1

Critical Control Point Assessment 

[Nursery]

[Location]

[Dates]

[Regulatory agency]

[Address]

[NOTE: This document is a template for completing a Critical Control Point (CCP) assessment 

of a regulated establishment. All text that should be deleted or replaced with the described 

information is in red and surrounded by brackets like these [ ].

Purpose: The need for information on all aspects of a nursery operations in a complete CCP

depends on the circumstances that initiated the CCP.

• If this is a first-time positive nursery, a complete CCP should be done. This will provide 

a basis for reassessment if the nursery is positive again and for onboarding new 

personnel assigned to CCP assessments in the future.

o A reduced-scope CCP focusing on the positive subsites and any other areas of 

concern can be conducted for first-time positive nurseries ifthe positive find 

clearly links to newly introduced infected material in an area that contains the 

risk of further spread in the nursery. The impacted State and the PPQ CFWG 

decide jointly on the scope of the CCP. 

• If this is a repeat nursery with new positives detections and there is no previous record 

of a complete CCP, a complete CCP is required for the nursery.

• If this is a repeat nursery with new positives detections and there is a complete CCP on 

record, another complete CCP is encouraged.

o Areduced-scope CCP focusing on only the positive subsites and any other 

areas of concern is acceptable if the impacted State and the PPQ CFWG 

decided jointly if portions of the previous CCP is still valid. The CCP still should

assess the nursery in total and make a record of all changes made to the 

nursery practices since the completion of the previous CCP and any areas that 

might contribute to the new infestations.]
2

1. Introduction 

1.1. Background 

This document was prepared by [Regulatory Agency], to document the information collected 

from the Critical Control Point (CCP) assessment at [Nursery] in [location, town, and state].

[This is standard language for all CCPs primarily provided for the benefit of the Nursey 

management. The author may shorten or omit text as needed.] Phytophthora ramorum is a 

regulated pest for the Unites States. APHIS regulates the domestic movement of host plants 

from areas with known P. ramorum infestations to prevent the spread of the pathogen to noninfested areas of the United States. A detection of P. ramorum in a commercial nursery that 

moves plant material interstate, or in a state considered free from P. ramorum, necessitates 

the applications of the Interstate Confirmed Nursery Protocol. As part of this protocol, the 

nursery site and operations are assessed to identify remediation and mitigation options, 

business/cultural practices, and best management practices (BMP) to address and eliminate 

P. ramorum at the nursery. These assessments are called Critical Control Point (CCP) 

assessments. A critical control point is a point, step, or procedure at which control can be 

applied and a hazard can be prevented, eliminated, or reduced to acceptable levels. In a 

nursery setting, CCPs include the processes and procedures of a nursery operation, from 

when the plants first arrive to when they leave production. By determining CCPs, applicable 

best management practices (BMPs) and/or mitigations the nursery can then institute a 

systems approach. A systems approach consists of a defined set of phytosanitary procedures, 

at least two of which have an independent effect in mitigating pest risk associated with the 

movement of commodities. By addressing CCPs, nurseries can reduce the risk of a potential 

hazard and take corrective steps towards P. ramorum mitigation and/or avoidance. Required 

mitigation measures are recorded in Exhibit D of the PPQ Form 519, Compliance Agreement 

(CA) 

General Information of Phytophthora ramorum 

[This is standard language for all CCPs primarily provided for the benefit of the Nursey 

management, it can be shortened or omitted as needed.] The oomycete pathogen 

Phytophthora ramorum is the causal agent of ramorum leaf blight and sudden oak death. P. 

ramorum is known to cause leaf blight and stem dieback on over 150 different plant species in 

over 80 genera, including several ornamentals commonly grown in commercial nurseries

(Parke and Peterson, 2019). The disease typically results in dark, brownish lesions on leaves 

or stems which can cause wilting and death of the plant. Visual diagnosis of P. ramorum can 

be complicated by many factors including its large host range and the fact that other 

pathogens and environmental conditions can elicit the same foliar and dieback symptoms. 

Further confounding detection, fungicides commonly used to control other Phytophthora

species on rhododendron and other hosts may mask symptoms (COMTF, 2020). Latent 

infections are a challenging obstacle for detection efforts because no visual symptoms exist 

to indicate presence of the pathogen. Infected plants may be asymptomatic, especially when 
3

grown in dry, cool climates. The onset of P. ramorum disease outbreak coincides with wet and 

warm weather in an outdoor nursery setting.

Water, soil, and even symptomless plants have all been broadly indicated as potential 

reservoirs of P. ramorum inoculum both in Europe and in North America. Experiments have 

shown water‐mediated spread of infection in natural systems and production facilities while 

circumstantial but convincing evidence has indicated that intense rain events leading to 

partial flooding of nursery beds can cause severe outbreaks of the disease in production 

nurseries. Inert potting mix has been shown to harbor viable chlamydospores of P. ramorum

for years and splash dispersal and plant-to-plant contact appear to be important for spread 

within nurseries with extended periods of leaf wetness likely required for infection.

P. ramorum, has been introduced to the United States on at least three separate occasions, 

almost certainly via the movement of nursery stock. This pathogen, responsible for 

widespread mortality of oak and tanoak in coastal California and southwestern Oregon, 

poses a threat to red oak–dominated ecosystems east of the Mississippi. APHIS has 

established quarantines and regulations to prevent further P. ramorum spread to noninfested areas of the United States.

References cited:

• Parke, J. L., and E. K. Peterson. 2019. Sudden oak death, sudden larch death, and 

ramorum blight. The Plant Health Instructor. DOI: 10.1094/PHI-I-2019-0701-02

• COMTF. 2020. Hosts and Symptoms. California Oak Mortality Task Force (COMTF). 

Accessed 5/2020. http://www.suddenoakdeath.org/diagnosis-andmanagement/hosts-and-symptoms/

1.2. Initiating Event

[Describe the initial positive detection(s). What type of inspection lead to the detection 

(general nursery survey or compliance inspection)? What type of sample lead to the positive 

detection(s) (e.g. plant, water, or soil positive)? List the State and Federal regulatory bodies 

represented in the CCP assessment. Describe any other circumstances or conditions relevant 

to the assessment.]

1.3. Documentation

Description of the nursery 

[Describe the layout of the nursery, and size of the nursery. Define, as known, the 

general type and number of plants within the nursery and the source of those plants.

Describe the propagation activities occurring on site. Finally include any information 

on the surrounding area relevant to the assessment, i.e., are there other nurseries, 

forested areas, or bodies of water nearby that may factor into the assessment.]
4

[Describe the business practices of the nursery. Record the businesses they ship to, 

their peak shipping seasons, and any related businesses or other locations associated 

with this nursery.]

Roads and beds. [Describe the overall condition of the roads in and around the 

nursery and the beds used for holding host plants.]

Greenhouses and hoop houses. 

[Describe the overall layout and size of the greenhouses and hoop houses. Describe

how plants are irrigated and treated within the structures.]

Water for irrigation. 

[Describe the overall water sources for the nursery including wells, municipal, nearby 

waterways, and holding ponds used to water plants, as well as any treatments or 

processes the water undergoes for irrigation.]

Nursery operations. 

[Describe the overall practices in the nurseries regarding deliveries, customer access, 

shipments, horticultural and propagation processes. Describe how the nursery treats

tools and pots, especially if reused.] 
5

Confirmed-positive sample subsites 

The blocks or locations of confirmed P. ramorum positive plants are listed in Table 1. 

Table 1. List of subsites in the [Nursery name] Nursery identifying block number, general 

description of the block, plant names, and number of P. ramorum positive plants recorded 

during [Year]. 

Block ID Descriptor of the block Plant species and name

[Location – prefer unique ID] [Brief description] [Latin binomial],

[varietal name]

• No. of positives: [X]

Pot size: [X gallon, etc.]

[Location – prefer unique ID] [Brief description] [Latin binomial],

[varietal name]

• No. of positives: [X]

Pot size: [X gallon, etc.]

[Location – prefer unique ID] [Brief description] [Latin binomial],

[varietal name]

• No. of positives: [X]

Pot size: [X gallon, etc.]

[Location – prefer unique ID] [Brief description] [Latin binomial],

[varietal name]

• No. of positives: [X]

Pot size: [X gallon, etc.]

[NOTE: Please add or delete as many rows as needed for the complete inventory.]
6

2. Assessment

2.1. Positive Subsites 

[In this section describe each positive subsite separately and document with pictures.]

 

SUBSITE 1. [Provide a brief description of the subsite to provide context for the pictures 

below. Take as many pictures as needed to see all angles or components of the subsite. Place

these photos into the report in place of the icon placeholders. Add captions to each picture

describing the picture and label 1A, 1B, etc. Add arrows or circles to indicate any important 

features or identified problem areas captured in the picture.]

SUBSITE 2. [If assessing more than one positive subsite, provide a separate description for 

each positive subsite. Provide a brief description of the scene to provide context for the 

pictures below. Take as many pictures as needed to see all angles or components of the 

subsite. Place these photos into the report in place of the icon placeholders. Add captions to 

each picture and label 2A, 2B, etc. Add arrows or circles to indicate any important features or 

identified problem areas captured in the picture.]

 
7

SUBSITE 3. [If assessing more than one positive subsite, provide a separate description for 

each positive subsite. Provide a brief description of the scene to provide context for the 

pictures below. Take as many pictures as needed to see all angles or components of the 

subsite. Place these photos into the report in place of the icon placeholders. Add captions to 

each picture and label 3A, 3B, etc. Add arrows or circles to indicate any important features or 

identified problem areas captured in the picture.]

2.2. Subsites Adjacent to Positive Subsites 

[In this section describe subsites that are adjacent to a positive subsite included in section 2.1

and subsites common to nurseries. Describe each subsite separately and document with 

pictures. A nursery may not have all of the following subsites. Delete the sections that do not 

apply to the nursery.]

SUBSITE 1. [Provide a brief description of the subsite to provide context for the pictures 

below. Take as many pictures as needed to see all angles or components of the subsite. Place 

these photos into the report in place of the icon placeholders. Add captions to each picture 

and label 1A, 1B, etc. Add arrows or circles to indicate any important features or identified 

problem areas captured in the picture.]
8

 
9

SUBSITE 2. [Add other subsites adjacent to positive subsites and elsewhere in the nursery to 

compare or contrast conditions relevant to the assessment. Provide a brief description of the 

subsite to provide context for the pictures below. Take as many pictures as needed to see all 

angles or components of the subsite. Place these photos into the report in place of the icon 

placeholders. Add captions to each picture describing the picture and label 2A, 2B, etc. Add 

arrows or circles to indicate the important features or identified problem areas in the 

picture.]

 

SUBSITE 3. Storage Area. [Describe areas used to store pots, tools or other equipment and 

describe the general condition of the area to provide context for the pictures below. Take as 

many pictures as needed to see all angles or components of the subsite. Place these photos 

into the report in place of the icon placeholders. Add captions to each picture describing the 

picture and label 3A, 3B, etc. Add arrows or circles to indicate the important features or 

identified problem areas captured in the picture.]
10

 

SUBSITE 4. Engineered Water Management System. [Describe water sources and drainage 

areas and describe the general condition of those areas. to provide context for the pictures 

below. Take as many pictures as needed to see all angles or components of the subsite. Place 

these photos into the report in place of the icon placeholders. Add captions to each picture 

describing the picture and label 4A, 4B, etc. Add arrows or circles to indicate the important 

features or identified problem areas captured in the picture.]

SUBSITE 5. Potting Building. [Describe any canning, potting and/or propagation facilities 

and the pots, tools or other equipment used to provide context for the pictures below. Take 

as many pictures as needed to see all angles or components of the subsite. Place these 

photos into the report in place of the icon placeholders. Add captions to each picture 

describing the picture and label 5A, 5B, etc. Add arrows or circles to indicate the important 

features or identified problem areas captured in the picture.]
11

 

 
12

SUBSITE 6. Retention Pond. [Describe any holding ponds used by the nursery and their 

condition to provide context for the pictures below. Take as many pictures as needed to see 

all angles or components of the subsite. Place these photos into the report in place of the 

icon placeholders. Add captions to each picture describing the picture and label 6A, 6B, etc.

Add arrows or circles to indicate the important features or identified problem areas captured 

in the picture.] 

 

 

SUBSITE 7. Plant Destruction Subsite. [If P. ramorum positive plants were destroyed by the 

nursery, describe where plants were burned and buried and record the date of destruction if 

known to provide context for the pictures below. Take as many pictures as needed to see all 

angles or components of the subsite. Place these photos into the report in place of the icon 

placeholders. Add captions to each picture describing the pictures and label 7A, 7B, etc. Add 

arrows or circles to indicate the important features or identified problem areas in the 

picture.] 
13

 

SUBSITE 8. Loading Docks. [Describe any shipping and receiving areas to provide context for 

the pictures below. Take as many pictures as needed to see all angles or components of the 

subsite. Place these photos into the report in place of the icon placeholders. Add captions to 

each picture describing the picture and label 9A, 9B, etc. Add arrows or circles to indicate the 

important features or identified problem areas captured in the picture.] 

 

 

3. General mitigation best practices

[Record pesticide records relevant to the positive subsites, training records of the facility, and 

distribution of crews throughout the nursery.

The following sections (3.1-3.10) provide general practices Best Management Practices 

common for combating P. ramorum incursion in a nursery setting. They are primarily 

included for the benefit of the Nursey management. This information can be changed or 

omitted depending on circumstances relevant to the assessment.]

3.1. Site Selection and Maintenance 

• Maintain and correct nursery roadways to promote drainage and prevent puddling or 

creation of muddy areas. This will also help to prevent splash onto plants from 

vehicles moving within the nursery.

• Design and manage the nursery layout and work flow to avoid cross contamination,

e.g. used pots are not carried through a clean production area of the nursery.

• Adequately control weeds on the nursery grounds.
14

3.2. Water Management 

• Water should drain away from the plant beds resulting in no standing water following 

irrigation in the beds or from surrounding beds. The drainage should be sufficient to 

allow water to flow to outside edge of nursery with no water remaining in the bed 

drainage areas for significant amounts of time. This will prevent splash dispersal from 

the drainage areas during either overhead irrigation or rain events to plants in close 

proximity. 

• Repair irrigation lines and fixtures.

• Monitor and annually test untreated irrigation water from any source, other than a 

well or municipal water supply, to confirm it is free from pathogens.

• Improve drainage patterns and maintain designed drainage channels to minimize 

standing water and mud accumulation.

3.3. Plant Procurement 

• New plants from outside of the nursery should be placed or held in a location that 

minimizes the potential contamination of existing stock on site. Water movement or 

splash from new plants to existing plants should be eliminated.

• Avoid commingling of P. ramorum host plants from different producers/sources in 

plant beds.

• All incoming nursery buy-ins should initially be placed in an area where leafy debris 

can be easily cleaned up and safely disposed.

• Trained and authorized personnel should visually inspect all incoming cuttings and 

nursery stock buy-ins, regardless of origin, for symptoms of disease prior to 

introduction into the nursery facility.

3.4. Plant Propagation (if applicable) 

• After every crop rotation, disinfect propagation mist beds, sorting areas, cutting 

benches, and equipment

• Collections of cuttings and seeds from the wild or nursery stock should be taken from 

healthy plants during non-rainy weather and, where possible, should be collected at 

approximately two feet or more above the soil surface.

• When taking cuttings from existing nursery stock, collect only from healthy plants and, 

if necessary, dip cuttings in an approved disinfectant solution before sticking. For 

plants that are prone to diseases, chemically treat crop in the field prior to taking 

cuttings.

• Restrict access to propagation areas so that only necessary personnel are permitted. 

3.5. Greenhouses and/or Hoop Houses 

• Discard unhealthy plants and plants that are unsuitable for selling.

• Install concrete floors for greenhouses so they are easily disinfected and leafy debris is 

easier to remove.
15

• Thoroughly clean and disinfest greenhouses between production runs.

• Provide footbaths with fresh disinfectant solution for greenhouse entryways.

3.6. Potting Media and Containers 

• Ensure that potting media is not located in areas that receive drainage from beds. All 

water should drain away from piles of potting media.

• Ensure that growing media is purchased from a reliable source and the components 

are low risk for containing pathogens.

• Use new or clean and properly disinfested pots.

• Do not store used containers in or near clean areas of the nursery.

• Store pots off the ground and in an area not exposed to contamination through water 

or by the surrounding environment.

3.7. Plant Beds 

• Where possible, space pots to reduce plant-to-plant contact and encourage air 

movement and drying during conducive times of the year for P. ramorum.

• Routinely clean plant beds of debris and dispose of debris away from beds and 

drainage.

• Nursery beds should have sufficient gravel or additional gravel added to sufficiently 

raise the surface level of the bed to prevent pots from sitting in standing water for any 

amount of time.

• Discard unthrifty or poorly growing plants

• Maintain separation between lots/ blocks? of P. ramorum hosts even if they are the 

same cultivar.

• P. ramorum hosts should not be located in plant beds within 1 meter of drainage areas

or nursery roadways. This will prevent splash dispersal of pathogens from the 

drainage areas.

• Raising P. ramorum hosts off the ground on raised benches with drainable bench tops 

will greatly reduce splash and dispersal of pathogens from the potentially infected 

ground.

• Avoid working in P. ramorum host beds when plants and the bed are wet.

3.8. Training 

• Train facility staff on the biology of P. ramorum and symptoms on hosts.

• Train employees on P. ramorum hosts to raise awareness and take appropriate 

precautions to reduce associated risk.

• Indicate P. ramorum host beds either with color or tags to promote awareness of 

personnel.

• Educate nursery personnel on your pest reporting program. Ensuring personnel know 

what to do regarding the discovery and reporting of symptomatic plants.
16

• Educate the appropriate employees and managers about the nursery’s implemented 

BMPs.

3.9. Scouting 

• Routinely monitor incoming plants for symptoms of soil-borne pathogens. 

• Routinely inspect landscape plants within the nursery grounds and the surrounding 

area for symptoms of disease. 

• Conduct a regular scouting program of all nursery stock for the signs of pests and 

diseases. 

• Thorough inspection of material prior to mowing or top working. Any symptomatic or 

suspicious material should be removed prior to mowing/top working.

3.10. Biosecurity 

• Designate specific employees to work with P. ramorum hosts.

• Have staff work only at one nursery location on a given day or require employees to 

change shoes and clothes before entering another location. 

• Ensure that personnel wear clean clothes and coverings when working with P. 

ramorum hosts on a daily basis.

• Disinfest shoes when returning from known P. ramorum infested sites or from other 

nursery sites. 

• Equipment tires should be cleaned and disinfected when working in P. ramorum host 

beds. 

• All staff vehicles should be washed in a designated location before returning to the 

nursery from another facility.

• Clean and disinfect all tools between plant beds and greenhouses, especially when 

working with P. ramorum hosts.

• When P. ramorum hosts are potted or sized up, clean all equipment, tables, gloves 

and aprons or other clothing before moving onto other plants. 

• Sanitize footwear before entering and exiting potting areas after visiting high risk 

areas.

• Trailers, carts, and other conveyances should be cleaned of debris daily. 

• Shipping docks and potting area should use dedicated cleaning tools to avoid crosscontamination. 

4. Recommended references 

Examples of programs based on identifying CCPs and implementing BMPs to address the 

associated risks of P. ramorum: 

Nursery Practices:

• National Ornamental Research Site at Dominican University CA (NORS-DUC) and 

California Department of Food and Agriculture (CDFA) 
17

• Washington State University Extension, Nursery Guidelines for Exclusion and 

Management of P. ramorum in Nurseries

PPQ approved disinfectants

• Table 12-1-1 Phytophthora ramorum Domestic Regulatory Program Manual 

https://www.aphis.usda.gov/import_export/plants/manuals/domestic/downloads/pramorum.pdf

5. Findings

[Provide a precise summary of the CCPs identified in this assessment and relevant to the 

detection and potenitalspread of Phytophthora ramorum in the nursery: may include plant 

acquisition, onboarding, propagation, increase, fungicide application and other treatments, 

irrigation, movement, sale, shipping, personnel activities, training, scouting, and records of 

these activities.

It is preferred that finding are presented in a bulleted list for easier incorporation into Exhibit 

D.

NOTE: Exhibit D is not included in the body of the CCP assessment but is used to establish a 

compliance agreement.]

6. Conclusions

[Provide a concise description of the assessment and circumstances specific to this nursery, 

and significant findings.]

 

CCP Assessment Participant list: 

• CCP team: [NAMES (Regulatory Agency)] 

• Observers: [NAMES (Affiliation, Position)]

• Nursery staff: [NAMES (Owner, Managers and/or Staff)]

• Photos provided by [NAMES (only include if photos were provided by individuals not 

on the CCP team]

 
18

Appendix 1. Site map 

Map of Nursery. [Provide enough descriptive information to provide context to the CCP report

and describe approximately where positive plants were found and any circles and arrows 

drawn on the map.]

[PLACE NURSERY MAP HERE]