Consolidates the GAP audit scope (water source, worker hygiene, harvest/post-harvest handling, traceability) and the HACCP plan components (hazard analysis, CCP identification for microgreens production, monitoring + verification + recordkeeping) that VDACS requires before issuing a Food Processing Plant License. This page is the gate that must close before SCBGP-style grocery-chain applications move forward — see SCBGP Outline & SCBGP 2027 Skeleton for the downstream narrative branch.
Pre-audit scratchpad. GAP + HACCP currently Not Started. The wholesale-channel revenue path is blocked until both clear VDACS review (~60–90 day clock on Food Processing Plant License).
The GAP audit pre-condition for any processing facility is a documented potable water source. For IronRoost's microgreens line that means either a municipal supply letter from the local utility or a drilled well with an annual potability certificate on file. The Virginia Department of Health (VDH) Office of Drinking Water is the issuing body — their letter goes into the GAP binder before the VDACS Food Processing Plant License filing because VDACS will not accept the application without it.
Five documents go into the GAP binder under the water-source umbrella: (1) the VDH letter on a public-water-supply letterhead (or the well-driller's completion report + most-recent potability certificate for a drilled source); (2) treatment system documentation if any in-line filtration, chlorination, or UV is installed between source and processing line; (3) a sample-collection SOP naming the sample point, the sample volume, the cadence, the lab, and the chain-of-custody form; (4) a water-system schematic showing every pipe, valve, and fixture between source and the most-distant processing tap (this is what the GAP auditor physically walks); (5) the current year's annual potability certificate from a state-certified lab.
The 5 water-source documents above also feed the Hydroponics Launch Readiness page's GAP prerequisite row block. Tracking both documents in the same binder prevents the audit-team rebuild that happens when two binders disagree on which lab ran which sample.
GAP audits score worker-hygiene SOPs against the FDA Food Code (Chapter 2 — Employee Health and Hygiene). The pass criteria are: signed handwashing SOP, single-use towel policy, glove-use policy, jewelry/nail-polish exclusion language, illness-reporting policy aligned with Food Code 2-201, visitor policy, and signed training logs for every worker who enters the processing line. Supervisor verification — a separate log signed by a designated shift lead — is the layer the auditor checks for evidence of actual practice, not just posted signage.
The handwash SOP must specify warm water (≥100°F), soap, 20-second scrub, and single-use towels — auditor checks the posted sign matches the trained procedure. Gloves policy states single-use, no reuse, change between tasks. Jewelry and nail polish are excluded in writing. The illness-reporting policy names the five Food Code 2-201 reportable conditions (norovirus, Salmonella, Shigella, E. coli O157:H7, hepatitis A) and the return-to-work rule. Training logs are signed annually by every worker; supervisor verification log is signed weekly by a designated lead.
Worker training records are the single most common GAP-audit failure mode. Incomplete or unsigned training logs are an automatic Conditional Pass — the auditor scores it as "evidence of practice not demonstrated." A posted handwash sign that no one can recall the date they last trained against is decoration; a dated, signed training log tied to a specific worker is documentation. IronRoost's training log cadence is annual for each worker plus a weekly supervisor verification sweep.
The microgreens-specific harvest zone is where GAP audits break. Five things must be in writing and demonstrated: (1) harvest SOP specifying cut height and sanitized-blade cadence; (2) a pre-cool window of ≤30 minutes from cut to ≤41°F; (3) a wash-and-dry step using chlorinated wash water at 50–100 ppm free chlorine with an ORP probe at the tank return; (4) a pack-and-label SOP putting a lot ID (date code + bench/run identifier) on every clamshell; and (5) a cold-chain dispatch with a cloud-connected temperature logger that alarms on excursion. These are the most common GAP audit findings when missing or undocumented.
The harvest SOP specifies cut height at the cotyledon-to-first-true-leaf transition, a sanitized blade cadence (replace or sanitize every 30 minutes minimum; record on the harvest log), and single-use glove handling. Pre-cool — cut product enters the cooler within 30 minutes and reaches ≤41°F inside the next 30 minutes. Wash tank is chlorinated to 50–100 ppm free chlorine with an ORP probe at the return line (target ORP ≥650 mV). Pack-and-label is on a clean, sanitized packaging surface with the clamshell lot ID printed/applied at the pack step. Cold-chain dispatch uses a cloud temp logger that pages on any >41°F excursion.
An unbroken cold chain is the single most-likely-to-fail control point during a microgreens GAP audit. The auditor physically inspects the cloud temp logger, asks for the alarm-on-excursion log, and verifies that corrective action was taken on every flagged dispatch. Cloud temp logger procurement is already noted in Hydroponics Launch Readiness Section 1.5; this checklist is the enduring documentation tie-in.
The cold-chain integrity story is strengthened by evidence a buyer already asked for it. The RRS Foodservice Buyer Outreach correspondence file is the standing example of a buyer-side request for cold-chain documentation; that request becomes supporting evidence in the GAP/HACCP narrative.
GAP traceability audits score against a lot-ID scheme that can trace any packaged unit back to a harvest lot and forward to whoever received it. The one-step-forward / one-step-back standard means: from any clamshell you can identify the grower batch, the pack lot, the dispatch record, and the receiving buyer — and from any buyer record you can identify which lots they received. The recall plan is the rehearsed response to a triggered trace: a mock-recall cadence of at least one per year, with trace-record retention ≥2 years.
The lot-ID scheme is date code + bench/run identifier printed on every clamshell (e.g., 260815-B3 = 2026-08-15, bench 3, run A). The forward trace log records grower batch → pack lot → dispatch → buyer for every shipment. The back trace log inverts that direction and indexes the buyer list by every lot they ever received. The recall SOP names the contact tree (Jean-Pierre → regulator → buyer → consumer-comms) and the response window target (≤24 hours from trigger to buyer notification). Mock-recall cadence is annual minimum; trace-record retention is ≥2 years per GAP standard.
A piece of paper that records every shipment beats a piece of software that nobody reads. The mock-recall is the test — if the recall team cannot pull the affected lot list from the records in under an hour, the system fails the audit even if every other component is excellent. Choose: paper log first, software second, only if paper log is sustained for ≥1 year.
The HACCP plan opens with a hazard analysis worksheet structured around FDA's seven HACCP principles: (1) preliminary steps (product description, process flow, intended use); (2) hazard analysis (biological, chemical, physical); (3) CCP identification; (4) critical limits; (5) monitoring procedures; (6) corrective actions; (7) verification + recordkeeping. The three hazard categories below are the inventories that feed the HACCP decision tree — if a hazard is not on this list, the resulting CCP audit will surface the gap.
The hazard analysis worksheet lists every plausible hazard in every process step, scores each on likelihood × severity, and identifies which become CCPs. The three categories below are the floor of the worksheet; the resulting CCP list (Section 6) flows out of the worksheet's "yes" rows. Use the cards below as the starting inventory and re-score against the actual process flow when it is finalized.
Salmonella, Listeria monocytogenes, E. coli O157:H7 are the three reference pathogens for fresh-cut leafy greens and microgreens. Source pathways: contaminated seed, contaminated water source, worker-to-product transfer, environmental carryover from a prior batch. Seed-surface treatment (calcium hypochlorite or equivalent) and source-water potability are the two highest-leverage prevention controls.
Decision-tree output: wash-tank CCP (Section 6, CCP 1) + worker-hygiene SOP (Section 2) reduce residual risk; CCPs become load-bearing for the residual > acceptable level.
Cleaning-residue chlorine residue above 100 ppm on finished product (allergen + off-flavor risk); sanitizer concentration drift in the wash tank (sub-50 ppm allows pathogen survival); pesticide carryover from seed treatment that survives the wash step. Each of the three has a different control point — chlorine residue is a final rinse limit, sanitizer drift is the wash-tank CCP (Section 6), pesticide carryover is the seed-source SOP.
Decision-tree output: wash-tank CCP (Section 6, CCP 1) catches sanitizer drift; final-rinse chlorine limit is a process-control check documented but not a CCP.
Metal fragments from blade wear (harvest blade + cutting-tool failure); glass from packaging line (clamshell lidding lamp, glass thermometers if any); plastic shard from clamshell seal failure (heat-seal station drift over time). Each is a contamination-from-equipment failure mode; the control is a tool inventory log + breakage reporting at the shift change.
Decision-tree output: packaging-line CCP (Section 6, CCP 3) catches the metal/glass case via breakage reporting + line stop; plastic shard is a tool-replacement trigger, not a CCP.
Four CCPs emerge from the Section 5 hazard analysis for the microgreens line: CCP 1 wash-water chlorine (50–100 ppm free chlorine, ORP ≥650 mV); CCP 2 cold-chain temperature (≤41°F pre-dispatch, cloud logger alarm on excursion); CCP 3 packaging-line metal/glass exclusion (tool inventory + breakage reporting); CCP 4 lot traceability (every clamshell labeled at pack). Each CCP has a critical limit, a monitoring cadence, a corrective action, and a verification log signature.
The 4 CCPs above already appear as pre-checkbox rows in Hydroponics Launch Readiness Section 5. This checklist is the enduring version — the same CCPs in the full HACCP-plan language, with critical limits, monitoring frequency, corrective actions, and verification signatures that VDACS expects in the bound HACCP binder.
The submission sequence is six steps in order: (1) VDH water-source letter in hand (this page Section 1); (2) HACCP plan + supporting SOPs compiled in one binder; (3) VDACS Food Processing Plant License application filed (~60–90 day review window); (4) on-site sanitation verification audit; (5) GAP audit (third-party auditor aligned to USDA-AMS standards, annual cadence); (6) license issued → wholesale + grocery-chain path opens. Skipping order costs weeks; out-of-order steps are the silent time-killer.
The VDACS Food Processing Plant License is the regulatory instrument that lets IronRoost sell into wholesale + grocery chains in Virginia. SCBGP-style applications that name a grocery-chain partner (or claim a grocery-channel revenue line) implicitly assume three things: (a) a passing GAP audit, (b) a validated HACCP plan with monitoring logs, and (c) an active VDACS Food Processing Plant License. Without all three, the SCBGP narrative branch that names a grocery-chain partner is unsupported. SCBGP Application Outline and SCBGP 2027 Pre-Application Skeleton both reference this gate explicitly.
The SCBGP narrative branch that names a grocery-chain partner assumes a regulated processing facility behind the product. A "we'll sort out the license later" framing fails the merit-review reading because VDACS has not yet blessed the facility as compliant. Lock the license first; let the grocery-chain narrative track license issuance, not the other way around. This page being complete (every box ticked, every CCP log initialized) is the literal signal that the gate is ready to close.
This page is print-to-PDF friendly. Press Ctrl+P (or Cmd+P on macOS) for a usable offline working copy. Digital checkbox state resets after printing — tick on the printed copy by hand, then return here and tick digitally to update this page's row status.
Once every box above is ticked, IronRoost Farms is ready to file the VDACS Food Processing Plant License — the regulatory instrument that opens the wholesale + grocery-chain revenue path. That license issuance, in turn, is the gate referenced on the SCBGP Outline and SCBGP 2027 Skeleton pages, where the grocery-chain narrative branch in the Project Narrative depends on a passing GAP audit + validated HACCP plan + active license.