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Produce GAPs 

Harmonized Food 

Safety Standard

January 5, 2018
For Official Government Use Only.

The Produce GAPs Harmonized Food Safety Standard is based on the Produce GAPs Harmonized 

Combined Harmonized Food Safety Standard Version 1.1, 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. 

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

Produce GAPs Harmonized Food Safety Standard

Section Page No.

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

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

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

General Questions (G)...................................................................................................... 2

G-1: Management Responsibility........................................................................................ 2

G-2: Food Safety Plan or Risk Assessment .......................................................................... 3

G-3: Documentation & Recordkeeping................................................................................ 4

G-4: Worker Education and Training .................................................................................. 5

G-5: Sampling and Testing ................................................................................................ 7

G-6: Traceability............................................................................................................... 8

G-7: Recall Program ......................................................................................................... 9

G-8: Corrective Actions and Food Safety Incidents .............................................................. 9

G-9: Self-Audits ............................................................................................................. 10

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

G-11: Waste Management................................................................................................ 18

Field Operations and Harvesting (F)............................................................................... 19

F-1: Field History and Assessment.................................................................................... 19

F-2: Agricultural Chemicals /Plant Protection Products....................................................... 21

F-3: Water System Description......................................................................................... 24

F-4: Water System Risk Assessment ................................................................................. 25

F-5: Water Management Plan........................................................................................... 26

F-6: Animal Control........................................................................................................ 29

F-7: Soil Amendments..................................................................................................... 31

F-8: Vehicles, Equipment, Tools and Utensils.................................................................... 32

Harvesting ...................................................................................................................... 35

F-9: Preharvest Assessment.............................................................................................. 35

F-10: Water/Ice Used in the Harvesting and Postharvest Operations..................................... 35
iii

F-11: Containers, Bins and Packaging Materials................................................................. 38

F-12: Field Packaging and Handling ................................................................................. 39

F-13: Postharvest Handling and Storage (Field Prior to Storage or Packinghouse) ................. 42

F-14: Equipment Sanitation and Maintenance .................................................................... 43

Post-Harvest Operations (P)........................................................................................... 45

P-1: Produce Sourcing..................................................................................................... 45

P-2: Agricultural Chemicals............................................................................................. 46

P-3: Facility ................................................................................................................... 48

P-4: Pest and Animal Control........................................................................................... 51

P-5: Equipment, Tools and Utensils.................................................................................. 52

P-6: Maintenance and Sanitation ...................................................................................... 54

P-7: Post-Harvest Water/Ice ............................................................................................. 59

P-8: Containers, Bins and Packaging................................................................................. 64

P-9: Storage ................................................................................................................... 67

P-10: Transportation (Packinghouse to Customer).............................................................. 70

Logo Use (L) .................................................................................................................. 72

L-1: Food Safety Plan or Quality Manual .......................................................................... 72

L-2: Traceability and Recall Programs............................................................................... 72

L-3: Approved Suppliers ................................................................................................. 73

L-4: GAP & GHP Logo Approved Use ............................................................................. 74
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Introduction

The Produce GAPs Harmonized Food Safety Standard is based on the Harmonization Initiative Harmonized 

Food Safety Standards located at: https://www.unitedfresh.org/food-safety/gap-harmonization-initiative/. 

This standard has been reorganized to align with the Produce GAPs Harmonized Food Safety Standard 

USDA Checklist.

Scopes of Audit

The Produce GAPs Harmonized Food Safety 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.

Standard Layout

The standard has specified columns for the Requirement (Req. # & 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 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)

Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-1: Management Responsibility

G-1.1 A food safety policy 

shall be in place. 

WP ● A written policy shall outline a 

commitment to food safety, in 

general terms, how it is implemented 

and how it is communicated to 

employees, and be signed by Senior 

Management. 

The auditor observes 

the food safety policy, 

observes that it is 

signed by Senior 

Management, and 

observes that it has 

been communicated 

to all employees in a 

manner that can be 

understood.

The Operation creates 

or revises the policy, 

or its communication 

to employees, to be in 

compliance.

G-1.2 Management has 

designated 

individual(s) with 

roles and 

responsibilities for 

food safety 

functions.

WP ● The Food Safety Plan shall designate 

who has the responsibility and 

authority for food safety, including a 

provision for the absence of key 

personnel. Twenty-four hour contact 

information shall be available for 

these individuals in case of food 

safety emergencies. These roles and 

responsibilities shall be 

communicated within the 

organization.

Auditor observes that 

the Food Safety Plan 

has identified 

individual(s) for key 

food safety activities. 

Auditor verifies that 

procedures include 

provisions for when 

the identified 

individual is not 

present.

Operation identifies 

individual(s) for key 

food safety activities 

in the Food Safety 

Plan. Operation 

identifies actions to be 

taken when the 

identified 

individual(s) are not 

present.

G-1.3 There is a 

disciplinary policy 

for food safety 

violations.

There shall be a policy that 

establishes corrective actions for 

personnel who violate established 

food safety policies or procedures.

Auditor observes the 

policy and checks for 

examples of 

enforcement.

The Operation creates 

or revises the policy, 

or its communication 

to employees, to be in 

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

G-2: Food Safety Plan or Risk Assessment

G-2.1 There shall be a 

written Food Safety 

Plan. The plan shall 

cover the Operation. 

The Operation and 

products covered 

shall be defined.

WP ● The Food Safety Plan shall identify 

all locations of Operation covered by 

the plan and shall identify physical, 

chemical, and biological hazards 

reasonably likely to occur and hazard 

control procedures, including 

monitoring, verification and 

recordkeeping, for all provisions 

covered by this audit.

Auditor shall observe 

the Food Safety Plan 

and verify that the 

plan has considered 

potential biological, 

chemical and physical 

hazards and has 

identified preventive 

controls for hazards 

that may reasonably 

affect food safety.

Operation develops or 

completes a Food 

Safety Plan for all 

locations of 

Operation.

G-2.2 The Food Safety 

Plan shall be 

reviewed at least 

annually.

R Operation shall be responsible for 

reviewing their Food Safety Plan at 

least annually, documenting the 

review procedure and revising the 

plan as necessary. Updated or revised 

on date shall be indicated.

Auditor reviews last 

Food Safety Plan 

review.

Operation reviews 

Food Safety Plan and 

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

G-2.3* 

*This 

question 

does not 

apply to 

field 

operation

s in the 

Harmoni

zed audit.

Operation has an 

Approved Supplier 

program for all 

incoming materials, 

including packaging.

R ● Operation has and maintains a current 

list of approved raw material 

suppliers. Approved Supplier 

program includes a procedure for 

accepting materials from alternate 

sources.

Auditor verifies a list 

of raw material 

suppliers is 

maintained and 

current. Auditor 

verifies that all 

materials received 

from alternate sources 

has followed 

established procedure.

Operation develops an 

Approved Supplier 

program and 

maintains current list. 

Operation develops a 

procedure for 

accepting materials 

from alternate 

sources. Operation 

ceases accepting or 

shipping materials 

from non-compliant 

suppliers.

G-3: Documentation & Recordkeeping

G-3.1 Documentation shall 

be kept that 

demonstrates the 

food safety plan is 

being followed.

R ● Documents and records of 

procedures, standard operating

procedures (SOPs) and policies shall 

be in place for meeting each of the 

food safety standards identified in the 

Food Safety Plan. Records comply 

with prevailing regulations.

Auditor reviews Food 

Safety Plan and 

verifies that all 

required 

documentation is 

available.

Operation develops 

missing 

documentation or 

recordkeeping 

procedures.

G-3.2 Documentation shall 

be readily available 

for inspection.

● Documents and records may be 

maintained on-site or at an off-site 

location, or accessible electronically 

(e.g., MSDS), and shall be available 

for inspection in a reasonable 

timeframe or as required by 

prevailing regulation. 

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.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-3.3 Documentation shall 

be retained for a 

minimum period of 

two years, or as 

required by 

prevailing 

regulation.

R ● Document and record handling policy 

or procedures require that 

documentation required by the food 

safety plan shall be retained for a 

minimum of two years, or as required 

by prevailing regulation.

Auditor reviews 

document handling 

procedures and 

verifies that required 

documentation is 

available for at least 

two years, or as 

required by prevailing 

regulation.

Operation revises 

documentation 

procedures. 

G-4: Worker Education and Training

G-4.1 All personnel shall 

receive food safety 

training.

R ● All personnel shall receive training in 

the food safety policy and plan, food 

safety procedures, sanitation and 

personal hygiene appropriate to their 

job responsibilities. Personnel shall 

receive training at hire and refresher 

training at prescribed frequencies. 

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.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-4.2 Personnel with food 

safety 

responsibilities shall 

receive training

sufficient to their 

responsibilities.

R ● The individual designated for food 

safety responsibilities demonstrates 

knowledge of food safety principles. 

Food safety designate has completed 

at least one formal food safety 

course/workshop, by job experience

or as required by prevailing 

regulation.

Auditor reviews the 

evidence of the 

individual’s training 

relevant to produce 

food safety, such as a 

degree or course 

certificate or receipt, 

or attendance at a 

relevant food safety 

meeting, or company 

training record. If the 

Operation passes the 

food safety audit, the 

food safety 

individual’s training 

is deemed adequate.

Individual must 

obtain demonstrable 

food safety training.

G-4.3 Contracted 

personnel are held to 

the relevant food 

safety standards as 

they would be as 

employees.

R ● Operation shall have procedures 

and/or records to demonstrate that 

contracted personnel whose activities 

can affect food safety have been 

informed of and, to the extent that 

can be verified, are in compliance 

with the relevant requirements of this 

standard.

Auditor reviews 

Operation’s evidence 

that contracted 

personnel are trained 

to the same food 

safety requirements as 

employees would be 

and, if practical 

during the audit, 

observes contracted 

personnel for 

compliance.

Operation obtains 

evidence, trains or 

discontinues using 

contracted personnel.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-5: Sampling and Testing

G-5.1 Where laboratory 

analysis is required 

in the Food Safety 

Plan, testing shall be 

performed by a GLP 

laboratory using 

validated methods.

R Operation utilizes laboratories that 

have, at minimum, passed a Good 

Laboratory Practices (GLP) audit or 

participates in a Proficiency Testing 

program, and utilizes BAM, AOAC 

International or testing methods that 

have been validated for detecting or 

quantifying the target organism(s) or 

chemical(s).

Auditor reviews 

Operation’s evidence 

that only GLP 

laboratories and 

validated methods are 

used.

Operation 

discontinues using 

non-GLP laboratory 

and non-validated 

testing methods.

G-5.2 Where 

microbiological 

analysis is required 

in the Food Safety 

Plan, samples shall 

be collected in 

accordance with an 

established sampling 

procedure and 

prevailing 

regulations. 

WP Operation utilizes a written sampling 

protocol when collecting samples for

microbiological testing. 

Auditor observes that 

the Operation has a 

sampling protocol for 

each type of 

microbiological 

testing required in the 

Operation’s food 

safety plan.

Operation develops or 

obtains written 

sampling protocols 

for each type of 

microbiological 

testing required in 

their Food Safety 

Plan.

G-5.3 Tests, their results 

and actions taken 

must be 

documented.

R All results for microbiological testing 

required in the Operation’s food 

safety plan shall be recorded and the 

records maintained for two years or 

as required by prevailing regulation.

Auditor reviews 

Operation’s 

recordkeeping of 

microbiological test 

results.

Operation maintains 

for at least two years 

test records for all 

required 

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

G-5.4 All required testing 

shall include test 

procedures and 

actions to be taken 

based on the results.

WP ● For all microbiological testing 

required by the food safety plan, 

Operation has a written testing 

procedure that includes test 

frequency, sampling, test procedures, 

responsibilities and actions to be 

taken based on results. If finished 

product is tested for pathogens or 

other adulterants, Operation’s 

procedures require that it shall not be 

distributed outside the Operation’s 

control until test results are obtained. 

Auditor reviews the 

Operation’s 

microbiological 

testing procedures for 

completeness.

Operation revises 

testing procedures for 

completeness and to 

meet expectations of 

the food safety plan. 

G-6: Traceability

G-6.1 A documented 

traceability program 

shall be established.

WP,

R

● Records that enable reconciliation of 

product delivered to recipients (one 

step forward) shall be maintained 

except for direct to consumer sales. 

Records shall be maintained that link 

product with source of the produce or 

production inputs, e.g., soil 

amendments, fertilizers, 

seeds/transplants, agricultural 

chemicals, homemade preparations 

(one step backward). Records shall 

include the date of harvest, quantities, 

farm identification (field or block), 

transporter and non-transporter. 

Additional information may be 

included. Contents and retention of 

records shall be consistent with 

applicable regulations.

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.
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Req. # Requirement DOC MAN Procedure Verification Corrective Action

G-6.2 A trace back and 

trace forward 

exercise shall be 

performed at least 

annually.

R The trace back and trace forward 

exercise shall achieve accurate 

traceability within 4 hr 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.

G-7: Recall Program

G-7.1 A documented recall 

program, including 

written procedures, 

shall be established.

WP,

R

● The recall program shall have a 

designated recall team. A mock recall 

exercise shall be performed at least 

annually at the Operation being 

audited. The mock recall shall 

include the trace back and trace 

forward exercise and shall be 

completed as stated in the program 

and in compliance to applicable 

regulations.

Auditor reviews 

records of most recent 

mock recall 

performed at the 

Operation.

Operation develops 

recall team and recall 

plan, and tests the 

plan for effectiveness.

G-8: Corrective Actions and Food Safety Incidents

G-8.1 The Operation shall 

have documented 

corrective action 

procedures.

WP,

R

● A documented Corrective Action is 

required for an observation or audit 

that contains a non-conformance with 

food safety requirements. The 

responsibility, methods, and timelines 

to address Corrective Actions shall be 

documented and implemented.

Auditor reviews 

corrective action 

procedures and 

examines records for 

evidence of 

compliance. 

Operation develops 

and implements 

corrective actions 

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

G-9: Self-Audits

G-9.1 The Operation shall 

have documented 

self-audit 

procedures.

R Internal audits will be conducted at a 

minimum annually by an assigned 

individual utilizing this standard to 

assist in the self-audit. All aspects of 

the Operation’s food safety plan will 

be audited and a written record of 

required corrective action will be 

documented.

Auditor reviews 

internal audit 

procedures and 

examines records for 

evidence of 

compliance. 

Operation develops 

and implements 

internal audit 

procedures.

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

G-10.1 Operation shall have 

a policy for toilet, 

hygiene, and health.

WP ● Each Operation shall establish written 

policies for their specific operations, 

which shall be in compliance with 

prevailing regulations for Worker 

Health and Hygiene Practices.

Auditor ensures that 

policies for toilet, 

hygiene and health 

exist.

Operation develops 

written policies 

covering toilets, 

hygiene and health.

G-10.2 Employees and 

visitors shall be 

made aware of and 

follow all personal 

hygiene practices as 

designated by the 

Operation.

● Operation’s hygiene policies shall 

apply to all employees, contractors, 

visitors, buyers, product inspectors, 

auditors, and other personnel in the 

field. The Operation shall designate 

competent supervisory personnel to 

ensure compliance by all workers, 

visitors, and field personnel with the 

requirements in this section.

Auditor observes 

personnel in field for 

evidence of 

compliance. Auditor 

notes whether s/he 

was informed of the 

policy.

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

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

G-10.3 Toilet facilities and 

restrooms shall be 

designed, 

constructed, and 

located in a manner 

that minimizes the 

potential risk for 

product 

contamination and 

are directly 

accessible for 

servicing.

● Toilet and handwashing facilities are 

situated during operation and 

servicing, and maintained so as not to 

pose a hazard to the produce or other 

opportunity for contamination. 

Restrooms are located away from 

produce handling areas.

Auditor visually and 

by records 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.

G-10.4 Toilet facilities shall 

be of adequate 

number, easily 

accessible to 

employees and 

visitors and in 

compliance with 

applicable 

regulations.

● The Operation will have verification 

that the number of toilet facilities and 

their location relative to employees 

meets the more stringent of federal, 

state or local regulations. 

Auditor verifies that 

the number of 

available toilet 

facilities and their 

location is compliant 

with prevailing 

regulation for the 

number of employees.

Operation obtains a 

sufficient number of 

toilet facilities to be 

compliant.

G-10.5 The practice of 

disposing of used 

toilet tissue on the 

floor, in trash 

receptacles, or in 

boxes is prohibited.

● Operation shall instruct employees 

that used toilet tissue shall only be 

disposed of in the toilet.

Auditor observes 

restrooms for 

evidence of 

compliance.

Retraining is 

performed and 

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

G-10.6 Toilet and wash 

stations shall be 

maintained in a 

clean and sanitary 

condition. 

R ● Toilet paper shall be available in 

toilet facility. Wash stations shall be 

located with the field sanitation units 

and include hand wash facilities with 

water that meets the microbial 

standard for drinking water, hand 

soap, disposable towels or other hand 

drying device, towel disposal 

container, and a tank that captures 

used hand wash water for disposal. 

These stations shall be provided 

inside or adjacent to toilet facilities. 

Restrooms shall include hand wash 

facilities with water that meets the 

microbial standard for drinking water, 

hand soap, disposable towels or other 

hand drying device, and towel 

disposal container. Gray water is 

plumbed or captured for disposal. 

Auditor observes 

toilet and 

handwashing facilities 

for compliance. 

Auditor observes 

checklist or other 

evidence of a 

documented system 

for tracking cleaning 

of toilets.

Toilet or handwashing 

facility is replaced, 

repaired or 

maintained to be 

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

G-10.7 Personnel shall wash 

their hands at any 

time when their 

hands may be a 

source of 

contamination.

● Personnel shall wash their hands prior 

to start of work, after each visit to a 

toilet, after using a 

handkerchief/tissue, after handling 

contaminated material, after smoking, 

eating or drinking, after breaks and 

prior to returning to work, after 

touching animals or waste and at any 

other time when their hands may 

have become a source of 

contamination. Antiseptic hand rubs 

may not be used as a substitute for 

soap (or other effective surfactant) 

and water.

Auditor observes 

compliance with 

personnel for 

evidence of 

compliance.

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

G-10.8 Signage requiring 

handwashing is 

posted.

Signage in applicable languages 

and/or pictures shall be provided 

adjacent to hand wash facilities 

requiring people to wash their hands 

after each toilet visit.

Auditor verifies that 

signage is present 

adjacent to all hand 

wash facilities and is 

in appropriate 

language or pictures 

to clearly 

communicate 

requirements to all 

employees.

Operation obtains and 

posts signage to be 

compliant.

G-10.9 Clothing, including 

footwear, shall be 

effectively 

maintained and 

worn so as to protect 

product from risk of 

contamination.

● Operation shall have a policy that 

employee clothing shall be clean at 

the start of the day and appropriate 

for the Operation. 

Auditor reviews 

policy and observes 

compliance with 

Operation’s policy.

Operation develops or 

revises clothing 

policy. Retraining is 

performed and 

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

G-10.10 If gloves are used, 

the Operation shall 

have a glove use 

policy.

● If rubber, disposable, cloth or other 

gloves are used in contact with 

product, the Operation shall have a 

glove use policy that specifies how 

and when gloves are to be used, 

cleaned, replaced and stored. Hands 

must be washed before putting on 

gloves. Policy shall be in compliance 

with current industry practices or 

regulatory requirements for that

commodity.

If gloves are used, 

auditor observes 

glove use for 

compliance with the 

Operation’s policy 

and current industry 

practices or regulatory 

requirements. 

Operation develops or 

revises glove policy. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

G-10.11 If protective 

clothing is required 

by the Operation in 

product handling 

areas, it shall be 

handled in a manner 

to protect against 

contamination. 

When appropriate, 

racks and/or storage 

containers or 

designated storage 

area for protective 

clothing and tools 

used by employees 

shall be provided.

If protective clothing is used in 

proximity to product, the Operation 

shall have a policy or procedures for 

how and when protective clothing are 

to be used, cleaned, replaced and 

stored. The Operation shall have a 

policy for how the clothing and tools 

shall be stored when not in use so as 

to avoid potential contamination. 

Policy shall be in compliance with 

current industry practices or 

regulatory requirements for that 

commodity.

If protective clothing 

is used, auditor 

observes use for 

compliance with the 

Operation’s policy 

and current industry 

practices or regulatory 

requirements. Auditor 

observes whether 

storage areas are 

designated, available 

and used.

Operation develops or 

revises protective 

clothing policy or 

procedures. 

Operation obtains and 

positions racks and 

storage containers as 

necessary. Retraining 

is performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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G-10.12 The wearing of 

jewelry, body 

piercings and other 

loose objects (e.g. 

false nails) shall be 

in compliance to 

company policy and 

applicable 

regulation.

Operation shall have a policy that 

personal effects such as jewelry, 

watches or other items shall not be 

worn or brought into fresh fruit and 

vegetable production areas if they 

pose a threat to the safety and 

suitability of the food. Policy shall be 

in compliance with current industry 

practices or regulatory requirements 

for that commodity. 

Auditor observes 

personnel in field for 

evidence of 

compliance.

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

G-10.13 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-10.14 Employees’ personal 

belongings shall be 

stored in designated 

areas.

Operation shall have a policy for 

when and how employee’s personal 

belongings shall be stored so as not to 

be a source of product contamination. 

Auditor observes 

personnel in field for 

evidence of 

compliance.

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

G-10.15 Smoking, eating, 

chewing gum or 

tobacco, drinking 

(other than water), 

urinating, defecating 

or spitting shall be 

prohibited except in 

clearly designated 

areas.

● Operation shall have policy 

prohibiting smoking, eating, chewing 

gum or tobacco, and drinking (other 

than water) except in designated 

areas. Such areas shall be designated 

so as not to provide a source of 

contamination. Operation shall have 

policy prohibiting spitting, urinating 

or defecating in any production area.

Auditor observes 

personnel for 

evidence of 

compliance.

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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G-10.16 Operation shall have 

a written policy that 

break areas are 

located so as not to 

be a source of 

product 

contamination.

WP Break areas shall be designated and 

located away from food 

contact/handling zones and 

production equipment.

Auditor observes 

break areas for 

evidence of 

compliance with 

Operation policy.

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

G-10.17 Drinking water shall 

be available to all 

employees. 

R Drinking water, which meets drinking 

water standards, shall be easily 

accessible to field personnel and in 

compliance with applicable 

regulation. Bottled water or potable 

drinking water stations with singleuse cups and a trash receptacle shall 

be available to all employees. 

Auditor observes 

evidence of drinking 

water accessibility 

and Operation’s 

evidence that water 

supplied to personnel 

meets drinking water 

standards. 

Operation makes 

drinking water 

available to 

employees, in 

compliance with 

prevailing regulation.

G-10.18 Workers and visitors 

who show signs of 

illness shall be 

restricted from 

direct contact with 

produce or foodcontact surfaces.

WP ● Operation shall have a policy that 

restricts employees, contractors, 

visitors, buyers, product inspectors, 

auditors, and other personnel in the 

Operation who show signs of illness 

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

from contact with product or food 

contact surfaces. Policy shall require 

that any person so affected 

immediately report illness or 

symptoms of illness to the 

management.

Auditor reviews 

policy and observes 

field personnel for 

evidence of 

compliance.

Operation develops 

and implements 

policy. Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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G-10.19 Personnel with 

exposed cuts, sores 

or lesions shall not 

be engaged in 

handling product. 

● Minor cuts or abrasions on exposed 

parts of the body are acceptable if 

covered with a non-permeable 

covering, bandage or glove. 

Bandages on hands shall be covered 

with gloves in compliance with 

Operation’s glove policy. 

Auditor observes 

personnel in field for 

evidence of 

compliance.

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

G-10.20 Operation shall have 

a blood and bodily 

fluids policy.

WP ● There shall be a written policy 

specifying the procedures for the 

handling/ disposition of food or 

product contact surfaces that have 

been in contact with blood or other 

bodily fluids.

Auditor reviews 

policy and observes 

Operation for 

evidence of 

compliance.

Operation develops 

and implements 

policy. Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

G-10.21 First aid kits shall be 

accessible to all 

personnel.

The kits shall be readily available in 

the vicinity of field work in the 

Operation and maintained in 

accordance with prevailing 

regulation. The kit materials shall be 

kept in a sanitary and usable 

condition.

Auditor observes that 

provisions exist for 

first aid kit to be 

readily available in 

vicinity of workers 

and is stocked in 

accordance with 

prevailing regulation.

Operation obtains and 

stocks a first aid kit 

and ensures it is 

readily accessible 

near field personnel.
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G-11: Waste Management

G-11.1 Operation has 

implemented a 

waste management 

plan.

● Operation implements procedures for 

the control, storage and disposal of 

trash, litter, and waste in areas used 

for produce handling activities. Such 

procedures minimize the potential for 

trash, litter, or waste to attract or 

harbor pests and protect against 

contamination of produce, food 

contact surfaces, areas used for 

produce handling activities, water 

sources, and water distribution 

systems. Waste treatment and 

disposal systems operate so that they 

do not constitute a potential source of 

contamination in produce handling 

areas. 

Auditor verifies the 

Operation has 

implemented a waste 

management plan.

Operation implements 

a waste management 

plan.

G-11.2 Trash shall not come 

in contact with 

produce.

● Trash handling and removal shall not 

pose a hazard of contamination of 

produce. 

Auditor reviews trash 

handling procedures 

for field operation, 

and observes trash 

handling practices for 

evidence of 

compliance.

Operation revises 

procedures. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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Field Operations and Harvesting (F)

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F-1: Field History and Assessment

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 for 

environmental conditions or risk 

awareness that has changed since the 

last assessment. The assessment 

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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F-1.2 For indoor growing 

and field storage 

buildings, building 

shall be constructed 

and maintained in a 

manner that prevents 

contamination of 

produce. 

● Building and equipment structures 

and surfaces (floors, walls, ceilings, 

doors, frames, hatches, etc.) shall be 

constructed in a manner that 

facilitates cleaning and sanitation and 

does not serve as harborage for 

contaminants or pests. Chill and cold 

storage loading dock areas shall be 

appropriately sealed, drained and 

graded. Fixtures, ducts, pipes and 

overhead structures shall be installed 

and maintained so that drips and 

condensation do not contaminate 

produce, raw materials or food 

contact surfaces. Water from 

refrigeration drip pans shall be 

drained and disposed of away from 

product and product contact surfaces. 

Drip pans and drains shall be 

designed to assure condensate does 

not become a source of 

contamination. Air intakes shall not 

be located near potential sources of 

contamination.

Auditor observes 

building and 

equipment for 

evidence that the 

building can be 

cleaned and 

maintained to prevent 

product 

contamination. 

Building deficiencies 

are corrected. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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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.

F-2: Agricultural Chemicals /Plant Protection Products

F-2.1 Use of agricultural 

chemicals shall 

comply with label 

directions and 

prevailing 

regulation.

R ● Agricultural chemicals, including 

post-harvest 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. Records of agricultural 

use are maintained.

Auditor reviews 

agricultural chemical 

use records for 

evidence of 

compliance with 

approved uses or label 

directions.

Operation develops 

and maintains 

agricultural chemical 

use records and 

maintains evidence of 

proper use of each 

chemical use. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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F-2.2 If product is 

intended for export, 

agricultural 

chemical use, 

including postharvest chemicals, 

shall consider 

requirements in the 

intended country of 

destination.

The Operation shall have procedures, 

such as pre-harvest interval and 

application rate, sufficient to meet the 

MRL entry requirements of the 

country(ies) in which the product is 

intended to be traded, if known 

during production.

Auditor reviews 

Operation’s procedure 

for complying with 

agricultural chemical 

restrictions in 

countries of 

destination. If the 

country of destination 

is unknown during 

production, this item 

is not applicable.

Operation develops 

procedures, and 

diverts non-compliant 

product to a market in 

which the product 

meets standards.

F-2.3 Agricultural 

chemicals shall be 

applied by trained, 

licensed or certified 

application 

personnel, as 

required by 

prevailing 

regulation.

R Operation maintains records 

demonstrating that all personnel 

responsible for chemical applications 

are trained and/or licensed, or 

supervised by licensed personnel, in 

compliance with prevailing 

regulation.

Auditor reviews 

records demonstrating 

that application 

personnel are licensed 

and/or trained in 

compliance with 

prevailing regulation.

Operation utilizes 

application personnel 

who are appropriately 

licensed and/or 

trained.
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F-2.4 Water used with 

agricultural 

chemicals shall not 

be a source of 

product or field 

contamination.

R Water used to dilute or deliver 

agricultural chemicals shall be from a 

source in compliance with the Water 

System Risk Assessment and Water 

Management Plan, consistent with 

current industry practices or 

regulatory requirements for that 

commodity. 

Auditor reviews the 

Water System Risk 

Assessment for 

evidence that water 

used with agricultural 

chemicals has been 

considered, and that 

agricultural chemical 

use policies are in 

compliance with the 

Water System Risk 

Assessment.

Operation revises the 

Water System Risk 

Assessment. 

Operation uses a 

water source in 

compliance with the 

Water System Risk 

Assessment. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

F-2.5 Agricultural 

chemical disposal 

shall not be a source 

of product or field 

contamination.

R Operation shall have procedures for 

disposal of waste agricultural 

chemicals and for cleaning of 

application equipment that protects 

against contamination of product and 

growing areas.

Auditor reviews 

procedures and 

observes chemical 

handling records for 

evidence of 

compliance.

Operation develops 

and implements 

procedures. Steps are 

taken to mitigate any 

contamination events.
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F-3: Water System Description

F-3.1 A water system 

description shall be 

available for review.

WP ● Water sources and the production 

blocks they may serve shall be 

documented and current. The 

description shall include one or more 

of the following: maps, photographs, 

drawings (hand drawings are 

acceptable) or other means to 

communicate the location of water 

source(s), permanent fixtures and the 

flow of the water system (including 

holding systems, reservoirs or any 

water captured for re-use). 

Permanent fixtures include wells, 

gates, reservoirs, valves, returns and 

other above ground features that 

make up a complete irrigation system 

shall be documented in such a 

manner as to enable location in the 

field or in hydroponic, aeroponic or 

aquaponics operations. 

Auditor reviews water 

system description or 

map, and verifies 

accuracy during 

inspection. 

Operation develops or 

corrects the water 

system description or 

map.

F-3.2 The water source 

shall be in 

compliance with 

prevailing 

regulations.

Water shall be sourced from a 

location and in a manner that is 

compliant with prevailing 

regulations.

Auditor determines 

whether the water 

source is compliant 

with regulations 

relevant for the 

intended use of the 

water. 

Operation 

discontinues use of 

the source until 

compliant with 

regulations. Affected 

produce is evaluated 

for potential 

contamination and 

disposition.
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F-3.3 Water systems shall 

not be crossconnected with 

human or animal 

waste systems.

● Water systems intended to convey 

untreated human or animal waste 

shall be separated from conveyances 

utilized to deliver water.

Auditor reviews water 

system for crossconnections with 

human or animal 

waste conveyances.

Operation 

discontinues use of 

the system until they 

are separated. 

F-4: Water System Risk Assessment

F-4.1 An initial risk 

assessment shall be 

performed and 

documented that 

takes into 

consideration the 

historical testing 

results of the water 

source, the 

characteristics of the 

crop, the stage of the 

crop, and the 

method of 

application. 

A ● A review or new assessment shall be 

conducted seasonally and any time 

there is a change made to the system 

or a situation occurs that could 

introduce an opportunity to 

contaminate the system. The risk 

assessment shall address potential 

physical, chemical, and biological 

hazards and hazard control 

procedures for the water distribution 

system. 

Auditor reviews the 

risk assessment for 

completeness of 

consideration of 

potential hazards.

Operation develops or 

updates the risk 

assessment.
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F-5: Water Management Plan

F-5.1 There shall be a 

water management 

plan to mitigate 

risks associated with 

the water system on 

an ongoing basis. 

WP ● The water management plan shall 

include the following: preventive 

controls, monitoring and verification 

procedures, corrective actions, and 

documentation. The plan shall be 

reviewed following any changes 

made to the water system risk 

assessment and adjusted accordingly 

to incorporate such changes. Training 

and/or retraining of personnel having 

oversight or performance duties shall 

be documented.

Auditor reviews the 

water management 

plan for accuracy and 

completeness relative 

to the risk assessment.

Operation develops or 

updates the water 

management plan.

F-5.2 Water testing shall 

be part of the water 

management plan, 

as directed by the 

water risk 

assessment and 

current industry 

standards or 

prevailing 

regulations for the 

commodities being 

grown.

WP ● As required, there shall be a written 

procedure for water testing during the 

production and harvest season, which 

includes frequency of sampling, who 

is taking the samples, where sample 

is taken, how the sample is collected, 

type of test and acceptance criteria. 

If all water is sourced from a 

municipal source, the municipal 

testing shall suffice. The frequency 

of testing and point of water 

sampling shall be determined based 

on the risk assessment and current 

industry standards or prevailing 

regulations for commodities being 

produced. 

Auditor verifies that a 

water testing program 

is in compliance with 

the risk assessment 

and current industry 

standards or 

prevailing regulations 

and is included in the 

water management 

plan. 

Operation develops a 

testing program 

consistent with risks 

identified in the risk 

assessment and with 

current industry 

standards or 

prevailing regulations 

for the commodities 

being produced. 
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F-5.3 The testing program 

shall be 

implemented 

consistent with the 

water management 

plan. 

R ● Testing shall be performed and 

documented according to procedures 

described in the water management 

plan. 

Auditor reviews 

testing records for 

compliance with the 

written plan.

Operation shall revise 

testing to be in 

compliance with the 

written plan. The 

corrective actions 

noted in the water 

management plan 

shall be followed until 

the conditions have 

been mitigated and 

the non-conformity 

has been resolved.

F-5.4 If water is treated to 

meet 

microbiological 

criteria, the 

treatment is 

approved and 

effective for its 

intended use, and is 

appropriately 

monitored.

R ● Treatment is approved for its 

intended use (e.g., EPA-registered 

antimicrobial pesticide) and is 

delivered in a manner to ensure that 

the treated water is consistently safe 

and of adequate sanitary quality for 

its intended use and/or consistently 

meets the relevant microbial quality 

criteria. Treatment is monitored at a 

frequency adequate to ensure that the 

treated water is consistently safe and 

of adequate sanitary quality for its 

intended use and/or consistently 

meets the relevant microbial quality 

criteria.

Auditor verifies that 

water treatment is 

approved for its 

intended use, reviews 

documentation that it 

is used effectively to 

meet the intended 

microbiological 

criteria, and reviews 

monitoring records 

for compliance with 

the Operation’s 

established procedure 

and acceptance 

criteria.

Operation 

discontinues use of 

unapproved 

treatments, uses 

approved treatments 

in an effective 

manner, and monitors 

the treatment at an 

adequate frequency.
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F-5.5 If post-harvest 

handling is used to 

achieve microbial 

criteria, Operation 

has documentation 

supporting its use.

R ● If die-off or removal rates or other 

methods (e.g., commercial washing) 

are used to achieve microbial criteria 

of water used during growing, 

Operation has scientific data or 

information used to support its 

effectiveness. Documentation 

includes the specific time interval or 

log reduction applied, how the time 

interval or log reduction was 

determined, and the dates of 

corresponding activities such as the 

dates of last irrigation and harvest, 

the dates of harvest and end of 

storage, and/or the dates of activities 

such as commercial washing.

Auditor verifies 

documentation for 

completeness.

Operation obtains 

documentation on, or 

discontinues use of, 

unsupported methods, 

uses approved 

methods in an 

effective manner, and 

maintains required 

documentation.

F-5.6 If Operation uses an 

alternative approach 

to regulatory 

microbiological 

testing, Operation 

has scientific data or 

information to 

support the 

alternative. 

R ● If Operation uses an alternative 

testing method, frequency or criteria 

to regulatory requirements, Operation 

has documentation supporting the 

alternative.

Auditor verifies 

documentation for 

completeness.

Operation obtains 

documentation on, or 

discontinues use of, 

the alternative.
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F-6: Animal Control

F-6.1 The Operation has a 

written risk 

assessment on 

animal activity in 

and around the 

production area.

A ● There shall be a written assessment 

of the growing fields and adjacent 

land, prior to each growing season, 

focusing on domestic and wild 

animal activity including grazing and 

feeding operations, noting crop 

characteristics, type and approximate 

number of animals, proximity to the 

growing field, water sources, and 

other relevant factors. 

Auditor reviews the 

written assessment to 

ensure it has been 

performed for this 

season and is 

complete.

Operation performs 

and documents the 

assessment.

F-6.2 The Operation 

routinely monitors 

for animal activity 

in and around the 

growing area during 

the growing season.

R ● There shall be scheduled monitoring 

of growing fields and adjacent land 

for evidence of animal activity. A 

frequency of monitoring and 

assessment shall be established based 

on production factors, such as the 

crop, geography, and other 

conditions. 

Auditor reviews 

monitoring records to 

ensure the frequency 

of monitoring is 

consistent with the 

schedule. 

Operation develops 

and implements a 

monitoring schedule.
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F-6.3 Based on the risk 

assessment, there 

shall be measures to 

prevent or minimize 

the potential for 

contamination from 

animals, including 

domesticated 

animals used in 

farming operations. 

WP,

R

● The Operation shall have riskappropriate actions to prevent or

minimize the potential for 

contamination of produce with 

pathogens from animal feces, 

including from domesticated animals 

used in farming operations. There 

shall be a written record of any 

mitigation or corrective actions. 

Preventive measures and corrective 

actions shall comply with all local, 

state and federal regulations 

concerning animal control and 

natural resource conservation.

Auditor reviews 

preventive measures 

and corrective action 

plans.

Operation develops 

and implements riskappropriate corrective 

actions for animal 

intrusions reasonably 

likely to contaminate 

produce in the field.
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F-7: Soil Amendments

F-7.1 The food safety plan 

shall address soil 

amendment risk, 

preparation, use, and 

storage. 

A,

R

● If animal-based soil amendments or 

biosolids are used, records of 

composition, dates of treatment, 

methods utilized and application 

dates must be documented. Evidence 

of processing adequate to eliminate 

pathogens of human concern, such as 

letter of guarantee, certificate of 

analysis (COA) or any test results or 

verification data (e.g., time and 

temperature) demonstrating 

compliance with process or microbial 

standards, shall be documented. Such 

soil amendments must be produced, 

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 

animal-based soil 

amendments or 

biosolids. Operation 

develops and 

implements policies 

to obtain treatment 

information for all 

animal-based soil 

amendments. 
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F-7.2 If a soil amendment 

containing raw or 

incompletely treated 

manure is used, it 

shall be used in a 

manner so as not to 

serve as a source of 

contamination of 

produce.

R ● If such a product is used, there shall 

be documentation of the composition, 

and time and method of application. 

Such use will be consistent with 

current industry practices or 

regulatory restrictions for that 

commodity. 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.

F-8: Vehicles, Equipment, Tools and Utensils

F-8.1 Equipment, 

vehicles, tools 

utensils and other 

items or materials 

used in farming 

operations that may 

contact produce are 

identified.

R Operation maintains a list of 

equipment, vehicles, tools, utensils 

and other items or materials that may 

pose a risk of produce contamination 

during normal use.

Auditor reviews the 

list for completeness.

Operation develops a 

list of equipment, 

vehicles, tools and 

utensils that may pose 

a risk of produce 

contamination during 

normal use.
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F-8.2 Equipment, 

vehicles, tools and 

utensils used in 

farming operations 

which come into 

contact with product 

are in good repair, 

and are not a source 

of contamination of 

produce.

WP,

R

● The Operation shall develop, 

implement, and schedule repair, 

cleaning, sanitizing, storage and 

handling procedures of all food 

contact surfaces to reduce and control 

the potential for contamination. 

Records must include the date and 

method of cleaning and sanitizing 

equipment. As necessary for food 

safety, vehicles and equipment shall 

be properly calibrated, operated, 

maintained, and used as intended. 

Equipment traffic flow is prevented 

from traveling through an untreated 

manure area into the harvesting field. 

These procedures shall be 

documented. Product contact tools, 

utensils and equipment shall be made 

of materials that can be cleaned and 

sanitized. Procedures include 

equipment and vehicles that are in the 

field infrequently. 

Auditor observes 

production and 

harvest vehicles, 

equipment, tools and 

utensils which may 

come into contact 

with produce for 

evidence of food 

safety risks. Auditor 

reviews maintenance, 

cleaning and 

sanitation records that 

demonstrate 

compliance with 

procedures.

Operation develops 

maintenance, cleaning 

and sanitation 

procedures for 

equipment, vehicles, 

tools and utensils that 

may pose a risk for 

produce 

contamination. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

F-8.3 Vehicles, 

equipment, tools and 

utensils shall be 

controlled so as not 

to be a source of 

chemical hazards.

WP Operation shall have a written 

procedure to address the spills and 

leaks (fuel, oil, hydraulic fluids) 

which might occur during equipment 

operation in the field. 

Auditor observes 

production and 

harvest vehicles, 

equipment, tools and 

utensils which may 

come into contact 

with produce for 

evidence of food 

safety risks. 

Operation repairs 

leaks and cleans any 

food contact surfaces. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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F-8.4 Vehicles, 

equipment, tools and 

utensils shall be

controlled so as not 

to be a source of 

physical hazards.

Operation has a glass and brittle 

plastic policy that addresses glass on 

production equipment and in growing 

area. Inspections performed in 

compliance with the policy shall be 

documented. 

Auditor observes 

production and 

harvest vehicles, 

equipment, tools and 

utensils which may 

come into contact 

with produce for 

evidence of food 

safety risks and for 

compliance with the 

glass and brittle 

plastic policy. 

Operation develops 

policy. Retraining is 

performed. Source of 

food safety risk is 

mitigated.

F-8.5 Cleaning and 

sanitizing 

procedures do not 

pose a risk of 

product 

contamination.

Equipment cleaning and sanitizing 

operations shall be conducted away 

from the product and other equipment 

to reduce the potential for 

contamination. Water used for 

cleaning and sanitizing shall meet the 

microbial standards for drinking 

water.

Auditor reviews 

cleaning and 

sanitizing procedures 

for steps to prevent 

contamination of 

produce, and observes 

Operation’s evidence 

of compliance.

Operation develops 

and implements 

procedures. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

F-8.6 Water tanks are 

cleaned at a 

sufficient frequency 

so as not to be a 

source of 

contamination. 

WP ● There shall be a written procedure for 

cleaning water tanks, such as those 

used for dust control, the water from 

which may contact produce in the 

field. 

Auditor reviews water 

tank cleaning 

procedures for steps 

to prevent 

contamination of 

produce, and observes 

Operation’s evidence 

of compliance.

Operation develops 

and implements 

procedures. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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Harvesting

F-9: Preharvest Assessment

F-9.1 A preharvest risk 

assessment shall be 

performed.

A ● The Operation shall have a preharvest 

assessment procedure, which 

describes when the assessment is 

performed and that it includes an 

evaluation of conditions that may be 

reasonably likely to result in 

physical, chemical, or biological 

contamination of the produce, and 

demonstrates that the Operation is in 

compliance with the food safety plan. 

Results of the evaluation shall be 

documented.

Auditor reviews most 

recent preharvest 

assessment for 

completeness and 

consistency with the 

food safety plan.

Operation develops 

and implements a 

preharvest assessment 

procedure.

F-10: Water/Ice Used in the Harvesting and Postharvest Operations

F-10.1 Operation has 

procedures for water 

used in contact with 

product or food 

contact surfaces.

WP, 

R

● Standard Operating Procedures 

(SOPs), including water-change 

schedules, shall be developed for all 

uses of water. Microbial and/or 

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

testing shall be performed, as 

appropriate to the specific Operation, 

to demonstrate that acceptance 

criteria have been met.

Auditor observes 

evidence of existence 

of water use SOPs.

Operation develops 

the SOPs. 
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F-10.2 Water use SOPs 

address the 

microbial quality of 

water or ice that 

directly contacts the 

harvested crop or is 

used on food-contact 

surfaces. 

R ● If water or ice directly contacts the 

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

as the final wash step prior to 

consumer packaging, or as a cooling 

aid in a consumer package, 

Operation’s water use SOP requires 

that water or ice when applied meets 

the microbial standards for drinking 

water, as defined by prevailing 

regulation. Water may be treated 

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

microbial standards or to prevent 

cross-contamination. Ice and water 

shall be sourced/manufactured, 

transported, and stored under sanitary 

conditions. Special considerations or 

variances may be appropriate for 

some crops, e.g. cranberries and 

watercress, where deliberate flooding 

of the field is part of production and 

harvest practices.

Auditor reviews 

Operation’s policy 

regarding water 

quality and its 

transport, and 

observes evidence 

that water or ice that 

contacts harvested 

crop or food contact 

surfaces meets the 

microbial standards 

for drinking water. 

Operation 

discontinues using 

water or ice that does 

not meet the 

microbial standards of 

drinking water. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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F-10.3 Water use SOPs 

address treatment of 

re-circulated water, 

if used. 

R ● Operation’s water use SOPs require 

re-circulated water to be treated using 

an approved antimicrobial to prevent 

it from becoming a source of 

contamination, according to 

prevailing regulation or industry 

specific standards for the commodity. 

Auditor reviews water 

use SOP for 

completeness, and 

observes water 

treatment records for 

adequacy and 

consistency of 

treatment.

Operation 

discontinues using recirculated water that 

is not treated 

sufficiently to prevent 

contamination of the 

produce. Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

F-10.4 Water use SOPs 

address condition 

and maintenance of 

water-delivery 

system.

R ● The water-delivery system shall be 

maintained so as not to serve as a 

source of contamination of produce, 

water supplies or equipment with 

pathogens, or to create an unsanitary 

condition.

Auditor reviews the 

SOP for inclusion of 

condition and 

maintenance of waterdelivery system, and 

observes maintenance 

records for evidence 

of compliance.

Operation revises 

SOP and implements 

maintenance 

procedures.

F-10.5 If applicable to the 

specific commodity, 

water use SOPs 

address control of 

wash water 

temperature.

R For produce demonstrated as being 

susceptible to microbial infiltration 

from wash water, wash water 

temperature differentials during 

immersion shall be considered. 

If applicable to the 

commodity being 

washed, auditor 

reviews the SOP for 

inclusion of water

temperature control, 

and observes 

monitoring records 

for evidence of 

compliance.

Operation revises 

SOP to address and 

control wash water 

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

F-11.1 Operation has 

written policy 

regarding storage of 

harvesting 

containers.

WP Harvesting containers shall be stored 

in a manner so as not to serve as a 

source of contamination to the extent 

feasible and appropriate.

Auditor observes 

whether Operation 

has a policy regarding 

storage of harvesting 

containers used in the 

field. Auditor 

observes current 

practices for 

compliance with 

policy.

Operation develops 

the policy. Retraining 

is performed and 

documented. 

F-11.2 Operation has 

written policy 

regarding inspection 

of food contact 

containers prior to 

use.

WP Food-contact totes, bins, packing 

materials, other harvest containers, 

and pallets shall be visually 

inspected, clean, intact and free of 

any foreign materials prior to use. 

Containers shall be sufficiently 

maintained so as not to become a 

source of contamination.

Auditor observes 

whether Operation 

has a policy regarding 

inspection of food 

contact containers and 

observes current 

practices for 

compliance with 

policy.

Operation develops 

the policy. Retraining 

is performed and 

documented. 

F-11.3 Operation has 

written policy 

regarding acceptable 

harvesting 

containers.

WP ● The types and construction of harvest 

containers and packing materials 

shall be appropriate to the commodity 

being harvested and suited for their 

intended purpose.

Auditor observes 

whether Operation 

has a policy regarding 

what types of 

containers and 

packing materials are 

acceptable for use 

during harvest, and 

observes current 

practices for 

compliance with the 

policy.

Operation develops 

the policy. Retraining 

is performed and 

documented. 
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F-11.4 Operation has 

written policy 

prohibiting use of 

harvest containers 

for non-harvest 

purposes.

WP ● Food-contact totes, bins and other 

harvest containers designated for 

harvesting shall not be used for other 

purposes unless clearly marked or 

labeled for that purpose.

Auditor observes 

whether Operation 

has a policy 

prohibiting use of 

harvest containers for 

other uses unless 

otherwise labeled, and 

observes current 

practices for 

compliance with the 

policy.

Operation develops 

the policy. Retraining 

is performed and 

documented. 

F-12: Field Packaging and Handling

F-12.1 Operation shall have 

a written policy that 

visibly 

contaminated, 

damaged or decayed 

produce is not 

harvested, or is 

culled. 

WP ● Employees are trained that only 

sound produce appropriate for the 

intended use is harvested, and that 

produce that has been visibly 

contaminated or otherwise damaged 

to an extent that it poses a microbial 

food safety hazard is not harvested or 

is culled. 

Auditor reviews 

written policy and 

evidence of employee 

training. Auditor 

inspects the harvest or 

sorting operation for 

evidence of 

compliance.

Operation develops 

the policy. Retraining 

is performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

F-12.2 Product that contacts 

the ground shall not 

be harvested unless 

the product normally 

grows in contact 

with the ground.

WP ● Operation has considered and 

developed written policies regarding 

produce that comes in contact with 

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

the degree practicable, contact of cut 

surfaces of harvested produce with 

soil. Policy shall be consistent with 

industry standards or prevailing 

regulations.

Auditor reviews 

written policy and 

evidence of employee 

training. Auditor 

inspects the harvest or 

sorting operation for 

evidence of 

compliance.

Operation develops 

the policy. Retraining 

is performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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F-12.3 Harvest procedures 

shall include 

measures to inspect 

for and remove 

physical hazards. 

Operation shall have procedures to 

detect glass/plastic breakage and 

remove possible physical 

contamination such as glass, metal, 

rocks, or other hazardous items, 

during harvesting operations.

Auditor inspects the 

harvest or sorting 

operation for evidence 

of hazard control.

Operation develops 

the procedure. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

F-12.4 Cloths, towels, or 

other cleaning 

materials that pose a 

risk of crosscontamination shall 

not be used to wipe 

produce.

Operations shall not use cloths or 

other cleaning materials to clean 

produce, unless there is a procedure 

to prevent 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.

F-12.5 Packaging materials 

shall be appropriate 

for their intended 

use.

● The product contact packaging shall 

be appropriate to the commodity 

being harvested and suited for its 

intended purpose.

Auditor observes 

evidence (e.g., 

information from 

supplier, customer 

specification, industry 

standards, prevailing 

regulation) that the 

packaging does not 

create an unsafe 

condition.

Operation 

discontinues use of 

the packaging until 

information can be 

obtained 

demonstrating safe 

use. Affected product 

is evaluated for 

potential 

contamination and 

disposition.
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F-12.6 Packaging shall be 

stored in a manner 

that prevents 

contamination.

Packaging storage shall be designed 

to maintain packaging dry, clean and 

free from dirt or residues so it 

remains fit for the purpose. Particular 

care shall be taken to prevent 

packaging from becoming a 

harborage for rodents and other 

vermin. Packaging shall be stored 

separately from hazardous chemicals, 

toxic substances and other sources of 

contamination.

Auditor inspects 

packaging storage 

area for evidence of 

compliance. 

Operation designates 

a storage area and 

practices that reduce 

risk of contamination. 

Affected packaging is 

evaluated for potential 

contamination and 

disposition.

F-12.7 Operation has 

written policy 

regarding whether 

packing 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 packing materials 

directly on the soil, or whether a 

physical buffer (e.g., buffer bin or 

slip sheet) is required. Policy shall 

be consistent with industry standards.

Auditor observes 

whether Operation 

has a policy regarding 

placement of packing 

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-13: Postharvest Handling and Storage (Field Prior to Storage or Packinghouse)

F-13.1 Harvested produce 

is handled in a 

manner such that it 

is not likely to 

become 

contaminated.

● Operation has a policy, in compliance 

with current industry practices or 

regulatory requirements for that 

commodity, regarding handling, 

walking, stepping, or lying on 

harvested produce, food contact 

surfaces or packaging materials, or 

coming in contact with produce that 

has not been handled in compliance 

with these standards, or that may 

otherwise result in contamination.

Auditor reviews 

policy and produce 

handling practices for 

evidence of 

compliance. 

Operation develops 

the policy. Retraining 

is performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.

F-13.2 Materials that come 

in contact with the 

produce shall be 

clean and in good 

repair.

● Operation has a policy that pallets, 

produce bins, totes and materials that 

come in contact with the produce or 

the containers during handling or 

storage shall be cleaned and, if 

practicable, sanitized sufficient so as 

not to be a source of contamination.

Auditor observes 

current practices for 

compliance with 

policy.

Operation develops 

the policy. Retraining 

is performed and 

documented. 

Affected materials are 

evaluated for potential 

contamination and 

disposition.
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F-13.3 Harvested produce 

shall be stored 

separately from 

chemicals which 

may pose a food 

safety hazard. 

● Chemicals, including cleaning and 

maintenance compounds shall be 

stored in an area separate from 

harvested produce.

Auditor observes 

produce storage area 

for evidence of 

compliance.

Operation designates 

a storage area and 

practices that reduce 

risk of contamination. 

Affected produce is 

evaluated for potential 

contamination and 

disposition.

Transportation (Field to Storage or Packinghouse)

F-14: Equipment Sanitation and Maintenance

F-14.1 The Operation shall 

have a policy, 

written procedures, 

and a checklist to 

verify cleanliness 

and functionality of 

shipping units (e.g., 

trailer).

WP,

R

● Shipping units shall be clean, 

functional and free of objectionable 

odors before loading, in compliance 

with current industry practices or 

regulatory requirements for that 

commodity. Refrigeration units, if 

used, must be in working order. 

Auditor reviews

cleaning and 

inspection procedures 

and inspects produce 

transport vehicles for 

cleanliness.

Operation develops 

the policy. Retraining 

is performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

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

F-14.2 Loading/unloading 

procedures and 

equipment shall 

minimize damage to 

and prevent 

contamination of 

produce.

Personnel responsible for the loading 

and unloading of produce shall take 

steps to minimize the potential of 

physical damage to produce, which 

can introduce and/or promote the 

growth of pathogens. 

Loading/unloading equipment shall 

be clean and well maintained and of 

suitable type to avoid contamination 

of the produce.

Auditor observes 

loading/unloading 

procedures for 

evidence of practices 

that result in 

excessive damage to 

produce. Auditor 

observes 

loading/unloading 

equipment for 

suitability and 

condition. 

Operation revises 

procedures. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for potential 

contamination and 

disposition.
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Post-Harvest Operations (P)

Req. # Requirement DOC MAN Procedure Verification Corrective Action

P-1: Produce Sourcing

P-1.1 The Operation has a 

policy and takes 

affirmative steps to 

ensure that all fresh 

produce that are 

packed or stored in 

the Operation are 

grown following 

requirements in 

Field Operations 

and Harvesting

harmonized 

standard.

R The Operation requires all raw 

product suppliers to provide 

evidence of food safety/GAP 

programs and compliance. Such 

evidence must include sufficient 

documentation to demonstrate that 

the supplier complies with the 

requirements in Field Operations 

and Harvesting harmonized 

standard.

Auditor reviews 

policy and verifies 

that Operation’s 

evidence of supplier 

compliance with food 

safety/GAP programs 

is in compliance with 

the Operation’s 

policy.

Operation obtains 

required 

documentation. 

Operation ceases 

accepting or shipping 

product from nonapproved suppliers, 

until sufficient 

documentation 

demonstrating 

compliance is 

received by the 

Operation.
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P-2: Agricultural Chemicals

P-2.1 Use of agricultural 

chemicals shall 

comply with label 

directions and 

prevailing 

regulation.

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

plant protection products) must be 

registered for such use as required by 

prevailing regulation, and used in 

accordance with label directions 

including application rates, worker 

protection standards, personal 

protection equipment, container 

disposal, storage, and all 

requirements specified for the 

chemical or compound. Records of 

use are maintained.

Auditor reviews postharvest agricultural 

chemical use records 

for evidence of 

compliance with 

approved uses or 

label directions.

Operation develops 

and maintains 

agricultural chemical 

use records and 

maintains evidence of 

proper use of each 

chemical use. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-2.2 If product is 

intended for export, 

pre- and postharvest agricultural 

chemical use shall 

consider 

requirements in the 

intended country of 

destination.

The Operation shall have procedures, 

such as review of pre-harvest 

intervals and adjustment of postharvest application rates, sufficient 

to meet the MRL entry requirements 

of the country(ies) in which the 

product is intended to be traded, if 

known during post-harvest handling.

Auditor reviews 

Operation’s 

procedure for 

complying with 

agricultural chemical 

restrictions in 

countries of 

destination. If the 

country of destination 

is unknown during 

post-harvest 

handling, this item is 

not applicable.

Operation develops 

procedures, and 

diverts non-compliant 

product to a market in 

which the product 

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

P-2.3 Agricultural 

chemicals shall be 

applied by trained, 

licensed or certified 

application 

personnel, as 

required by 

prevailing 

regulation.

R Operation maintains records 

demonstrating that all personnel 

responsible for chemical applications 

are trained and/or licensed, or 

supervised by licensed personnel, in 

compliance with prevailing 

regulation.

Auditor reviews 

records 

demonstrating that 

application personnel 

are licensed and/or 

trained in compliance 

with prevailing 

regulation.

Operation utilizes 

application personnel 

who are appropriately 

licensed and/or 

trained.
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P-3: Facility

P-3.1 Building shall be 

constructed and 

maintained in a 

manner that 

prevents 

contamination of 

produce during 

staging and cooling.

● Building and equipment structures 

and surfaces (floors, walls, ceilings, 

doors, frames, hatches, etc.) shall be 

constructed in a manner that 

facilitates cleaning and sanitation 

and does not serve as harborage for 

contaminants or pests. Chill and 

cold storage loading dock areas shall 

be appropriately sealed, drained and 

graded. Fixtures, ducts, pipes and 

overhead structures shall be installed 

and maintained so that drips and 

condensation do not contaminate 

produce, raw materials or food 

contact surfaces. Water from 

refrigeration drip pans shall be 

drained and disposed of away from 

product and product contact surfaces. 

Drip pans and drains shall be 

designed to assure condensate does 

not become a source of 

contamination. Air intakes shall not 

be located near potential sources of 

contamination.

Auditor observes 

building and 

equipment for 

evidence that the 

building can be 

cleaned and 

maintained to prevent 

product 

contamination. 

Building deficiencies 

are corrected. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.
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P-3.2 Adequate lighting 

shall be provided in 

all areas. 

Lighting in all areas shall be 

sufficient to enable cleaning, 

sanitation, repairs, etc. 

Auditor observes, 

directly or by other 

evidence, that 

sufficient lighting is 

provided to the 

worker to clearly see 

the task being 

performed.

Operation installs 

adequate, lighting.

P-3.3 Only essential glass 

and brittle plastic 

shall be present in 

the building. 

R Light bulbs, fixtures, windows, 

mirrors, skylights and other glass 

and brittle plastic in the building or 

in the product path entering or 

exiting the building shall be of the 

safety type, or shall be otherwise 

protected to prevent breakage. If 

glass or brittle plastic must be used, 

there shall be a written glass and 

brittle plastic control policy, 

including a glass and brittle plastic 

register. 

Auditor observes 

glass and brittle 

plastic use in 

building, and glass 

and brittle plastic 

control policy and 

glass and brittle 

plastic register for 

compliance. 

Operation develops a 

glass and brittle 

plastic control policy 

or eliminates all glass 

and brittle plastic in 

the building.

P-3.4 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-3.5 Operation has 

procedures to 

prevent pest 

harborage in any 

equipment stored 

near the building. 

Equipment stored outside is stored 

away from the building perimeter. 

Equipment is not to accumulate near 

the building. Bone yards are located 

away from the building. Outside 

equipment storage areas are included 

in pest control program.

Auditor observes 

outside equipment 

storage areas for 

evidence of 

compliance.

Operation includes 

outside storage areas 

in pest control 

program. Equipment 

is moved to be in 

compliance. 

P-3.6 If applicable, 

Operation has a 

written Allergen 

Control Program. 

A,

WP

● The Allergen Control Program lists 

the allergens in use or storage at the 

Operation specific to country 

regulations. If applicable, procedures 

address identification and 

segregation of allergens during 

storage and handling as based on a 

risk assessment conducted by the 

Operation.

Auditor reviews 

Allergen Control 

Program and inspects 

Operation for 

evidence of allergen 

use and storage.

Operation develops 

and implements an 

Allergen Control 

Program or 

eliminates allergens 

from the Operation.
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P-4: Pest and Animal Control

P-4.1 Operation has 

procedures to 

manage pests to the 

extent appropriate 

to the Operation. 

WP ● Operation has a written pest control 

program, performed by a trained pest 

control operator (or licensed where 

required by prevailing regulation). 

The written program includes 

policies and procedures applicable to 

that Operation, such as storage of 

outside equipment or other factors 

dealing with pest harborages, and 

maps of the location of pest traps 

outside and inside the Operation. 

Operation maintains a pest-control 

log that includes dates of inspection, 

inspection reports and steps taken to 

eliminate any problems. 

Applications of pesticides (e.g., 

insecticides, rodenticides) shall be 

performed in compliance with local, 

state, and federal pesticide 

regulations.

Auditor reviews pest 

control program, pest 

control operator’s 

credentials, and 

inspects Operation 

for pest activity.

Operation develops, 

documents and 

implements an 

effective pest control 

program.

P-4.2 Operation restricts 

animals from food 

handling areas.

● Domesticated animals are prohibited 

from pack house, cooling, and 

storage facilities unless procedures 

are in place for their safe presence. 

Procedures are in place to exclude 

wild and feral animals to the degree 

practical and to monitor for and 

mitigate contamination from animal 

excreta.

Auditor looks for 

evidence of animals 

or animal activity.

Operation develops, 

documents and 

implements an 

effective animal 

control program.
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P-4.3 If used, pest control 

devices, including 

rodent traps and 

electrical flying 

insect devices, are 

located so as to not 

contaminate 

produce or food 

handling surfaces.

Only non-toxic traps and pest control 

devices are used inside the packing 

house or storage building.

Auditor reviews pest 

control program and 

placement of pest 

control devices. 

Operation removes or 

repositions pest 

control devices to be 

compliant.

P-5: Equipment, Tools and Utensils

P-5.1 All food contact 

equipment, tools 

and utensils are 

designed and made 

of materials that are 

easily cleaned and 

maintained.

● 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. 

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 

non-compliant food 

contact equipment, 

tools and utensils.

P-5.2 Equipment is 

installed in a way 

that provides access 

for cleaning.

Cooling, packing and other food 

contact equipment is installed away 

from walls and otherwise positioned 

so as not to inhibit access for proper 

cleaning. 

Auditor observes 

positioning of all 

food contact 

equipment for 

compliance.

Operation relocates 

the equipment to be 

compliant.
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P-5.3 Equipment 

lubrication is 

managed so as not 

to contaminate food 

products.

Only food-grade lubricants are used 

on food processing and packaging 

equipment, or on any other 

equipment where incidental food 

contact may occur, unless the 

equipment manufacturer specifies 

only a non-food 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.

P-5.4 All instruments 

used to measure 

temperature, pH, 

antimicrobial levels 

and or other 

important devices 

used to monitor 

requirements in this 

section shall be 

adequately 

maintained and 

calibrated at a 

frequency sufficient 

to assure continuous 

accuracy. 

R ● Records shall be kept. If an ORP 

system is used, an independent 

measurement shall be used to verify 

compliance. Test methods or test 

strips used to monitor requirements 

shall be appropriate to their use, 

sufficiently sensitive to their 

intended purpose and available in 

adequate numbers for their 

designated use. 

Auditor reviews 

calibration and 

verification 

procedures and 

records.

Operation develops, 

documents and 

implements 

calibration and 

verification 

procedures and 

records.
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P-5.5 Foreign material 

control devices are 

inspected and 

maintained. 

R If included in the Food Safety Plan, 

foreign material control devices shall 

be included as part of a Preventive 

Maintenance Schedule or other 

program and maintained to ensure 

effective operation. Calibration 

checks shall be performed according 

to written procedure or 

manufacturer’s recommendations.

Auditor inspects any 

foreign material 

control devices and 

maintenance and 

calibration check 

records for 

compliance.

Operation develops 

written procedures 

for inspection, 

calibration checks 

and maintenance of 

foreign material 

control devices. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-6: Maintenance and Sanitation

P-6.1 A Preventive 

Maintenance and/or 

Master Cleaning 

Schedule, with 

related SOPs, shall 

be established.

WP,

R

● There is a written cleaning and 

sanitation schedule for all food and 

non-food contact surfaces including 

floors, drains, walls, ceilings and 

other surfaces that may pose a source 

of product contamination. Roof leaks 

shall be promptly identified, 

controlled and repaired. Operation 

has procedures for cleaning and 

sanitation of cooling equipment. 

Drip pans and drains shall be 

maintained to assure condensate 

does not become a source of 

contamination.

Auditor reviews 

Preventive 

Maintenance and/or 

Master Cleaning 

Schedule, observes 

building and 

equipment for 

evidence that the 

building is cleaned 

and maintained to 

prevent product 

contamination. 

Auditor reviews 

building maintenance 

records for evidence 

of repairs.

Operation develops a 

Preventive 

Maintenance and/or 

Master Cleaning 

Schedule, with 

related SOPs. 

Building deficiencies 

are corrected. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.
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P-6.2 Any temporary 

repairs on food 

contact surfaces are 

constructed of foodgrade material. 

Operation has a 

procedure to ensure 

that permanent 

repairs are 

implemented in a 

timely manner.

Operation has procedures to ensure 

temporary repairs are compliant with 

all food safety requirements, and do 

not create potential sources of 

chemical, microbiological or 

physical contamination. Permanent 

repairs are implemented as soon as 

practical; Operation establishes 

timelines and responsibilities for 

completion. 

Auditor observes 

temporary repairs, if 

present, and 

Operation’s plans for 

timely completion.

Operation develops 

and implements a 

temporary repair 

procedure. Operation 

immediately fixes 

any non-compliant 

temporary repairs. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-6.3 All cleaning agents 

shall be approved 

for their intended 

use on food contact 

surfaces.

All chemicals used for cleaning or 

sanitizing of food contact equipment, 

tools, utensils, containers and other 

food contact surfaces shall be 

approved for that use, according to 

the chemical manufacturer or 

supplier and all federal, state and 

local requirements, and shall be used 

in a manner consistent with the 

approved use.

Auditor reviews 

cleaning and 

sanitizing chemicals 

purchasing practices 

or procedures, 

storage area, and use 

procedures to verify 

compliance.

Operation ceases use 

of unapproved 

chemicals. Retraining 

is performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.
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P-6.4 Cleaning equipment 

and tools are clean, 

in working order 

and stored properly 

away from product 

handling areas.

Equipment, utensils and tools used 

for cleaning or sanitizing, including 

food contact and non-food contact 

surfaces, are maintained in a manner 

sufficient to avoid becoming a 

source of produce contamination and 

are stored away from product 

handling areas.

Auditor reviews 

practices or 

procedures for use 

and storage of 

cleaning and 

sanitizing equipment, 

tools and utensils, 

and observes storage 

area for compliance.

Operation develops 

written procedures 

for maintaining and 

storing cleaning and 

sanitizing equipment, 

tools and utensils. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-6.5 Food contact 

surfaces shall be 

cleaned, sanitized 

and maintained 

according to the 

Food Safety Plan

R ● Prior to use, the lines used for 

washing, grading, sorting, or packing 

shall be cleaned and sanitized as 

appropriate per risk assessment or 

prevailing regulations. Records must 

include the date and method of 

cleaning and sanitizing equipment. 

When in use, the lines shall be 

maintained so as not to be a source 

of contamination with pathogens.

Auditor reviews 

cleaning and 

sanitizing procedures 

and records and 

observes food contact 

surfaces to verify 

compliance.

Operation develops 

written cleaning and 

sanitizing procedures 

and records 

consistent with the 

Food Safety Plan. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.
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P-6.6 Transporting 

equipment shall be 

maintained to 

prevent 

contamination of 

products being 

transported. 

R ● Pallet jacks, carts, trolleys and 

forklifts, shall be maintained to 

prevent contamination of products 

being transported and are listed on 

the Preventive Maintenance and/or 

Master Cleaning Schedules. 

Auditor observes 

transporting 

equipment and 

reviews Schedules 

and records for 

evidence of 

compliance.

Operation develops 

and implements 

Preventive 

Maintenance and/or 

Master Cleaning 

Schedules.

P-6.7 Waste materials and 

their removal are 

managed to avoid 

contamination.

● Trash, leaves, trim, culls, waste 

water and other waste materials are 

removed from the produce handling 

areas at a frequency sufficient to 

avoid becoming a source of produce 

contamination.

Auditor observes 

waste control 

procedures in 

produce handling 

areas. 

Operation develops a 

written waste control 

procedure. 

Operational 

deficiencies are 

corrected. Retraining 

is performed and 

documented. 

P-6.8 Outside garbage 

receptacles/dumpste

rs 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-6.9 The plant grounds 

are reasonably free 

of litter, waste culls, 

vegetation, debris 

and standing water.

Operation has procedures to 

maintain the grounds surrounding 

the building in a manner to minimize 

sources of contamination, such as 

litter, vegetation, waste culls, debris 

and standing water that may be pest 

attractants or harborages. 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.
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P-6.10 Sewage or septic 

systems are 

maintained so as not 

to be a source of 

contamination.

● After a significant event (such as 

flooding or an earthquake) that could 

negatively impact a sewage or septic 

system, Operation takes appropriate 

steps to ensure that sewage and 

septic systems continue to operate in 

a manner that does not contaminate 

produce, food contact surfaces, areas 

used for produce handling, 

agricultural water sources, or 

agricultural water distribution 

systems.

If a significant event 

has occurred, auditor 

reviews steps taken 

by Operation to 

verify sewage or 

septic system is not a 

source of 

contamination. 

Sewage or septic 

systems deficiencies 

are corrected. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-6.11 The sewage 

disposal system is 

adequate for the 

process and 

maintained to 

prevent direct or 

indirect product 

contamination.

● The human waste and gray water 

sewage system has sufficient 

capacity to handle the Operation’s 

peak flows and not cause direct or 

indirect product contamination. 

Cross-connections with product 

contact water systems are prohibited. 

Auditor observes 

Operation for 

evidence of 

compliance. 

Operation suspends 

operation until 

sewage disposal 

system functions so 

as to prevent risk of 

product 

contamination. 

Affected product and 

product handling 

areas are evaluated 

for potential 

contamination and 

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

P-7.1 A water system 

description shall be 

prepared. 

R ● Water sources and the Operations 

they serve shall be documented and 

current. The description shall 

include one or more of the 

following: maps, photographs, 

drawings (hand drawings are 

acceptable) or other means to 

communicate the location of water 

source(s), permanent fixtures and the 

flow of the water system (including 

holding systems, reservoirs or any 

water captured for re-use). 

Permanent fixtures include wells, 

gates, reservoirs, valves, returns, 

backflow prevention and other above 

ground features that make up a 

complete water distribution system 

shall be documented in such a 

manner as to enable location in the 

Operation. 

Auditor reviews 

water system 

description or map, 

and verifies accuracy 

during Operation 

inspection. 

Operation develops 

or corrects the water 

system description or 

map.
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P-7.2 Documented 

scheduled 

assessment of water 

system including 

delivery equipment 

shall be performed. 

R ● The water-delivery system shall be 

maintained so as not to serve as a 

source of contamination of produce, 

water supplies or equipment with 

pathogens, or to create an unsanitary 

condition. Water installations and 

equipment are constructed and 

maintained to prevent back 

siphonage backflow and cross 

connections between product contact 

water and waste water. Routine 

checks verify that back siphonage 

and backflow prevention units are 

functioning properly (annual or as 

needed to maintain continuous 

protection). Results are documented.

Auditor reviews 

maintenance records 

and examines water 

system for 

compliance with 

water system 

maintenance 

program, including 

backflow prevention 

and crossconnections. 

Operation corrects 

deficiencies in ability 

of water system to 

reliably distribute 

safe water and 

schedules water 

system assessments. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-7.3 Water use SOPs 

address the 

microbial quality of 

water or ice that 

directly contacts the 

harvested crop or is 

used on foodcontact surfaces. 

R ● If water or ice directly contacts the 

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

use SOP requires that water or ice 

when applied meets the microbial 

standards for drinking water, as 

defined by prevailing regulation or 

the country in which the product is 

intended to be traded, whichever is 

more stringent. Water may be 

treated (e.g., with chlorine) to 

achieve the microbial standards or to 

prevent cross-contamination. Ice 

and water shall be 

sourced/manufactured, transported, 

and stored under sanitary conditions. 

Auditor reviews 

Operation’s policy 

regarding water 

quality and its 

transport, and 

observes evidence 

that water or ice that 

contacts harvested 

crop or food contact 

surfaces meets the 

microbial standards 

for drinking water. 

Operation 

discontinues using 

water or ice that does 

not meet the 

microbial standards 

of drinking water. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.
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P-7.4 Operation’s Food 

Safety Plan includes 

produce washing 

process, if used.

A,

WP

● If produce is washed, an initial risk 

assessment of the washing process 

shall be performed that takes into 

consideration the commodity, type 

of wash system, type of sanitizer, 

and water quality.

Auditor reviews Food 

Safety Plan and 

operational 

procedures to 

determine if washing 

process has been 

considered.

Operation revises 

Food Safety Plan to 

include produce 

washing process.

P-7.5 If used, water 

antimicrobial 

treatments shall be 

monitored 

sufficiently to 

assure continuous 

control.

R ● Microbial, physical or chemical 

testing shall be performed, as 

appropriate to the specific Operation, 

to demonstrate that acceptance 

criteria have been met.

Auditor reviews 

monitoring records 

for compliance with 

the Operation’s 

established procedure 

and acceptance 

criteria.

Operation establishes 

monitoring program 

that assures 

continuous control of 

water antimicrobial 

treatment to meet 

acceptance criteria.

P-7.6 Re-circulated water 

that contacts 

product or food 

contact surfaces 

shall be treated 

using an approved 

antimicrobial 

process or chemical 

treatment.

● Re-circulated water shall be treated 

using an antimicrobial treatment 

sufficient to prevent crosscontamination. Treatments shall be 

in compliance with prevailing 

regulation or the country in which 

the product is intended to be traded, 

whichever is more stringent. 

Auditor reviews 

water treatment 

process and evidence 

of compliance with 

regulation and the 

Operation’s 

established 

procedure.

Operation suspends 

operation until water 

treatment functions 

so as to prevent risk 

of product 

contamination. 

Affected product and 

product handling 

areas are evaluated 

for potential 

contamination and 

disposition.
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P-7.7 Operation has 

documentation 

demonstrating 

regulatory approval

of the wash water 

antimicrobials in 

use.

R Only wash water antimicrobials or 

antimicrobial systems registered or 

approved by EPA, FDA or the 

prevailing regulatory agency for 

their specific intended use may be 

used in the dump tank wash water, 

on the spray line or other food 

contact purposes.

Auditor reviews 

documentation for 

appropriateness of 

use.

Operation obtains 

documentation or 

discontinues use of 

the antimicrobial 

system and 

implements use of 

appropriate 

antimicrobial system. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-7.8 If wash water 

antimicrobial is 

used, it shall be 

used in accordance 

with established 

operational 

procedure and 

manufacturer 

instructions. 

R Records shall be kept. Operation 

shall have a procedure that includes 

minimum limits for antimicrobial in 

wash water for food safety. 

Procedure shall include how to 

control, monitor and record use of 

wash water antimicrobial as needed 

to assure compliance with minimum 

limits. Operation shall have a 

procedure as to what corrective 

actions are taken if criteria are not 

met.

Auditor reviews 

operational 

procedures and 

antimicrobial use and 

corrective actions 

records for 

compliance. 

Operation develops, 

documents and 

implements 

procedures for use of 

the antimicrobial 

system in compliance 

with manufacturer 

instructions. Affected 

product is evaluated 

for potential 

contamination and 

disposition.
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P-7.9 If applicable to the 

specific commodity, 

water use SOPs 

address control of 

immersion water 

temperature.

R For produce that is immersed in 

water and demonstrated as being 

susceptible to microbial infiltration 

from water, water temperature 

differentials during immersion shall 

be controlled in accordance with 

prevailing regulation or industry 

guidelines. 

If applicable to the 

commodity being 

immersed, auditor 

reviews the SOP for 

inclusion of water 

temperature control, 

and observes 

monitoring records 

for evidence of 

compliance.

Operation revises 

SOP to address and 

control water 

temperature.

P-7.10 Water-change 

schedules shall be 

developed for all 

uses of water where 

water is re-used.

Operation shall have procedures for 

changing water that is re-used, such 

as recirculated water, flumes and 

dump tanks. 

Auditor observes 

water use procedures 

and evidence of 

compliance.

Operation develops 

water use procedures. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-7.11 Debris, damaged 

and/or visibly 

contaminated 

produce shall be 

removed from wash 

areas/dump tanks to 

the extent possible.

Operation has procedures to 

determine how and when debris, 

damaged and/or visibly 

contaminated produce shall be 

removed from wash areas/dump 

tanks. 

Auditor reviews 

procedures and 

observes wash areas 

for evidence of 

compliance.

Operation develops, 

documents and 

implements a wash 

area control program. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.
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P-8: Containers, Bins and Packaging

P-8.1 Specifications for 

all packaging 

materials that 

impact on finished 

product safety shall 

be provided and 

comply with 

prevailing 

regulations. 

R The methods and responsibility for 

developing and approving detailed 

specifications and labels for all 

packaging shall be documented. A 

register of packaging specifications 

and label approvals shall be 

maintained and kept current. 

Auditor reviews 

documentation on 

methods and 

responsibilities for 

packaging materials 

and label approvals.

Operation revises 

labels and packaging 

materials to be 

compliant with 

prevailing 

regulations.

P-8.2 Operation has 

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 productcontact 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-8.3 Operation has 

written policy 

regarding whether 

product-contact 

containers are 

permitted in direct 

contact with the 

ground. 

WP If produce does not normally contact 

the ground during production, 

Operation has considered and 

developed written policies regarding 

placement of product-contact 

containers directly on the ground, or 

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 product-contact 

containers in direct 

contact with the 

ground. Auditor 

observes current 

practices for 

compliance with 

policy.

Operation develops 

the policy. 

Retraining is 

performed and 

documented. 

P-8.4 Operation has 

written policy 

regarding inspection 

of food contact 

containers and bins 

prior to use.

WP Food-contact totes, bins, packing 

materials, other harvest containers, 

and pallets shall be visually 

inspected, clean, intact and free of 

any foreign materials prior to use. 

Containers shall be sufficiently 

maintained so as not to become a 

source of contamination.

Auditor observes 

whether Operation 

has a policy 

regarding inspection 

of food contact 

containers and 

observes current 

practices for 

compliance with 

policy.

Operation develops 

the policy. 

Retraining is 

performed and 

documented. 
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P-8.5 Operation has 

written policy 

regarding 

acceptable productcontact containers.

WP ● The types and construction of 

product-contact containers and 

packing materials shall be 

appropriate to the commodity being 

handled and suited for their intended 

purpose. Produce shall only be 

stored in clean and sanitary 

containers.

Auditor observes 

whether Operation 

has a policy 

regarding what types 

of containers and 

packing materials are 

acceptable for use, 

and observes current 

practices for 

compliance with the 

policy.

Operation develops 

the policy. 

Appropriate productcontact containers are 

obtained. Affected 

product is evaluated 

for potential 

contamination and 

disposition.

P-8.6 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. Foodcontact totes, bins and other packing 

containers and equipment that are no 

longer cleanable shall not be used for 

packing but can be used for other 

non-food uses if clearly 

marked/labeled.

Auditor observes 

whether Operation 

has a policy 

prohibiting use of 

product-contact 

containers for other 

uses unless otherwise 

labeled, and observes 

current practices for 

compliance with the 

policy.

Operation develops 

the policy. 

Retraining is 

performed and 

documented. 

P-8.7 Pallets shall be kept 

clean and in good 

condition as 

appropriate for their 

intended use.

Operation inspects pallets prior to 

use for conditions that may be a 

source of produce contamination. 

Pallets that are not cleanable are 

removed from use. Pallets and other 

wooden surfaces are properly dried 

after being washed. 

Auditor observes 

pallets for 

compliance.

Operation removes 

noncompliant pallets 

from use. 
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P-9: Storage

P-9.1 Product storage 

areas and conditions 

shall be appropriate 

to the commodities 

stored.

Produce storage locations and 

conditions shall not pose a risk of 

produce contamination, consistent 

with industry standards or prevailing 

regulation.

Auditor observes 

storage area for 

evidence that stored 

produce is protected 

from contamination.

Operation designates 

and maintains storage 

areas to prevent 

contamination of 

produce.

P-9.2 Iced produce is 

handled so as not to 

serve as a source of 

contamination. 

Protective measures are provided in 

areas where iced product is stored 

over food items in order to prevent 

melting ice from contaminating 

product below.

Auditor inspects any 

iced product on 

premises for 

compliance.

Operation develops 

written procedures to 

handling and storage 

of iced product. 

Operational 

deficiencies are 

corrected. Retraining 

is performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-9.3 Non-product 

storage areas shall 

be maintained so as 

not to be a source of 

product or materials 

contamination.

Areas designated to store materials, 

whether indoors or out, shall be 

clean, well ventilated, and designed 

to protect materials and produce 

from contaminants. 

Auditor observes 

storage area for 

evidence that stored 

materials are 

protected from 

contamination.

Operation designates 

and maintains storage 

areas to prevent 

contamination of 

non-product 

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

P-9.4 Materials and 

packaging materials 

shall be protected 

from contaminants.

Materials stored in uncovered areas 

shall be protected from condensate, 

sewage, dust, dirt, chemicals, 

allergens or other contamination. 

Materials shall be stored off the 

floor/ground on pallets, slip-sheets 

or stands and covered where 

applicable. 

Auditor observes 

stored materials for 

protection from 

contamination.

Operation develops 

and implements 

written procedures 

for materials storage. 

Operational 

deficiencies are 

corrected. Affected 

product is evaluated 

for potential 

contamination and 

disposition. 

P-9.5 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-9.6 All chemicals shall 

be stored in a secure 

separate area. All 

chemicals shall be 

properly labeled.

Chemicals, including cleaning and 

maintenance compounds and 

lubricants, when not being used, are 

stored away from product handling 

areas and in a manner that inhibits 

unauthorized access. Food-grade 

and non food-grade lubricants are 

kept separate from each other.

Auditor observes that 

chemicals are 

properly labeled and 

storage practices 

protect against 

product 

contamination.

Operation designates 

a secure area for 

storage of chemicals. 

Unlabeled chemicals 

are labeled or 

properly discarded. 

Retraining is 

performed and 

documented. 
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P-9.7 When produce is 

cooled, it is cooled 

to temperatures 

appropriate to the 

commodity 

according to current 

established 

regulatory or 

industry standards. 

R When required for food safety or by 

industry guidelines, steps are taken 

to minimize temperature increases 

and minimize the time between 

produce receipt and cooling at the 

Operation. The product temperature 

and equipment control mechanisms 

are calibrated and monitored at a 

defined frequency and temperatures 

are kept appropriate to the 

commodity. Records are maintained.

Auditor reviews 

cooling procedures 

for commodities 

requiring temperature 

control, and reviews 

temperature logs for 

evidence of 

compliance.

Operation develops 

and implements 

procedures to monitor 

cooling procedures in 

compliance with 

current established 

regulatory or industry 

standards. 

P-9.8 Where temperature 

control is required 

for food safety, 

cooling facilities 

shall be fitted with 

temperature 

monitoring 

equipment or 

suitable temperature 

monitoring device. 

R Temperature monitoring equipment 

shall be located in all temperature 

controlled areas, and shall be located 

so as to accurately monitor the 

temperature. Temperature measuring 

devices shall be monitored and 

calibrated on a scheduled basis or as 

needed.

Auditor observes 

evidence that 

temperatures are 

being monitored, and 

reviews calibration 

records and 

procedures for 

temperature 

monitoring 

equipment.

Operation establishes 

and implements 

temperature 

monitoring 

procedures.

P-9.9 Cooling equipment 

shall be maintained 

so as not to be a 

source of product 

contamination.

● Cooling equipment (e.g. 

hydrocoolers, air coolers), shall be 

inspected, all debris removed, and 

cleaned and sanitized according to 

written sanitation SOPs.

Auditor reviews 

cooling equipment 

maintenance and 

sanitation procedures 

and inspects 

equipment for 

compliance with 

procedures.

Operation develops 

and implements 

effective maintenance 

and sanitation 

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

P-10.1 There is a written 

policy for 

transporters and 

conveyances to 

maintain a specified 

temperature(s) 

during transit.

WP When refrigerated transport is 

required for food safety, transporters 

have written, predetermined 

temperature ranges for commodities 

being transported.

Auditor reviews 

documentation of 

predetermined 

temperature ranges.

Operation develops, 

documents and 

implements 

temperature range 

requirements.

P-10.2 Prior to loading, the 

vehicle shall be precooled. 

WP,

R

When refrigerated transport is 

required for food safety, the proper 

temperature for pre-cooling is 

appropriate to the type of produce 

and as specified by documented 

protocol.

Auditor reviews 

documented protocol, 

shipping checklist 

records, and observes 

vehicles during 

loading for 

compliance.

Operation develops, 

documents and 

implements vehicle 

cooling requirements.

P-10.3 The refrigerated 

transport vehicles 

shall have properly 

maintained and 

fully functional 

refrigeration 

equipment.

WP When refrigerated transport is 

required for food safety, Operation 

has a written policy that refrigerated 

transportation equipment shall be 

controlled by a thermostatic device 

as necessary to maintain 

temperatures in the cargo area for the 

particular type of produce being 

transported and as specified by 

documented protocol.

Auditor reviews 

written policy and 

observes refrigerated 

transport vehicles in 

use at the time of the 

audit.

Operation develops, 

documents and 

implements a policy. 

Retraining is 

performed and 

documented. 

P-10.4 Where required, 

temperatures of 

product are taken 

and recorded prior 

to or upon loading.

WP When refrigerated transport is 

required for food safety, Operation 

has a written procedure for when and 

how to measure product 

temperatures prior to or during 

loading.

Auditor reviews 

written procedure and 

observes temperature

monitoring 

procedures during 

loading

Operation develops, 

documents and 

implements a policy. 

Retraining is 

performed and 

documented. 
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P-10.5 The Operation shall 

have a policy, 

written procedures, 

and a checklist to 

verify cleanliness 

and functionality of 

shipping units (e.g., 

trailer).

WP,

R

● Shipping units shall be clean, 

functional and free of objectionable 

odors before loading, in compliance 

with current industry practices or 

regulatory requirements for that 

commodity. Refrigeration units, if 

used, must be in working order. 

Procedures include prohibition of 

raw animal or animal product 

transport, or other materials that 

reasonably may be a source of 

contamination with biological, 

chemical or physical hazards. 

Shipping units shall be washed 

between loads if prior transport 

included materials that reasonably 

may be a source of contamination. 

A responsible individual shall sign 

or initial the completed checklist or 

inspection report.

Auditor reviews 

cleaning procedures 

and inspection 

records and inspects 

produce transport 

vehicles for 

cleanliness.

Operation develops 

the policy and written 

procedures. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.

P-10.6 Loading/unloading 

procedures and 

equipment shall 

minimize damage to 

and prevent 

contamination of 

produce.

Personnel responsible for the loading 

and unloading of produce shall take 

steps to minimize the potential of 

physical damage to produce, which 

can introduce and/or promote the 

growth of pathogens. 

Loading/unloading equipment shall 

be clean and well maintained and of 

suitable type to avoid contamination 

of the produce.

Auditor observes 

loading/unloading 

procedures for 

evidence of practices 

that result in 

excessive damage to 

produce. Auditor 

observes 

loading/unloading 

equipment for 

suitability and 

condition. 

Operation revises 

procedures. 

Retraining is 

performed and 

documented. 

Affected product is 

evaluated for 

potential 

contamination and 

disposition.
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Logo Use (L)

Req. # Requirement DOC MAN Procedure Verification Corrective Action

L-1: Food Safety Plan or Quality Manual

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.

L-2: Traceability and Recall Programs

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

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

L-4.1 The logo is only 

used on products, 

processes, and 

packaging as 

approved on the SC652.

R ● The Operation shall have a copy of 

the approved SC-652 which lists the 

products, processes, and packaging 

types the logo is approved to be used 

on. The logo is being used as 

approved.

Auditor verifies that 

the Operation is only 

using the logo as 

approved on the SC652.

Operation 

discontinues use of 

packaging on 

unapproved products, 

processes, and/or 

packaging. 

L-4.2 All packaging or 

labels, which bear 

the GAP & GHP 

logo, are 

accountable items.

WP,

R

● The Operation shall have a policy 

stating all packaging or labels are 

accounted for.

Auditor reviews 

policy.

Operation develops 

policy that ensures 

accountability of all 

packaging or labels 

bearing the logo.

L-4.3 The Operation's 

inventory list of 

these packaging or 

labels is maintained 

and current.

R ● The Operation shall have an 

inventory list of any packaging or 

labels bearing the logo or language.

Auditor reviews 

records for accuracy 

and to ensure 

inventory list is up to 

date.

Operation develops 

and maintains an 

inventory list of all 

packaging and labels.

L-4-4 The logo is only 

used on packaging 

and labels that are 

clean and bright in 

appearance, without 

marks, stains, or 

other evidence of 

previous use.

R ● The Operation is only using 

packaging and labels that are clean 

and bright in appearance without 

marks, stains, or other evidence of 

previous use.

Auditor verifies that 

packaging and labels 

are clean and bright in 

appearance.

Operation updates 

their practices to use 

the logo on packaging 

and labels that are 

clean and bright in 

appearance.