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Harmonized GAP Audits
Harmonized GAP audits expand the systems of food safety control for produce businesses to consider more potential hazards and to require more preventive measures. They include topics like allergen controls, self audits, multiple risk assessments, internal corrective action programs, approved supplier systems, disciplinary procedures for food safety violations, and designations of 24-hr food safety contacts.
Harmonized GAP audits are intended to align the many requirements of multiple audit schemes to create efficiencies for the produce business and to provide a high level of food safety assurance to buyers at the same time. They ‘harmonize’ the Good Agricultural and Handling Practices of Basic GAP/GHP audits with the requirements of FSMA’s Produce Safety Rule.
As with Basic GAP/GHP audits, the General Questions are reviewed with every audit, and the business may choose which of the following scopes the want audited:
- Field Operations & Harvesting
- Post-Harvest Operations
- Logo Use (for businesses using the USDA GAP logo on their products)
Harmonized GAP audits have mandatory questions that must be answered as compliant if applicable to the operation in order to pass the audit. Any questions answered as Corrective Action Needed will need to be addressed in order to pass the following year’s audit. The farm or business must answer at least 80% of applicable questions as compliant on each scope to pass the audit. All crops included in the audit are listed on the certificate.
We presented a session in 2021 on the structure of the Harmonized GAP audits and explained key concepts for audit success, including risk assessments & written risk management plans, trace back/trace forward exercises & mock recalls, water tests, and water system descriptions. This presentation is available in two formats:
Several questions require the farm to meet 'current industry practices' or 'prevailing regulations.' Prevailing regulations can refer to state environmental or pesticide laws, worker safety laws, or other regulations relevant to the operation and the location. Current industry practices refer to industry guidance for specific commodities. Industry guidance written in collaboration with the FDA for specific crops are available here:
- Potatoes (June 2013) (PDF 7325KB)
- Cantaloupes and Netted Melons (March 29, 2013) (PDF 4.77MB)
- Fresh Culinary Herbs (January 2013) (PDF 7.34MB)
- Green Onions (February 2010) (PDF 1.9MB)
- Fresh Tomato Supply Chain – 3rd Edition (September 2018) (PDF 2.9MB)
- Lettuce and Leafy Greens Supply Chain – 1st Edition (April 2006) (PDF 464KB)
- An Example of How These Guidances Are Created - Cantaloupes
The Harmonized GAP checklist (PDF Version February 8, 2021) used by auditors is publicly available, and can be used to perform your self-audit.
The Harmonized GAP standard (PDF Version February 8, 2021) is used by auditors to evaluate each question and gives much more of the requirements that must be met for each question. We strongly recommend using the Harmonized GAP standard as you prepare to make sure you meet all the requirements of each question.
Both the checklist and the standard for the Harmonized GAP Audits were recently revised and released on February 16, 2021. The current materials will be used until April 30, 2021. The new materials will be used starting on May 1, 2021.
The current USDA Harmonized GAP standards and checklists remain in effect through April 30, 2021:
Effective May 1, 2021, the new standards and checklists will be used for USDA Harmonized GAP and GAP Plus+ audits. Here is summary of the changes to the standards:
The new USDA Harmonized GAP standard and checklist were revised to reflect recent updates to the Produced Harmonized GAP standard, and to include Tomato Audit Protocol metrics.
- Harmonized GAP Standard (Version 2) (PDF)
- Harmonized GAP Checklist (Version 5) (XLS)
- Harmonized GAP Checklist (Version 5) (PDF)
Free guidebooks and food safety plan and record templates are available from:
More information about the Harmonized GAP standard can be found with the United Fresh Produce Association. They are the creators and stewards of the Harmonized GAP standard and have processes to review the standard itself, resolve questions and disputes, and maintain the audit standard.