Agricultural Quality Assessment Division QAD 1062 Checklist

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

Dated Issued: 08/09/07 Approved by __________JW

Current Good Manufacturing Requirements Reference Document Conform? 

Y or N Objective Evidence Findings/Remarks

1. PERSONNEL

The plant management shall take all reasonable measures and precautions to ensure 

the following:

1.a Disease Control. Any person who, by medical examination or supervisory 

observation, is shown to have, or appears to have, an illness, open lesion, including 

boils, sores, or infected wounds, or any other abnormal source of microbial

contamination by which there is a reasonable possibility of food, food-contact 

surfaces, or food-packaging materials becoming contaminated, shall be excluded 

from any operations which may be expected to result in such contamination until 

the condition is corrected. Personnel shall be instructed to report such health 

conditions to their supervisors. Not meeting these criteria is a major nonconformance.

1.b Cleanliness. All persons working in direct contact with food, food-contact 

surfaces, and food-packaging materials shall conform to hygienic practices while 

on duty to the extent necessary to protect against contamination of food. The 

methods for maintaining cleanliness include, but are not limited to:

1.b.1 Wearing outer garments suitable to the operation in a manner that protects 

against the contamination of food, food-contact surfaces, or food-packaging 

materials.

1.b.2 Maintaining adequate personal cleanliness.

1.b.3 Washing hands thoroughly (and sanitizing if necessary to protect against 

contamination with undesirable microorganisms) in an adequate hand-washing 

facility before starting work, after each absence from the work station, and at any 

other time when the hands may have become soiled or contaminated. Not meeting 

these criteria is a major non-conformance. 

1.b.4 Removing all unsecured jewelry and other objects that might fall into food, 

equipment, or containers, and removing hand jewelry that cannot be adequately 

sanitized during periods in which food is manipulated by hand. If such hand 

jewelry cannot be removed, it may be covered by material which can be maintained 

in an intact, clean, and sanitary condition and which effectively protects against the 

contamination by these objects of the food, food-contact surfaces, or foodpackaging materials.

1.b.5 Maintaining gloves, if they are used in food handling, in an intact, clean, and 

sanitary condition. 

1.b.6 Wearing, where appropriate, in an effective manner, hair nets, headbands, 

caps, beard covers, or other effective hair restraints.
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1.b.7 Storing clothing or other personal belongings in areas other than where food 

is exposed or where equipment or utensils are washed.

1.b.8 Confining the following to areas other than where food may be exposed or 

where equipment or utensils are washed: eating food, chewing gum, drinking 

beverages, or using tobacco.

1.b.9 Taking any other necessary precautions to protect against contamination of 

food, food-contact surfaces, or food-packaging materials with microorganisms or 

foreign substances including, but not limited to, perspiration, hair, cosmetics, 

tobacco, chemicals, and medicines applied to the skin.

1.c Education and Training. Personnel responsible for identifying sanitation 

failures or food contamination shall have a background of education or experience, 

or a combination thereof, to provide a level of competency necessary for 

production of clean and safe food. Food handlers and supervisors shall receive 

appropriate training in proper food handling techniques and food-protection 

principles and shall be informed of the danger of poor personal hygiene and 

insanitary practices.

1.d Supervision. Responsibility for assuring compliance by all personnel with all 

requirements of this part shall be clearly assigned to competent supervisory 

personnel.

2. PLANT AND GROUNDS

2.a Grounds. The grounds about a food plant under the control of the operator 

shall be kept in a condition that will protect against the contamination of food. The 

methods for adequate maintenance of grounds include, but are not limited to:

2.a.1 Properly storing equipment, removing litter and waste, and cutting weeds or 

grass within the immediate vicinity of the plant buildings or structures that may 

constitute an attractant, breeding place, or harborage for pests. Not meeting these 

criteria is a major non-conformance if linked to egg rule and potential for pest 

harborage outside facility.

2.a.2 Maintaining roads, yards, and parking lots so that they do not constitute a 

source of contamination in areas where food is exposed.

2.a.3 Adequately draining areas that may contribute contamination to food by 

seepage, foot-borne filth, or providing a breeding place for pests.

2.a.4 Operating systems for waste treatment and disposal in an adequate manner so 

that they do not constitute a source of contamination in areas where food is 

exposed.
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2.a.5 If the plant grounds are bordered by grounds not under the operator's control,

care shall be exercised in the plant by inspection, extermination, or other means to 

exclude pests, dirt, and filth that may be a source of food contamination.

2.b Plant Construction and Design. Plant buildings and structures shall be 

suitable in size, construction, and design to facilitate maintenance and sanitary 

operations for food-manufacturing purposes. The plant and facilities shall:

2.b.1 Provide sufficient space for such placement of equipment and storage of 

materials as is necessary for the maintenance of sanitary operations and the 

production of safe food.

2.b.2 Permit the taking of proper precautions to reduce the potential for 

contamination of food, food-contact surfaces, or food-packaging materials with 

microorganisms, chemicals, filth, or other extraneous material. The potential for 

contamination may be reduced by adequate food safety controls and operating 

practices or effective design, including the separation of operations in which 

contamination is likely to occur, by one or more of the following means: location, 

time, partition, air flow, enclosed systems, or other effective means. Not meeting 

these criteria is a major non-conformance.

2.b.3 Permit the taking of proper precautions to protect food in outdoor bulk 

fermentation vessels by any effective means, including:

2.b.3.a Using protective coverings.

2.b.3.b Controlling areas over and around the vessels to eliminate harborages for 

pests.

2.b.3.c Checking on a regular basis for pests and pest infestation.

2.b.3.d Skimming the fermentation vessels, as necessary.

2.b.4 Be constructed in such a manner that floors, walls, and ceilings may be 

adequately cleaned and kept clean and kept in good repair; that drip or condensate 

from fixtures, ducts and pipes does not contaminate food, food-contact surfaces, or 

food-packaging materials; and that aisles or working spaces are provided between 

equipment and walls and are adequately unobstructed and of adequate width to 

permit employees to perform their duties and to protect against contaminating food 

or food-contact surfaces with clothing or personal contact.
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2.b.5 Provide adequate lighting in hand-washing areas, dressing and locker rooms, 

and toilet rooms and in all areas where food is examined, processed, or stored and 

where equipment or utensils are cleaned; and provide safety-type light bulbs, 

fixtures, skylights, or other glass suspended over exposed food in any step of 

preparation or otherwise protect against food contamination in case of glass 

breakage.

2.b.6 Provide adequate ventilation or control equipment to minimize odors and 

vapors (including steam and noxious fumes) in areas where they may contaminate 

food; and locate and operate fans and other air-blowing equipment in a manner that 

minimizes the potential for contaminating food, food-packaging materials, and 

food-contact surfaces.

2.b.7 Provide, where necessary, adequate screening or other protection against 

pests.

3. SANITARY OPERATIONS

3.a General Maintenance. Buildings, fixtures, and other physical facilities of the 

plant shall be maintained in a sanitary condition and shall be kept in repair 

sufficient to prevent food from becoming adulterated within the meaning of the act. 

Cleaning and sanitizing of utensils and equipment shall be conducted in a manner 

that protects against contamination of food, food-contact surfaces, or foodpackaging materials.

3.b Substances used in cleaning and sanitizing; storage of toxic materials. (1) 

Cleaning compounds and sanitizing agents used in cleaning and sanitizing 

procedures shall be free from undesirable microorganisms and shall be safe and 

adequate under the conditions of use. Compliance with this requirement may be 

verified by any effective means including purchase of these substances under a 

supplier's guarantee or certification, or examination of these substances for 

contamination. Only the following toxic materials may be used or stored in a plant 

where food is processed or exposed:

3.b.1 Those required to maintain clean and sanitary conditions;

3.b.2 Those necessary for use in laboratory testing procedures;

3.b.3 Those necessary for plant and equipment maintenance and operation; and

3.b.4 Those necessary for use in the plant's operations.

3.c Toxic cleaning compounds, sanitizing agents, and pesticide chemicals shall be 

identified, held, and stored in a manner that protects against contamination of food, 

food-contact surfaces, or food-packaging materials. Not meeting these criteria is 

a major non-conformance with strong evidence of possible crosscontamination.
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3.d Pest Control. No pests shall be allowed in any area of a food plant. Guard or 

guide dogs may be allowed in some areas of a plant if the presence of the dogs is 

unlikely to result in contamination of food, food-contact surfaces, or foodpackaging materials. Effective measures shall be taken to exclude pests from the 

processing areas and to protect against the contamination of food on the premises 

by pests. The use of insecticides or rodenticides is permitted only under 

precautions and restrictions that will protect against the contamination of food, 

food-contact surfaces, and food-packaging materials.

Not meeting these criteria is a major non-conformance.

3.e Sanitation of Food-contact Surfaces. All food-contact surfaces, including 

utensils and food-contact surfaces of equipment, shall be cleaned as frequently as 

necessary to protect against contamination of food.

3.e.1 Food-contact surfaces used for manufacturing or holding low-moisture food 

shall be in a dry, sanitary condition at the time of use. When the surfaces are wetcleaned, they shall, when necessary, be sanitized and thoroughly dried before 

subsequent use.

3.e.2 In wet processing, when cleaning is necessary to protect against the 

introduction of microorganisms into food, all food-contact surfaces shall be 

cleaned and sanitized before use and after any interruption during which the foodcontact surfaces may have become contaminated. Where equipment and utensils 

are used in a continuous production operation, the utensils and food-contact 

surfaces of the equipment shall be cleaned and sanitized as necessary.

3.e.3 Sanitizing agents shall be adequate and safe under conditions of use. Any 

facility, procedure, or machine is acceptable for cleaning and sanitizing equipment 

and utensils if it is established that the facility, procedure, or machine will routinely 

render equipment and utensils clean and provide adequate cleaning and sanitizing 

treatment.

4. SANITARY FACILITIES AND CONTROLS

Each plant shall be equipped with adequate sanitary facilities and accommodations including, but not limited to:
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4.a Water Supply. The water supply shall be sufficient for the operations intended 

and shall be derived from an adequate source. Any water that contacts food or 

food-contact surfaces shall be safe and of adequate sanitary quality. Running water 

at a suitable temperature, and under pressure as needed, shall be provided in all 

areas where required for the processing of food, for the cleaning of equipment, 

utensils, and food-packaging materials, or for employee sanitary facilities. 

Not meeting these criteria is a major non-conformance.

4.b Plumbing. Plumbing shall be of adequate size and design and adequately 

installed and maintained to:

4.b.1 Carry sufficient quantities of water to required locations throughout the plant.

4.b.2 Properly convey sewage and liquid disposable waste from the plant.

4.b.3 Avoid constituting a source of contamination to food, water supplies, 

equipment, or utensils or creating an unsanitary condition.

Not meeting these criteria is a major non-conformance.

4.b.4 Provide adequate floor drainage in all areas where floors are subject to 

flooding-type cleaning or where normal operations release or discharge water or 

other liquid waste on the floor.

4.b.5 Provide that there is not backflow from, or cross-connection between, piping 

systems that discharge waste water or sewage and piping systems that carry water 

for food or food manufacturing.

4.c Sewage Disposal. Sewage disposal shall be made into an adequate sewerage 

system or disposed of through other adequate means.

4.d Toilet Facilities. Each plant shall provide its employees with adequate, readily 

accessible toilet facilities. Compliance with this requirement may be accomplished 

by:

4.d.1 Maintaining the facilities in a sanitary condition.

4.d.2 Keeping the facilities in good repair at all times.

4.d.3 Providing self-closing doors.

4.d.4 Providing doors that do not open into areas where food is exposed to airborne 

contamination, except where alternate means have been taken to protect against 

such contamination (such as double doors or positive air-flow systems).

4.e Hand-Washing Facilities. Hand-washing facilities shall be adequate and 

convenient and be furnished with running water at a suitable temperature. 

Compliance with this requirement may be accomplished by providing:

4.e.1 Hand-washing and, where appropriate, hand-sanitizing facilities at each 

location in the plant where good sanitary practices require employees to wash 

and/or sanitize their hands.
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4.e.2 Effective hand-cleaning and sanitizing preparations.

4.e.3 Sanitary towel service or suitable drying devices.

4.e.4 Devices or fixtures, such as water control valves, so designed and constructed 

to protect against recontamination of clean, sanitized hands.

4.e.5 Readily understandable signs directing employees handling unprotected food, 

unprotected food-packaging materials, of food-contact surfaces to wash and, where 

appropriate, sanitize their hands before they start work, after each absence from 

post of duty, and when their hands may have become soiled or contaminated. 

These signs may be posted in the processing room(s) and in all other areas where 

employees may handle such food, materials, or surfaces.

4.e.6 Refuse receptacles that are constructed and maintained in a manner that 

protects against contamination of food.

4.f Rubbish and Offal Disposal. Rubbish and any offal shall be so conveyed, 

stored, and disposed of as to minimize the development of odor, minimize the 

potential for the waste becoming an attractant and harborage or breeding place for 

pests, and protect against contamination of food, food-contact surfaces, water 

supplies, and ground surfaces.

5. EQUIPMENT AND UTENSILS

5.a All plant equipment and utensils shall be so designed and of such material and 

workmanship as to be adequately cleanable, and shall be properly maintained. The 

design, construction, and use of equipment and utensils shall preclude the 

adulteration of food with lubricants, fuel, metal fragments, contaminated water, or 

any other contaminants. Food-contact surfaces shall be corrosion-resistant when in 

contact with food. They shall be made of nontoxic materials and designed to 

withstand the environment of their intended use and the action of food, and, if 

applicable, cleaning compounds and sanitizing agents. Food-contact surfaces shall 

be maintained to protect food from being contaminated by any source, including 

unlawful indirect food additives.

5.b Seams on food-contact surfaces shall be smoothly bonded or maintained so as 

to minimize accumulation of food particles, dirt, and organic matter and thus 

minimize the opportunity for growth of microorganisms.

5.c Equipment that is in the manufacturing or food-handling area and that does not 

come into contact with food shall be so constructed that it can be kept in a clean 

condition.

5.d Holding, conveying, and manufacturing systems, including gravimetric, 

pneumatic, closed, and automated systems, shall be of a design and construction 

that enables them to be maintained in an appropriate sanitary condition.
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5.e Each freezer and cold storage compartment used to store and hold food capable 

of supporting growth of microorganisms shall be fitted with an indicating 

thermometer, temperature-measuring device, or temperature-recording device so 

installed as to show the temperature accurately within the compartment.

5.f Instruments and controls used for measuring, regulating, or recording 

temperatures, pH, acidity, water activity, or other conditions that control or prevent 

the growth of undesirable microorganisms in food shall be accurate and adequately 

maintained, and adequate in number for their designated uses.

5.g Compressed air or other gases mechanically introduced into food or used to 

clean food-contact surfaces or equipment shall be treated in such a way that food is 

not contaminated with unlawful indirect food additives.

6. PROCESSES AND CONTROLS

6.a All operations in the receiving, inspecting, transporting, segregating, preparing, 

manufacturing, packaging, and storing of food shall be conducted in accordance 

with adequate sanitation principles. Appropriate quality control operations shall be 

employed to ensure that food is suitable for human consumption and that foodpackaging materials are safe and suitable. Overall sanitation of the plant shall be 

under the supervision of one or more competent individuals assigned responsibility 

for this function. All reasonable precautions shall be taken to ensure that 

production procedures do not contribute contamination from any source. Chemical, 

microbial, or extraneous-material testing procedures shall be used where necessary 

to identify sanitation failures or possible food contamination. All food that has 

become contaminated to the extent that it is adulterated within the meaning of the 

act shall be rejected, or if permissible, treated or processed to eliminate the 

contamination.

6.a.1Raw materials and other ingredients. (1) Raw materials and other ingredients 

shall be inspected and segregated or otherwise handled as necessary to ascertain 

that they are clean and suitable for processing into food and shall be stored under 

conditions that will protect against contamination and minimize deterioration. Raw 

materials shall be washed or cleaned as necessary to remove soil or other 

contamination. Water used for washing, rinsing, or conveying food shall be safe 

and of adequate sanitary quality. Water may be reused for washing, rinsing, or 

conveying food if it does not increase the level of contamination of the food. 
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6.a.2 Raw materials and other ingredients shall either not contain levels of 

microorganisms that may produce food poisoning or other disease in humans, or 

they shall be pasteurized or otherwise treated during manufacturing operations so 

that they no longer contain levels that would cause the product to be adulterated 

within the meaning of the act. Compliance with this requirement may be verified 

by any effective means, including purchasing raw materials and other ingredients 

under a supplier's guarantee or certification.

6.a.3 Raw materials and other ingredients susceptible to contamination with 

afflation or other natural toxins shall comply with current FDA regulations and 

action levels for poisonous or deleterious substances before these materials or 

ingredients are incorporated into finished food. Compliance with this requirement 

may be accomplished by purchasing raw materials and other ingredients under a

supplier's guarantee or certification, or may be verified by analyzing these 

materials and ingredients for aflatoxins and other natural toxins.

6.a.4 Raw materials, other ingredients, and rework susceptible to contamination 

with pests, undesirable microorganisms, or extraneous material shall comply with 

applicable Food and Drug Administration regulations and defect action levels for 

natural or unavoidable defects if a manufacturer wishes to use the materials in 

manufacturing food. Compliance with this requirement may be verified by any 

effective means, including purchasing the materials under a supplier's guarantee or 

certification, or examination of these materials for contamination.

6.a.5 Raw materials, other ingredients, and rework shall be held in bulk, or in 

containers designed and constructed so as to protect against contamination and 

shall be held at such temperature and relative humidity and in such a manner as to 

prevent the food from becoming adulterated within the meaning of the act. Material 

scheduled for rework shall be identified as such.

6.a.6 Frozen raw materials and other ingredients shall be kept frozen. If thawing is 

required prior to use, it shall be done in a manner that prevents the raw materials 

and other ingredients from becoming adulterated within the meaning of Federal 

Food, Drug, and Cosmetic Act.

6.a.7 Liquid or dry raw materials and other ingredients received and stored in bulk 

form shall be held in a manner that protects against contamination.

6.b.1 Manufacturing operations. Equipment and utensils and finished food 

containers shall be maintained in an acceptable condition through appropriate 

cleaning and sanitizing, as necessary. Insofar as necessary, equipment shall be 

taken apart for thorough cleaning.
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6.b.2 All food manufacturing, including packaging and storage, shall be conducted 

under such conditions and controls as are necessary to minimize the potential for 

the growth of microorganisms, or for the contamination of food. One way to 

comply with this requirement is careful monitoring of physical factors such as 

time, temperature, humidity, water activity, pH, pressure, flow rate, and 

manufacturing operations such as freezing, dehydration, heat processing, 

acidification, and refrigeration to ensure that mechanical breakdowns, time delays, 

temperature fluctuations, and other factors do not contribute to the decomposition 

or contamination of food.

6.b.3 Food that can support the rapid growth of undesirable microorganisms, 

particularly those of public health significance, shall be held in a manner that 

prevents the food from becoming adulterated within the meaning of the act. 

Compliance with this requirement may be accomplished by any effective means, 

including:

6.b.3.a Maintaining refrigerated foods at 45 °F (7.2 °C) or below as appropriate for 

the particular food involved. 

6.b.3.b Maintaining frozen foods in a frozen state.

6.b.3.c Maintaining hot foods at 140 °F (60 °C) or above.

6.b.3.d Heat treating acid or acidified foods to destroy mesophilic microorganisms 

when those foods are to be held in hermetically sealed containers at ambient 

temperatures.

6.b.4 Measures such as sterilizing, irradiating, pasteurizing, freezing, refrigerating, 

controlling pH or controlling water activity that are taken to destroy or prevent the 

growth of undesirable microorganisms, particularly those of public health 

significance, shall be adequate under the conditions of manufacture, handling, and 

distribution to prevent food from being adulterated within the meaning of the act.

Not meeting these criteria is a major non-conformance.

6.b.5 Work-in-process shall be handled in a manner that protects against 

contamination.

6.b.6 Effective measures shall be taken to protect finished food from contamination 

by raw materials, other ingredients, or refuse. When raw materials, other 

ingredients, or refuse are unprotected, they shall not be handled simultaneously in a 

receiving, loading, or shipping area if that handling could result in contaminated 

food. Food transported by conveyor shall be protected against contamination as 

necessary. Not meeting these criteria is a major non-conformance.
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6.b.7 Equipment, containers, and utensils used to convey, hold, or store raw 

materials, work-in-process, rework, or food shall be constructed, handled, and 

maintained during manufacturing or storage in a manner that protects against 

contamination.

6.b.8 Effective measures shall be taken to protect against the inclusion of metal or 

other extraneous material in food. Compliance with this requirement may be 

accomplished by using sieves, traps, magnets, electronic metal detectors, or other 

suitable effective means.

6.b.9 Food, raw materials, and other ingredients that are adulterated within the 

meaning of the act shall be disposed of in a manner that protects against the 

contamination of other food. If the adulterated food is capable of being 

reconditioned, it shall be reconditioned using a method that has been proven to be 

effective or it shall be reexamined and found not to be adulterated within the 

meaning of the act before being incorporated into other food.

6.b.10 Mechanical manufacturing steps such as washing, peeling, trimming, 

cutting, sorting and inspecting, mashing, dewatering, cooling, shredding, extruding, 

drying, whipping, defatting, and forming shall be performed so as to protect food 

against contamination. Compliance with this requirement may be accomplished by 

providing adequate physical protection of food from contaminants that may drip, 

drain, or be drawn into the food. Protection may be provided by adequate cleaning 

and sanitizing of all food-contact surfaces, and by using time and temperature 

controls at and between each manufacturing step.

6.b.11 Batters, breading, sauces, gravies, dressings, and other similar preparations 

shall be treated or maintained in such a manner that they are protected against 

contamination. Compliance with this requirement may be accomplished by any 

effective means, including one or more of the following:

6.b.11.a Using ingredients free of contamination.

6.b.11.b Employing adequate heat processes where applicable.

6.b.11.c Using adequate time and temperature controls.

6.b.11.d Providing adequate physical protection of components from contaminants 

that may drip, drain, or be drawn into them.

6.b.11.e Cooling to an adequate temperature during manufacturing.

6.b.11.f Disposing of batters at appropriate intervals to protect against the growth 

of microorganisms.

6.b.12 Filling, assembling, packaging, and other operations shall be performed in 

such a way that the food is protected against contamination. Compliance with this 

requirement may be accomplished by any effective means, including:
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6.b.12.a Use of a quality control operation in which the critical control points are 

identified and controlled during manufacturing.

6.b.12.b Adequate cleaning and sanitizing of all food-contact surfaces and food 

containers.

6.b.12.c Using materials for food containers and food- packaging materials that are 

safe and suitable.

6.b.12.d Providing physical protection from contamination, particularly airborne 

contamination.

6.b.12.e Using sanitary handling procedures.

6.b.13 Food such as, but not limited to, dry mixes, nuts, intermediate moisture 

food, and dehydrated food, that relies on the control of aw for preventing the 

growth of undesirable microorganisms shall be processed to and maintained at a 

safe moisture level. Compliance with this requirement may be accomplished by 

any effective means, including employment of one or more of the following 

practices:

6.b.13.a Monitoring the water activity of food.

6.b.13.b Controlling the soluble solids-water ratio in finished food.

6.b.13.c Protecting finished food from moisture pickup, by use of a moisture 

barrier or by other means, so that the water activity of the food does not increase to 

an unsafe level.

6.b.14 Food such as, but not limited to, acid and acidified food, that relies 

principally on the control of pH for preventing the growth of undesirable 

microorganisms shall be monitored and maintained at a pH of 4.6 or below. 

Compliance with this requirement may be accomplished by any effective means, 

including employment of one or more of the following practices:

6.b.14.a Monitoring the pH of raw materials, food in process, and finished food.

6.b.14.b Controlling the amount of acid or acidified food added to low-acid food.

6.b.15 When ice is used in contact with food, it shall be made from water that is 

safe and of adequate sanitary quality, and shall be used only if it has been 

manufactured in accordance with current good manufacturing practice as outlined 

in this part.

7. WAREHOUSING AND DISTRIBUTION

7.a Storage and transportation of finished food shall be under conditions that will 

protect food against physical, chemical, and microbial contamination as well as 

against deterioration of the food and the container.
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8. DEFECT ACTION LEVELS 

8.a Compliance with defect action levels does not excuse violation of the 

requirement in section 402(a)(4) of the act that food not be prepared, packed, or 

held under unsanitary conditions or the requirements in this part that food 

manufacturers, distributors, and holders shall observe current good manufacturing 

practice. Evidence indicating that such a violation exists causes the food to be 

adulterated within the meaning of the act, even though the amounts of natural or 

unavoidable defects are lower than the currently established defect action levels. 

The manufacturer, distributor, and holder of food shall at all times utilize quality 

control operations that reduce natural or unavoidable defects to the lowest level 

currently feasible.

8.b The mixing of a food containing defects above the current defect action level 

with another lot of food is not permitted and renders the final food adulterated 

within the meaning of the act, regardless of the defect level of the final food.