Self Inspection
Question No.	Audit Question	Given Answer	Given Score	Possible Score	Recommendation	Auditor Comments	Audio/ Picture
01.01	Have Good Agricultural Practices (GAP) manuals covering each growing area within the scope of this audit (e.g., growing operation, orchard, vineyard) been developed and are they available for review?	Yes	5	5		Yes. A personalized GAP manual covering each growing area within the scope of this audit had been developed and available for review. GAP manual was indexed and easy to navigate.
01.02	Have documented Good Agricultural Practices (GAP)self-audits been completed for each growing area that is within the scope of this audit (e.g. growing operation, orchard, vineyard)?	Yes	7	7		Yes. A self inspection had been done on 1-18-2010 for each growing area within the scope of this audit.

Traceability
Question No.	Audit Question	Given Answer	Given Score	Possible Score	Recommendation	Auditor Comments	Audio/ Picture
02.01	Is the growing area(s) adequately identified or coded to enable trace back and trace forward in the event of a recall?	Yes	15	15		Yes. A detailed map with lot numbers assigned conducive to a trace back and trace forward in the event of a recall was available for review.

Ground History
Question No.	Audit Question	Given Answer	Given Score	Possible Score	Recommendation	Auditor Comments	Audio/ Picture
03.01	Were farming area(s) used for growing food crops for human consumption last season?	Yes	0	0		Yes. Records available and verbal confirmation Richard Breschini the growing area was used for growing food crops the previous season.
03.02	Has the growing area(s) been used for any non-agricultural functions? If No, go to 3.03	No	7	7		No. The growing area has not been used for any non-agricultural functions.
03.02a	If the land had been used previously for non-agricultural functions have soil tests been conducted showing soil was negative or within an appropriate regulatory agency's approved limits for contaminants?	N/A	0	0		N/A Refer to 03.02
03.03	Has the growing area(s) been used for animal husbandry or grazing land for animals? If No, go to 3.04	No	7	7		No. The growing area has not been used for animal husbandry.
03.03a	If the land was used previously for animal husbandry or grazing land for livestock, has a risk evaluation been performed?	N/A	0	0		N/A Refer to 03.03
03.04	Is there any evidence of animal activity in the crop that is a potential food safety risk?	No	20	20		No. No evidence of flooding since the previous season.
03.05	Has flooding from uncontrolled causes occurred on the growing area(s) since the previous growing season? If No, go to 3.06	No	0	0		No. Flooding had not occurred since the previous season.
03.05a	If the growing area(s) and product was affected from the flood waters, is there documented evidence that corrective measures were taken to affected land and product?	N/A	0	0		N/A Refer to 03.05
03.05b	Have soil tests been conducted on the flooded area(s) showing soil was negative or within an appropriate regulatory agency's approved limits for contaminants?	N/A	0	0		N/A Refer to 03.05
03.06	Is the growing operation under organic principles? If No , go to 3.07	No	0	0	Definition for "organic principles": A system that relies on ecosystem management rather than external agricultural inputs. http://www.fao.org/ORGANICAG/fram11-e.htm	No. The growing operation is not under organic principles.
03.06a	Is current certification by an accredited organic certification organization on file and available for review?	N/A	0	0		N/A Refer to 03.06
03.07	If the growing area(s) is a new purchase or lease, has a documented risk assessment been undertaken?	N/A	0	0		N/A Refer to 03.01

Adjacent Land Use
Question No.	Audit Question	Given Answer	Given Score	Possible Score	Recommendation	Auditor Comments	Audio/ Picture
04.01	Is the adjacent land to the growing area a possible source of contamination from intensive livestock production (e.g. feed lots, dairy operations, poultry houses, meat rendering operation)? If No, go to 4.02	No	10	10		No. The adjacent lands to the growing area are neighbors growing various food crops. No issues of potential cross contamination from intensive livestock production.
04.01a	Have appropriate measures been taken to mitigate this possible contamination source onto the growing area (e.g. buffer areas, physical barriers, fences, ditches, etc.)?	N/A	0	0		N/A Refer to 04.01
04.02	Are, or is there evidence of domestic animals, wild animals, grazing lands (includes homes with hobby farms, and non commercial livestock) in proximity to growing operation? If No, go to 4.03	Yes	0	10	Examples include chicken coops, dogs, horses, homes with hobby farms, wild pigs etc. Auditor must consider the maturity stage and type of crop involved. For example, pig activity around a ground level berry crop is different from a high level tree crop.	Yes. A hobby goat farm is located on south east corner of farming operation.
04.02a	Have physical measures been put in place to restrain domestic animals, grazing lands, (includes homes with hobby farms, and non commercial livestock) and their waste from entering the growing area (e.g. vegetative strips, wind breaks, physical barriers, berms, fences, diversion ditches.)?	Yes	15	15		Yes. Goats are restrained behind a fenced area. A drainage ditch surrounds the fenced area as a preventative measure for rain runoff into the growing area.
04.02b	Is there a written policy supported by visual evidence that domestic, livestock, or wild animals are not allowed in the growing area? Note: This includes any packaging or equipment storage areas.	Yes	10	10		Yes. GAP manual includes a policy not allowing animals of any kind in the growing and packaging areas.
04.02c	Are measures in place to reduce or limit the animal intrusion (i.e., monitoring field perimeter for signs of intrusion)?	Yes	15	15		Yes. Perimeters of fields are monitored daily by Grower and employees for evidence of animal intrusion. Verbal confirmation from Richard Breschini.
04.03	Are untreated animal manure piles, compost, biosolids, or nonsynthetic amendment stored and/or applied on adjacent land? If No, go to 4.04	No	10	10		No. There are no untreated manures or composts stored or applied on adjacent lands.
04.03a	Have physical measures been taken to secure untreated animal manure piles, compost, biosolids, or nonsynthetic amendment stored and/or applied on adjacent land?	N/A	0	0		N/A Refer to 04.03
04.03b	If biosolids are stored and/or applied on adjacent land, has the adjacent landowner supplied paperwork confirming the biosolids meet prevailing guidelines, governmental, or local standards?	N/A	0	0		N/A Refer to 04.03
04.04	Is the growing area situated in a higher risk location where contamination could occur from nearby operations or functions (e.g. leach fields, runoff or potential flooding from sewers, toilet systems, industrial facilities, labor camps)? If No, go to 4.05	No	10	10		No. The growing area is not situated in a high risk location. Refer to 04.01
04.04a	Have appropriate measures been taken to mitigate risks related to nearby operations?	N/A	0	0		N/A Refer to 04.04
04.05	Is there a documented and implemented policy that infant or toddler aged children are not allowed in the growing area? NOTE: This includes any packaging or equipment storage areas.	Yes	10	10		Yes. Documentation presented that infants and children are not allowed in the growing or packaging area.

Fertilizer/Crop Nutrition
Question No.	Audit Question	Given Answer	Given Score	Possible Score	Recommendation	Auditor Comments	Audio/ Picture
05.01	Is untreated human sewage sludge used in the growing cycle? If this question is answered Yes, automatic failure of this audit will result.	No	20	20		No. Untreated human sewage sludge is not used in the growing operation.
05.02	Is compost produced from animal derived materials used by the grower? If No, go to 5.03	No	0	0		No. Compost of any kind is not used in the growing operation.
05.02a	Are compost applications incorporated into the soil prior to planting or bud burst for tree crops and not applied during the growing season?	N/A	0	0		N/A Refer to 05.02
05.02b	Are there compost use records available for each growing area, including application records which shows that the interval between application and harvest was not less than 45 days?	N/A	0	0		N/A Refer to 05.02
05.02c	Are there Certificate(s) of Analysis (CoA) from the compost supplier(s) that covers pathogen and heavy metal testing (plus any other legally/best practice required testing) and does the grower have relevant letters of guarantee regarding SOP's and logs?	N/A	0	0		N/A Refer to 05.02
05.03	Are biosolids used? If No, go to 5.04. NOTE: Special attention to commodity specific guidelines rules (e.g., Californian Leafy Greens) which ban the use of biosolids, see 5.03d	No	0	0		No. Bio-solids are not used in the growing operation.
05.03a	Are biosolids incorporated into the soil prior to planting or bud burst for tree crops and not applied during the growing season?	N/A	0	0		N/A Refer to 05.03
05.03b	Are the grower's biosolids use records available for each growing area, especially application records?	N/A	0	0		N/A Refer to 05.03
05.03c	Are there a Certificate(s) of Analysis (COA) from the biosolid supplier(s) certifying compliance with prevailing national/ local standards and guidelines? If this question is answered No, automatic failure of this audit will result.	N/A	0	0		N/A Refer to 05.03
05.03d	Are biosolids being applied to crops where the country of production regulations/guidelines ban the use such materials e.g. Leafy Green Commodity Specific Guidelines in California? If this question is answered Yes, automatic failure of this audit will result.	N/A	0	0		N/A Refer to 05.03
05.04	Is untreated animal manure used? If No, go to 5.05. NOTE: Special attention to commodity specific guidelines rules (e.g., Californian Leafy Green Commodity Specific Guidelines) which ban the use of untreated animal manures. See 5.04d	No	15	15		No. Untreated animal manure is not used in the growing operation.
05.04a	Is untreated animal manure incorporated into the soil prior to planting or bud burst for tree crops and not applied during the growing season?	N/A	0	0		N/A Refer to 05.04
05.04b	Are there untreated animal manure records available for each growing area including application records which shows that the interval between application and harvest was not less than 120 days (unless more stringent laws or guidelines exist)?	N/A	0	0		N/A Refer to 05.04
05.04c	Are there Certificate(s) of Analysis (COA), specification or some other document available for review provided by the untreated animal manure supplier stating the components of the material?	N/A	0	0		N/A Refer to 05.04
05.04d	Are untreated animal manures being applied to crops where the country regulations/guidelines ban the use such materials (e.g., Californian Leafy Green Commodity Specific Guidelines)? If this question is answered Yes, automatic failure of this audit will result.	N/A	0	0		N/A Refer to 05.04
05.05	Are other nonsynthetic crop treatments used (e.g. compost teas, fish emulsions, fish meal, blood meal,"bio fertilizers")? If No, go to 5.06	No	0	0		No. Non-synthetic crop treatments are not used in the growing operation.
05.05a	Are nonsynthetic treatments that contain animal products or animal manures applied to the edible portions crops?	N/A	0	0		N/A Refer to 05.05
05.05b	Are nonsynthetic crop treatment records available for each growing area including application records demonstrating the interval between application and harvest was not less than 45 days?	N/A	0	0		N/A Refer to 05.05
05.05c	Are there Certificate(s) of Analysis available from the nonsynthetic crop treatment suppliers that covers pathogen and heavy metal testing (plus any other legally/best practice required testing)?	N/A	0	0		N/A Refer to 05.05
05.06	Are any soil amendments (except inorganic nutrients/fertilizers) used that do not contain animal products and/or animal manures? If No, go to 5.07	No	0	0		No. Soil amendments of any kind are not used in the growing operation.
05.06a	Are the grower's soil amendment (except inorganic nutrients/fertilizers that do not contain animal products and/or animal manures) records available for review including application records?	N/A	0	0		N/A Refer to 05.06
05.06b	Are there Certificate(s) of Analysis (COA) and/or letters of guarantee stating that the materials used are free from animal products and/or animal manures?	N/A	0	0		N/A Refer to 05.06
05.07	Are inorganic fertilizers used? If No, go to 5.08	Yes	0	0		Yes. Inorganic fertilizers are used in the growing operation. Calcium Ammonium Nitrate 17-0-0, Ammonium Nitrate 20-0-0, Urea Ammonium Nitrate 32-0-0 and a blended pre-plant 5-17-17 are used in the growing operation as side dress or water run applications.
05.07a	Are the grower's inorganic fertilizer records available for review including application records?	Yes	10	10		Yes. Richard Breschini provided fertilization histories for all fields. Dates, rates and method of application are recorded.
05.07b	Are there Certificate(s) of Analysis (COA), letters of guarantee or some other documents from the inorganic fertilizer supplier(s) that specifies the source of all the ingredients including inert materials?	No	0	7	Certificate(s) of Analysis (COA), letters of guarantee or other formal documentation from the fertilizer manufacturer's or supplier(s) should be current and state any inert or active ingredient substances used as "fillers" (e.g., clay pellets, granular limestone).	No. Labels of guaranteed analysis specifying the source of all ingredients were not available.
05.08	If fertilizers and/or fertilizer containers are stored on the property, are they stored in a manner to prevent contamination to the growing area(s) or any of water sources?	Yes	3	3		Yes. Portable fertilizer tanks installed at each well site. Tanks were properly labeled with no visible leaks or cracks observed that could contaminate the water source. NOTE: Tanks were filled with 32-0-0 and properly labeled.

Irrigation/Water Use
Question No.	Audit Question	Given Answer	Given Score	Possible Score	Recommendation	Auditor Comments	Audio/ Picture
06.01	Does the growing operation practice dryland farming? If No, go to 6.02.	No	0	0	This refers to crop production that relies only on direct rainfall.	No. The growing operation does not practice dry-land farming.
06.01a	If the growing operation practices dryland farming, are there water systems used in the growing operation to supply for crop needs such as crop protection/fertilizer applications, and frost or freeze prevention program? If No, go to 6.02	N/A	0	0		N/A Refer to 06.01
06.01b	Are microbiological tests, including Generic E.coli conducted on water used for crop protection/fertilizer applications, and frost or freeze prevention program? If No, go to 6.01d.	N/A	0	0		N/A Refer to 06.01
06.01c	Are the microbiological tests current and conducted at the required and/or expected frequencies?	N/A	0	0		N/A Refer to 06.01
06.01d	Do written procedures (SOPs) exist covering proper sampling protocols which include how samples should be identified?	N/A	0	0		N/A Refer to 06.01
06.01e	Do written procedures (SOPs) exist covering corrective measures for unsuitable or abnormal water testing results?	N/A	0	0		N/A Refer to 06.01
06.01f	If unsuitable or abnormal results have been detected, have documented corrective measures been performed?	N/A	0	0		N/A Refer to 06.01
06.02	Is the water used for the growing operation sourced from Municipal or District water pipeline systems? If No, go to 6.03	No	0	0	(No recommendation)	No. Water is not used from Municipal or District water pipeline systems.
06.02a	Are microbiological tests, including Generic E.coli conducted on water used for crop protection/fertilizer applications, and frost or freeze prevention program? If No, go to 6.02c.	N/A	0	0		N/A Refer to 06.02
06.02b	Are the microbiological tests current and conducted at the required and/or expected frequencies?	N/A	0	0		N/A Refer to 06.02
06.02c	Do written procedures (SOPs) exist covering proper sampling protocols?	N/A	0	0		N/A Refer to 06.02
06.02d	Do written procedures (SOPs) exist covering corrective measures for unsuitable or abnormal water testing results?	N/A	0	0		N/A Refer to 06.02
06.02e	If unsuitable or abnormal results have been detected, have documented corrective measures been performed?	N/A	0	0		N/A Refer to 06.02
06.02f	Are the crops irrigated by a micro irrigation or drip system?	N/A	0	0		N/A Refer to 06.02
06.02g	Is overhead irrigation used to irrigate the crop or as part of a frost or freeze prevention program? NOTE: "Irrigating the crop" refers to irrigation during the mature growing cycle. This does not include pre-planting or just after planting to create a stand.	N/A	0	0		N/A Refer to 06.02
06.02h	Are the crops irrigated by flood irrigation or a furrow system?	N/A	0	0		N/A Refer to 06.02
06.02i	Are the crops sub irrigated (also known as seepage irrigation)?	N/A	0	0		N/A Refer to 06.02
06.03	Is the water used in the growing operation sourced from wells? If No, go to 6.04	Yes	0	0		Yes. Water is used from wells located on the farm site.
06.03a	Are all well heads an adequate distance from untreated manure?	Yes	15	15		Yes. There were no untreated manure piles in proximity to the well heads. NOTE: Manure is not used or stored on adjacent properties.
06.03b	Is the well designed to prevent contamination?	Yes	10	10		Yes. Well casing was completely sealed.
06.03c	Is it evident that the well(s) is free from contamination issues and are measures taken to minimize contamination of wells?	Yes	10	10		Yes. Area around well was clean and lubricating shaft oil is not stored at the well site.
06.03d	Are records kept for periodic inspections and treatment of wells (if performed) available for review?	Yes	7	7		Yes. Wells are examined before each use. A sanitary condition inspection checklist is filled out monthly for each well.
06.03e	Are microbiological tests, including Generic E.coli conducted on water used for irrigation, crop protection/fertilizer applications, and frost or freeze prevention program? If No, go to 6.03g	Yes	20	20		Yes.
06.03f	Are the microbiological tests current and conducted at the required and/or expected frequencies?	Yes	15	15		Yes. Testing under Leafy Greens Marketing Agreement (LGMA) guidelines on a monthly basis for Generic E-Coli. Last test results available for 5-12-2010. No issues were detected.
06.03g	Do written procedures (SOPs) exist covering proper sampling protocols?	Yes	10	10		Yes. Using the LGMA standards for water sampling protocols. Policy and procedures were on file.
06.03h	Do written procedures (SOPs) exist covering corrective measures for unsuitable or abnormal water testing results?	Yes	10	10		Yes. Using the LGMA standards for corrective measures for unsuitable water test results. Policy and procedures were included in GAP manual.
06.03i	If unsuitable or abnormal results have been detected, have documented corrective measures been performed?	N/A	0	0		N/A There have been no unsuitable or abnormal water results detected.
06.03j	Are the crops irrigated by a micro irrigation or drip system?	Yes	0	0		Yes. A drip irrigation system is used in the growing operation.
06.03k	Is overhead irrigation used to irrigate the crop or as part of a frost or freeze prevention program? NOTE: "Irrigating the crop" refers to irrigation during the mature growing cycle. This does not include pre-planting or just after planting to create a stand.	Yes	0	0	Information gathering question. Reducing contact with edible portion of the crop is believed to reduces microbial risk.	Yes. Overhead irrigation is used during the mature growing cycle.
06.03l	Are the crops irrigated by flood irrigation or a furrow system?	Yes	0	0	Information gathering question. Reducing contact with edible portion of the crop is believed to reduces microbial risk.	Yes. Crops are furrow irrigated.
06.03m	Are the crops sub irrigated (also known as seepage irrigation)?	No	0	0	Information gathering question. Reducing contact with edible portion of the crop is believed to reduces microbial risk.	No. Crops are not sub irrigated.
06.04	Is the water used in the growing operation sourced from ponds, reservoirs, watersheds or other surface water source? If No, go to 6.05	No	0	0		No. Water is not used from surface water sources such as reservoirs and ponds.
06.04a	Is surface water in adequate distance from untreated manure?	N/A	0	0		N/A Refer to 06.04
06.04b	Do animals (domestic, livestock, or wild) have access to the water source?	N/A	0	0		N/A Refer to 06.04
06.04c	Is it evident that the water source is free of contamination issues and are measures taken to minimize contamination of the water source?	N/A	0	0		N/A Refer to 06.04
06.04d	Are records kept for the periodic visual inspections and disinfection treatments (if used) available for review?	N/A	0	0		N/A Refer to 06.04
06.04e	Are microbiological tests, including Generic E.coli conducted on water used for irrigation, crop protection/fertilizer applications, and frost or freeze prevention program? If No, go to 6.04g	N/A	0	0		N/A Refer to 06.04
06.04f	Are the microbiological tests current and conducted at the required and/or expected frequencies?	N/A	0	0		N/A Refer to 06.04
06.04g	Do written procedures (SOPs) exist covering proper sampling protocols?	N/A	0	0		N/A Refer to 06.04
06.04h	Do written procedures (SOPs) exist covering corrective measures for unsuitable or abnormal water testing results?	N/A	0	0		N/A Refer to 06.04
06.04i	If unsuitable or abnormal results have been detected, have documented corrective measures been performed?	N/A	0	0		N/A Refer to 06.04
06.04j	Are the crops irrigated by a micro irrigation or drip system?	N/A	0	0		N/A Refer to 06.04
06.04k	Is overhead irrigation used to irrigate the crop or as part of a frost or freeze prevention program? NOTE: "Irrigating the crop" refers to irrigation during the mature growing cycle. This does not include pre-planting or just after planting to create a stand.	N/A	0	0		N/A Refer to 06.04
06.04l	Are the crops irrigated by flood irrigation or a furrow system?	N/A	0	0		N/A Refer to 06.04
06.04m	Are the crops sub irrigated (also known as seepage irrigation)?	N/A	0	0		N/A Refer to 06.04
06.05	Is the water used in the growing operation sourced from canals, rivers, ditches, or other open flowing water systems? If No, go to 6.06	No	0	0		No. Water is not used from an open flowing water system.
06.05a	Is surface water in adequate distance from untreated manure?	Yes	15	15		N/A Refer to 06.05
06.05b	Is the water source under the direction of a water authority or district?	N/A	0	0		N/A Refer to 06.05
06.05c	Do animals (domestic, livestock, or wild) have access to the water source?	N/A	0	0		N/A Refer to 06.05
06.05d	Is it evident that the water source is free of contamination issues and are measures taken to minimize contamination of the water source?	N/A	0	0		N/A Refer to 06.05
06.05e	Are records kept for periodic visual inspection and disinfection (if occurring) of the water source and available for review?	N/A	0	0		N/A Refer to 06.05
06.05f	Are microbial tests, including Generic E.coli conducted on water used for irrigation, crop protection/fertilizer applications, and frost or freeze prevention program? If No, go to 6.05h	Yes	20	20		N/A Refer to 06.05
06.05g	Are the microbiological tests current and conducted at the required and/or expected frequencies?	N/A	0	0		N/A Refer to 06.05.
06.05h	Do written procedures (SOPs) exist covering proper sampling protocols?	N/A	0	0		N/A Refer to 06.05
06.05i	Do written procedures (SOPs) exist covering corrective measures for unsuitable or abnormal water testing results?	Yes	10	10		N/A Refer to 06.05
06.05j	If unsuitable or abnormal results have been detected, have documented corrective measures been performed?	N/A	0	0		N/A Refer to 06.05
06.05k	Are the crops irrigated by a micro irrigation or drip system?	N/A	0	0		N/A Refer to 06.05
06.05l	Is overhead irrigation used to irrigate the crop or as part of a frost or freeze prevention program? NOTE: "Irrigating the crop" refers to irrigation during the mature growing cycle. This does not include pre-planting or just after planting to create a stand.	N/A	0	0		N/A Refer to 06.05
06.05m	Are the crops irrigated by flood irrigation or furrow system?	N/A	0	0		N/A Refer to 06.05
06.05n	Are the crops sub irrigated (also known as seepage irrigation)?	N/A	0	0		N/A Refer to 06.05.
06.06	Is reclaimed water used in the growing operation? NOTE: This refers to wastewater that has gone through a treatment process. If No, go to 6.07.	No	0	0		No. Reclaimed water is not used in the growing operation.
06.06a	Is the reclamation process under the direction of a water reclamation management or authority?	N/A	0	0		N/A Refer to 06.06
06.06b	Are microbial control measures for reclaimed water utilized?	N/A	0	0		N/A Refer to 06.06
06.06c	Are microbial tests, including Generic E.coli conducted on water used for irrigation, crop protection/fertilizer applications, and frost or freeze prevention program? If No, go to 6.06e	N/A	0	0		N/A Refer to 06.06
06.06d	Are the microbiological tests current and conducted at the required and/or expected frequencies?	N/A	0	0		N/A Refer to 06.06
06.06e	Do written procedures (SOPs) exist covering proper sampling protocols?	N/A	0	0		N/A Refer to 06.06
06.06f	Do written procedures (SOPs) exist covering corrective measures for unsuitable or abnormal water testing results?	N/A	0	0		N/A Refer to 06.06
06.06g	If unsuitable or abnormal results have been detected, have documented corrective measures been performed?	N/A	0	0		N/A Refer to 06.06
06.06h	Are the crops irrigated by a micro irrigation or drip system?	N/A	0	0		N/A Refer to 06.06
06.06i	Is overhead irrigation used to irrigate the crop or as part of a frost or freeze prevention program? NOTE: "Irrigating the crop" refers to irrigation during the mature growing cycle. This does not include pre-planting or just after planting to create a stand.	N/A	0	0		N/A Refer to 06.06
06.06j	Are the crops irrigated by flood irrigation or a furrow system?	N/A	0	0		N/A Refer to 06.06
06.06k	Are the crops sub irrigated (also known as seepage irrigation)?	N/A	0	0		N/A Refer to 06.06
06.07	Are tail water (run off water) systems used in the growing operation? If No, go to 6.08.	No	0	0		No. Tail water systems are not used in the growing operation.
06.07a	Is tail water in adequate distance from untreated manure?	N/A	0	0		N/A Refer to 06.07
06.07b	Do animals (domestic, livestock, or wild) have access to the tail water systems?	N/A	0	0		N/A Refer to 06.07
06.07c	Is it evident that the water source is free of contamination issues and are measures taken to minimize contamination of the tail water system?	N/A	0	0		N/A Refer to 06.07
06.07d	Are records kept for periodic visual inspection and disinfection (if occurring) of the water source and available for review?	N/A	0	0		N/A Refer to 06.07
06.07e	Are microbial tests conducted, including Generic E.coli on water used for irrigation, crop protection/fertilizer applications, and frost or freeze prevention program? If No, go to 6.07g	N/A	0	0		N/A Refer to 06.07
06.07f	Are the microbiological tests current and conducted at the required and/or expected frequencies?	N/A	0	0		N/A Refer to 06.07
06.07g	Do written procedures (SOPs) exist covering proper sampling protocols?	N/A	0	0		N/A Refer to 06.07
06.07h	Do written procedures (SOPs) exist covering corrective measures for unsuitable or abnormal water testing results?	N/A	0	0		N/A Refer to 06.07
06.07i	If unsuitable or abnormal results have been detected, have documented corrective measures been performed?	N/A	0	0		N/A Refer to 06.07
06.07j	Are the crops irrigated by a micro irrigation or drip system?	N/A	0	0		N/A Refer to 06.07
06.07k	Is overhead irrigation used to irrigate the crop or as part of a frost or freeze prevention program? NOTE: "Irrigating the crop" refers to irrigation during the mature growing cycle. This does not include pre-planting or just after planting to create a stand.	N/A	0	0		N/A Refer to 06.07
06.07l	Are the crops irrigated by flood irrigation or furrow system?	N/A	0	0		N/A Refer to 06.07
06.07m	Are the crops sub irrigated (also known as seepage irrigation)?	N/A	0	0		N/A Refer to 06.07
06.08	Are check valves, anti-siphon devices, or other back flow prevention systems in use when and where necessary?	Yes	10	10		Yes. Anti-siphon devices are installed at well sites.
06.09	Is irrigation equipment not in use free from pest contamination and stored clean off the ground?	Yes	10	10		Yes. Portable irrigation equipment was stored on pipe trailers and off the ground.

Crop Protection
Question No.	Audit Question	Given Answer	Given Score	Possible Score	Recommendation	Auditor Comments	Audio/ Picture
07.01	Is there a documented policy and/or procedures for the mixing/loading of crop protection materials?	Yes	5	5		Yes. Documentation and procedures provided by the applicators Wilbur Ellis and Green Valley for the mixing/loading of crop chemicals and were in good order. Qualified Applicator Licenses on file.
07.01a	Is mixing, loading, or the dilution of crop protection materials performed safely and within a distance where the growing area and water sources are not affected?	N/A	0	0		N/A This activity was not observed the day of the farm audit tour.
07.02	Is there a documented policy and/or procedures for the rinsing and cleaning of crop protection equipment?	Yes	5	5		Yes. Documentation and procedures provided by the applicators Wilbur Ellis Co. and Green Valley Co-Op for the rinsing and cleaning of application equipment and were in good order. Qualified Applicator Licenses on file in GAP manual.
07.02a	Is rinsing and cleaning of crop protection equipment performed safely and within a distance where land and water sources are not affected?	N/A	0	0		N/A This activity was not observed the day of the farm audit tour.
07.03	Is there documentation that shows the individual(s) making decisions for crop protection are qualified?	Yes	10	10		Yes. Mike Middaugh is a licensed California Pest Control Adviser (PCA) responsible for making all crop protection decisions. License # 71264 Expiration 12-31-2010.
07.04	Is there documentation that shows employees who handle crop protection materials are trained or are under the supervision of a trained individual?	N/A	0	0		N/A Farm employees do not handle crop protection chemicals. Contracted Commercial Applicators are responsible for the training and supervision of their employees. Training Procedures were on file. Qualified Applicator licenses and training certificates on file and included in GAP manual.
07.05	Does the growing operation follow a pesticide application recording program? If No, go to 7.06 If this question is answered No, automatic failure of this audit will result.	Yes	20	20		Yes. Monterey County Agriultural Chemical monthly use reports were on file.
07.05a	Are crop protection application records up to date and available for review?	Yes	15	15		Yes. Grower had all application records and crop histories on file. NOTE: PCA maintains a data record keeping of all applications and are available upon demand from internet computer data management system. (CDMS).
07.06	Are crop protection materials registered in the country of use for the target crop where official registration is in place? If this question is answered Yes, skip to question 7.07. If no official registration system is utilized answer this question N/A and go to 7.06a. Where a system exists, but a crop protection chemical being used is not registered for the target crop either "in country" or by extrapolation (see 7.06a), the response to this question is No. If this question is answered No, automatic failure of this audit will result.	Yes	20	20		Yes. US EPA Registration numbers are listed on Monthly use reports and PCA recommendation forms.
07.06a	Does the country of production allow the use of crop protection materials that are registered for the target crop in another country, as long as the use of this material does not contravene any prevailing national and local laws in the destination country (e.g. maximum residue limit, banned lists, etc.)? If this question is answered No, automatic failure of this audit will result.	N/A	0	0		N/A Refer to 07.06
07.07	Are crop protection applications restricted by the guidelines established by the product label, manufacturer recommendation, or by prevailing national/ local standards and guidelines? If this question is answered No, automatic failure of this audit will result.	Yes	20	20		Yes. Crop protection applications are restricted by guidelines established by the product manufacture.
07.08	Where harvesting is restricted by pre-harvest intervals (as required on the crop protection chemical product labels, manufacturer recommendations and/or by prevailing national/ local standards) is the grower adhering to these pre-harvest interval time periods? If this question is answered No, automatic failure of this audit will result.	Yes	20	20		Yes. Pre-harvest interval restrictions are established by the product manufacture and listed on the label. PCA notes pre-harvest interval restriction on notice of intent (NOI) to apply chemicals and provides NOI to Grower prior to application.
07.09	Are employee re-entry intervals established as required by the pesticide label, manufacturer recommendation, or by prevailing national/ local standards and guidelines?	Yes	10	10		Yes. Employee re-entry intervals are established by the manufacture and listed on the product label.
07.10	When crop protection applications occur, does posting take place on area of treatment according to prevailing national/ local standards and guidelines?	Yes	10	10		N/A This activity was not observed the day of the farm audit tour.
07.11	To avoid drift, are crop protection applications restricted when gusts are excessive?	N/A	0	0		N/A This activity was not observed the day of the farm audit tour.
07.12	If crop protection containers are stored on the property (even temporarily), are they stored in a manner to prevent contamination and disposed of responsibly?	N/A	0	0		N/A Crop chemicals are not stored at this farm site.
07.13	Have documented policies and/or procedures been developed for the monitoring of crop protection application equipment (e.g. calibration procedures, inspections, replacement)?	Yes	10	10		Yes. Documentation and procedures provided by the applicators for the monitoring and calibration of crop protection application equipment and were in good order.
07.13a	Is it evident that the equipment used for crop protection applications is in good working order?	N/A	0	0		N/A There were no crop protection equipment present to inspect the day of the farm audit tour.

Employee Hygiene (This applies to on-the-farm staff not the harvesting staff)
Question No.	Audit Question	Given Answer	Given Score	Possible Score	Recommendation	Auditor Comments	Audio/ Picture
08.01	Does the growing operation have a documented and implemented policy for dealing with employees who appear to be physically ill, or become ill while working?	Yes	10	10		Yes. A documented policy dealing with employees who become ill while working was provided and included in GAP manual.
08.02	Does the growing operation have a documented and implemented policy regarding employees with open sores and wounds?	Yes	10	10		Yes. A documented policy regarding employees with open wounds and sores was provided and included in GAP manual.
08.03	Does the growing operation have a documented and implemented procedure in place requiring for all commodities that come in contact with blood to be destroyed? If this question is answered No, automatic failure of this audit will result.	Yes	20	20		Yes. A documented policy requiring all commodities that come in contact with blood are to be destroyed, presented and included in GAP manual.
08.04	Does the growing operation have documented and implemented policies prohibiting eating, drinking (including gum chewing) using tobacco in the growing area?	Yes	10	10		Yes. A documented policy not allowing the use of tobacco and eating in the growing area presented and included in GAP manual.
08.05	Is there a food safety hygiene training program covering new and existing employees and are there records of these training events?	Yes	15	15		Yes. Food safety hygiene program along with training records and attendance sheets presented and in good order.
08.06	Are there operational toilet facilities provided? If NO, go to 8.07. If this question is answered No, the audit will result in an automatic failure.	Yes	20	20		Yes. Portable toilets are provided by A & G Pumping Services. Their SSOP was on file and included in GAP manual.
08.06a	Are the toilet facilities placed within ¼ mile or 5 minutes walking distance of all employees?	Yes	10	10		Yes.
08.06b	Are toilet facilities in a suitable location to prevent contamination to the growing area?	Yes	15	15		Yes
08.06c	Is a minimum of one toilet facility provided for each group of 20 employees?	Yes	5	5		Yes
08.06d	Do toilet facilities have visuals or signs, written in the appropriate languages, reminding employees to wash their hands before returning to work?	Yes	2	2		Yes. Signage in English and Spanish were posted.
08.06e	Are the toilets maintained in a clean and sanitary condition and are there records showing toilet cleaning, servicing and stocking is occurring regularly?	Yes	10	10		Yes
08.06f	Are the catch basins of the toilets designed and maintained to prevent contamination in the field (e.g. free from leaks and cracks)?	N/A	0	0		N/A Refer to 08.06
08.06g	Is there is a documented and implemented procedure for emptying the catch basin in a hygienic manner and also in a way that prevent product, packaging, equipment and water system contamination?	Yes	5	5		Yes. Refer to 08.06
08.07	Is there evidence of fecal contamination in proximity to the growing area or any storage areas? (This refer to a single account of human or domestic animal fecal matter and/or systematic discoveries of wild animal manure) If this question is answered Yes, automatic failure of this audit will result.	No	20	20		No. There was no evidence of fecal contamination in proximity to the growing or storage areas.
08.08	Are there operational hand washing facilities provided? If No, go to 8.09	Yes	15	15		Yes. Operational hand wash stations are an integral part of portable toilet facilities.
08.08a	Are the hand washing facilities placed within ¼ mile or 5 minutes walking distance of all employees?	Yes	10	10		Yes
08.08b	Are hand wash stations clearly visible (e.g. situated outside the toilet facility) and easily accessible to workers?	Yes	0	0		Yes
08.08c	Are hand wash stations properly stocked with soap, paper towels and trash can?	Yes	5	5		Yes
08.08d	Are the hand wash stations designed and being maintained to prevent contamination onto the growing area ( i.e. spent water does not go straight to the ground)?	Yes	5	5		Yes
08.08e	Does the growing operation have a documented and implemented policy and procedure in place requiring employees to wash their hands (e.g. prior to beginning work, after breaks, after toilet use)?	Yes	10	10		Yes
08.09	Is fresh potable drinking water provided for workers? If No, go to 8.10	Yes	10	10		Yes. Potable drinking water is available to workers. NOTE: Workers bring bottled water or use company provided coolers.
08.09a	If used, are water containers maintained in a clean condition?	N/A	0	0		N/A Water containers were not observed. Only bottled water was available.
08.10	Are first-aid kits available and is the inventory maintained properly?	Yes	5	5		Yes.
08.11	Are there trash cans available on the farm placed in suitable locations?	Yes	5	5		Yes. Trash cans available at equipment yards and next to portable toilet facilities.
08.12	Are there any foreign material issues observed that are or could be potential risks to the product in the growing area (e.g jewelry)?	No	5	5		No. There was no evidence of foreign materials in the growing areas.

Food Security
Question No.	Audit Question	Given Answer	Given Score	Possible Score	Recommendation	Auditor Comments	Audio/ Picture
09.01	Are measures taken to control vehicle access to the growing area? (specified access roads, furrows, etc)?	Yes	5	5		Yes. Specified access roads.
09.02	Are postings such as "No Trespassing" and/or " Restricted Entry" used appropriately?	No	0	5	http://www.usda.gov/documents/PreHarvestSecurity_final.pdf	No. Signs are not posted at all entrances.
09.03	Are entrances to ranch-level roads restricted by gates, chains, guard stations, etc.?	No	0	5	http://www.usda.gov/documents/PreHarvestSecurity_final.pdf	No. Gates or chains are not used.
09.04	Are wells or other water sources secured and designed to prohibit tampering?	No	0	5	http://www.usda.gov/documents/PreHarvestSecurity_final.pdf	No. Wells are not surrounded with continuous fencing.
09.05	Are grounds and facilities monitored by either in house or contracted personnel?	Yes	5	5		Yes. Grower and foreman monitor farm sites and equipment yards. Verbal confirmation from Richard Breschini.
09.06	Are staff members instructed to note and report suspicious activity?	Yes	5	5		Yes
09.07	Are high risk areas (e.g. spray equipment, equipment shops, sheds) monitored?	Yes	5	5		Yes. High risks areas monitored by grower and foreman. Verbal confirmation from Richard Breschini.
09.08	Is equipment examined for tampering prior to use?	Yes	5	5		Yes
09.09	Are company supervisors required to undergo documented security training with attendance records?	Yes	5	5		Yes. Training records and attendance sheets presented for security events.
09.10	Is education material related to security made available?	Yes	5	5		Yes. Food security education material provided by Monterey County Agricultural commissioner's office in English and Spanish and available to employees.
09.11	Are inventory records of agricultural chemicals maintained? If No, go to 9.12	N/A	0	0		N/A Chemicals are not stored at this farm site.
09.11a	Are the inventory records periodically reconciled with inventory?	N/A	0	0		N/A Refer to 09.11
09.12	Are all personal materials kept away from the harvest and packaging of the harvesting operation?	Yes	5	5		Yes.

PrimusLabs Audit (124518) Ranch V07.04 Rev. 1
Customer(s)	Breschini & Sons Contact:. . Address: 38305 Elm Ave. Greenfield California 93927 United States Phone Number: . Fax Number: 831-674-0836 Email(s):.
Grower(s)	Breschini & Sons Contact:Richard Breschini Address: 1245 Walker Drive Salinas California 93960 United States Phone Number: 831-320-9350 Email(s):julio@andrewsmithco.com
Ranch(s)	Toroni Ranch (Breschini & Sons) Soledad California United States
Audit Type:	Farm/Ranch
Foreman or Contact Person (and email):	Richard Breschini (breschini&sons@aol.com)
Location/City:	Soledad
State:	California
Country:	United States
Date Audit Started:	06/07/2010 08:30
Date Audit Finished:	06/07/2010 10:30
Commodity(ies):	Butter Lettuce (Butterhead), Romaine Lettuce, Beans, Onions, Broccoli, Lettuce, Lettuce, Lettuce, Celery, Cauliflower
Auditor:	Andy Alonzo (Sub-Contract Auditors)
Audit Percentage Score:	98%
Announced Audit?	Yes
Audit Scope:	A third party audit inspection of a vegetable farm operation growing various varieties of vegetable crops. Audit scope includes a visual survey of water sources, equipment, storage, fertilization, pest management, adjacent lands and review of required food safety files.
Audit Entered By:	Andy Alonzo
Other Auditing Personnel And Role:	N/A

Audit Scoring Summary
	Self Inspection	Score	12
		Possible Points	12
		Percent Score	100%
	Traceability	Score	15
		Possible Points	15
		Percent Score	100%
	Ground History	Score	34
		Possible Points	34
		Percent Score	100%
	Adjacent Land Use	Score	80
		Possible Points	90
		Percent Score	89%
	Fertilizer/Crop Nutrition	Score	48
		Possible Points	55
		Percent Score	87%
	Irrigation/Water Use	Score	162
		Possible Points	162
		Percent Score	100%
	Crop Protection	Score	145
		Possible Points	145
		Percent Score	100%
	Employee Hygiene (This applies to on-the-farm staff not the harvesting staff)	Score	222
		Possible Points	222
		Percent Score	100%
	Total	Score	718
		Possible Points	735
		Percent Score	98%