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USDA Harmonized GAP

Standard

February 9, 2024
For Official Government Use Only. 

The United States Department of Agriculture (USDA) Harmonized Good Agricultural Practices 

(GAP) Audit program 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 non-exclusive 

copyright license. 

This issue of the USDA’s Harmonized GAP Standard supersedes the previous issue which has been 

in effect since May 1, 2021. 

A summary of changes and the Program Manual are available on the AMS website: 

https://www.ams.usda.gov/services/auditing/gap-ghp/harmonized

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.
ii

USDA Harmonized GAP 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 ......................................................................................... 7

G-4: Worker Education and Training ............................................................................................ 8

G-5: Sampling and Testing .......................................................................................................... 10

G-6: Traceability .......................................................................................................................... 12

G-7: Recall Program .................................................................................................................... 13

G-8: Corrective Actions and Food Safety Incidents .................................................................... 14

G-9: Self-Audits ........................................................................................................................... 15

G-10: Worker Health/Hygiene and Toilet/Handwashing Facilities ............................................. 16

G-11: Agricultural and Cleaning Chemicals................................................................................. 25

G-12: Waste Management ........................................................................................................... 29

G-13: Food Defense ..................................................................................................................... 30

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

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

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

F-2: Water System Description .............................................................................................. 33

F-3: Water System Risk Assessment ..................................................................................... 35

F-4: Water Management Plan ................................................................................................ 36

F-5: Animal Control ............................................................................................................... 39

F-6: Soil Amendments and Alternative Growing Media/Substrate ....................................... 41

F-7: Vehicles, Equipment, Tools and Utensils ...................................................................... 43

Harvesting ..................................................................................................................................... 46

F-8: Preharvest Risk Assessment ........................................................................................... 46

F-9: Water/Ice Used in the Harvesting and Post-Harvest Operations ................................... 47

F-10: Containers, Bins and Packaging Materials ................................................................... 50

F-11: Field Packaging and Handling ..................................................................................... 52

F-12: Post-Harvest Handling and Storage (Field Prior to Storage or Packinghouse)............ 54

F-13: Equipment Sanitation and Maintenance ....................................................................... 55
iii

Post-Harvest Operations (P)...................................................................................................... 56

P-1: Produce Sourcing ................................................................................................................. 56

P-2: Facility.................................................................................................................................. 57

P-3: Pest and Animal Control ...................................................................................................... 61

P-4: Equipment, Tools and Utensils............................................................................................ 63

P-5: Maintenance and Sanitation ................................................................................................. 65

P-6: Post-Harvest Water/Ice ........................................................................................................ 70

P-7: Containers, Bins and Packaging........................................................................................... 75

P-8: Storage.................................................................................................................................. 78

P-9: Transportation (Packinghouse to Customer)........................................................................ 81

Logo Use (L) ................................................................................................................................ 83

L-1: Food Safety Plan or Quality Manual.................................................................................... 83

L-2: Traceability and Recall Programs......................................................................................... 84

L-3: Approved Suppliers.............................................................................................................. 85

L-4: GAP & GHP Logo Approved Use....................................................................................... 86

Tomato Audit Protocol Open-field Production and Harvesting ............................................ 87

TOF-1 Management Responsibility.............................................................................................. 87

TOF-2: Self Audits ....................................................................................................................... 88

TOF-3: Field History and Pre-harvest Assessments.................................................................... 89

TOF-4: Workers Health/Hygiene and Toilet/Handwashing Facilities ........................................ 91

TOF-5: Pesticides......................................................................................................................... 93

TOF-6: Water Used in Growing Activities.................................................................................. 94

TOF-7: Soil Amendments............................................................................................................ 96

TOF-8: Sanitizing Agents Used During Harvest......................................................................... 97

TOF-9: Product Containers.......................................................................................................... 98

TOF-10: Field Packing of Tomatoes ........................................................................................... 99

Tomato Audit Protocol Packinghouse .................................................................................... 100

TPH-1 Management Responsibility............................................................................................ 100

TPH-2: Raw Material Sourcing .................................................................................................. 101

TPH-3: Traceability .................................................................................................................... 102

TPH-4: Self Audits ..................................................................................................................... 103

TPH-5: Product Containers and Packaging Materials............................................................... 104

TPH-6: Packinghouse Condition and Equipment...................................................................... 106

A. General Building .......................................................................................................... 106

B. Facility and Equipment ................................................................................................ 107

TPH-7: Worker Health/Hygiene and Toilet/Handwashing Facilities........................................ 108

TPH-8: Product Wash Water Management ............................................................................... 109
iv

TPH-9: Quarantine or On-hold Materials.................................................................................. 112

TPH-10: Tomato Rerunning Processes...................................................................................... 113

TPH-11: Food Defense Awareness............................................................................................ 114

Tomato Audit Protocol Greenhouse........................................................................................ 115

TGH-1 Management Responsibility........................................................................................... 115

TGH-2: Recordkeeping and Traceability.................................................................................... 116

A. Greenhouse Packing..................................................................................................... 116

B. Packinghouse Packed Greenhouse Tomatoes.............................................................. 117

TGH-3: Self-Audit..................................................................................................................... 118

TGH-4: Greenhouse................................................................................................................... 119

TGH-5: Worker Health/Hygiene and Toilet/Handwashing Facilities....................................... 120

TGH-6: Pesticides...................................................................................................................... 121

TGH-7: Water Used in Growing Activities............................................................................... 122

TGH-8: Soil and Soil Amendments........................................................................................... 124

TGH-9: Sanitizing Agents Used During Harvest ...................................................................... 125

TGH-10: Product Wash Water Management............................................................................. 126

TGH-11: Product Containers and Packaging Materials............................................................. 129

Tomato Audit Protocol Repacking and Distribution ............................................................ 130

TPD-1 Management Responsibility............................................................................................ 130

TPD-2 Raw Material Sourcing ................................................................................................... 131

TPD-3 Traceability ..................................................................................................................... 132

TPD-4: Self Audits ..................................................................................................................... 133

TPD-5: Product Containers and Packaging Materials............................................................... 134

A. Bins, Gondolas, Totes.................................................................................................. 134

B. Primary Packing Boxes................................................................................................ 135

TPD-6: Packinghouse Condition and Equipment...................................................................... 137

A. General Building .......................................................................................................... 137

B. Facility and Equipment ................................................................................................ 138

TPD-7: Worker Health/Hygiene and Toilet/Handwashing Facilities........................................ 139

TPD-8: Product Wash Water Management ............................................................................... 140

TPD-9: Quarantine or On-hold Materials.................................................................................. 143

TPD-10: Food Defense Awareness............................................................................................ 144
USDA Harmonized GAP Standard 

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INTRODUCTION

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

Food Safety Standards located at: https://www.freshproduce.com/resources/food-safety/producegaps-harmonized-audit-standard/. This standard has been reorganized to align with the USDA 

Harmonized GAP Checklist.

SCOPES OF AUDIT

The Harmonized GAP 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) 

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 
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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 and food 

safety culture, in general terms. 

Everyone in the organization shall 

understand the policy and be aware of 

their role in insuring that this is met 

(e.g., through training initiatives, 

communication efforts, feedback to 

management, performance 

measurements related to food safety). 

The policy shall be communicated in a 

language understood by employees and 

workers. The policy shall be signed by 

senior management, and includes a 

date when the policy was created and 

any dates of revision.

The auditor reviews 

the food safety policy,

observes that it 

includes a proactive 

approach to promoting 

food safety culture,

observes that it is 

signed by senior 

management, has been 

communicated and 

made accessible to all 

employees and workers 

in a manner that can be 

understood, and 

includes a date when 

the policy was created 

or revised.

The operation creates 

or revises the policy, or 

its communication to 

employees and workers

to be in compliance.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-1.2 Management has 

designated 

individual(s) on-site 

and remote, including 

a list of alternatives 

authorized to act in 

absence of designated 

individuals, 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 on-site, 

including a provision for the absence of 

key employees and workers. Twentyfour-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.

The organization’s senior management 

shall determine and provide, in a timely 

manner, the resources needed to 

implement and maintain the food safety 

plan.

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. Auditor 

observes whether 

senior management has 

provided the resources 

needed to implement 

and maintain the food 

safety plan.

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. Senior 

Management commits 

resources needed to 

implement and 

maintain the food 

safety plan.

G-1.3 There is a corrective 

action policy for food 

safety violations

resulting from 

employees and 

workers.

There shall be a policy that establishes 

corrective actions for employees and 

workers 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, 

and trains or retrains

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 the operation covered by 

the plan. The plan shall address

physical, chemical, and biological 

hazards reasonably likely to occur as 

well as 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 physical, 

chemical, and 

biological hazards and 

has identified 

preventive controls for 

hazards that may 

reasonably affect food 

safety.

Operation develops or 

completes a food 

safety plan for all 

products and locations 

of operation.

G-2.2 The food safety plan 

shall be reviewed at 

least annually and 

when changes that 

affect the operation 

occur.

R Operation shall be responsible for 

reviewing their food safety plan at least 

annually or anytime changes that affect 

the operation occur (e.g., purchase of 

new packing equipment, changes in 

management, new product type), 

documenting the review procedure and 

revising the plan as necessary. 

Updated or revised on date shall be 

indicated, and a written record of 

review shall be signed by senior 

management.

Auditor shall review 

documentation that the 

food safety plan is 

reviewed and revised 

at least annually, or 

when changes that 

affect the operation 

occur.

Operation reviews the 

food safety plan at 

least annually or when 

changes that affect the 

operation occur.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-2.3 Operation has an 

approved supplier 

program for all 

incoming materials, 

including packaging, 

soil amendments, and 

alternative growing 

media, soil-less 

media, and 

substrates.

R ● Operation has and maintains a current 

list of approved raw material suppliers

relevant to food safety. Approved 

supplier program includes a procedure 

for accepting materials from primary 

and alternate sources to ensure that 

materials will not serve as a potential 

source of contamination (e.g., 

obtaining Certificate of Analysis for 

soil amendments). 

Auditor verifies a list 

of material suppliers is 

maintained and 

current. Auditor 

verifies that all 

materials received 

from alternate sources 

have 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.

G-2.4 Operation has an 

approved services 

program for all 

services which may 

impact the safety of 

the product. 

R ● Operation has and maintains a current 

list of approved service providers 

which could impact the safety of the 

product such as portable sanitation unit 

servicers, equipment technicians, or 

field workers. All approved service 

providers are provided at minimum the 

operation’s food safety policies for 

proper restroom use and handwashing, 

illness policies, and other policies 

relevant to the service provider’s job 

(e.g., food safety practices during 

equipment maintenance). 

Auditor verifies a list 

of approved service 

providers is maintained 

and current. Auditor 

verifies that all 

services received from 

alternate sources have 

been provided food 

safety policies and 

procedures prior to 

work occurring. 

Operation develops an 

approved services 

program and maintains 

a current list. 

Operation develops a 

procedure for 

accepting services 

from alternate 

providers. Operation 

ceases utilizing service 

providers who have not 

been provided the 

operation’s food safety 

policies. 
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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. Employees and workers have 

access to the most current version of 

the operation’s documents and records 

of procedures as related to the 

employee’s job responsibilities.

Records comply with prevailing 

regulations.

Auditor reviews food 

safety plan and verifies 

that all required 

documentation relevant 

to employee’s and 

worker’s job 

responsibilities is 

available and up to 

date.

Operation develops 

missing documentation 

or recordkeeping 

procedures. Operation 

provides employees 

and workers with the 

most up-to-date 

versions of documents 

and records of 

procedures as related 

to the employee’s and 

worker’s job 

responsibilities.

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. 
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G-4: Worker Education and Training

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-4.1 All employees and 

workers shall receive 

food safety training,

appropriate to their 

job responsibilities.

R ● All employees and workers shall 

receive training in the food safety 

policy and plan, food safety 

procedures, sanitation, and personal 

hygiene appropriate to their job 

responsibilities. Employees and 

workers shall be trained to notify a 

designated individual if a food safety 

risk is identified. All concerns are 

promptly considered, and when 

appropriate to the circumstance, acted 

upon. Employees and workers shall 

receive training at hire, refresher 

training at prescribed frequencies (at 

least annually), and retraining when 

deficiencies are identified, and as 

required by prevailing regulation. 

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 Employees and 

workers 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 sufficient on 

the job training/experience or has 

completed at least one adequate food 

safety course/workshop, 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 workers 

are held to the 

relevant food safety 

standards as they 

would be as 

employees or 

workers.

R ● Operation shall have procedures and/or 

records to demonstrate that contracted 

workers whose activities can affect 

food safety have been informed of and, 

to the extent that can be verified,

comply with the relevant requirements 

of this standard.

Auditor reviews 

operation’s evidence 

that contracted workers 

are trained to the same 

food safety 

requirements as 

employees and workers 

would be and, if 

practical during the 

audit, observes 

contracted workers for 

compliance.

Operation obtains 

evidence, trains, or 

discontinues using 

contracted workers.
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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 or 

laboratory 

participating in a 

proficiency testing 

program using 

scientifically valid 

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 FDA’s 

Bacteriological Analytical Manual

BAM, AOAC International or testing 

methods that have been validated for 

detecting or quantifying the target 

organism(s) or chemical(s). At a 

minimum, laboratory procedures are 

scientifically valid methods and in 

accordance with prevailing regulation. 

Auditor reviews 

operation’s evidence 

that only GLP 

or laboratories 

participating in a 

proficiency testing 

program and 

scientifically valid 

methods are used.

Operation discontinues 

using non-GLP 

or non-accredited 

laboratory and not 

scientifically valid

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

and records kept.

WP, 

R

Operation utilizes a written sampling 

protocol that includes test frequency 

and procedures when collecting 

samples for microbiological testing for 

food safety. 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 observes that 

the operation has a 

sampling protocol for 

each type of 

microbiological testing 

required in the 

operation’s food safety 

plan. Auditor reviews 

operation’s 

recordkeeping of 

microbiological test 

results.

Operation develops or 

obtains written 

sampling protocols for 

each type of 

microbiological testing 

required in their food 

safety plan.

Operation maintains 

test records for at least 

two years for all 

required 

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

G-5.3 All microbiological 

testing as directed by 

the food safety plan 

shall include 

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 policy describing

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 (i.e., test and hold).

Auditor reviews the 

operation’s 

microbiological testing

policy for 

completeness.

Operation revises 

testing policy and 

actions 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, and homemade preparations 

(one step backward). Records shall 

include the items, the date of receipt or 

harvest, quantities, and lot numbers or 

farm identification (field or block), and 

transporter. Additional information 

may be included. Contents and 

retention of records shall be consistent 

with prevailing regulation. 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-6.2 A trace back and 

trace forward 

exercise shall be 

performed at least 

annually.

R The trace back and trace forward 

records check exercise shall achieve 

accurate traceability within 4 hours 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

● Operation shall have written 

procedures that detail each step of the 

recall process including tasks and 

responsibilities. Written procedures 

detail communication with customers 

about recalled products, including how 

to withdrawal, return, dispose, or divert 

the affected product. Verification 

procedures shall document that the 

recall was conducted effectively. 

Auditor shall review 

documentation of the 

recall program and 

written procedures. 

Operation develops a 

recall program 

including written 

procedures. 

G-7.2 The recall program 

shall have a 

designated recall 

team. 

R Operation has an established recall 

team and keeps up-to-date contact 

information for the internal and 

external individuals involved in the 

operation’s recall activities (e.g., key 

company employees, legal counsel, 

regulatory agencies, insurance agent, 

media spokesperson). 

Auditor reviews 

operation’s established 

recall team contact 

information. 

Operation develops a 

recall team and keeps 

up-to-date contact 

information for all 

team members. 

G-7.3 A mock recall 

exercise shall be 

performed at least 

annually at the 

operation being 

audited. 

R The mock recall shall include a trace 

back and trace forward exercise for a 

hypothetical product on the market and 

include involvement by designated 

recall team members as established by 

the recall program. 

Auditor reviews 

records of most recent 

mock recall exercise 

performed at the 

operation. 

Operation develops a 

written recall plan, 

performs a mock recall 

exercise, and keeps 

records. 
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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 (e.g., root 

cause analysis exercise) shall be 

documented and implemented.

Auditor reviews 

corrective action 

procedures and 

examines records for 

evidence of 

compliance. 

Operation develops 

and implements 

corrective action 

procedures.

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 written hold and release

procedures to 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. 

Disposition must be documented (e.g., 

if the product was released, destroyed, 

donated, redirected).

Auditor reviews 

procedure, reviews 

records and observes 

all currently on-hold, 

quarantined, and 

rejected materials for 

compliance with 

procedure and their 

disposition. Product 

release procedure is 

being followed and 

release records are 

kept.

Non-compliances are 

corrected on site. If 

on-hold, quarantined or 

rejected materials are 

not segregated or 

released 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 who is knowledgeable in 

this standard, utilizing this standard to 

assist in the self-audit. All aspects of 

the operation’s food safety plan will be 

audited annually 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 comply 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, workers,

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, workers,

contractors, visitors, buyers, product 

inspectors, auditors, and other 

personnel in the operation. The 

operation shall designate competent 

supervisory personnel to ensure 

compliance by all employees, workers, 

and visitors with the requirements in 

this section.

Auditor observes 

employees, workers, 

and visitors in 

operation for evidence 

of compliance. 

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, serviced, 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, workers,

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 and 

workers 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

and workers.

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 and 

workers 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 the 

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. 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.

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 spills or 

leaks of field 

sanitation units.

WP A written response plan is developed 

and implemented in the event of a 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 Employees and 

workers shall wash 

their hands at any 

time when their 

hands may be a 

source of 

contamination.

● Employees and workers 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. 

Handwashing shall be monitored by 

visible observation when possible 

and/or confirming use of handwashing 

resources such as towels and soap to 

verify adequate handwashing is 

occurring. 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 

employees and workers

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.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.10 Clothing, including 

footwear, shall be 

effectively 

maintained, 

laundered, 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. 

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 prevailing regulation 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.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

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 employees and workers 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 protective 

clothing shall not be left on product, 

work surfaces, equipment or packaging 

material or taken into restrooms but 

hung on racks or in designated areas. 

When appropriate, racks shall be 

available and located 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. 

If employees and 

workers wear 

protective clothing, 

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.

G-10.13 The wearing of 

jewelry, body 

piercings and other 

loose objects shall be 

in compliance to 

company policy and 

applicable regulation.

Operation shall have a policy that 

personal effects such as jewelry, 

false nails or eyelashes, watches, 

personal electronics (e.g., ear buds), or 

other items (including decorations that 

may fall from clothing and become a 

physical hazard) 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 

employees and workers 

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-10.14 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 Employee’s and 

worker’s personal 

belongings shall be 

stored in designated 

areas.

Operation shall have a policy for when 

and how employee’s and worker’s 

personal belongings shall be stored so 

as not to be a source of product 

contamination. 

Auditor observes 

employee and worker

produce handling areas 

and designated area 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 

employees and workers

for evidence of 

compliance.

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

G-10.17 Operation shall have 

a policy that break 

areas are located so 

as not to be a source 

of product 

contamination.

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.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-10.18 Drinking water shall 

be available to all 

field employees and 

workers. 

R Drinking water, which meets drinking 

water standards, shall be easily 

accessible to field workers 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 and workers. 

Auditor observes 

evidence of drinking 

water accessibility and 

operation’s evidence 

that water supplied to 

employees and workers 

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 and from 

entering produce 

handling areas.

WP ● Operation shall have a written policy 

that restricts employees, workers,

contractors, visitors, buyers, product 

inspectors, auditors, and other 

personnel in the operation who show 

signs of foodborne illness (e.g., 

vomiting, jaundice, diarrhea) from 

contact with product or food contact 

surfaces and from entering produce 

handling areas where direct or indirect 

contamination could occur (e.g., shared 

use of tools by workers) until their 

condition no longer presents a risk to 

public health. Policy shall require that 

any person affected to immediately 

report illness or symptoms of illness to 

the management.

Auditor reviews 

written policy and 

observes workers and 

visitors for evidence of 

compliance.

Operation develops 

and implements policy. 

Retraining is 

performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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G-10.20 Employees and 

workers 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. Bandages or other coverings for 

cuts, sores, or lesions shall not pose a 

physical hazard to produce. 

Auditor observes 

employees and workers 

for evidence of 

compliance.

Affected product is 

evaluated for potential 

contamination and 

disposition.

Retraining is 

performed and 

documented. 

G-10.21 Operation shall have 

and implement 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. 

Affected product is 

evaluated for potential 

contamination and 

disposition. Retraining 

is performed and 

documented. 

G-10.22 First aid kits shall be 

accessible to all

employees and 

workers.

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 

employees and 

workers.
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G-11: Agricultural and Cleaning Chemicals

G-11.1 Use of pesticides and 

other 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. Affected 

product is evaluated for 

potential contamination 

and disposition.

Retraining is 

performed and 

documented. 
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G-11.2 Pre- and postharvest 

agricultural chemical 

use, shall consider the 

maximum residue 

limit (MRL) 

requirements in the 

country of origin or 

intended country of 

destination.

R The operation shall have procedures, 

such as review of preharvest intervals

and adjustment of postharvest 

application rates and communication 

with buyers about potential countries 

where product is intended to be sold 

sufficient to meet the MRL 

requirements of the country/countries 

in which the product is grown and 

intended to be sold/distributed, if 

known during production or 

postharvest handling.

Auditor reviews 

operation’s procedure 

for complying with 

agricultural chemical 

restrictions in countries 

of destination. If the 

country of destination 

is unknown during 

production or 

postharvest handling 

by this operation, the 

auditor will review the 

operation’s compliance 

with agricultural 

chemical restrictions 

for the country where 

the produce was 

grown. 

Operation develops 

procedures, and diverts 

non-compliant product 

to a market in which 

the product meets 

standards.

G-11.3 Agricultural 

chemicals shall be 

applied by trained, 

licensed, or certified 

applicators 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 applicators, in 

compliance with prevailing regulation. 

The responsible person(s) must be able 

to prepare the required application mix 

according to the label instructions. 

Auditor reviews 

records demonstrating 

that applicators are 

licensed and/or trained 

in compliance with 

prevailing regulation. 

Auditors shall verify 

agricultural chemical 

mixes are prepared 

properly by 

interviewing the 

responsible person(s), 

if available. 

Operation utilizes 

applicators who are 

appropriately licensed 

and/or trained. 

Retraining is 

performed and 

documented. 
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G-11.4 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. Affected 

product is evaluated for 

potential contamination 

and disposition. 

Retraining is 

performed and 

documented. 

G-11.5 Use of water 

treatment agricultural 

chemicals shall 

comply with label 

directions and 

prevailing regulation. 

R ● Agricultural chemicals used to manage 

water quality, including sanitizers and 

disinfectants, 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 antimicrobial pesticides may 

be permitted for use if allowed under 

regulations of the prevailing agency. 

Records of water treatment are 

maintained, and include crop, date and 

location of application, chemical used, 

application rate and method. 

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. Affected 

product is evaluated for 

potential contamination 

and disposition. 

Retraining is 

performed and 

documented. 
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G-11.6 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.

G.11.7 All cleaning agents 

shall be appropriate 

for use on food 

contact surfaces.

All chemicals used for cleaning of food 

contact equipment, tools, utensils, 

containers, and other food contact 

surfaces shall be appropriate 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 labeled use. SDS 

are on file for all chemicals used in the 

operation and are readily accessible.

Auditor reviews 

cleaning and sanitizing 

chemicals purchasing 

practices or 

procedures, storage 

area, and use 

procedures to verify 

compliance.

Operation ceases use of 

unapproved chemicals. 

Affected product is 

evaluated for potential 

contamination and 

disposition. Retraining 

is performed and 

documented. 

G-11.8 Compressed air or 

other gases that 

contact food or food 

contact surfaces must 

be maintained in a 

manner that does not 

serve as a potential 

source of product 

contamination. 

R Compressed air or other gases that are 

used in produce handling equipment, 

contact produce directly, or used in the 

process to clean food‐contact surfaces 

must be properly maintained and 

inspected regularly. Compressed air or 

other gases must be properly stored and 

handled according to the label or 

manufacturer's instructions. When the 

food safety plan indicates that 

microbial or chemical testing is 

required to minimize potential food 

safety risks, documentation of test 

results and corrective actions are kept. 

Records of compressed air and gas 

system maintenance is documented. 

Auditor reviews 

records of maintenance 

and testing results 

(when required by the 

food safety plan) of the 

compressed air or gas 

system. Auditor 

observes the 

appropriate use, 

storage, and/or 

handling of the 

compressed air or other 

gases used in contact 

with food and food 

contact surfaces. 

Operation develops 

records to document 

maintenance and test 

results of compressed 

air and other gas 

systems that contact 

food or food contact 

surfaces. Retraining is 

performed and 

documented. 
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G-12: Waste Management

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-12.1 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 growing and 

handling areas. 

Auditor verifies the 

operation has 

implemented a waste 

management plan.

Operation implements 

a waste management 

plan.

G-12.2 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. Affected 

product is evaluated 

for potential 

contamination and 

disposition. Retraining 

is performed and 

documented. 
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G-13: Food Defense

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-13.1 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-13.2 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.
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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.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

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.

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: Water System Description

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-2.1 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: type of water source 

(e.g., surface, ground, reuse) 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-2.2 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 for water quality 

as it relates to food safety.

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.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-2.3 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. Septic tanks and 

sewage conveyance locations are 

identified by the operation in relation 

to water systems. 

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-3: Water System Risk Assessment

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-3.1 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-4: Water Management Plan

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-4.1 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 employees and workers

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-4.2 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-4.3 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-4.4 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 microbial 

quality criteria indicated by current 

industry standard or prevailing 

regulation. Treatment is monitored at a 

frequency sufficient to meet treatment 

objectives. 

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-4.5 If microbial die-off is 

used to achieve the 

operation’s 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-4.6 If operation uses an 

alternative approach 

to regulatory 

microbiological 

testing compared to 

current industry 

standards or 

regulations, operation 

has scientific data or 

information to 

support the 

alternative as 

providing the same 

level of public health 

protection.

R ● If operation uses an alternative testing 

method, frequency or criteria compared 

to industry standards or regulatory 

requirements, operation has 

documentation to support the 

alternative as providing the same level 

of public health protection.

Auditor verifies 

documentation for 

completeness.

Operation obtains 

documentation on, or 

discontinues use of, the 

alternative.
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F-5: Animal Control

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-5.1 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 domesticated and wild animal 

activity including grazing and feeding 

operations, noting crop characteristics

(e.g., does crop grow on ground vs. 

tree), type concentration and 

occurrences 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-5.2 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.
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F-5.3 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 (e.g., 

installation of buffer zones, fences, 

ditches, berms, etc.) 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-6: Soil Amendments and Alternative Growing Media/Substrate

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-6.1 The food safety plan 

shall address risk, 

preparation, use, and 

storage of animalbased soil 

amendments or 

biosolids.

A,

R

● If animal-based soil amendments or 

biosolids are used, records of 

composition, dates of treatment (if 

produced by your operation), 

application methods 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-6.2 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 as required 

by current industry 

standard or 

prevailing regulation.

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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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-6.3 If an alternative 

growing media, soilless media, or 

substrate not of 

animal-origin is used 

(e.g., perlite, peat, 

coconut fiber, rock 

wool, clay pebbles), 

it is appropriate for 

its intended use and 

stored and handled in 

a manner to minimize 

the risk of 

contamination.

WP, 

R

The operation shall have a procedure 

for storing and handling alternative 

growing media, soil-less media, and 

substrate so that it does not pose a food 

safety risk to produce. Operation 

maintains a record of type, supplier, 

and use (e.g., clay pebbles used for 

growing hydroponic herbs).

Auditor reviews 

procedure and records 

to determine the media 

or substrate is 

appropriate for its 

intended use and being 

stored and handled in a 

manner that does not 

introduce 

contamination.

Operation develops a 

procedure for storing 

and handling growing 

media or substrate 

being used and 

develops the records 

needed for verification.
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F-7: Vehicles, Equipment, Tools and Utensils

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-7.1 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-7.2 Equipment, vehicles, 

tools and utensils 

used in farming 

operations which 

come into contact 

with product are in 

good repair, fit for 

purpose, 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 and foot traffic is 

managed to prevent the introduction of 

potential food safety hazards. 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, and 

traffic procedures for 

equipment, vehicles,

workers, 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-7.3 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.

F-7.4 Vehicles, equipment, 

tools and utensils 

shall be controlled so 

as not to be a source 

of physical hazards.

R Operation has a glass and brittle plastic 

policy that addresses glass on 

production and harvesting vehicles, 

equipment, tools, and utensils in the 

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. Source of food 

safety risk is mitigated. 

Retraining is 

performed and 

documented.

F-7.5 Cleaning and 

sanitizing procedures 

do not pose a risk of 

product 

contamination.

Equipment cleaning and sanitizing 

operations shall be conducted in a 

manner that minimizes the risk of 

becoming a source of contamination in 

growing and/or product storage areas. 

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.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-7.6 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 and other water 

holding containers (e.g., cisterns, water 

totes, agricultural chemical tanks, dust 

control tanks), from which water 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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Harvesting

F-8: Preharvest Risk Assessment

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-8.1 A preharvest risk 

assessment shall be 

performed.

A ● The operation shall have a preharvest 

risk 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-9: Water/Ice Used in the Harvesting and Post-Harvest Operations

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-9.1 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-9.2 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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Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-9.3 If an antimicrobial 

process or chemical 

treatment is used for 

harvest or postharvest water, it shall 

be used in 

accordance with 

manufacturer 

instructions and the 

operation’s written 

SOP.

WP, 

R

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

antimicrobial pesticide (e.g., sanitizer 

or disinfectant) to prevent it from 

becoming a source of contamination. 

Treatment 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 indicated by 

current industry standard or prevailing 

regulation. Treatment is monitored at a 

frequency to meet treatment objectives. 

Records shall be kept.

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. Operation 

develops, documents, 

and implements 

procedures for use of 

the antimicrobial 

system in compliance 

with manufacturer’s 

label and instructions 

including monitoring 

for meeting the 

established acceptance 

criteria. Affected 

product is evaluated 

for potential 

contamination and 

disposition. Retraining 

is performed and 

documented. 

F-9.4 If water contacting 

product or food 

contact surfaces is reused, it shall be 

treated using a 

registered or 

approved 

antimicrobial process 

or chemical 

treatment.

● Re-used water shall be managed using 

an antimicrobial treatment sufficient to 

prevent cross-contamination, unless 

current industry standard or prevailing 

regulation provide an alternative.

Auditor reviews water 

treatment process and 

evidence of 

compliance with 

regulation and the 

operation’s established 

procedure.

Operation suspends 

operation until water 

treatment functions to 

prevent risk of product 

contamination. 

Affected product and 

product handling areas 

are evaluated for 

potential 

contamination and 

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

F-9.5 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-9.6 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 controlled in 

accordance with current industry 

standards or prevailing regulations. 

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 

wash water 

temperature.
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F-10: Containers, Bins and Packaging Materials

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-10.1 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-10.2 Operation has written 

policy regarding 

inspection of food 

contact containers 

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. 

F-10.3 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-10.4 Operation has written 

policy prohibiting 

use of harvest 

containers for nonharvest purposes.

WP ● Food-contact totes, bins packing and 

packaging materials and 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-11: Field Packaging and Handling

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-11.1 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-11.2 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-11.3 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-11.4 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-11.5 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-11.6 Packaging shall be 

stored in a manner 

that minimizes

contamination.

Packaging storage shall keep 

packaging dry, clean and free from dirt 

or residues so it remains fit for the 

purpose. 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-11.7 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 current

industry standards or prevailing 

regulation.

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: Post-Harvest Handling and Storage (Field Prior to Storage or Packinghouse)

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-12.1 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-12.2 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.
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F-13: Equipment Sanitation and Maintenance

Req. # Requirement DOC MAN Procedure Verification Corrective Action

F-13.1 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-13.2 Loading/unloading 

procedures and 

equipment shall 

minimize damage to 

and prevent 

contamination of 

produce.

Employees and workers 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/Good Agricultural Practices 

(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/Good 

Agricultural Practices 

(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: Facility

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-2.1 Operation has 

initially and at least 

annually thereafter, 

performed a

documented risk 

assessment of the 

packinghouse, and 

has addressed all 

identified risks.

 A ● Records shall be available to 

demonstrate that the packinghouse has 

been evaluated with regards to 

potential food safety risks associated 

with the packinghouse and the 

activities taking place within. Workers 

shall be trained on what the food 

safety risks are and how to manage 

them.

Auditors verify the 

operation has 

performed and 

documented a risk 

assessment of the 

packinghouse.

Auditor verifies that 

control measures for 

all significant risks 

identified during the 

analysis are 

implemented.

The operation shall 

perform and document 

a risk assessment for 

the packinghouse. 

Training of 

appropriate workers

may need to take place 

on conducting and 

recording this 

assessment. Operation 

trains workers on the 

maintenance of the 

food safety risks 

identified and how to 

manage and record the 

management of these 

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

P-2.2 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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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-2.3 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-2.4 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-2.5 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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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-2.6 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 

facility for evidence of 

allergen use, storage,

and employee training.

Operation develops 

and implements an 

Allergen Control 

Program or eliminates 

allergens from the 

facility.
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P-3: Pest and Animal Control

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-3.1 Operation has 

procedures to 

manage pests to the 

extent appropriate to 

the operation. 

WP,

R

● 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-3.2 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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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-3.3 If used, pest control 

devices, including 

rodent traps and 

electrical flying 

insect devices, are 

located 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-4: Equipment, Tools and Utensils

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-4.1 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, cleanable, and well 

maintained to prevent bacterial 

harborage.

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-4.2 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-4.3 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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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-4.4 All instruments or 

tools (e.g., test strips, 

titration kits) 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 ● If an in-line system is used, an 

independent measurement shall be 

used to verify compliance. Test 

methods, electronic devices, or test 

strips (within valid expiration date) 

used to monitor parameters shall be 

appropriate to their use, sufficiently 

sensitive to their intended purpose, 

and available in adequate numbers for 

their designated use. Calibration of 

measuring and monitoring equipment 

(thermometers, pH meters, scales, 

chemical application equipment, or 

other monitoring devices) is 

performed using an established 

method or according to manufacturer’s 

instructions. Records shall be kept.

Auditor reviews 

calibration and 

verification 

procedures to verify 

that an established 

method or 

manufacturer’s 

instructions are 

followed and reviews 

records.

Operation develops, 

documents and 

implements calibration 

and verification 

procedures and 

records.

P-4.5 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 and conform to 

current industry standard or prevailing 

regulation.

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.
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P-5: Maintenance and Sanitation

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-5.1 A preventive 

maintenance 

schedule with related 

SOPs shall be 

established.

WP,

R

● There is a written preventative 

maintenance schedule for all food and 

non-food contact surfaces including 

equipment, 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 

maintenance of cooling equipment. 

Drip pans and drains shall be 

maintained to assure condensate does 

not become a source of contamination. 

Floors are maintained to minimize 

and/or facilitate the removal of 

standing water.

Auditor reviews 

preventive 

maintenance schedule

and observes building 

and equipment for 

evidence that the 

building is maintained 

to prevent product 

contamination. 

Auditor reviews 

building maintenance 

records for evidence 

of repairs.

Operation develops a 

Preventive 

Maintenance 

Schedule, with related 

SOPs. Building 

deficiencies are 

corrected. Retraining 

is performed and 

documented. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-5.2 A master cleaning 

schedule with related 

SOPs shall be 

established.

WP, 

R

● There is a written cleaning schedule 

for all food and non-food contact 

surfaces including equipment, floors, 

drains, walls, ceilings, and other 

surfaces which may pose a source of 

product contamination. Established 

SOPs shall include instructions, 

person(s) responsible, specific 

frequency, and cleaning products and 

concentration. Sanitation tools must be 

appropriate for their designated 

purpose.

Auditor reviews 

cleaning records and 

associated SOPs and 

observes that food and 

non-food contact 

surfaces are cleaned in 

a manner and 

frequency sufficient to 

preventing product 

contamination.

Operation develops a 

master cleaning 

schedule with related 

SOPs. Cleaning 

deficiencies are 

corrected. 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

P-5.3 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. 

Cleaning and sanitation protocols are 

reviewed and updated respective to 

temporary repairs. Equipment is 

cleaned and sanitized after repair prior 

to being used.

Auditor observes 

temporary repairs, if 

present, and 

operation’s plans for 

timely completion of 

permanent repairs and 

cleaning and sanitation 

protocols.

Operation develops 

and implements a 

temporary repair 

procedure and a plan 

for permanent repairs. 

Operation 

immediately fixes any 

non-compliant 

temporary repairs. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

P-5.4 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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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-5.5 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-5.6 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-5.7 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 

waste control 

procedure. 

Operational 

deficiencies are 

corrected. Retraining 

is performed and 

documented. 
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P-5.8 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. 

P-5.9 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-5.10 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-5.11 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-6: Post-Harvest Water/Ice

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-6.1 A postharvest water 

system description 

shall be prepared. 

R ● Postharvest 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 the 

postharvest water 

system description or 

map and verifies 

accuracy during 

operation inspection. 

Operation develops or 

corrects the

postharvest water 

system description or 

map.
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P-6.2 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-6.3 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-6.4 The operation’s food 

safety plan includes 

the produce washing 

process, if used.

A,

WP

● If produce is washed, a risk 

assessment of the washing process 

includes 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-6.5 Re-used water that 

contacts product or 

food contact surfaces 

shall be treated using 

a registered or

approved 

antimicrobial process 

or chemical 

treatment.

● Re-used water shall be treated using 

an antimicrobial treatment sufficient to 

prevent cross-contamination, 

according to current industry standard 

or prevailing regulation. 

Auditor reviews water 

treatment process and 

evidence of 

compliance with 

regulation and the 

operation’s established 

procedure.

Operation suspends 

operation until water 

treatment functions to

prevent risk of product 

contamination. 

Affected product and 

product handling areas 

are evaluated for 

potential 

contamination and 

disposition.
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P-6.6 If a postharvest 

water antimicrobial 

treatment is used, it 

shall be used in 

accordance with 

established 

operational 

procedure and 

manufacturer 

instructions. 

R ● Treatment 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 indicated by 

current industry standard or prevailing 

regulation. Treatment is monitored at a 

frequency to meet treatment 

objectives. Records shall be kept.

Auditor reviews water 

use SOP for 

completeness and 

observes water 

treatment records for 

adequacy and 

consistency of 

treatment. Water 

treatment outcomes 

align with current 

industry standard or 

prevailing regulation.

Operation develops, 

documents, and 

implements 

procedures for use of 

the antimicrobial in 

compliance with 

manufacturer’s label 

and instructions 

including monitoring 

for meeting the 

established acceptance 

criteria established by 

current industry 

standard or prevailing 

regulation. Affected 

product is evaluated 

for potential 

contamination and 

disposition. 

Retraining is 

performed and 

documented.

P-6.7 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 current industry 

standards or prevailing regulation. 

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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P-6.8 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-6.9 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-7: Containers, Bins and Packaging

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-7.1 Specifications for all 

packaging materials 

and labels that 

impact 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-7.2 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-7.3 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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P-7.4 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-7.5 Operation has 

written policy 

regarding whether 

product-contact 

containers are 

permitted in direct 

contact with the 

ground or floor. 

WP 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-7.6 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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P-7.7 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-7.8 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-7.9 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-8: Storage

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-8.1 Product storage areas 

and conditions shall 

be appropriate to the 

commodities stored.

Produce storage locations and 

conditions shall minimize risk of 

produce contamination, consistent 

with current 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-8.2 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 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-8.3 Non-product storage 

areas shall be 

maintained so as not 

to be a source of 

product or materials 

contamination.

Areas designated to store materials

and equipment, 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-8.4 Food packaging and 

packing materials 

shall be stored in a 

manner that 

minimizes 

contamination.

Food packaging and packing 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-8.5 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.

P-8.6 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. 
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-8.7 When produce is 

cooled, it is cooled to 

temperatures 

appropriate to the 

commodity 

according to current 

established 

regulatory or 

industry standards. 

R When required by the food safety plan

or by industry guidelines for food 

safety, 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 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-8.8 Where temperature 

control is required by 

the food safety plan, 

cooling facilities 

shall be fitted with 

temperature 

monitoring 

equipment or 

suitable temperature 

monitoring device.

R Temperature monitoring equipment 

shall be located in all temperaturecontrolled 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.

P-8.9 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-9: Transportation (Packinghouse to Customer)

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-9.1 There is a written 

policy for 

transporters and 

conveyances to 

maintain a specified 

temperature(s) 

during transit.

WP When refrigerated transport is required 

by the food safety plan, 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-9.2 Prior to loading, the 

vehicle shall be precooled. 

WP,

R

When refrigerated transport is required 

by the food safety plan, 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-9.3 The refrigerated 

transport vehicles 

shall have properly 

maintained and fully 

functional 

refrigeration 

equipment.

WP When refrigerated transport is required 

by the food safety plan, 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 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-9.4 Where required, 

temperatures of 

product are taken 

and recorded prior to 

or upon loading.

WP, 

R

When refrigerated transport is required 

by the food safety plan, 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

and temperature 

records during 

loading.

Operation develops, 

documents and 

implements a policy. 

Retraining is 

performed and 

documented. 
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P-9.5 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-9.6 Loading/unloading 

procedures and 

equipment shall 

minimize damage to 

and prevent 

contamination of 

produce.

Employees and workers 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 

SC-652.

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 

SC-652.

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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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 9, 2024)

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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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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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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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Version 3.0 (February 9, 2024)

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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 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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 9, 2024)

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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.
USDA Harmonized GAP Standard 

Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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 reviewed 

for potential product 

adulteration. 

Retraining is 

performed.
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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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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Version 3.0 (February 9, 2024)

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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.