# Prepare records for GAP audits, produce-water assessments and plant exports

URL: https://leafwrit.com/us/usda-harmonized-gap-farm-checklist/
Reviewed: 2026-10-29

Prepare the audit application and Harmonized GAP checklist for a USDA food-safety audit. Covered farms also need the applicable written agricultural-water assessment. For nursery exports, prepare the phytosanitary inspection application with the export certification specialist.

## USDA GAP audit: agree on scope and request the service

USDA Good Agricultural Practices audits are voluntary audits. For a USDA GAP audit, agree on the service and scope with the selected USDA office, then prepare the USDA GAP audit request form SC-237A and the SC-651 agreement.

### Submit through the selected office

Send SC-237A and SC-651 to the selected local USDA audit office for receipt confirmation and scheduling. Keep the office response and final scope with the forms.

### Agree the buyer's audit program and scope first

A buyer’s acceptance criteria for USDA GAP certified farms may differ from USDA’s, so confirm them before booking. For GAP certification USDA expects every selected audit scope to be completed in full; a split audit remains incomplete until all relevant work is finished. Agree the actual crop and operating season with the audit office so the requested services can be assessed.

### Confirm scheduling after submitting SC-237A

A USDA representative should contact the applicant within 48 hours of receipt, excluding weekends and holidays, to schedule the audit. Confirm the actual appointment with the audit office before arranging the farm’s preparation schedule.

### Review the participation agreement and optional report release

Use the optional release request if you want audit results sent to a web-based system or another party. Audit results are released to third parties only with the auditee’s written consent. If a buyer needs a direct report, identify the correct recipient and obtain the required authorization. Keep the optional sharing decision distinct from the underlying request for audit services.

### Coordinate SC-430 with the originating office

Use SC-430, revision 09/2025, with the originating audit office. Indicate new or updated applicant information and enter identity, street and billing addresses, DBA, contacts and tax identification. Leave FEIRS/SCION and internal billing-processing entries to the office.

### Build a crop-protection evidence index for G-11

For G-11, document compliance with pesticide labels and applicable regulations. Verify applicator training, licensing or certification and assess residue limits in the country of origin or destination. Match the products, completed applications and operator qualifications to the crops in the audit scope.

Check water used with agricultural chemicals, water-treatment products, chemical disposal and cleaning-agent suitability for food-contact surfaces. Assess contamination from compressed air or gases contacting food or those surfaces. The Plus+ storage-separation item is marked as a Plus+ question in the combined document. Read that applicability marking instead of assuming every combined-checklist row applies identically to every requested program.

### Understand the auditor's findings and score sheets

Audit responses are Compliant, Corrective Action Needed, Immediate Action Required and Not Applicable. Auditors document corrective or immediate-action findings and explain not-applicable answers. Review the response totals by section and identify the question numbers requiring corrective action.

On the Corrective Action Report, enter the report reference and date, nonconformity, related question or food-safety-plan section, proposed correction and implementation timeframe. The auditor's acceptance of a proposed corrective action remains an official audit step.

## Agricultural water records: irrigation logs and FDA assessments

**Covered farms that directly apply pre-harvest water to covered produce other than sprouts need a written water assessment unless the exemption in 21 CFR 112.43(b) applies.** Sprouts and harvest/post-harvest water retain their separate requirements.

### Compliance dates

The compliance dates are April 7, 2025 for large farms, April 6, 2026 for small farms, and April 5, 2027 for very small farms. These dates concern the revised non-sprout pre-harvest provisions.

Under 21 CFR 112.43(a), the assessment is written at the beginning of the growing season, as appropriate, and at least annually. It concerns water applied directly to covered produce during growing activities. The assessment and determinations require supervisory review.

### What the assessment must evaluate

- The water system assessment includes the source's location and whether it is groundwater or surface water, open or closed distribution, and protection from contamination. Relevant hazards include animal activity, animal-origin soil amendments, and untreated or improperly treated human waste on nearby land.
- Water-use practices include the direct application method and the interval between the last direct application and harvest.
- Crop characteristics include susceptibility to contaminants adhering to the surface or entering the produce.
- Environmental conditions include heavy rain, extreme weather, air temperature and sun exposure.
- Other relevant factors include water-testing results when testing forms part of the assessment.

The exemption in section 112.43(b) has two conditions. The water must meet one of its specified routes: the applicable section 112.44(a) criteria and groundwater-testing requirements, the public-water requirements of section 112.44(c), or treatment under section 112.46. Its quality must also be reasonably likely to remain unchanged before use, including during storage and conveyance.

### Use the FDA form

The optional [Agricultural Water Assessment Builder](https://www.fda.gov/food/food-safety-modernization-act-fsma/agricultural-water-assessment-builder) offers an online tool and a June 2024 Version 2.0 paper tool. Enter farm identification in A-1–A-3, the water-source name in C-1 and the distribution-system name in D-1. In M-2, enter the interval between the last water application and harvest for each covered crop.

Information entered online is neither shared with FDA nor saved by the tool. Save or print the completed assessment locally. Using the builder does not constitute FDA approval.

### Outcomes and records

Unsafe water requires immediate discontinuation of the relevant use and corrective measures before resuming. Hazards related to specified nearby animal activity, animal-origin soil amendments or human waste require mitigation promptly, no later than the same growing season. For other hazards under section 112.43(c)(4), mitigate as soon as practicable and within one year, or test and take the applicable action.

Where no actionable hazard is identified under section 112.43(c)(3), regular inspection and maintenance still apply. Reassessment is annual and follows significant changes that increase the likelihood of contamination.

Keep inspection findings, written assessments and determinations, applicable analytical results, and records of corrective or mitigation actions. Additional records depend on the testing, treatment or mitigation route used.

## Nursery shipments and exports: phytosanitary certificates and PCIT

For nursery exports, start with [APHIS’s export certification specialist](https://www.aphis.usda.gov/plant-exports/certification) for your state. Have the plant commodity and destination ready before preparing the application. The authorized certification official, or ACO, helps with inspection and the PCIT application route.

### Establish the destination requirement

A phytosanitary certificate attests inspection, freedom from specified pests and conformity with the importing country’s plant-health regulations.

### Prepare PPQ Form 572

The current official PDF is **PPQ Form 572, APR 2020**, with OMB control **0579-0052** and printed expiry **03/2027**. Its instructions assign items 1–11 to the applicant and 12–17 to the officer. Submit the application electronically or by another authorized method.

Leave the export-inspection section to the officer. It contains location, material examined and infested, findings or treatment, officer signature and inspection date and time.

### Establish which destination instructions are official

Provide official destination requirements when they differ from the phytosanitary database. Use import permits, special authorizations or correspondence from the importing country’s National Plant Protection Organization as evidence.

Official communications must be translated into English, with bilingual documents acceptable where English is included. Arrange the translation through the exporter and keep it connected to the original. Ask the ACO to resolve an unfamiliar condition rather than interpreting a technical plant-health term solely through a commercial summary.

### Distinguish domestic export certification from reexport

For foreign-origin plants or products imported with a valid phytosanitary certificate, ask about reexport certification. It may rely on the original certificate, additional inspection or both. Protect the material from infestation during US storage.

### Arrange inspection before loading obstructs access

Make the commodity accessible for verification, sampling and inspection before loading. Inspection cannot occur onboard an aircraft or ship, or after bulk loading into a maritime container. Coordinate packing and loading with the ACO before access becomes obstructed.

Settle who supplies labor to open and close packages and the facilities needed for the official's work. Provide adequate facilities, equipment and lighting for inspection. Confirm the practical arrangement rather than leaving a visiting official to discover that the consignment cannot be reached or examined.

### Protect the identity of certified material

Safeguard certified shipments from infestation between sampling and shipping. Confirm any material-specific instructions with the ACO and keep the consignment identifiable until dispatch.

### Obtain the issued certificate through the accepted route

Apply and track the certification through PCIT with the ACO. Once issued, the certificate is available online to print. Request another delivery option if needed and confirm how it will reach the applicant and consignee.

## Next step

For an audit, start with the [Harmonized GAP service](https://www.ams.usda.gov/services/auditing/gap-ghp/harmonized). For a shipment, contact the export certification specialist before loading.


