in such a manner as to 

enable location in the Operation. 

Auditor reviews water 

system description or 

map, and verifies 

accuracy during 

Operation inspection. 

Operation develops or 

corrects the water 

system description or 

map.
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P-7.2 Documented 

scheduled 

assessment of water 

system including 

delivery equipment 

shall be performed. 

R ● The water-delivery system shall be 

maintained so as not to serve as a 

source of contamination of produce, 

water supplies or equipment with 

pathogens, or to create an unsanitary 

condition. Water installations and 

equipment are constructed and 

maintained to prevent back siphonage 

backflow and cross connections 

between product contact water and 

wastewater. Routine checks verify 

that back siphonage and backflow 

prevention units are functioning 

properly (annual or as needed to 

maintain continuous protection). 

Results are documented.

Auditor reviews 

maintenance records 

and examines water 

system for compliance 

with water system 

maintenance program, 

including backflow 

prevention and crossconnections.

Operation corrects 

deficiencies in ability 

of water system to 

reliably distribute safe 

water and schedules 

water system 

assessments. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-7.3 Water use SOPs 

address the microbial 

quality of water or 

ice that directly 

contacts the 

harvested crop or is 

used on food-contact 

surfaces.

R ● If water or ice directly contacts the 

harvested crop or is used on foodcontact surfaces, Operation’s water 

use SOP requires that water or ice 

when applied meets the microbial 

standards for drinking water, as 

defined by prevailing regulation or the 

country in which the product is 

intended to be traded, whichever is 

more stringent. Water may be treated 

(e.g., with chlorine) to achieve the 

microbial standards or to prevent 

cross-contamination. Ice and water 

shall be sourced/manufactured, 

transported, and stored under sanitary 

conditions. 

Auditor reviews 

Operation’s policy 

regarding water 

quality and its 

transport, and 

observes evidence that 

water or ice that 

contacts harvested 

crop or food contact 

surfaces meets the 

microbial standards 

for drinking water. 

Operation 

discontinues using 

water or ice that does 

not meet the microbial 

standards of drinking 

water. Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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P-7.4 Operation’s Food 

Safety Plan includes 

produce washing 

process, if used.

A,

WP

● If produce is washed, an initial risk 

assessment of the washing process 

shall be performed that takes into 

consideration the commodity, type of 

wash system, type of sanitizer, and 

water quality.

Auditor reviews Food 

Safety Plan and 

operational procedures 

to determine if 

washing process has 

been considered.

Operation revises 

Food Safety Plan to 

include produce 

washing process.

P-7.5 If used, water 

antimicrobial 

treatments shall be 

monitored 

sufficiently to assure 

continuous control.

R ● Microbial, physical or chemical 

testing shall be performed, as 

appropriate to the specific Operation, 

to demonstrate that acceptance criteria 

have been met.

Auditor reviews 

monitoring records for 

compliance with the 

Operation’s 

established procedure 

and acceptance 

criteria.

Operation establishes 

monitoring program 

that assures 

continuous control of 

water antimicrobial 

treatment to meet 

acceptance criteria.

P-7.6 Re-used water that 

contacts product or 

food contact surfaces 

shall be treated using 

an approved 

antimicrobial process 

or chemical 

treatment.

● Re-used water shall be treated using 

an antimicrobial treatment sufficient to 

prevent cross- contamination, unless 

prevailing regulation or commodity 

specific standards provide an 

alternative. Treatments shall be in 

compliance with prevailing regulation 

or the country in which the product is 

intended to be traded, whichever is 

more stringent. 

Auditor reviews water 

treatment process and 

evidence of 

compliance with 

regulation and the 

Operation’s 

established procedure.

Operation suspends 

operation until water 

treatment functions so 

as to prevent risk of 

product 

contamination. 

Affected product and 

product handling areas 

are evaluated for 

potential 

contamination and 

disposition.
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P-7.7 Operation has 

documentation 

demonstrating 

regulatory approval 

of the wash water 

antimicrobials in use.

R Only wash water antimicrobials or 

antimicrobial systems registered or 

approved by EPA, FDA or the 

prevailing regulatory agency for their 

specific intended use may be used in 

the dump tank wash water, on the 

spray line or other food contact 

purposes.

Auditor reviews 

documentation for 

appropriateness of use.

Operation obtains 

documentation or 

discontinues use of the 

antimicrobial system 

and implements use of 

appropriate 

antimicrobial system. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

P-7.8 If wash water 

antimicrobial is used, 

it shall be used in 

accordance with 

established 

operational 

procedure and 

manufacturer 

instructions. 

R Records shall be kept. Operation shall 

have a procedure that includes 

minimum limits for antimicrobial in 

wash water for food safety. Procedure 

shall include how to control, monitor 

and record use of wash water 

antimicrobial as needed to assure 

compliance with minimum limits. 

Operation shall have a procedure as to 

what corrective actions are taken if 

criteria are not met.

Auditor reviews 

operational procedures 

and antimicrobial use 

and corrective actions 

records for 

compliance. 

Operation develops, 

documents and 

implements 

procedures for use of 

the antimicrobial 

system in compliance 

with manufacturer 

instructions. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-7.9 If applicable to the 

specific commodity, 

water use SOPs 

address control of 

immersion water 

temperature.

R For produce that is immersed in water 

and demonstrated as being susceptible 

to microbial infiltration from water, 

water temperature differentials during 

immersion shall be controlled in 

accordance with prevailing regulation 

or industry guidelines. 

If applicable to the 

commodity being 

immersed, auditor 

reviews the SOP for 

inclusion of water 

temperature control, 

and observes 

monitoring records for 

evidence of 

compliance.

Operation revises SOP 

to address and control 

water temperature.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-7.10 Water change 

schedules shall be 

developed for all 

uses of water where 

water is re-used.

Operation shall have procedures for 

changing water that is re-used, such as 

recirculated water, flumes and dump 

tanks. 

Auditor observes 

water use procedures 

and evidence of 

compliance.

Operation develops 

water use procedures. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

P-7.11 Debris, damaged 

and/or visibly 

contaminated 

produce shall be 

removed from wash 

areas/dump tanks to 

the extent possible.

Operation has procedures to determine 

how and when debris, damaged and/or 

visibly contaminated produce shall be 

removed from wash areas/dump tanks.

Auditor reviews 

procedures and 

observes wash areas 

for evidence of 

compliance.

Operation develops, 

documents and 

implements a wash 

area control program. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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P-8: Containers, Bins and Packaging

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-8.1 Specifications for all 

packaging materials 

that impact on 

finished product 

safety shall be 

provided and comply 

with prevailing 

regulations. 

R The methods and responsibility for 

developing and approving detailed 

specifications and labels for all 

packaging shall be documented. A 

register of packaging specifications 

and label approvals shall be 

maintained and kept current. 

Auditor reviews 

documentation on 

methods and 

responsibilities for 

packaging materials 

and label approvals.

Operation revises 

labels and packaging 

materials to be 

compliant with 

prevailing regulations.

P-8.2 Operation has a 

written procedure for 

inspecting incoming 

packaging materials.

WP, 

R

All packaging materials are inspected 

for evidence of contamination upon 

arrival. Results are recorded.

Auditor reviews 

procedure and 

examples of packaging 

for compliance.

Operation creates or 

revises policy. 

Contaminated or 

adulterated packaging 

material is rejected or 

discarded. Retraining 

is performed.

P-8.3 Operation has 

written policy 

regarding storage 

and post-storage 

handling of productcontact containers.

WP Product-contact containers, as 

appropriate to the specific Operation 

(e.g., harvest bins, totes, crates, sacks, 

buckets, finished product clam shells, 

bags or packaging films), shall be 

stored, or handled (e.g., cleaned prior 

to post-storage use), in a manner so as 

not to serve as a source of 

contamination.

Auditor observes 

whether Operation has 

a policy regarding 

storage and handling 

of product-contact 

containers used in the 

Operation. Auditor 

observes current 

practices for 

compliance with 

policy.

Operation develops 

the policy. Retraining 

is performed and 

documented. 
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-8.4 Materials that come 

in contact with the 

produce shall be 

clean and in good 

repair.

WP, 

R

Operation has written procedures for 

cleaning and, if practicable, sanitizing 

of pallets, produce bins, totes and 

materials that come in contact with the 

produce during handling or storage so 

as not to be a source of contamination. 

Procedures require that cleaning and 

sanitizing be documented.

Auditor reviews SOP, 

cleaning logs and 

records, interviews 

responsible 

individuals for 

knowledge of the SOP 

and observes 

containers, employees 

and records for 

evidence of 

compliance.

Operation develops 

the policy. Retraining 

is performed and 

documented. Affected 

materials are evaluated 

for potential 

contamination and 

disposition.

P-8.5 Operation has 

written policy 

regarding whether 

product-contact 

containers are 

permitted in direct 

contact with the 

ground or floor. 

WP If produce does not normally contact 

the ground during production, 

Operation has considered and 

developed written policies regarding 

placement of product-contact 

containers directly on the ground or 

floor, or whether a physical buffer 

(e.g., buffer bin or slip sheet) is 

required, or use of containers 

constructed to prevent contact of the 

produce or produce contact surfaces 

with the ground. Policy shall be 

consistent with industry standards.

Auditor observes 

whether Operation has 

a policy regarding 

placement of productcontact containers in 

direct contact with the 

ground. Auditor 

observes current 

practices for 

compliance with 

policy.

Operation develops 

the policy. Retraining 

is performed and 

documented. 

P-8.6 Operation has 

written policy 

regarding inspection 

of food contact 

containers and bins 

prior to use.

WP Food-contact totes, bins, packing and 

packaging materials, other harvest 

containers, and pallets shall be 

visually inspected, clean, intact and 

free of any foreign materials prior to 

use. Containers shall be sufficiently 

maintained so as not to become a 

source of contamination.

Auditor observes 

whether Operation has 

a policy regarding 

inspection of food 

contact containers and 

observes current 

practices for 

compliance with 

policy.

Operation develops 

the policy. Retraining 

is performed and 

documented. 
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-8.7 Operation has 

written policy 

regarding acceptable 

product-contact 

containers.

WP ● The types and construction of productcontact containers and packing 

materials shall be appropriate to the 

commodity being handled and suited 

for their intended purpose. Produce 

shall only be stored in clean and 

sanitary containers.

Auditor observes 

whether Operation has 

a policy regarding 

what types of 

containers and packing 

materials are 

acceptable for use, and 

observes current 

practices for 

compliance with the 

policy.

Operation develops 

the policy. 

Appropriate productcontact containers are 

obtained. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-8.8 Operation has 

written policy 

prohibiting use of 

product-contact 

containers for nonproduct purposes 

unless clearly 

marked or labeled 

for that purpose.

WP Food-contact totes, bins and other 

product-contact containers shall not be 

used for other purposes unless the 

Operation has a policy or procedure 

that clearly designates approved nonproduct contact uses and how the 

containers are to be marked or labeled 

for that purpose. Food-contact totes, 

bins and other packing containers and 

equipment that are no longer cleanable 

shall not be used for packing but can 

be used for other non-food uses if 

clearly marked/labeled.

Auditor observes 

whether Operation has 

a policy prohibiting 

use of product-contact 

containers for other 

uses unless otherwise 

labeled, and observes 

current practices for 

compliance with the 

policy.

Operation develops 

the policy. Retraining 

is performed and 

documented. 

P-8.9 Pallets shall be kept 

clean and in good 

condition as 

appropriate for their 

intended use.

Operation inspects pallets prior to use 

for conditions that may be a source of 

produce contamination. Pallets that 

are not cleanable are removed from 

use. Pallets and other wooden 

surfaces are properly dried after being 

washed. 

Auditor observes 

pallets for compliance.

Operation removes 

noncompliant pallets 

from use. 
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P-9: Storage

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-9.1 Product storage areas 

and conditions shall 

be appropriate to the 

commodities stored.

Produce storage locations and 

conditions shall not pose a risk of 

produce contamination, consistent 

with industry standards or prevailing 

regulation.

Auditor observes 

storage area for 

evidence that stored 

produce is protected 

from contamination.

Operation designates 

and maintains storage 

areas to prevent 

contamination of 

produce.

P-9.2 Iced produce is 

handled so as not to 

serve as a source of 

contamination. 

Protective measures are provided in 

areas where iced product is stored over 

food items in order to prevent melting 

ice from contaminating product below.

Auditor inspects any 

iced product on 

premises for 

compliance.

Operation develops 

written procedures to 

handling and storage 

of iced product. 

Operational 

deficiencies are 

corrected. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-9.3 Non-product storage 

areas shall be 

maintained so as not 

to be a source of 

product or materials 

contamination.

Areas designated to store materials, 

whether indoors or out, shall be clean, 

well ventilated, and designed to 

protect materials and produce from 

contaminants. 

Auditor observes 

storage area for 

evidence that stored 

materials are protected 

from contamination.

Operation designates 

and maintains storage 

areas to prevent 

contamination of nonproduct materials.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-9.4 Materials and 

packaging materials 

shall be protected 

from contaminants.

Materials stored in uncovered areas 

shall be protected from condensate, 

sewage, dust, dirt, chemicals, allergens 

or other contamination. Materials shall 

be stored off the floor/ground on 

pallets, slip-sheets or stands and 

covered where applicable.

Auditor observes 

stored materials for 

protection from 

contamination.

Operation develops 

and implements 

written procedures for 

materials storage. 

Operational 

deficiencies are 

corrected. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-9.4.a The operation has a 

procedure to ensure 

that purchased 

materials, work in 

progress and finished 

products are used in 

the correct order, and 

within the allocated 

shelf life when 

applicable.

WP The operation clearly outlines a

procedure in which work in progress, 

finished products, purchased 

materials, such as packing materials, 

cleaning chemicals and any other 

materials that may have an impact on 

food safety, shall be used in 

accordance with the allocated shelf 

life, i.e. materials used on a first in 

first out basis or in the correct order as

established by the policy or procedure.

Auditor observes the 

procedure for stock 

management is 

implemented 

effectively.

Operation develops 

and implements 

effective procedures 

for stock management.

P-9.5 Adequate space shall 

be maintained 

between rows of 

stored materials to 

allow cleaning and 

inspection. 

WP Materials shall be stored away from 

walls and ceilings. Written procedures 

shall be followed to guarantee the 

proper cleaning, inspection and 

monitoring for pest activity in storage 

areas.

Auditor reviews the 

procedures and 

observes the storage 

area to determine 

whether storage 

practices allow 

cleaning, inspection 

and monitoring for 

pest activities. 

Operation develops 

and implements a 

written procedure, and 

moves material into 

compliance.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-9.6 All chemicals shall 

be stored in a secure 

separate area. All 

chemicals shall be 

properly labeled.

Chemicals, including cleaning and 

maintenance compounds and 

lubricants, when not being used, are 

stored away from product handling 

areas and in a manner that inhibits 

unauthorized access. Food-grade and 

non food-grade lubricants are kept 

separate from each other.

Auditor observes that 

chemicals are properly 

labeled and storage 

practices protect 

against product 

contamination.

Operation designates a 

secure area for storage 

of chemicals. 

Unlabeled chemicals 

are labeled or properly 

discarded. Retraining 

is performed and 

documented. 

P-9.7 When produce is 

cooled, it is cooled to 

temperatures 

appropriate to the 

commodity 

according to current 

established 

regulatory or 

industry standards. 

R When required for food safety or by 

industry guidelines, steps are taken to 

minimize temperature increases and 

minimize the time between produce 

receipt and cooling at the Operation. 

The product temperature and 

equipment control mechanisms are 

calibrated and monitored at a defined 

frequency and temperatures are kept 

appropriate to the commodity.

Records are maintained.

Auditor reviews 

cooling procedures for 

commodities requiring 

temperature control, 

and reviews 

temperature logs for 

evidence of 

compliance.

Operation develops 

and implements 

procedures to monitor 

cooling procedures in 

compliance with 

current established 

regulatory or industry 

standards. 

P-9.8 Where temperature 

control is required 

for food safety, 

cooling facilities 

shall be fitted with 

temperature 

monitoring 

equipment or 

suitable temperature 

monitoring device. 

R Temperature monitoring equipment 

shall be located in all temperature

controlled areas, and shall be located 

so as to accurately monitor the 

temperature. Temperature measuring 

devices shall be monitored and 

calibrated on a scheduled basis or as 

needed.

Auditor observes 

evidence that 

temperatures are being 

monitored, and 

reviews calibration 

records and 

procedures for 

temperature 

monitoring equipment.

Operation establishes 

and implements 

temperature 

monitoring 

procedures.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-9.9 Cooling equipment 

shall be maintained 

so as not to be a 

source of product 

contamination.

WP,R ● Cooling equipment (e.g. hydrocoolers, 

air coolers), shall be inspected, all 

debris removed, and cleaned and 

sanitized according to written 

sanitation SOPs.

Auditor reviews 

cooling equipment 

maintenance and 

sanitation procedures 

and inspects 

equipment for 

compliance with 

procedures.

Operation develops 

and implements 

effective maintenance 

and sanitation 

procedures.
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P-10: Transportation (Packinghouse to Customer)

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-10.1 There is a written 

policy for 

transporters and 

conveyances to 

maintain a specified 

temperature(s) 

during transit.

WP When refrigerated transport is required 

for food safety, transporters have 

written, predetermined temperature 

ranges for commodities being 

transported.

Auditor reviews 

documentation of 

predetermined 

temperature ranges.

Operation develops, 

documents and 

implements 

temperature range 

requirements.

P-10.2 Prior to loading, the 

vehicle shall be precooled. 

WP,

R

When refrigerated transport is required 

for food safety, the proper temperature 

for pre-cooling is appropriate to the 

type of produce and as specified by 

documented protocol.

Auditor reviews 

documented protocol, 

shipping checklist 

records, and observes 

vehicles during 

loading for 

compliance.

Operation develops, 

documents and 

implements vehicle 

cooling requirements.

P-10.3 The refrigerated 

transport vehicles 

shall have properly 

maintained and fully 

functional 

refrigeration 

equipment.

WP When refrigerated transport is required 

for food safety, Operation has a 

written policy that refrigerated 

transportation equipment shall be 

controlled by a thermostatic device as 

necessary to maintain temperatures in 

the cargo area for the particular type 

of produce being transported and as 

specified by documented protocol.

Auditor reviews 

written policy and 

observes refrigerated 

transport vehicles in 

use at the time of the 

audit.

Operation develops, 

documents and 

implements a policy. 

Retraining is 

performed and 

documented. 

P-10.4 Where required, 

temperatures of 

product are taken 

and recorded prior to 

or upon loading.

WP, 

R

When refrigerated transport is required 

for food safety, Operation has a 

written procedure for when and how to 

measure product temperatures prior to 

or during loading.

Auditor reviews 

written procedure and 

observes temperature 

monitoring procedures 

during loading.

Operation develops, 

documents and 

implements a policy. 

Retraining is 

performed and 

documented. 
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-10.5 The Operation shall 

have a policy, 

written procedures, 

and a checklist to 

verify cleanliness 

and functionality of 

shipping units (e.g., 

trailer).

WP,

R

● Shipping units shall be clean, 

functional and free of objectionable 

odors before loading, in compliance 

with current industry practices or 

regulatory requirements for that 

commodity. Refrigeration units, if 

used, must be in working order. 

Procedures prohibit raw animal or 

animal product transport, or other 

materials that reasonably may be a 

source of contamination with 

biological, chemical (including 

allergens) or physical hazards, unless 

appropriate risk mitigation strategies 

are in place. Shipping units shall be 

washed between loads if prior 

transport included materials that 

reasonably may be a source of 

contamination. A responsible 

individual shall sign or initial the 

completed checklist or inspection 

report.

Auditor reviews 

cleaning procedures 

and inspection records 

and inspects produce 

transport vehicles for 

cleanliness.

Operation develops 

the policy and written 

procedures. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-10.6 Loading/unloading 

procedures and 

equipment shall 

minimize damage to 

and prevent 

contamination of 

produce.

Personnel responsible for the loading 

and unloading of produce shall take 

steps to minimize the potential of 

physical damage to produce, which 

can introduce and/or promote the 

growth of pathogens. 

Loading/unloading equipment shall be 

clean and well maintained and of 

suitable type to avoid contamination 

of the produce.

Auditor observes 

loading/unloading 

procedures for 

evidence of practices 

that result in excessive 

damage to produce. 

Auditor observes 

loading/unloading 

equipment for 

suitability and 

condition.

Operation revises 

procedures. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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LOGO USE (L)

L-1: Food Safety Plan or Quality Manual

Req. # Requirement DOC MAN Procedure Verification Corrective Action

L-1.1 The Operation's food 

safety plan or quality 

manual contains 

procedures on how 

the USDA GAP & 

GHP logo will be 

used.

WP ● The Operation shall have a written 

policy describing proper use of the 

logo including having attained 

approved GAP & GHP program status 

by meeting the acceptance criteria for 

the audit being performed covering all 

scopes of the audit which are 

applicable to their Operation. All 

commodities grown, handled or 

processed by the Operation must be 

covered by the audit.

Auditor shall review 

the Food Safety Plan 

for detailed and 

complete procedures 

on logo use.

The Operation shall 

develop procedures on 

USDA GAP & GHP 

logo use.

L-1.2 There is a designated 

person to be 

responsible for the 

control of inventory 

bearing the logo.

WP ● The Operation shall designate, in their 

food safety plan or quality manual, an 

individual or individuals that are 

responsible for the control of inventory 

(any containers or labels) bearing the 

logo or language.

Auditor verifies there 

is a designated person 

responsible for control 

of inventory bearing 

the logo.

Operation designates 

an individual, in their 

food safety plan or 

quality manual, to be 

responsible for the 

inventory bearing the 

USDA logo.
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L-2: Traceability and Recall Programs

Req. # Requirement DOC MAN Procedure Verification Corrective Action

L-2.1 The Operation uses 

the USDA GAP & 

GHP logo only on 

packages, containers, 

or consumer units 

which are traceable.

WP ● The Operation shall have a policy that 

prohibits the use of the logo on any 

packages, containers or consumer units 

that are not part of the established 

traceability program.

Auditor reviews policy 

and observes packages 

labeled at the facility 

with the USDA GAP

& GHP logo are 

traceable.

Operation develops a 

policy.
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L-3: Approved Suppliers

Req. # Requirement DOC MAN Procedure Verification Corrective Action

L-3.1 The Operation has 

supplied a list of 

approved suppliers to 

the local Federal or 

State auditor's office.

R ● Operation supplies the local Federal or 

State office who conducts the audit, 

with a current list of approved 

suppliers. The Operation will notify 

the office of any additions to the 

suppliers list as well as if a supplier is 

no longer in compliance and must be 

removed from the list.

Auditor reviews record 

showing all names of 

suppliers and verifies 

dates of when their 

names were given to 

the local auditor’s 

office.

Operation supplies list 

to the local office.

L-3.2 All suppliers 

currently in use by 

the Operation are 

listed on the supplied 

list of approved 

suppliers.

WP,

R

● Operation procures ingredients and 

materials only from approved 

suppliers.

Auditor reviews 

receipt records and 

compares suppliers of 

ingredients and 

materials against list of 

approved suppliers.

Operation updates 

and/or creates list of 

approved suppliers, 

and procures only 

from these suppliers.

L-3.3 All suppliers have 

successfully 

completed and met 

the requirements of a 

USDA approved 

GAP & GHP audit 

(USDA GAP&GHP 

audit, commodity 

specific audit, 

Produce GAPs 

Harmonized Audit, 

or Harmonized GAP 

Plus+ Audit).

R ● The Operation requires the 

packinghouses, distribution centers 

and other post-farm gate operations 

who wish to utilize the logo, to have an 

approved supplier program, which at a 

minimum verifies that all suppliers of 

fresh produce have successfully 

completed and met the requirements of 

a USDA approved GAP & GHP audit. 

All audits must be conducted by a 

licensed USDA auditor under federal 

oversight.

Auditor reviews 

evidence of suppliers 

having met the 

requirements of a 

USDA GAP & GHP 

audit.

Operation ceases to 

use non-compliant 

suppliers. Noncompliant suppliers 

must discontinue use 

of the logo 

immediately.
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L-4: GAP & GHP Logo Approved Use

Req. # Requirement DOC MAN Procedure Verification Corrective Action

L-4.1 The logo is only used 

on products, 

processes, and 

packaging as 

approved on the SC652.

R ● The Operation shall have a copy of the 

approved SC-652 which lists the 

products, processes, and packaging 

types the logo is approved to be used 

on. The logo is being used as 

approved.

Auditor verifies that 

the Operation is only 

using the logo as 

approved on the SC652.

Operation discontinues 

use of packaging on 

unapproved products, 

processes, and/or 

packaging. 

L-4.2 All packaging or 

labels, which bear 

the GAP & GHP 

logo, are accountable 

items.

WP,

R

● The Operation shall have a policy 

stating all packaging or labels are 

accounted for.

Auditor reviews 

policy.

Operation develops 

policy that ensures 

accountability of all 

packaging or labels 

bearing the logo.

L-4.3 The Operation’s 

inventory list of these 

packaging or labels is 

maintained and 

current.

R ● The Operation shall have an inventory 

list of any packaging or labels bearing 

the logo or language.

Auditor reviews 

records for accuracy 

and to ensure 

inventory list is up to 

date.

Operation develops 

and maintains an 

inventory list of all 

packaging and labels.

L-4-4 The logo is only used 

on packaging and 

labels that are clean 

and bright in 

appearance, without 

marks, stains, or 

other evidence of 

previous use.

R ● The Operation is only using packaging 

and labels that are clean and bright in 

appearance without marks, stains, or 

other evidence of previous use.

Auditor verifies that 

packaging and labels 

are clean and bright in 

appearance.

Operation updates 

their practices to use 

the logo on packaging 

and labels that are 

clean and bright in 

appearance.
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TOMATO AUDIT PROTOCOL OPEN-FIELD PRODUCTION AND HARVESTING

TOF-1: Management Responsibility

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-1.1 Operation has current 

copies of the 

Commodity Specific 

Food Safety 

Guidelines for the 

Fresh Tomato Supply 

Chain, Food Safety 

Programs and 

Auditing Protocol for 

the Fresh Tomato 

Supply Chain, the 

relevant Harmonized 

Food Safety 

Standard, and 

additional food 

safety documents as 

required by state 

and/or federal 

regulation.

R ● Operation has a current copy of the 

Guidelines, this audit document and all 

other required documents.

Auditor observes the 

current copies at the 

operation.

Operation obtains 

current copies.
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TOF-2: Self Audits

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-2.1 Operation has 

procedures for 

conducting selfaudits and conducts 

self-audits to verify 

compliance with 

established internal 

policies and 

procedures.

WP, 

R

● In addition to the requirements of the 

Harmonized Standards, the operation’s 

self-audit procedure ensures 

compliance with established internal 

policies and procedures, Commodity 

Specific Food

Safety Guidelines for the Fresh 

Tomato Supply Chain, these Tomato 

Metrics, and additional food safety 

documents as required by state and/or 

federal regulation.

Auditor reviews the 

self-audit procedures, 

and records of selfaudits to verify 

compliance with the 

procedures.

Operation develops 

and maintains selfaudit program, with 

corrective actions 

preventive measures, 

documentation and 

follow-up.
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TOF-3: Field History and Pre-harvest Assessments

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-3.1 If the field is subject 

to flooding, operation 

has an established 

decision tree or 

corrective action plan 

in the event of 

flooding in the 

production area. 

Procedures prohibit 

harvest of product 

that has come into 

contact with flood 

waters.

WP ● Flooding is defined as the uncontrolled 

introduction of large amounts of water 

of unknown quality into the production 

area that is reasonably likely to come 

into contact with the edible portion of 

the crop, or otherwise cause 

adulteration of the crop. If the field is 

subject to flooding, procedure is 

established that includes a decision 

tree or corrective action to take in the 

event of flooding in a production area.

Procedure specifies performance of a 

written risk assessment, which will 

consider whether there is an increased 

potential of contamination from the 

flood event. If warranted by the risk 

assessment, a no-harvest zone is 

positioned so that operations in the 

non-flooded zone are not compromised 

by the flooded zone; for example, 10 

feet.

If the field is subject to 

flooding, auditor 

verifies that the 

operation has a 

policy/procedure 

regarding flooded 

fields. Auditor looks 

for evidence of 

flooding in the field. 

If the field has flooded 

since the last audit, the 

auditor observes the 

operation's risk 

assessment for current 

acceptability of the 

field and/or crop.

Operation develops a 

written procedure for 

flooded fields. 

Operation must 

obtain/develop a 

written risk assessment 

for the relevant field.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-3.2 Operation shall 

conduct the required 

Combined 

Harmonized 

Standard F-9.1 preharvest risk 

assessment no more 

than five (5) days 

from the first 

scheduled harvest 

date.

A ● The environmental assessment is 

reperformed, and documented, for 

environmental conditions that 

reasonably may have changed since 

the last assessment, including flooding, 

adequacy of water sources for their 

intended use, adjacent land uses, 

animal migrations, debris, worker 

health and hygiene, or other potential 

sources of fruit adulteration.

Auditor reviews the 

reassessment 

document, including 

corrective action 

documents for 

mitigations or 

deficiencies identified 

in the pre-production 

risk assessment, and 

confirms the 

assessment occurred 

within five (5) days of 

the first scheduled 

harvest date.

Operation develops or 

modifies the 

document, or reviews, 

as needed. Perform 

training as needed.
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Version 3.0 (February 8, 2021)

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TOF-4: Workers Health/Hygiene and Toilet/Handwashing Facilities

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-4.1 A response plan is in 

place in the event of 

a major spill or leak 

of field sanitation 

units.

WP, 

R

● A written corrective response plan is 

developed and implemented in the 

event of a major leak or spill.

Auditor verifies 

existence of the plan 

and interviews the 

responsible person for 

knowledge.

Operation prepares or

edits the plan. Retrain 

or replace the 

responsible person.

TOF-4.2 If hand wash water 

tanks are used, they 

are cleaned and 

sanitized and the 

water is changed 

periodically.

R ● Water tanks used to provide hand wash 

water shall be maintained at a 

prescribed frequency in a clean and 

sanitary manner.

Auditor reviews 

cleaning and sanitizing 

protocol and service 

logs, and visually 

observes condition of 

water tanks for signs 

of noncompliance.

Clean and sanitize the 

tank, replace water to 

compliance.

TOF-4.3 Policies shall require 

hand washing with 

soap and potable 

water at the 

appropriate time, 

such as before 

starting work, after 

use of toilet facilities, 

after breaks and 

when hands may 

have become 

contaminated. Policy 

shall apply to 

employees, outside 

contractors, 

inspectors, and 

visitors. Compliance 

is emphasized by 

management. 

WP, 

R

● Operation shall have a written SOP 

regarding hand washing practices. 

Operation management reinforces 

importance of and compliance with 

handwashing policy. Sanitizers may 

not be used in lieu of soap and water 

hand washing, but may be used to 

supplement. If gloves are used when 

contacting tomatoes or food contact 

surfaces, policies will clearly 

communicate that gloves are not a 

replacement for good handwashing 

practices.

Auditor observes 

handwashing practices 

of employees and 

visitors for 

compliance. If 

handwashing practices 

are observed to be 

compliant, auditor will 

judge management 

emphasis to be 

sufficient. Affected 

product is evaluated 

for potential 

contamination

and disposition.

SOP is developed or 

revised. Retraining is 

performed. 

Management increases 

frequency of or 

approach to 

reinforcing hand 

washing policy.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-4.4 If gloves are used, 

there must be a 

written SOP 

regarding their use.

WP, 

R

● If gloves are used for product or food 

contact purposes, operation shall have 

a written policy and SOP regarding 

their use, maintenance and disposal, 

including cleaning of reusable gloves, 

not taking gloves into restrooms or 

eating areas, replacing gloves that may 

be damaged or have become a source 

of contamination. The SOP should 

also address limitations of use of nonsanitary gloves (i.e., work gloves).

The SOP will require that reusable 

gloves shall not be taken home by 

workers for cleaning and sanitizing.

If gloves are used, 

auditor reviews the 

SOP, records of SOP 

performance, and 

visually verifies that 

glove use is consistent 

with the SOP; i.e., 

gloves at the beginning 

of tomato handling 

activities are clean and 

not damaged; workers 

are observed to not 

take gloves into 

restrooms or eating 

areas; and that gloves 

are not taken into 

restrooms or eating 

areas.

SOP is developed or 

revised. Noncompliances are 

corrected on site. 

Retraining is 

performed.
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Version 3.0 (February 8, 2021)

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TOF-5: Pesticides

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-5.1 Pesticide Usage 

Water used to mix 

pesticides meets 

FDA E. coli 

standards for water in 

21 CFR § 112.44(a); 

i.e., no detectable 

generic E. coli in 100 

mL of agricultural 

water.

R ● Operation has a written policy 

requiring foliar-application pesticides 

to be diluted only with water that 

meets FDA microbial standards for 

post-harvest agricultural water. 

Operations will have documentation 

demonstrating compliance, such as test 

results for the water source used.

Auditor reviews the 

policy and inspects 

pesticide mixing and 

application records.

Operation develops a 

written policy. 

Retraining of pesticide 

applicator as needed. If 

unknown or nondrinking quality water 

was used to prepare 

pesticides, then test the 

water source for 

compliance with FDA 

E.coli standards for 

post-harvest 

agricultural water. Do 

not harvest product

unless water test 

results demonstrate 

compliance.
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Version 3.0 (February 8, 2021)

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TOF-6: Water Used in Growing Activities

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-6.1 Non-Foliar The 

water test meets FDA 

E. coli standards for 

foliar application 

water as described in 

21 CFR § 112.44(b).

R ● Written procedure requires a BAM or 

other testing procedure validated for 

generic E.coli quantitation in water.

Auditor reviews water 

test results and any 

corrective actions 

taken to bring the 

water source into 

compliance.

Perform a sanitary 

survey for each 

affected water source, 

perform any remedial 

action as required and 

retest. If the retest also 

exceeds the standard, 

further evaluate 

potential corrective 

actions, such as 

treatment, retreatment, 

or discontinue use of 

source.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-6.2 Foliar The water test 

meets FDA standards 

for water in 21 CFR 

§ 112.44(a); i.e., no 

detectable generic E. 

coli in 100 milliliters 

(mL) of agricultural 

water. 

R ● Written procedure requires a BAM or 

other testing procedure validated for 

generic E.coli quantitation in water.

Auditor reviews water 

test results and any 

corrective actions 

taken to bring the 

water source into 

compliance. If 

tomatoes have been 

contacted with 

noncompliant water, 

auditor reviews the 

risk assessment and 

disposition.

Perform a sanitary 

survey for each 

affected water source, 

perform any remedial 

action as required and 

retest. If the retest also 

exceeds the standard, 

further evaluate 

potential corrective 

actions, such as 

treatment, retreatment, 

or discontinue use of 

source. Operation 

shall evaluate tomatoes 

that have been 

contacted with 

noncompliant water to 

assess food safety risk. 

The assessment is 

documented and 

tomatoes dispositioned 

accordingly.
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Version 3.0 (February 8, 2021)

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TOF-7: Soil Amendments

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-7.1 If fertilizers 

containing manures 

or composts are used, 

only properly treated 

(composted or heat 

treated) manures are 

allowed for use in 

fields. Biosolids are 

not permitted.

R ● Soil amendment use records are 

available, reviewed and current 

(conventional or organic). If treated 

manures are used, records of 

composition, dates of treatment, 

methods utilized, application dates and 

letter of guarantee, certificate of 

analysis (COA) or any test results or 

verification data demonstrating 

compliance with process or microbial 

standards must be documented. For 

non-composted animal by-productscontaining soil amendments, the 

operations shall retain a certificate or 

letter showing the lethality of the 

process. Compost applications shall 

be no less than 45 days prior to 

harvest.

Auditor reviews the 

amendment use 

documents and records 

demonstrating 

compliance with 

prevailing national or 

local established 

composting or heat 

treatment standards or 

guidelines.

Operations must obtain 

the necessary 

documents. If the 

documents cannot be 

obtained, field cannot 

be harvested for that 

crop cycle.
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TOF-8: Sanitizing Agents Used During Harvest

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-8.1 All compounds used 

to clean or sanitize 

food contact 

containers, tools, 

utensils, equipment 

or other food contact 

surfaces are 

approved for that use 

by the US EPA, FDA 

or other prevailing 

agency. Actual use 

conforms to label 

directions.

R ● Documentation is available to 

demonstrate that cleaning and 

sanitizing products are approved for 

their use and are used according to 

label directions. Sanitizing chemicals 

uses shall be documented.

Auditors review 

documentation and 

supplies to confirm 

approved use, and 

interview individuals 

responsible for their 

use for knowledge of 

approved use. Auditor 

reviews records of use, 

and visually observes 

use, to verify 

compliance with label 

directions.

Non-compliances are 

corrected on-site. 

Records are reviewed 

for potential product 

adulteration. 

Retraining is 

performed.
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TOF-9: Product Containers

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-9.1 Reusable product 

bins, trays and 

containers are made 

of impervious 

materials that can be 

cleaned and 

sanitized.

WP ● Written SOP requires that all re-usable 

product containers are made of 

materials that can be sanitized, or clean 

and sanitary liners are used. Wood is 

not an appropriate food contact 

surface. Procedures require damaged 

containers that are no longer easily 

cleanable or sanitary shall be removed 

from service of food contact purposes.

Auditor reviews SOP, 

visually observes 

product bins, trays and 

containers and their 

use for evidence of 

noncompliance.

Policy is developed or 

revised. Noncompliances are 

corrected. Operation 

makes a commitment 

for phasing out 

nonconforming 

product containers; 

e.g., wooden bins, in a 

reasonable timeline. 

Retraining is 

performed.

TOF-9.2 Operation has a 

policy that requires 

bins trays and boxes 

made of corrugated 

cardboard are for 

single use only.

WP ● Written policy prohibits re-use of 

single-use bins, trays and boxes made 

of corrugated cardboard or fiberboard 

for product contact purposes.

Auditor reviews 

policy, observes 

practices related to 

corrugated cardboard 

or fiberboard bins, 

trays and boxes for 

evidence of 

noncompliance.

Policy is developed or 

revised. Tomatoes that 

have been packed in a 

reused cardboard or 

fiberboard bin, tray or 

box shall be corrected, 

which may include 

tomatoes are 

segregated, washed 

and repacked in new 

containers, or 

discarded. Retraining 

is performed.

TOF-9.3 SOP specifies that 

workers do not 

remove harvest 

buckets from the 

field. 

WP ● Written SOP prohibits taking harvest 

buckets home.

Auditor reviews SOP 

and observes practices 

related to handling of 

harvest buckets.

Policy is developed or 

revised. Retraining is 

performed.
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Version 3.0 (February 8, 2021)

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TOF-10: Field Packing of Tomatoes

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TOF-10.1 Packing containers 

shall be labeled as to 

their source, and to 

identify that the 

product has been 

field packed.

R ● Cartons or other primary packaging 

shall be labeled accurately and shall 

clearly communicate the tomatoes 

were packaged in the field.

Auditor observes 

packaging for accuracy 

and is clearly labeled 

as field packed.

Operation ceases to 

use non-compliant 

packaging or labeling. 

Noncompliances are 

corrected on-site.
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TOMATO AUDIT PROTOCOL PACKINGHOUSE

TPH-1 Management Responsibility

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-1.1 Operation has current 

copies of the 

Commodity Specific 

Food Safety 

Guidelines for the 

Fresh Tomato Supply 

Chain, Food Safety 

Programs and 

Auditing Protocol for 

the Fresh Tomato 

Supply Chain, the 

relevant Harmonized 

Food Safety 

Standard, and 

additional food

safety documents as 

required by state 

and/or federal 

regulation.

R ● Operation has a current copy of the 

Guidelines, this audit document and all 

other required documents.

Auditor observes the 

current copies at the 

operation.

Operation obtains 

current copies.

TPH-1.2 Operation has been 

registered or 

permitted as a food 

handling 

establishment as 

required by state or 

federal regulation. 

R ● Operation demonstrates knowledge of 

prevailing requirements and has a copy 

of required permit(s) or registration.

Auditor reviews copies 

at the operation to 

verify they are current 

and complete.

Operation applies for 

or renews required 

permits or registration.
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TPH-2: Raw Material Sourcing

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-2.1 The operation has a 

policy and takes 

affirmative steps to 

ensure that all fresh 

tomatoes that are 

packed or stored in 

the facility are grown 

following 

requirements in 

Tomato Metrics 

Audit - Open Field 

Production, Harvest 

and Field Packing. 

WP ● The packinghouse requires all raw 

product suppliers to provide evidence 

of food safety/GAP programs and 

compliance. Such evidence must 

include sufficient documentation to 

demonstrate that the supplier complies 

with the requirements in Tomato 

Metrics Audit - Open Field 

Production, Harvest and Field 

Packing.

Auditor reviews policy 

and verifies that 

operation’s evidence 

of supplier compliance 

with food safety/GAP 

programs is in 

compliance with the 

operation’s policy.

Operation obtains 

required 

documentation. 

Operation ceases 

accepting or shipping 

product from nonapproved suppliers, 

until sufficient 

documentation 

demonstrating 

compliance is received 

by the operation.

TPH-2.2 Operation has 

procedures to ensure 

that the tomato 

staging area and 

staging practices do 

not pose a risk of 

tomato 

contamination.

WP ● The packinghouse staging area is 

designed so that overhead areas do not 

pose a contamination risk of uncovered 

tomatoes, or that tomatoes are 

protected during staging to prevent 

contamination.

Auditor reviews 

procedures and 

inspects staging area 

for potential sources of 

contamination.

Operation develops 

procedures and/or 

redesigns staging area 

or staging practices to 

prevent reasonably 

likely to occur 

opportunities for 

contamination. 

Tomatoes that have 

become contaminated 

are discarded.
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TPH-3: Traceability

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-3.1 Lot identification 

shall be labeled on 

all cases and clearly 

legible. 

WP ● A product coding system is in place 

where product or raw material shall be 

labeled with grower and lot 

identification, and coded to enable 

access to date of harvest and/or 

packing, origin (name of farm, grower 

and/or packing location), and country 

of origin for traceback purposes.

Auditor reviews 

coding procedures, 

observes cases for 

appropriate coding, 

and verifies 

compliance by review 

of records.

Boxes with missing, 

inaccurate or illegible 

coding are labeled 

with appropriate 

identification. 

Procedure is developed 

or revised. Retraining 

is performed.
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TPH-4: Self Audits

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-4.1 Operation has 

procedures for 

conducting selfaudits and conducts 

self-audits to verify 

compliance with 

established internal 

policies and 

procedures

WP,

R

● In addition to the requirements of the 

Harmonized Standards, the operation’s 

self-audit procedure ensures 

compliance with established internal 

policies and procedures, the 

Commodity Specific Food Safety 

Guidelines for the Fresh Tomato 

Supply Chain, these Tomato Metrics, 

and additional food safety documents 

as required by state and/or federal 

regulation.

Auditor reviews the 

self-audit procedures, 

and records of selfaudits to verify 

compliance with the 

procedures.

Operation develops 

and maintains selfaudit program, with 

corrective actions 

preventive measures, 

documentation and 

follow-up.
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Version 3.0 (February 8, 2021)

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TPH-5: Product Containers and Packaging Materials

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-5.1 Tomato-contact bulk 

bins, gondolas, totes 

and trays shall not be 

constructed of wood.

WP ● In accordance with the Post-Harvest 

Operations Harmonized Standard P8.7 regarding acceptable productcontact containers, operation has

eliminated or has a plan to eliminate 

the use of wooden product contact 

containers.

Auditor reviews SOP, 

visually observes 

product bins, trays and 

containers and their 

use for evidence of 

non-compliance.

Policy is developed or 

revised. Noncompliances are 

corrected. Operation 

removes nonconforming product 

containers from food 

contact purposes. 

Retraining is 

performed. Operation 

develops a plan to 

phase out wooden 

bins, and demonstrates 

compliance with the 

plan.

TPH-5.2 The operation has 

written procedures 

for cleaning and 

sanitizing of produce 

food contact 

containers, requiring 

that bulk bins, 

gondolas, totes and 

trays are cleaned and 

sanitized periodically 

and is documented.

WP, 

R

● Written SOP is established to ensure 

that bulk bins, gondolas, totes, trays 

and other food contact containers and 

implements are adequately cleaned and 

sanitized at a frequency sufficient to 

maintain clean and sanitary food 

contact surfaces, and documentation of 

compliance is maintained.

Auditor reviews SOP, 

cleaning logs and 

records, interviews 

responsible individuals 

for knowledge of the 

SOP and observes 

containers, employees 

and records for 

evidence of 

compliance.

Policy is developed or 

revised. Noncompliances are 

corrected on site. 

Retraining is 

performed.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-5.3 Operation has a 

policy that requires 

bins trays and boxes 

made of corrugated 

cardboard are for 

single use only. 

R ● Written policy prohibits re-use of 

single-use bins, trays and boxes made 

of corrugated cardboard or fiberboard 

for product contact purposes. 

Repacking of tomatoes into a 

corrugated cardboard container that

contained the same lot of tomatoes is 

acceptable, provided the container is 

clean, sanitary and properly labeled.

Auditor reviews 

policy, observes 

practices related to 

corrugated cardboard 

or fiberboard bins, 

trays and boxes for 

evidence of noncompliance.

Policy is developed or 

revised. Tomatoes that 

have been packed in a 

re-used cardboard or 

fiberboard bin, tray or 

box shall be corrected, 

which may include 

tomatoes are 

segregated, washed 

and repacked in new 

containers, or 

discarded. Retraining 

is performed.
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TPH-6: Packinghouse Condition and Equipment

A. General Building 

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-6.1 Facility is 

constructed/ arranged 

to allow separation of 

incoming, in-process 

and finished 

products. 

R ● Facilities or processes assure 

separation and positioning of incoming 

raw materials so as not to become a 

source of contamination of in-process 

and finished product.

Auditor observes 

placement of incoming 

raw materials, inprocess and finished 

products for 

opportunities for crosscontamination. 

Procedures are 

developed or revised. 

Non-compliances are 

corrected on site. 

Retraining is 

performed.

TPH-6.2 Operation has 

procedures that 

minimize the 

accumulation of 

standing water. 

WP ● If floor drains exist, they are adequate, 

functional, free of obstruction and are 

properly maintained and cleaned 

sufficient to prevent them from 

becoming sources of contamination. If 

standing water exists, it is removed 

from floors and floors cleaned in a 

manner and at a frequency sufficient to 

prevent creation of a source of 

contamination.

Auditor observes floor 

drains and evidence of 

standing water for 

compliance with 

procedures.

Floor drains are 

installed, repaired or 

maintained, or 

procedures are 

modified, to prevent 

standing water from 

becoming a potential 

source of 

contamination.
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B. Facility and Equipment

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-6.3 All food contact 

surfaces are made of 

material and 

designed to be easily 

cleaned and 

sanitized, and are 

maintained in good 

condition.

● All tomato contact surfaces and 

equipment are made of materials, 

designed or constructed to be easily 

cleaned and sanitized, all food contact 

surfaces are free of rust or corrosion, 

and seams between food contact 

surfaces are smooth or accessible for 

cleaning.

Auditor observes 

product contact 

surfaces and 

equipment and their 

use for evidence of 

non-compliance.

Non-compliances are 

corrected or replaced. 

Operation makes a 

commitment for 

phasing out nonconforming tomato 

contact surfaces and 

equipment, in a 

reasonable timeline. 

Retraining is 

performed.

TPH-6.4 Wood is not used as 

a food contact 

surface. 

● Operation has eliminated, or has a plan 

to eliminate, use of wooden items as 

food contact surfaces.

Auditor inspects 

facility for evidence of 

wooden food contact 

surfaces.

Operation that still 

utilizes wood as a food 

contact surface has a 

plan to phase out such 

surfaces, and is in 

compliance with the 

plan.

TPH-6.5 SDS are on file for 

all chemicals used in 

the facility, and 

readily accessible.

R ● Operation maintains a list of all 

chemicals approved for use in facility 

and maintains SDS for all. SDS are in 

a location easily accessible by 

employees.

Auditor reviews SDS 

binder and observes 

chemicals in facility 

for evidence of 

compliance.

Obtain missing SDS. 

Relocate SDS.
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TPH-7: Worker Health/Hygiene and Toilet/Handwashing Facilities

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-7.1 If portable hand wash 

water tanks are used, 

they are cleaned and 

sanitized and the 

water is changed 

periodically.

R ● Water tanks used to provide hand wash 

water shall be maintained at a 

prescribed frequency in a clean and 

sanitary manner.

Auditor reviews 

cleaning and sanitizing 

protocol and service 

logs, and visually 

observes condition of 

water tanks for signs 

of non-compliance.

Clean and sanitize the 

tank, replace water to 

compliance.
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TPH-8: Product Wash Water Management

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-8.1 In systems where 

tomatoes are 

submerged or dwell 

in water, water 

temperature is 

monitored and 

controlled. Water 

temperature should 

be at least 10oF 

above average pulp 

temperature of 

tomatoes when 

entering the water.

R ● Operation shall have methods for 

determining average pulp temperature 

of a minimum of 5 tomatoes, a 

procedure for control of water 

temperature, shall monitor temperature 

at a prescribed frequency sufficient to 

assure continuous compliance 

(minimum of hourly), and shall 

maintain records of water temperature. 

Operation shall have a procedure as to 

what corrective actions are taken if 

criteria are not met. Water spray or 

shower systems, wherein tomatoes are 

not submerged or dwell, do not require 

temperature control.

Auditor shall review 

the procedure and shall 

review records of 

temperature 

monitoring. Auditor 

observes process 

including the 

operation’s sampling 

of pulp and water 

temperatures. Auditor 

reviews records for 

deviations and their 

disposition.

Procedure is developed 

or revised. Retraining 

is performed. 

Tomatoes washed in 

water at temperatures 

less than the average 

measured pulp 

temperature shall be 

discarded back to the 

last evidence of 

compliance.

TPH-8.2 Operations utilizing 

spray systems in 

place of whole 

tomato immersion 

shall design the line 

so that the entire 

tomato surface is 

rinsed.

● Spray systems shall be designed such 

that rinse water contacts all surfaces of 

the tomato.

Auditor observes spray 

system for compliance.

Equipment or process 

is redesigned or 

retrofitted to ensure all 

surfaces of tomato are 

contacted.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-8.3 If a spray bar system 

is used, operation has 

a water use SOP that 

addresses treatment 

of that water.

WP ● Operation’s water use SOP requires 

spray bar water to be treated using an 

approved antimicrobial to maintain a 

microbially hostile environment on 

equipment.

Auditor shall review 

water use SOP for 

completeness, and 

observes water 

treatment records for 

adequacy and 

consistency of 

treatment.

Operation discontinues 

using spray bar water 

that is not treated 

sufficiently to maintain 

a hostile environment 

on equipment. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

TPH-8.4 If water quality is 

based upon a 

chlorine-based 

sanitizer, the process 

shall be targeted to 

be at least 100 ppm 

free available 

chlorine (FAC), 

measured at the exit 

of the product from 

the water system, 

unless validation data 

are available to 

demonstrate a lower 

FAC is effective 

under operating 

conditions.

R ● Operation shall have a procedure to 

manage FAC levels, shall establish 

process adjustments for when the FAC 

drops below 100 ppm, and shall 

maintain records to verify proper 

management of levels.

Auditor shall review 

the procedure and shall 

review records of FAC 

measurement and 

appropriate 

management. Auditor 

reviews records for 

deviations and their 

disposition.

Procedure is developed 

or revised. Retraining 

is performed. 

Tomatoes washed in 

water at FAC less than 

100 ppm shall be 

discarded back to the 

last evidence of 

compliance.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-8.5 If water quality is 

based upon a 

peroxyacetic, 

peracetic or peracid 

system, levels shall 

be maintained in 

accordance with 

manufacturer’s label 

directions.

R ● Operation shall have a procedure to 

manage peracid levels, shall establish 

process targets so as not to drop below 

the minimum ppm, shall establish 

adjustments for when the peracid level 

drops below the target ppm, and shall 

maintain records to verify proper 

management of levels.

Auditor shall review 

the procedure and shall 

review records of 

peracetic measurement 

and appropriate 

management. Auditor 

reviews records for 

deviations and their 

disposition.

Procedure is developed 

or revised. Retraining 

is performed. 

Tomatoes washed in 

water at less than 

manufacturer’s 

recommendation shall 

be discarded back to 

the last evidence of 

compliance.
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TPH-9: Quarantine or On-hold Materials

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-9.1 Materials placed on 

hold, quarantined or 

rejected are clearly 

identified and 

segregated from 

other products and 

packaging materials.

R ● Operation has a written procedure to 

clearly identify and segregate on-hold, 

quarantined and rejected materials, to 

prevent commingling with other 

products or adulteration of products, 

production area or packaging 

materials.

Auditor reviews 

procedure, reviews 

logs and observes all 

currently on-hold, 

quarantined and 

rejected materials for 

compliance with 

procedure.

Non-compliances are 

corrected on site. If 

on-hold, quarantined 

or rejected materials 

are not segregated 

according to 

procedure, operation 

shall assess potential 

for product 

adulteration. 

Procedures are 

developed or revised. 

Retraining is 

performed.
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TPH-10: Tomato Rerunning Processes

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-10.1 Tomato lots shall not 

be commingled in a 

rerunning process. 

Boxes shall not be 

reused if prohibited 

by prevailing 

regulation or law

R ● Operation has a policy prohibiting 

commingling of tomato lots if lots are 

rerun.

Auditor reviews the 

policy, observes 

packing records and, if 

possible, example of 

rerunning process, for 

compliance.

Operation ceases 

commingling lots. 

Boxes with 

commingled lots are 

labeled with 

component tomato 

sources and lot 

identification. Policy 

is developed or 

revised. Retraining is 

performed.
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TPH-11: Food Defense Awareness

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPH-11.1 The facility is 

registered with FDA 

as required by the 

Public Health 

Security and 

Bioterrorism 

Preparedness and 

Response Act of 

2002.

R ● If required by 21 CFR Part 1, Subpart 

H, facility is registered with FDA and 

registration is current.

Auditor asks whether 

facility is registered. 

Facility is not required 

to demonstrate 

registration to auditor.

Facility registers with 

FDA as required.

TPH-11.2 There are procedures 

in place that readily 

identify employees, 

and those with 

specific access 

privileges, e.g., to 

chemical storage, to 

the water system. 

R ● Operation has a written procedure for 

identifying current employees. 

Procedure also indicates which 

employees have access to restricted 

areas or materials, and how access is 

restricted.

Auditor reviews 

procedure, verifies list 

of special access 

employees, observes 

restricted areas and 

materials for evidence 

of compliance and 

interviews employees 

for knowledge of 

procedure.

Procedures are 

developed or revised. 

Retraining is 

performed.
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TOMATO AUDIT PROTOCOL GREENHOUSE

TGH-1 Management Responsibility

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-1.1 Operation has current 

copies of the 

Commodity Specific 

Food Safety 

Guidelines for the 

Fresh Tomato Supply 

Chain, Food Safety 

Programs and 

Auditing Protocol for 

the Fresh Tomato 

Supply Chain, the 

relevant Harmonized 

Food Safety 

Standard, and 

additional food safety 

documents as 

required by state 

and/or federal 

regulation.

R ● Operation has a current copy of the 

Guidelines, this audit document and 

all other required documents.

Auditor observes the 

current copies at the 

operation.

Operation obtains 

current copies.
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TGH-2: Recordkeeping and Traceability

A. Greenhouse Packing

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-2.1 Containers shall be

accurately labeled 

with commodity 

name, greenhouse 

firm name and 

information

sufficient to allow for 

source and lot

identification.

WP ● A product coding system is in place 

where product shall be labeled with 

grower and lot identification, and 

coded to enable access to date of 

harvest and/or packing, origin (name 

of greenhouse, grower and/or packing 

location), and country of origin for 

traceback purposes. If using reusable 

containers, procedures ensure that 

labels are accurate prior to packing.

Auditor reviews coding 

procedures, observes 

cases for appropriate 

coding, and verifies 

compliance by review 

of records.

Boxes with missing, 

inaccurate or illegible 

coding are labeled 

with appropriate 

identification 

Procedure is 

developed or revised. 

Retraining is 

performed.
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B. Packinghouse Packed Greenhouse Tomatoes

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-2.2 The greenhouse shall 

maintain supply chain 

information available 

to the packinghouse 

to facilitate accurate 

traceability; i.e., 

quantity, greenhouse 

identification and 

date of harvest/pack. 

WP ● Operation has procedures to retain 

and provide to the packinghouse 

records of source of seed or 

transplants, soil inputs, irrigation 

water sources and test records, names 

of crews involved in greenhouse 

operations, and other crop history 

information relevant to product safety. 

Records are retained for at least two 

years or as required by prevailing 

regulation.

Auditor reviews policy 

and reviews records for 

compliance.

Policy is developed or 

revised. Noncompliances are 

corrected on-site. 

Retraining is 

performed.
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TGH-3: Self-Audit

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-3.1 Operation has 

procedures for 

conducting selfaudits and conducts 

self-audits to verify 

compliance with 

established internal 

policies and 

procedures 

WP ● In addition to the requirements of the 

Harmonized Standards, the 

operation’s self-audit procedure 

ensures compliance with established 

internal policies and procedures, the 

Commodity Specific Food Safety 

Guidelines for the Fresh Tomato 

Supply Chain, these Tomato Metrics 

and additional food safety documents 

as required by state and/or federal 

regulation.

Auditor reviews the 

self-audit procedures, 

and records of selfaudits to verify 

compliance with the 

procedures.

Operation develops 

and maintains selfaudit program, with 

corrective actions 

preventive measures, 

documentation and 

follow-up.
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TGH-4: Greenhouse

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-4.1 The greenhouse shall 

be enclosed.

WP, 

R

● The greenhouse shall be permanent or 

temporary structure, sufficiently 

enclosed to maintain a controlled 

environment. This does not apply to 

open structures such as shade or hoop 

houses, which should operate 

according to the auditing protocol for 

Open Field Production, Harvest and 

Field Packing.

The Auditor shall 

inspect the structure for 

compliance with this 

definition.

If the structure is not 

in compliance, either 

the facility must be 

brought into 

compliance or 

different audit criteria 

(i.e., auditing protocol 

for Open Field 

Production, Harvest 

and Field Packing) 

should be used.

TGH- 4.2 A foot dip station or 

other measure should 

be used to prevent the 

introduction of 

harmful 

microorganisms or 

agents and a written 

record of the sanitizer 

and maintenance 

kept.

WP, 

R

● If the facility has determined that 

footborne contaminants are a risk to 

food safety, they shall have 

procedures that effectively prevent 

contaminants from being brought into 

the greenhouse on shoes. This could 

be by means of chemical disinfectants 

in foot dips, sprays or boot wash, or 

by means of a shoe change procedure. 

If chemical disinfectants are used, the 

chemical shall be used according to 

label instructions and monitored at a 

frequency sufficient to assure 

continual effectiveness, and records 

shall be maintained to demonstrate 

compliance.

If the facility is using 

footborne 

contamination controls, 

the auditor shall review 

the procedure, and will 

observe whether those 

procedures are being 

followed at the time of 

the audit. The auditor 

shall also review any 

associated records, 

including the label 

instructions for any 

chemical disinfectants 

used, for evidence of 

compliance with the 

facility’s procedures.

If the facility is using 

footborne 

contamination 

controls, they shall 

develop or implement 

the procedures to be 

effective, including 

training in their use.
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TGH-5: Worker Health/Hygiene and Toilet/Handwashing Facilities

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-5.1 Restrooms should not 

open directly into 

greenhouse 

production areas. 

● Restrooms that do open directly into 

greenhouse production areas shall be 

equipped with self-closing 

mechanisms or have a maze-type 

entrance/exit.

Auditor visually 

verifies that the toilet 

facilities are located 

and designed in a 

compliant manner.

Operation retrofits or 

relocates the toilet 

facility.

TGH-5.2 If portable hand wash 

water tanks are used, 

they are cleaned and 

sanitized and the 

water is changed 

periodically. 

R ● Water tanks used to provide hand 

wash water shall be maintained at a 

prescribed frequency in a clean and 

sanitary manner.

Auditor reviews 

cleaning and sanitizing 

protocol and service 

logs, and visually 

observes condition of 

water tanks for signs of 

non-compliance.

Clean and sanitize the 

tank, replace water to 

compliance.

TGH-5.3 Operation shall have 

a written policy 

regarding employees’ 

outer garments.

WP ● Policy includes that employees shall 

wear suitable outer garments, not 

reasonably likely to serve as a source 

of contamination of tomato or food 

contact surface, and, as appropriate to 

the operation, use of plastic aprons 

and sleeves, and empty pockets above 

the waist. Outer garments shall be 

changed after cleaning drains, 

restrooms or other activities that may 

result in contamination.

Auditor reviews the 

policy, observes 

employees for 

compliance and 

interviews employees 

for knowledge of the 

policy.

Policy is developed or 

revised. Noncompliances are 

corrected on site. 

Retraining is 

performed.
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TGH-6: Pesticides

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-6.1 Water used to mix 

pesticides meets FDA 

E. coli standards for 

water in 21 CFR § 

112.44(a); i.e., no 

detectable generic E. 

coli in 100 mL of 

agricultural water.

R ● Operation has a written policy 

requiring foliar-application pesticides 

to be diluted only with water that 

meets FDA microbial standards for 

post-harvest agricultural water. 

Operations will have documentation 

demonstrating compliance, such as 

test results for the water source used.

Auditor reviews the 

policy and inspects 

pesticide mixing and 

application records.

Operation develops a 

written policy. 

Retraining of pesticide 

applicator as needed. 

If unknown or 

nondrinking quality 

water was used to 

prepare pesticides, 

then test the water 

source for compliance 

with drinking water E. 

coli standards. Do not 

harvest product unless 

test results 

demonstrate 

compliance.
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TGH-7: Water Used in Growing Activities

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-7.1 Non-Foliar The 

water test meets FDA 

E.coli standards for 

foliar application of 

water as described in 

21 CFR § 112.44(b).

R ● Written procedure requires a BAM or 

other testing procedure validated for 

generic E. coli quantitation in water.

Auditor reviews water 

test results and any 

corrective actions taken 

to bring the water 

source into compliance.

Perform a sanitary 

survey for each 

affected water source, 

perform any remedial 

action as required and 

retest. If the retest 

also exceeds the 

standard, further 

evaluate potential 

corrective actions, 

such as treatment, 

retreatment, or 

discontinue use of 

source.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-7.2 Foliar The water test 

meets FDA standards 

for water in 21 CFR § 

112.44(a); i.e., no 

detectable generic E. 

coli in 100 milliliters 

(mL) of agricultural 

water. 

R ● Written procedure requires a BAM or 

other testing procedure validated for 

generic E. coli quantitation in water.

Auditor reviews water 

test results and any 

corrective actions taken 

to bring the water 

source into compliance. 

If tomatoes have been 

contacted with noncompliant water, 

auditor reviews the risk 

assessment and 

disposition.

Perform a sanitary 

survey for each 

affected water source, 

perform any remedial 

action as required and 

retest. If the retest 

also exceeds the 

standard, further 

evaluate potential 

corrective actions, 

such as treatment, 

retreatment, or 

discontinue use of 

source. Operation 

shall evaluate 

tomatoes that have 

been contacted with 

noncompliant water to 

assess food safety risk. 

The assessment is 

documented and 

tomatoes dispositioned 

accordingly.
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TGH-8: Soil and Soil Amendments

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-8.1 Soil or other growth 

medium shall be 

stored in a manner 

that minimizes 

opportunities for 

contamination. 

● If soil or growth medium is stored 

onsite, it is held in a sanitary manner 

to ensure it is not a source of 

contamination. Procedures for storage 

of growth media shall comply with 

prevailing laws or regulations in the 

location of the greenhouse.

The auditor shall 

observe storage 

location and procedures 

for evidence of 

compliance.

Operation develops a 

written procedure and 

provides training. If 

there is evidence of 

contamination of 

public health 

significance, the 

medium shall not be 

used.

TGH-8.2 Fertilizer 

manufacturer’s 

instructions for usage 

and storage shall be 

followed.

R ● Non-organic fertilizers must be used 

and stored in compliance with label 

instructions and any prevailing 

federal, state or local regulations. 

Fertilizer uses shall be documented.

Auditor reviews nonorganic fertilizers used, 

storage location and 

application records.

Perform training on 

fertilizer handling and 

recordkeeping 

procedures, as needed.

TGH-8.3 If fertilizers 

containing manures 

or composts are used, 

only properly treated 

(composted or heat 

treated) manures are 

allowed for use in 

greenhouses. 

Biosolids are not 

permitted.

R ● Soil amendment use records are 

available, reviewed and current 

(conventional or organic). If treated 

manures are used, records of 

composition, dates of treatment, 

methods utilized, application dates 

and letter of guarantee, certificate of 

analysis (COA) or any test results or 

verification data demonstrating 

compliance with process or microbial 

standards must be documented. For 

non-composted animal by-products 

containing soil amendments, the 

operations shall retain a certificate or 

letter showing the lethality of the 

process. Compost applications shall 

be no less than 45 days prior to 

harvest.

Auditor reviews the 

amendment use 

documents and records 

demonstrating 

compliance with 

prevailing national or 

local established 

composting or heat 

treatment standards or 

guidelines.

Operations must 

obtain the necessary 

documents. If the 

documents cannot be 

obtained, crop cannot 

be harvested for that 

crop cycle.
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TGH-9: Sanitizing Agents Used During Harvest

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-9.1 All compounds used 

to clean or sanitize 

food contact 

containers, tools, 

utensils, equipment 

or other food contact 

surfaces are approved 

for that use by the US 

EPA, FDA or other 

prevailing agency. 

Actual use conforms 

to label directions.

R ● Documentation is available to 

demonstrate that cleaning and 

sanitizing products are approved for 

their use, and are used according to 

label directions. Sanitizing chemicals 

uses shall be documented.

Auditors review 

documentation and 

supplies to confirm 

approved use, and 

interview individuals 

responsible for their 

use for knowledge of 

approved use. Auditor 

reviews records of use, 

and visually observes 

use, to verify 

compliance with label 

directions.

Non-compliances are 

corrected on-site. 

Records are reviewed 

for potential product 

adulteration. 

Retraining is 

performed.

TGH-9.2 Chemicals used on 

product that are not 

registered pesticides 

may be permitted for 

food contact use if 

allowed under 

regulations of the 

FDA or prevailing 

agency.

R ● Any product contact chemicals not

specifically approved as registered

pesticides shall be identified, the

authority permitting their use 

identified and their uses documented.

Auditors review 

documentation and 

supplies to confirm 

approved use, and 

interview individuals 

responsible for their 

use for knowledge of 

approved use. Auditor 

reviews records of use, 

and visually observes 

use, to verify 

compliance with label 

directions.

Non-compliances are 

corrected on-site. 

Records are review ed 

for potential product 

adulteration. 

Retraining is 

performed.
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TGH-10: Product Wash Water Management

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-10.1 In systems where 

tomatoes are 

submerged or dwell 

in water, water 

temperature is 

monitored and 

controlled. Water 

temperature should 

be at least 10oF above 

average pulp 

temperature of 

tomatoes when 

entering the water.

R ● Operation shall have methods for 

determining average pulp temperature 

of a minimum of 5 tomatoes, a 

procedure for control of water 

temperature, shall monitor 

temperature at a prescribed frequency 

sufficient to assure continuous 

compliance (minimum of hourly) and 

shall maintain records of water

temperature. Operation shall have a 

procedure as to what corrective 

actions are taken if criteria are not 

met. Water spray or shower systems, 

wherein tomatoes are not submerged 

or dwell, do not require temperature 

control.

Auditor shall review 

the procedure and shall 

review records of 

temperature 

monitoring. Auditor 

observes process 

including the 

operation’s sampling of 

pulp and water 

temperatures. Auditor 

reviews records for 

deviations and their 

disposition.

Procedure is 

developed or revised. 

Retraining is 

performed. Tomatoes 

washed in water at 

temperatures less than 

the average measured 

pulp temperature shall 

be discarded back to 

the last evidence of 

compliance.

TGH-10.2 Operations utilizing 

spray systems in 

place of whole 

tomato immersion 

shall design the line 

so that the entire 

tomato surface is 

rinsed. 

● Spray systems shall be designed such 

that rinse water contacts all surfaces 

of the tomato.

Auditor observes spray 

system for compliance.

Equipment or process 

is redesigned or 

retrofitted to ensure all 

surfaces of tomato are 

contacted.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-10.3 If a spray bar system 

is used, operation has 

a water use SOP that 

addresses treatment 

of that water.

WP ● Operation’s water use SOP requires 

spray bar water to be treated using an 

approved antimicrobial to maintain a 

microbially hostile environment on 

equipment.

Auditor shall review 

water use SOP for 

completeness, and 

observes water 

treatment records for 

adequacy and 

consistency of 

treatment.

Operation discontinues 

using spray bar water 

that is not treated 

sufficiently to 

maintain a hostile 

environment on 

equipment. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

TGH-10.4 If water quality is 

based upon a 

chlorine-based 

sanitizer, the process 

shall be targeted to be 

at least 100 ppm free 

available chlorine 

(FAC), measured at 

the exit of the product 

from the water 

system, unless 

validation data are 

available to 

demonstrate a lower 

FAC is effective 

under operating 

conditions. 

R ● Operation shall have a procedure to 

manage FAC levels, shall establish 

process adjustments for when the 

FAC drops below 100 ppm, and shall 

maintain records to verify proper 

management of levels

Auditor shall review 

the procedure and shall 

review records of FAC 

measurement and 

appropriate 

management. Auditor 

reviews records for 

deviations and their 

disposition.

Procedure is 

developed or revised. 

Retraining is 

performed. Tomatoes 

washed in water at 

FAC less than 100 

ppm shall be discarded 

back to the last 

evidence of 

compliance.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-10.5 If water quality is 

based upon a 

peroxyacetic, 

peracetic or peracid 

system, levels shall 

be maintained in 

accordance with 

manufacturer’s label 

directions.

R ● Operation shall have a procedure to 

manage peracid levels, shall establish 

process targets so as not to drop 

below the minimum ppm, shall 

establish adjustments for when the 

peracid level drops below the target 

ppm, and shall maintain records to 

verify proper management of levels.

Auditor shall review 

the procedure and shall 

review records of 

peracetic measurement 

and appropriate 

management. Auditor 

reviews records for 

deviations and their 

disposition.

Procedure is 

developed or revised. 

Retraining is 

performed. Tomatoes 

washed in water at less 

than manufacturer’s 

recommendation shall 

be discarded back to 

the last evidence of 

compliance.
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TGH-11: Product Containers and Packaging Materials

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TGH-11.1 Operation has a 

written procedure for 

inspecting incoming 

packaging material. 

R ● All packaging materials are inspected 

for evidence of contamination upon 

arrival. Results are recorded.

Auditor reviews 

procedure and 

examples of packaging 

and receiving records 

for compliance.

Operation creates or 

revises policy. 

Contaminated or 

adulterated packaging 

material is rejected or 

discarded. Retraining 

is performed.

TGH-11.2 Reusable containers 

and food contact 

equipment and 

utensils shall be 

constructed of 

impervious materials 

that can be easily 

cleaned and sanitized.

R ● Written SOP requires that all reusable 

product containers are made of 

materials that can be sanitized, or 

clean and sanitary liners are used. 

Wood is not an appropriate food 

contact surface. Procedures require 

damaged containers that are no longer 

easily cleanable or sanitary shall be 

removed from service of food contact 

purposes.

Auditor reviews SOP, 

visually observes 

product bins, trays and 

containers and their use 

for evidence of noncompliance.

Policy is developed or 

revised. Noncompliances are 

corrected. Operation 

makes a commitment 

for phasing out nonconforming product 

containers; e.g., 

wooden bins, in a 

reasonable timeline. 

Retraining is 

performed.

TGH-11.3 Finished product 

containers are 

prohibited from direct 

contact with the floor, 

and pallets, slip 

sheets, and supports 

used to keep product 

containers off the 

floor are clean and in 

good condition.

WP ● Operation has a policy prohibiting 

finished product containers in direct 

contact with the floor, and that pallets, 

slip sheets, and supports used to keep 

product containers off the floor are 

maintained so as not to be a source of 

contamination.

Auditor reviews policy 

and examines finished 

product staging and 

storage areas and 

pallets, slip sheets, and 

supports for 

compliance with the 

policy.

Operation creates or 

revises policy. Noncompliances are 

corrected on site. 

Retraining is 

performed.
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TOMATO AUDIT PROTOCOL REPACKING AND DISTRIBUTION

TPD-1 Management Responsibility

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-1.1 Operation has current 

copies of the 

Commodity Specific 

Food Safety 

Guidelines for the 

Fresh Tomato Supply 

Chain, Food Safety 

Programs and 

Auditing Protocol for 

the Fresh Tomato 

Supply Chain, the 

relevant Harmonized 

Food Safety 

Standard, and 

additional food safety 

documents as 

required by state 

and/or federal 

regulation.

R ● Operation has a current copy of the 

Guidelines, this audit document and all 

other required documents.

Auditor observes the 

current copies at the 

operation.

Operation obtains 

current copies.

TPD-1.2 Operation has been 

registered or 

permitted as a food 

handling 

establishment as

required by state or 

federal regulation.

WP ● Operation demonstrates knowledge of 

prevailing requirements and has a copy 

of required permit(s) or registration.

Auditor reviews copies 

at the operation to 

verify they are current 

and complete.

Operation applies for 

or renews required 

permits or registration.
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TPD-2 Raw Material Sourcing

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-2.1 The operation has a 

policy and takes 

affirmative steps to 

ensure that all fresh 

tomatoes that are 

packed or stored in 

the facility are grown 

following 

requirements in 

Tomato Metrics 

Audit - Open Field 

Production, Harvest 

and Field Packing. 

WP ● The packinghouse requires all raw 

product suppliers to provide evidence 

of food safety/GAP programs and 

compliance. Such evidence must 

include sufficient documentation to 

demonstrate that the supplier complies 

with the requirements in Tomato 

Metrics Audit - Open Field 

Production, Harvest and Field 

Packing.

Auditor reviews policy 

and verifies that 

operation’s evidence 

of supplier compliance 

with food safety/GAP 

programs is in 

compliance with the 

operation’s policy.

Operation obtains 

required 

documentation. 

Operation ceases 

accepting or shipping 

product from 

nonapproved suppliers, 

until sufficient 

documentation 

demonstrating 

compliance is received 

by the operation.

TPD-2.2 Operation has 

procedures to ensure 

that the tomato 

staging area and 

staging practices do 

not pose a risk of 

tomato 

contamination.

WP ● The packinghouse staging area is 

designed so that overhead areas do not 

pose a contamination risk of uncovered 

tomatoes, or that tomatoes are 

protected during staging to prevent 

contamination.

Auditor reviews 

procedures and 

inspects staging area 

for potential sources of 

contamination.

Operation develops 

procedures and/or 

redesigns staging area 

or staging practices to 

prevent reasonably 

likely to occur 

opportunities for 

contamination. 

Tomatoes that have 

become contaminated 

are discarded.
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TPD-3 Traceability

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-3.1 All levels of the 

tomato supply chain 

shall maintain 

adequate traceability 

to a minimum of 

immediate next 

recipient and 

immediate previous 

supplier.

WP ● Operation shall have a procedure to 

identify the sources of incoming 

product and recipients of outgoing 

product (including trash).

Auditor shall review 

procedure.

Procedure is developed 

or revised.

TPD-3.2 Establish procedures 

to maintain lot 

identity of tomatoes, 

including setbacks 

and primary 

containers, 

throughout the 

repacking process. 

WP ● Operation shall have a procedure and 

maintain records to identify all 

outgoing product lots and shipments 

with all component tomato lots and 

prior lots in reused primary boxes, in 

both traceback and trace forward 

directions.

Auditor shall review 

procedure and review 

batch records for 

compliance. Auditor 

shall ask operation to 

traceback one, auditor 

selected product lot to 

all supplier lots and 

primary boxes, and 

trace forward one 

supplier lot to all 

product lots and 

shipments.

Procedure is developed 

or revised. Retraining 

is performed.

TPD-3.3 Establish procedures 

for reconciliation of 

incoming tomato lots 

to usage. 

WP ● Operation shall have a procedure and 

maintain records of tomato use and 

shrink to allow 100% reconciliation of 

tomato lots within 4 hrs.

Auditor reviews 

reconciliation 

procedure and asks 

operation to provide 

records to support one, 

auditor-selected 

reconciliation.

Procedure is developed 

or revised. Retraining 

is performed.
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TPD-4: Self Audits

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-4.1 Operation has 

procedures for 

conducting selfaudits, and conducts 

self-audits to verify 

compliance with 

established internal 

policies and 

procedures. 

WP, 

R

● In addition to the requirements of the 

Harmonized Standards, the operation’s 

self-audit procedure ensures 

compliance with established internal 

policies and procedures, the 

Commodity Specific Food Safety 

Guidelines for the Fresh Tomato 

Supply Chain, these Tomato Metrics 

and additional food safety documents 

as required by state and/or federal 

regulation.

Auditor reviews the 

self-audit procedures, 

and records of selfaudits to verify 

compliance with the 

procedures.

Operation develops 

and maintains selfaudit program, with 

corrective actions 

preventive measures, 

documentation and 

follow-up.
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TPD-5: Product Containers and Packaging Materials

A. Bins, Gondolas, Totes

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-5.1 Tomato-contact bulk 

bins, gondolas, totes 

and trays shall not be 

constructed of wood.

WP ● In accordance with the Post- Harvest 

Operations Harmonized Standard P8.7 regarding acceptable productcontact containers, operation has 

eliminated or has a plan to eliminate 

the use of wooden product contact 

containers.

Auditor reviews SOP, 

visually observes 

product bins, trays and 

containers and their 

use for evidence of 

noncompliance.

Policy is developed or 

revised. Noncompliances are 

corrected. Operation 

removes nonconforming product 

containers from food 

contact purposes. 

Retraining is 

performed. Operation 

develops a plan to 

phase out wooden 

bins, and demonstrates 

compliance with the 

plan.

TPD-5.2 The operation has 

written procedures 

for cleaning and 

sanitizing of produce 

food contact 

containers, requiring 

that bulk bins, 

gondolas, totes and 

trays are cleaned and 

sanitized periodically 

and is documented. 

WP, 

R

● Written SOP is established to ensure 

that bulk bins, gondolas, totes, trays 

and other food contact containers and 

implements are adequately cleaned and 

sanitized at a frequency sufficient to 

maintain clean and sanitary food 

contact surfaces, and documentation of 

compliance is maintained.

Auditor reviews SOP,

cleaning logs and 

records, interviews 

responsible individuals 

for knowledge of the 

SOP and observes 

containers, employees 

and records for 

evidence of 

compliance.

Policy is developed or 

revised. Noncompliances are 

corrected on site. 

Retraining is 

performed.
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B. Primary Packing Boxes

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-5.3 The repacker must 

label the container as 

being repacked. The 

box contains 

information on the 

commodity, repacker 

identification and 

provides lot 

identification. 

R ● Operation shall ensure that all product 

containers containing repacked 

tomatoes are labeled as repacked. The 

container shall also include the 

commodity, repacker identification, 

and repacker lot identification.

Auditor observes 

repacked product 

boxes for compliance.

Procedure is developed 

or revised. Retraining 

is performed.

TPD-5.4 Operation has a 

process to ensure that 

inaccurate 

information on 

previously used 

boxes is obliterated, 

or otherwise made 

clear that original 

information no 

longer applies, to 

prevent 

misidentification. 

WP ● Boxes shall not be reused if prohibited 

by prevailing regulation or law.

Auditor observes one 

or more repacked lots 

and repacking 

documentation for 

those lots using reused 

cartons to verify that 

only the cartons from 

the original lot(s) are 

used to repack 

reworked tomatoes and 

a positive effort has 

been made to 

obliterate (mark out by 

any means) inaccurate 

information; OR a 

label that clearly states 

the information on the 

box is no longer valid 

has been affixed and 

has the proper lot 

information on the 

label.

Operation ceases using 

boxes inappropriately. 

Procedure is developed 

or revised. Retraining 

is performed.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-5.5 Used boxes may be 

used as secondary 

shipping containers, 

provided that the 

original identification 

information on the 

box has been 

obliterated or 

otherwise made clear 

that it is no longer 

accurate.

● Operation may reuse tomato boxes as 

secondary (no product contact) 

shipping containers. Operation has a 

process to ensure that inaccurate 

information is obliterated, or otherwise 

made clear that original information no 

longer applies, to prevent 

misidentification.

If used boxes are used 

as secondary shipping 

containers, auditor 

observes one or more 

repacked lots and 

repacking 

documentation for 

those lots using reused 

cartons to verify that a 

positive effort has 

been made to 

obliterate (mark out by 

any means) inaccurate 

information; OR a 

label that clearly states 

the information on the 

box is no longer valid 

has been affixed and 

has the proper lot 

information on the 

label.

Operation relabels 

mislabeled boxes. 

Procedure is developed 

or revised. Retraining 

is performed.
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TPD-6: Packinghouse Condition and Equipment

A. General Building

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-6.1 Facility is 

constructed/arranged 

to allow separation of 

incoming, in-process 

and finished 

products.

R ● Facilities or processes assure 

separation and positioning of incoming 

raw materials so as not to become a 

source of contamination of in-process 

and finished product.

Auditor observes 

placement of incoming 

raw materials, inprocess and finished 

products for 

opportunities for crosscontamination.

Procedures are 

developed or revised. 

Non-compliances are 

corrected on site. 

Retraining is 

performed.

TPD-6.2 Operation has 

procedures that 

minimize the 

accumulation of 

standing water. 

WP ● If floor drains exist, they are adequate, 

functional, free of obstruction and are 

properly maintained and cleaned 

sufficient to prevent them from 

becoming sources of contamination. If 

standing water exists, it is removed 

from floors and floors cleaned in a 

manner and at a frequency sufficient to 

prevent creation of a source of 

contamination.

Auditor observes floor 

drains and evidence of 

standing water for 

compliance with 

procedures.

Floor drains are 

installed, repaired or 

maintained, or 

procedures are 

modified, to prevent 

standing water from 

becoming a potential 

source of 

contamination.
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B. Facility and Equipment

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-6.3 All food contact 

surfaces are made of 

material and 

designed to be easily 

cleaned and 

sanitized, and are 

maintained in good 

condition.

● All tomato contact surfaces and 

equipment are made of materials, 

designed or constructed to be easily 

cleaned and sanitized, all food contact 

surfaces are free of rust or corrosion, 

and seams between food contact 

surfaces are smooth or accessible for 

cleaning.

Auditor observes 

product contact 

surfaces and 

equipment and their 

use for evidence of 

non-compliance.

Non-compliances are 

corrected or replaced. 

Operation makes a 

commitment for 

phasing out nonconforming tomato 

contact surfaces and 

equipment, in a 

reasonable timeline. 

Retraining is 

performed.

TPD-6.4 Wood is not used as a 

food contact surface. 

● Operation has eliminated, or has a plan 

to eliminate, use of wooden items as 

food contact surfaces

Auditor inspects 

facility for evidence of 

wooden food contact 

surfaces.

Operation that still 

utilizes wood as a food 

contact surface has a 

plan to phase out such 

surfaces, and is in 

compliance with

the plan.

TPD-6.5 SDS are on file for 

all chemicals used in 

the facility, and 

readily accessible.

R ● Operation maintains a list of all 

chemicals approved for use in facility, 

and maintains SDS for all. SDS are in 

a location easily accessible by 

employees.

Auditor reviews SDS 

binder and observes 

chemicals in facility 

for evidence of 

compliance.

Obtain missing SDS. 

Relocate SDS.
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TPD-7: Worker Health/Hygiene and Toilet/Handwashing Facilities

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-7.1 If portable hand wash 

water tanks are used, 

they are cleaned and 

sanitized and the 

water is changed 

periodically. 

R ● Water tanks used to provide hand wash 

water shall be maintained at a 

prescribed frequency in a clean and 

sanitary manner.

Auditor reviews 

cleaning and sanitizing 

protocol and service 

logs, and visually 

observes condition of 

water tanks for signs 

of noncompliance.

Clean and sanitize the 

tank, replace water to 

compliance.
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TPD-8: Product Wash Water Management

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-8.1 In systems where 

tomatoes are 

submerged or dwell 

in water, water 

temperature is 

monitored and 

controlled. Water 

temperature should 

be at least 10oF above 

average pulp 

temperature of 

tomatoes when 

entering the water.

R ● Operation shall have methods for 

determining average pulp temperature 

of a minimum of 5 tomatoes, a 

procedure for control of water 

temperature, shall monitor temperature 

at a prescribed frequency sufficient to 

assure continuous compliance 

(minimum of hourly), and shall 

maintain records of water temperature. 

Operation shall have a procedure as to 

what corrective actions are taken if 

criteria are not met. Water spray or 

shower systems, wherein tomatoes are 

not submerged or dwell do not require 

temperature control.

Auditor shall review 

the procedure and shall 

review records of 

temperature 

monitoring. Auditor 

observes process 

including the 

operation’s sampling 

of pulp and water 

temperatures. Auditor 

reviews records for 

deviations and their 

disposition.

Procedure is developed 

or revised. Retraining 

is performed. 

Tomatoes washed in 

water at temperatures 

less than the average 

measured pulp 

temperature shall be 

discarded back to the 

last evidence of 

compliance.

TPD-8.2 Operations utilizing 

spray systems in 

place of whole 

tomato immersion 

shall design the line 

so that the entire 

tomato surface is 

rinsed.

● Spray systems shall be designed such 

that rinse water contacts all surfaces of 

the tomato.

Auditor observes spray 

system for compliance.

Equipment or process 

is redesigned or 

retrofitted to ensure all 

surfaces of tomato are 

contacted.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-8.3 If a spray bar system 

is used, operation has 

a water use SOP that 

addresses treatment 

of that water.

WP ● Operation’s water use SOP requires 

spray bar water to be treated using an 

approved antimicrobial to maintain a 

microbially hostile environment on 

equipment.

Auditor shall review 

water use SOP for 

completeness, and 

observes water 

treatment records for 

adequacy and 

consistency of 

treatment.

Operation discontinues 

using spray bar water 

that is not treated 

sufficiently to maintain 

a hostile environment 

on equipment. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

TPD-8.4 If water quality is 

based upon a 

chlorine-based 

sanitizer, the process 

shall be targeted to 

be at least 100 ppm 

free available 

chlorine (FAC), 

measured at the exit 

of the product from 

the water system, 

unless validation data 

are available to 

demonstrate a lower 

FAC is effective 

under operating 

conditions. 

R ● Operation shall have a procedure to 

manage FAC levels, shall establish 

process adjustments for when the FAC 

drops below 100 ppm, and shall 

maintain records to verify proper 

management of levels.

Auditor shall review 

the procedure and shall 

review records of FAC 

measurement and 

appropriate 

management. Auditor 

reviews records for 

deviations and their 

disposition.

Procedure is developed 

or revised. Retraining 

is performed. 

Tomatoes washed in 

water at FAC less than 

100 ppm shall be 

discarded back to the 

last evidence of 

compliance.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-8.5 If water quality is 

based upon a 

peroxyacetic, 

peracetic or peracid 

system, levels shall 

be maintained in 

accordance with 

manufacturer’s label 

directions. 

R ● Operation shall have a procedure to 

manage peracid levels, shall establish 

process targets so as not to drop below 

the minimum ppm, shall establish 

adjustments for when the peracid level 

drops below the target ppm, and shall 

maintain records to verify proper 

management of levels.

Auditor shall review 

the procedure and shall 

review records of 

peracetic measurement 

and appropriate 

management. Auditor 

reviews records for 

deviations and their 

disposition.

Procedure is developed 

or revised. Retraining 

is performed. 

Tomatoes washed in 

water at less than 

manufacturer’s 

recommendation shall 

be discarded back to 

the last evidence of 

compliance.
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TPD-9: Quarantine or On-hold Materials

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-9.1 Materials placed on 

hold, quarantined or 

rejected are clearly 

identified and 

segregated from 

other products and 

packaging materials.

R ● Operation has a written procedure to 

clearly identify and segregate on-hold, 

quarantined and rejected materials, to 

prevent commingling with other 

products or adulteration of products, 

production area or packaging 

materials.

Auditor reviews 

procedure, reviews 

logs and observes all 

currently on-hold, 

quarantined and 

rejected materials for 

compliance with 

procedure.

Non-compliances are 

corrected on site. If 

on-hold, quarantined 

or rejected materials 

are not segregated 

according to 

procedure, operation 

shall assess potential 

for product 

adulteration. 

Procedures are 

developed or revised. 

Retraining is 

performed.
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TPD-10: Food Defense Awareness

Req. # Requirement DOC MAN Procedure Verification Corrective Action

TPD-10.1 The facility is 

registered with FDA 

as required by the 

Public Health 

Security and 

Bioterrorism 

Preparedness and 

Response Act of 

2002.

R ● If required by 21 CFR Part 1, Subpart 

H, facility is registered with FDA and 

registration is current.

Auditor asks whether 

facility is registered. 

Facility is not required 

to demonstrate 

registration to auditor.

Facility registers with 

FDA as required.

TPD-10.2 There are procedures 

in place that readily 

identify employees, 

and those with 

specific access 

privileges, e.g., to 

chemical storage, to 

the water system.

WP ● Operation has a written procedure for 

identifying current employees. 

Procedure also indicates which 

employees have access to restricted 

areas or materials, and how access is 

restricted.

Auditor reviews 

procedure, verifies list 

of special access 

employees, observes 

restricted areas and 

materials for evidence 

of compliance and 

interviews employees 

for knowledge of 

procedure.

Procedures are 

developed or revised. 

Retraining is 

performed.