United States Departmentof Agriculture 

Agricultural MarketingService 

Fruit and VegetablePrograms 

Fresh ProductsBranchBulletin 

FPB 08-02 INSTRUCTIONS FOR THE CORRECTIVE ACTION PROCESS IN THE 

11/28/2007 GOOD AGRICULTURAL PRACTICES & GOOD HANDLING PRACTICES 

(GAP&GHP) AUDIT VERIFICATION PROGRAM 

I. Purpose To outline the policy for requesting and reviewing corrective actions in the 

GAP&GHP Program. 

n. Policy Effective October 1,2007, a corrective action report is required for any 

GAP&GHP audit that fails because of a specific "automatic unsatisfactory" or 

because a particular scope fails to meet the minimum passing score of eighty 

percent (80%). This report must be submitted to the lead auditor or state audit 

program supervisor prior to a federal or federal-state auditor conducting a reaudit of the farm/facility. 

Observing and Recording Non -conformities 

When an "automaticunsatisfactory"is observedon an audit, the auditor shall 

write a detailedobservationof the practiceor procedurethat caused the failure 

'including time, location,individualwho witnessedit and the specific question 

or item that was noted as a non-conformity. The observation causing the 

failure shouldbe reportedverbally and in writing to the person who oversees 

the Food SafetyProgramfor the auditee. A correctiveaction report form is 

attached for the auditor's use. 

The same procedure shall be followed when a particular scope fails to meet the 

minimum passing score, i.e., a corrective action report must be completed for 

the non - conformities noted. 

Evaluating Corrective Action Reports 

When the lead auditoror state audit program supervisorreceives the corrective 

action report from the auditee, it should be evaluatedfor the followingitems 

(not all may applyto every deficiency): 

Distribution: HQ ( FM( FS ( FPM ( 0 I C 

Originating OffiGe: Field Operations Section 

FileMaintenanceInstructions:File in Bulletin Binder until incorporated in handbook. 
FPB 08-02 

11/28/2007 

Page 2 

Attachments: 

. Short Ten" CorrectiveActions- Does it includethe details ofthe 

failure(s) and an immediate solution to the issue? Does it show who at 

the farm/facility is responsible for verifying the corrective action(s) has 

been implemented? Does it appear to be a reasonable solution to the 

problem? Does the corrective action confom1 to policies or Standard 

Operating Procedures (SOPs) listed in their food safety plan? 

. Root Cause Analysis- Whennecessary, does it include longterm 

actions needed to correctthe issue? Usually a root cause analysis 

requires a change in SOPs or a policy in the food safetyplan - has this 

been included? 

See attachment for an example of a corrective action plan. 

Once the corrective action report has been reviewed and the actions taken 

appear to be reasonable and appropriate, the lead auditor or state audit program 

supervisor will notify the auditee that the corrective actions were reviewed and 

will be verified during the re-audit. If however, the actions seem lacking or do 

not address the issue, notify the auditee and request that they review the 

corrective actions again, revise and resubmit for approval. It is important to 

remember that corrective actions are not approved as effective until they are 

verified during the re-audit. If there are questions regarding evaluating 

corrective action reports, please contact your Federal Program Manager or the 

Field Operations Section. 

Verifying Corrective Actions 

When the audit team performs the re-audit of the farm/facility, auditors must 

review the results of the corrective action plan to determine that the actions 

were implemented and that they achieved the desired results. The audit team 

should verify the corrective actions through the use of observations, records, 

and document reviews. 

The corrective action report shall be kept with the audit checklist and 

scoresheet in the office of record for the audit. 

Exhibit #1 - Blank Corrective Action Report 

Exhibit #2 - Example of Completed Corrective Action Report 

~e~l~:toJ 

Branch Chief 
USDA Fruit and Vegetable Programs Report#: 

of Good Agricultural Practice & Good Handling Practices 

CORRECTIVEACTION REPORT 

Date: Company Name/Farm: 

Lead Auditor: 

Crop: 

Description of Non-Conformity: 

Notified company staff at time of finding non-conformity: YES or NO 

Checklist question number and/or section of auditee food safety plan non-conformity is associated with: 

Company Representative Signature: 

SIGNATURE AFFIRMS FACTS CONCERNING NON-CONFORMITY ARE CORRECT 

Corrective Action Proposed and Time Frame for Implementation: (Attach separate sheet if necessary) 

Auditor Signature for Acceptance of Proposed Corrective Action and Timetable for Implementation: 

Top portion for AUDITOR USE ONLY; bottom portionfor Companyand Auditor use. 

FPB 08-02 Exhibit # 1 

November 28, 2007 
USDA Fruitand VegetablePrograms Report#: 

Good Agricultural Practice &Good Handling Practices 1 of 1 

CORRECTIVE ACTION REPORT 

Company Name/Farm: Date: 

QRS Produce Co November 21, 2007 

Timbuktu, Some state USA 

Lead Auditor: Joe Q Auditor 

Crop: Sweet Peppers 

Description of Non"Conformity: 

Observation - During review of the sOI1ing and packing of sweet peppers on the packing line at approximately 

I 0:45am, auditor observed several packers chewing tobacco and spitting tobacco juice onto the packing line in 

close proximity to unused packing cartons. The packers hadjust retumed from a break and had not utilized this 

particular packing line today. 

Auditor reported issue to QC Manager who was acting as a guide to the audit team. QC Manager observed 

issue as well. Audit was terminated, as this observation is an automatic unsatisfactory under "Observation of 

employee practices that jeopardize or may jeopardize the safety of the produce." 

Notified company staff at time of finding non-conformity' ES r NO 

Checklist question and/or sectionof auditeefood safety plan non-conformityis associatedwith: One of the 5 automatic 

unsatisfactory areas on audit 

Company Representative Signature: 

11/,1 C R¥/'Uf-trtatil'e 

SIGNATURE AFFIRMS FACTS CONCERNING NON-CONFORMITY ARE CORRECT 

Corrective Action Proposed and Time Frame for Implementation: (Attach separate sheet if necessary) 

CORRECTIVE ACTIONS TAKEN: Graders were takenoff the line and asked to removechew. The packing 

line was shut down and the area cleaned and sanitized accordingto company's Food SafetyPlan. Unused 

: cartons that may have been contaminatedwere removed fromarea, and not used. Gradersthen retumed to 

packing activities. All packers reminded that chewing or eatingis not allowed on packingline. 

Upon review of personal hygienetraining records by QC Manager,it was found that the graders that had the 

chew did not receive the requiredpersonal sanitation and hygienetraining. QC Managerwas instructed by 

senior management to verify that all current employeeshavereceived the proper training,and that all new 

employees must receive the proper training prior to workingon the packing lines. Also each line supervisor 

must verify that any new employeesare trained before allowingpacker to work on the line. 

AuditorSignature forAcceptanceof ProposedCorrectiveActionandTimetablefor Implementation: 

J~YvQ AuiUt-or 11(26(07 

TopportionforAUDITORUSEONLY:bottomportionforCompanyandAuditoruse. 

FPB 08-02 Example #2 

November 28, 2007