CSQ CERTIFICATION
The CSQ Certification Program and applicable standards were built around ISO/IEC 17067
USDA Harmonized GAP+ Certification: Government-Backed Produce Food Safety Audits
USDA Harmonized GAP+ is a government-administered food safety audit program for fresh produce operations that has been acknowledged as equivalent to GFSI Technical Equivalence Requirements. Conducted by USDA-licensed auditors through federal and state departments of agriculture, it provides growers, packers, and handlers with a credible, FSMA-aligned certification that satisfies the food safety requirements of major retailers and institutional buyers. Kiwa ASI is a USDA-approved third-party certification body offering Harmonized GAP+ audits nationwide.
- GFSI Technical Equivalence
- USDA-Administered Program
- FSMA Produce Safety Rule Aligned
What is USDA Harmonized GAP+ Certification?
USDA Harmonized GAP+ certification is a government-administered food safety audit program for fresh produce operations that verifies compliance with Good Agricultural Practices (GAP) and Good Handling Practices (GHP), with additional requirements aligned to the FDA's Food Safety Modernization Act (FSMA) Produce Safety Rule. It is the only USDA GAP audit program acknowledged as equivalent to the Global Food Safety Initiative (GFSI) Technical Equivalence Requirements, giving certified operations the credibility needed to supply major retailers who require GFSI-level food safety assurance.
The program is administered by the USDA Agricultural Marketing Service (AMS) through its Specialty Crops Inspection Division and is based on the Produce GAPs Harmonized Food Safety Standard developed by the GAPs Harmonization Initiative, a collaborative effort among industry, government, and academic stakeholders to create a single, unified produce food safety audit standard. The "Plus+" designation indicates that the standard goes beyond the base Harmonized GAP requirements by incorporating criteria that specifically address GFSI benchmarking requirements and FSMA alignment. The current version is Harmonized GAP Plus+ Standard Version 5.1, effective July 3, 2025.
Unlike private third-party certification schemes, USDA Harmonized GAP+ audits are conducted by trained and licensed federal and federal-state department of agriculture employees, as well as USDA-approved third-party certification bodies like Kiwa ASI. This government backing gives the program a unique level of credibility and objectivity. For produce growers, packers, and handlers, particularly small and mid-size operations, USDA Harmonized GAP+ offers an accessible, cost-effective path to a GFSI-equivalent certification that opens doors to retail, foodservice, and institutional markets.
Government-Administered, GFSI-Equivalent
USDA Harmonized GAP+ is the only government-run food safety audit program acknowledged as equivalent to GFSI Technical Equivalence Requirements. This means your certification carries both the credibility of a USDA-backed program and the market acceptance of a GFSI-equivalent standard, a combination no private scheme can offer.
Built on the Harmonized Standard
The program is based on the Produce GAPs Harmonized Food Safety Standard, a consensus-based standard developed by industry, government, and academic stakeholders through the GAPs Harmonization Initiative. This ensures the audit requirements reflect real-world produce operations and current scientific understanding of food safety risks.
FSMA Produce Safety Rule Aligned
USDA Harmonized GAP+ incorporates requirements that directly align with FDA FSMA's Produce Safety Rule, helping certified operations demonstrate compliance with federal food safety regulations. This dual-purpose audit reduces the burden of meeting both customer and regulatory requirements through separate processes.
Flexible Scope Options
The program offers multiple audit scopes, General Questions, Field Operations & Harvesting, Post-Harvest Operations, Warehouse, Food Defense, Integrated Pest Management, Logo Use, and Tomato-specific protocols, allowing operations to select the scopes that match their specific activities and customer requirements.
WHO IT'S FOR
Who Needs USDA Harmonized GAP+ Certification?
USDA Harmonized GAP+ certification applies to any operation involved in the production, harvesting, packing, handling, storage, or distribution of fresh fruits and vegetables. The program is designed to be accessible to operations of all sizes, from small family farms to large vertically integrated grower-shippers and offers a GroupGAP option that allows multiple small producers to certify together under a shared food safety management system.
Fresh Produce Growers
Open-Field Fruit & Vegetable Farms
Field-level growing operations producing fresh fruits and vegetables — leafy greens, berries, tree fruit, root crops, melons, vine crops, and row vegetables. The Field Operations & Harvesting scope evaluates agricultural water quality, soil amendments, worker hygiene, field sanitation, wildlife and domestic animal controls, and pre-harvest assessments. This is the core scope for any farm seeking USDA GAP+ certification.
Indoor & Protected Growing Operations
Greenhouses, High Tunnels & Controlled Environments
Operations growing produce in enclosed or semi-enclosed structures including greenhouses, high tunnels, hoop houses, and vertical farms. These operations are audited under the Field Operations scope with additional considerations for enclosed growing environments, nutrient solution management, condensation control, and substrate handling.
Harvest Crews & Field Packing
Contract Harvesters & Field-Level Packing Teams
Operations that pick, field-pack, or perform initial handling of produce before it moves to a packinghouse or distribution point. Audited under the Field Operations & Harvesting scope, these operations are evaluated on harvest container sanitation, field packing practices, worker hygiene, portable sanitation facilities, and transportation from field to facility.
Packinghouses
Produce Packing, Grading & Repacking Facilities
Facilities that receive harvested produce and prepare it for market through washing, sorting, grading, waxing, packing, labeling, and palletizing. The Post-Harvest Operations scope evaluates facility sanitation, equipment cleaning, pest control, temperature management, water quality (for post-harvest water applications), traceability systems, and packaging material controls.
Storage & Cold Chain Facilities
Cold Storage, Controlled Atmosphere & Warehousing
Facilities providing pre-cooling, cold storage, controlled atmosphere storage, or general warehousing for fresh produce. The Warehouse addendum (new in Version 5.1) covers receiving procedures, temperature monitoring, facility sanitation, pest control, product identification and traceability, and FIFO inventory management in warehouse environments.
Distribution & Logistics
Produce Distribution Centers & Cross-Docking Operations
Operations that aggregate, store, and distribute fresh produce to retail, foodservice, or institutional buyers. Distribution operations can be audited under the Post-Harvest and/or Warehouse scopes, covering cold chain integrity, vehicle inspection, loading practices, and product handling during distribution.
GroupGAP Participants
Small Farm Groups, Food Hubs & Marketing Cooperatives
USDA's GroupGAP program allows multiple producers operating under a shared food safety management system to achieve GAP+ certification collectively. This is ideal for small farms, food hubs, farm-to-institution programs, and agricultural cooperatives that want USDA GAP+ certification but need to share the cost and administrative burden across a group of producers.
Tomato Operations
Tomato-Specific Production, Packing & Repack
Operations that produce, harvest, pack, store, distribute, or repack tomatoes have access to four additional Tomato Audit Protocol scopes: Open-Field Production & Harvesting, Packinghouse, Greenhouse, and Repack & Distribution. These optional scopes verify compliance with requirements specifically developed for tomato food safety.
ADVANTAGES
What Are the Benefits of USDA Harmonized GAP+ Certification?
Retail & Institutional Market Access
USDA Harmonized GAP+ certification satisfies the food safety audit requirements of major retailers, foodservice distributors, and institutional buyers who require GFSI-level assurance from their produce suppliers. Because the program holds GFSI technical equivalence, buyers who accept GFSI-recognized certifications — including Walmart, Costco, Kroger, Sysco, and school nutrition programs — accept USDA Harmonized GAP+ as meeting their supplier requirements.
Government-Backed Credibility
As a USDA-administered program, Harmonized GAP+ carries a level of institutional credibility that no private certification scheme can match. The program is overseen by the USDA Agricultural Marketing Service, and audits are conducted by trained federal and state agriculture employees or USDA-approved third-party CBs. This government backing provides buyers, regulators, and consumers with additional confidence in the integrity of the audit process and results.
FSMA Regulatory Compliance
USDA Harmonized GAP+ is specifically designed to align with FDA FSMA's Produce Safety Rule, helping certified operations demonstrate federal regulatory compliance alongside customer food safety requirements. Rather than managing FSMA compliance and food safety certification as two separate processes, GAP+ integrates both into a single audit framework — reducing administrative burden and ensuring your operation addresses regulatory and commercial requirements simultaneously.
Accessible for Small & Mid-Size Operations
The USDA Harmonized GAP+ program is designed to be accessible to operations of all sizes, with the GroupGAP option making certification economically viable for small and mid-size farms that could not justify the cost of individual third-party certification. GroupGAP allows grower groups, food hubs, and cooperatives to certify together under a single food safety management system, sharing audit costs and administrative resources while still achieving individual producer recognition.
USDA GAP & GHP Logo Use
Certified operations that complete the Logo Use scope can use the official USDA GAP & GHP logo on their packaging and promotional materials — a recognizable mark of government-verified food safety that differentiates your product at the point of sale. This visual credential communicates food safety assurance directly to buyers and consumers.
Continuous Improvement Through Annual Audits
The 80% compliance threshold combined with Corrective Action Needed (CAN) designations creates a structured framework for continuous improvement. Questions scored as CAN must be addressed before the next annual audit, ensuring that your food safety programs strengthen progressively year over year rather than remaining static after initial certification.
Prepare for USDA Harmonized GAP+ with Kiwa ASI Training
Build audit readiness and ensure your team understands the food safety practices required for USDA Harmonized GAP+ certification. Kiwa ASI offers training programs directly relevant to the GAP+ audit requirements, from FSMA-mandated courses to produce-specific food safety training.
HACCP Certification Training
HACCP Certification Training
Comprehensive HACCP training based on Codex Alimentarius principles — essential for packinghouse and post-harvest operations that need to develop HACCP plans for identified Critical Control Points. Covers hazard analysis, CCP identification, critical limit establishment, monitoring procedures, corrective actions, and verification activities.
16 Contact Hours
4 Half-Day Sessions
Live Virtual
HACCP Certificate Included
Upcoming Dates — $695 Per Seat
May 11–14, 2026
🕓 8:30 AM – 12:30 PM CT
💻 Live via Zoom · 4 half-days
July 20–23, 2026
🕓 8:30 AM – 12:30 PM CT
💻 Live via Zoom · 4 half-days
Aug 31 – Sep 3, 2026
🕓 8:30 AM – 12:30 PM CT
💻 Live via Zoom · 4 half-days
October 5–8, 2026
🕓 8:30 AM – 12:30 PM CT
💻 Live via Zoom · 4 half-days
December 14–17, 2026
🕓 8:30 AM – 12:30 PM CT
💻 Live via Zoom · 4 half-days
Need to train 6+ people? Ask about on-site private training → | US.Info@kiwa-asi.com
Internal Auditor Training
Internal Audit Food Safety Training
Equip your team to conduct effective internal audits — a key component of maintaining GAP+ certification year over year. Covers audit planning, checklist review, evidence gathering, non-conformity documentation, corrective action follow-up, and self-audit procedures aligned with the USDA Harmonized GAP+ standard.
6 Contact Hours
1 Full Day
Live Virtual
Certificate Included
Upcoming Dates — $500 Per Seat
July 14, 2026
🕓 8:30 AM – 2:30 PM CT
💻 Live via Zoom · Full day
November 5, 2026
🕓 8:30 AM – 2:30 PM CT
💻 Live via Zoom · Full day
Need to train 6+ people? Ask about on-site private training → | US.Info@kiwa-asi.com
THE AUDIT
What Does a USDA Harmonized GAP+ Audit Cover?
A USDA Harmonized GAP+ audit evaluates your operation against a set of scopes selected based on your activities and customer requirements. Every audit includes the General Questions scope, plus one or more operational scopes. The audit is conducted on-site by a USDA-approved auditor who reviews documentation, observes operations, and interviews staff to assess compliance with the Harmonized GAP Plus+ Standard (Version 5.1).
Audit Scopes
| Scope | Code | Applies To | Status |
|---|---|---|---|
| General Questions | G | All operations | Required with every audit |
| Field Operations & Harvesting | F | Farms, growers, harvest crews | Select if applicable |
| Post-Harvest Operations | P | Packinghouses, processing, cooling | Select if applicable |
| Warehouse | W | Warehouse facilities that pack and hold produce | Optional addendum (new in v5.1) |
| Food Defense | FD | Operations seeking food defense verification | Optional addendum (new in v5.1) |
| Integrated Pest Management | IPM | Growers demonstrating IPM practices | Optional addendum (new in v5.1) |
| Logo Use | L | Operations using USDA GAP & GHP logo | Required if using logo |
| Tomato: Open-Field Production & Harvesting | T1 | Tomato field operations | Optional tomato-specific |
| Tomato: Packinghouse | T2 | Tomato packing facilities | Optional tomato-specific |
| Tomato: Greenhouse | T3 | Tomato greenhouse operations | Optional tomato-specific |
| Tomato: Repack & Distribution | T4 | Tomato repack and distribution | Optional tomato-specific |
Key Audit Areas by Scope
General Questions (G) — Required for Every Audit
Food safety policy and management commitment, organizational structure and food safety responsibilities, risk assessments, worker training programs, internal self-audits, approved supplier programs, corrective action procedures, traceability and recall plans, food safety contact designations (including 24-hour contact), and disciplinary procedures for food safety violations.
Field Operations & Harvesting (F)
Agricultural water quality (testing and management), soil amendments and biosolids (application timing and composting practices), worker health and hygiene, field sanitation facilities, wildlife and domestic animal controls, adjacent land use risk assessment, pesticide and fertilizer application and record keeping, harvest container management, field vehicle sanitation, and pre-harvest assessments.
Post-Harvest Operations (P)
Facility design and construction, equipment maintenance and sanitation, post-harvest water quality (for washing, cooling, and other water applications), pest control programs, temperature management and cold chain integrity, employee hygiene and training, packaging material controls, product identification and traceability, allergen controls, foreign material prevention, HACCP plans for identified CCPs, and chemical residue requirements for countries-of-export.
Warehouse (W) — New in Version 5.1
Receiving and inspection procedures, storage area sanitation, temperature monitoring, pest control, product identification and FIFO inventory management, equipment maintenance, loading and shipping practices, and traceability within the warehouse environment.
Food Defense (FD) — New in Version 5.1
Vulnerability assessments, facility access controls, personnel security measures, supply chain security, and food defense plan documentation and review.
Integrated Pest Management (IPM) — New in Version 5.1
IPM plan development and implementation, pest identification and monitoring, threshold-based intervention strategies, cultural and biological control practices, and record keeping of IPM activities.
Assessment Categories
USDA Harmonized GAP+ uses a compliance-based assessment system rather than a numerical scoring model:
| Assessment | Code | Meaning |
|---|---|---|
| Compliant | C | Requirement is fully met with objective evidence |
| Corrective Action Needed | CAN | Non-conformance identified that must be addressed before next annual audit |
| Immediate Action Required | IAR | Imminent food safety risk requiring immediate correction |
| Not Applicable | N/A | Requirement does not apply to this operation |
Pass/Fail Threshold
Minimum 80% compliance on each scope is required to pass the audit. The compliance percentage is calculated based on the number of applicable questions scored as Compliant (C) divided by the total number of applicable questions in that scope. Each scope is evaluated independently — an operation could pass the General scope but fail the Field Operations scope if compliance falls below 80% in that area.
Immediate Action Required (IAR) Conditions
An IAR is issued when a non-conformance represents an imminent food safety risk. Specific IAR triggers include:
- Produce grown, processed, packed, or held under conditions that promote or cause contamination
- Employee practices (personal or hygienic) that jeopardize or may jeopardize produce safety
- Presence or evidence of rodents, or an excessive amount of insects or pests
IAR findings require immediate on-site correction. Failure to correct an IAR condition during the audit may result in audit failure.
Corrective Action Requirements
| Finding Type | Timeline | Details |
|---|---|---|
| Corrective Action Needed (CAN) | Before next annual audit | Non-conformance must be corrected and documented before the following year’s audit |
| Immediate Action Required (IAR) | Immediate (during audit) | Imminent food safety risk must be corrected on-site during the audit |
| Audit Failure | Re-audit required | If compliance falls below 80% on any scope, corrective actions must be implemented and a re-audit scheduled |
How to Prepare for USDA Harmonized GAP+ Certification
Most operations need 2–4 months of focused preparation before their initial USDA Harmonized GAP+ audit, depending on the maturity of existing food safety programs and the scopes being audited. Here's a step-by-step approach.
01
Identify Your Required Scopes
Determine which audit scopes apply to your operation: General Questions (required for all), Field Operations & Harvesting (for farms and harvest crews), Post-Harvest Operations (for packinghouses and cooling facilities), Warehouse, Food Defense, IPM, Logo Use, and/or Tomato-specific protocols. Your customers may specify which scopes they require — confirm this before preparing.
02
Download and Study the Current Standard and Checklist
Obtain the Harmonized GAP Plus+ Standard Version 5.1 and the corresponding audit checklist from the USDA AMS website (ams.usda.gov). Review every question in your applicable scopes to understand exactly what auditors will evaluate and what documentation and evidence are required for each.
03
Conduct an Internal Gap Analysis
Compare your current food safety practices against each requirement in your applicable scopes. Document gaps, prioritize them based on food safety risk, and assign responsibility for addressing each one. Kiwa ASI offers pre-assessment consulting services through ASI Training and Consulting to help identify gaps before your official audit.
04
Develop Your Food Safety Plan
Create a comprehensive, written food safety plan that addresses all the requirements in the General Questions scope: food safety policy, organizational structure with food safety responsibilities, risk assessments, worker training program, internal self-audit schedule, approved supplier program, corrective action procedures, traceability and recall plan, and designated 24-hour food safety contact.
05
Implement Operational Controls
Build or strengthen the operational programs required by your selected scopes. For Field Operations: water testing schedules, soil amendment application records, wildlife monitoring logs, and pre-harvest assessment procedures. For Post-Harvest: sanitation SOPs, pest control programs, temperature monitoring systems, HACCP plans for identified CCPs, and packaging material controls. Document everything — the audit evaluates both practices and records.
06
Train Your Team
Ensure all employees receive food safety training appropriate to their role. Farm workers need GAP and hygiene training; packinghouse staff need GMP, sanitation, and allergen awareness training. If your operation is subject to the FSMA Produce Safety Rule, at least one person must complete PSA Grower Training. Document all training with topic, date, trainer, and attendee records. See our training section above for available courses.
07
Conduct an Internal Self-Audit
Perform a complete self-audit using the USDA Harmonized GAP+ checklist before your official certification audit. Walk through every question in your applicable scopes, score your own compliance, and address any findings with documented corrective actions. Internal self-audits are themselves a requirement of the General Questions scope.
08
Schedule Your USDA Harmonized GAP+ Audit with Kiwa ASI
Contact Kiwa ASI to schedule your certification audit. Our team will confirm your applicable scopes, audit duration, and logistics based on your operation type and size. We recommend scheduling at least 4–6 weeks in advance, particularly during peak harvest season when auditor availability may be limited. Contact us at info@asifood.com or call 1 (800) 477-0778.
Why Choose Kiwa ASI for USDA Harmonized GAP+ Certification?
Kiwa ASI has been providing food safety solutions to the agriculture and produce industry since the 1940s. As a USDA-approved third-party certification body, we combine deep produce industry knowledge with the global resources of the Kiwa network to deliver a thorough, efficient, and genuinely helpful audit experience.
Fresh Produce Expertise
Auditors Who Understand Produce Operations
Kiwa ASI auditors bring real-world experience across the produce supply chain, from field-level GAP audits on leafy greens and berry operations to packinghouse and cold storage evaluations. Our auditors understand seasonal pressures, harvest logistics, water management challenges, and the practical realities of produce food safety, which means audits that are rigorous but grounded in how your operation actually works.
USDA-Approved Certification Body
Government-Authorized, Nationally Recognized
Kiwa ASI is an approved USDA third-party certification body authorized to conduct Harmonized GAP+ audits. Your audit results and certification are issued through a recognized, USDA-approved entity, giving your certification the government-backed credibility that retailers and institutional buyers require.
Training & Preparation Support
Build Audit Readiness Before Your Certification Audit
Through ASI Training and Consulting, LLC, Kiwa ASI offers PSA Grower Training, HACCP certification, internal auditor training, and custom on-site programs — all directly relevant to USDA Harmonized GAP+ preparation. Training services are offered separately from certification to maintain the independence required of an accredited certification body.
Responsive Scheduling & Client Service
Fast Turnaround, Season-Aware Scheduling
Produce operations run on harvest calendars, and audit timing matters. Kiwa ASI offers responsive scheduling with dedicated client service representatives who understand seasonal constraints, coordinate audit logistics, and ensure a smooth process from quote through certificate issuance. We work to accommodate your timeline — not the other way around.
Global Kiwa Network
Local Expertise, National & International Reach
As part of Kiwa, a global testing, inspection, and certification company operating in 30+ countries, Kiwa ASI can support multi-location and multi-state produce operations with consistent audit quality. Whether you operate a single farm, a multi-site grower-shipper, or a GroupGAP collective, Kiwa ASI has the infrastructure and auditor network to serve your certification needs.
Frequently Asked Questions About USDA Harmonized GAP+ Certification
USDA Harmonized GAP+ is a government-administered food safety audit program for fresh produce operations, managed by the USDA Agricultural Marketing Service. It verifies compliance with Good Agricultural Practices (GAP) and Good Handling Practices (GHP) while incorporating additional requirements aligned to the FDA FSMA Produce Safety Rule and GFSI Technical Equivalence Requirements. The "Plus+" designation indicates this enhanced level of requirements beyond the base Harmonized GAP standard.
USDA Harmonized GAP+ is not technically "GFSI-recognized" in the same way as private schemes like SQF or BRCGS, but it has been acknowledged as equivalent to GFSI Technical Equivalence Requirements. This means major retailers and buyers who require GFSI-level food safety assurance accept USDA Harmonized GAP+ certification. It is the only government-run program to achieve this GFSI equivalence status.
The base USDA Harmonized GAP audit covers the core Produce GAPs Harmonized Food Safety Standard requirements. USDA Harmonized GAP+ (the "Plus+") adds criteria that address GFSI Technical Equivalence Requirements and FSMA Produce Safety Rule alignment. If your buyers require GFSI-level certification, you need the GAP+ version. Additional topics in GAP+ include product identification on packaging, labeling and chemical residue requirements for countries-of-export, control of non-conforming product, sourcing of seed stock and propagation materials, and HACCP plans for identified CCPs in packinghouses.
You must achieve a minimum of 80% compliance on each scope included in your audit. Compliance is calculated as the number of questions scored Compliant (C) divided by total applicable questions in that scope. Each scope is evaluated independently, so you must meet the 80% threshold on every scope — not just overall. Questions scored as Immediate Action Required (IAR) indicate imminent food safety risks and must be corrected on-site during the audit.
USDA Harmonized GAP+ certification is valid for one year. Annual re-audits are required to maintain certification. If your operation fails an unannounced verification audit during the certificate year, the certification may be revoked.
GroupGAP is a USDA program that allows multiple producers to achieve GAP+ certification together under a shared food safety management system. A central management entity (such as a food hub, cooperative, or marketing organization) develops and oversees the group's food safety program. Individual producers within the group are audited through a combination of internal audits by the group management and external verification audits by the USDA-approved CB. GroupGAP makes certification accessible and affordable for small farms by sharing costs and administrative resources across the group.
The current version is Harmonized GAP Plus+ Standard Version 5.1, effective July 3, 2025. Version 5.1 added three new addenda: Warehouse, Food Defense, and Integrated Pest Management. The core requirements from the previous version remain unchanged — Version 5.1 expanded the available scope options.
Both are accepted by major retailers as GFSI-level produce food safety certifications, but they differ in structure. PrimusGFS is a private, GFSI-recognized standard using a score-based system (90% overall / 85% per module) with multiple technical modules. USDA Harmonized GAP+ is a government-administered program using a compliance-based system (80% per scope) with GFSI technical equivalence. PrimusGFS covers additional post-harvest scopes like processing and storage/distribution with more granular GMP and HACCP modules, while GAP+ focuses primarily on pre-harvest and packinghouse operations. Your choice often depends on buyer requirements, operation type, and whether government-backed credibility or private-scheme market acceptance is more valuable to your business.
The cost depends on your operation type, number of scopes, facility size, and audit duration. There is also an annual $250 GFSI certification fee that covers the technical equivalency approval process. Auditor travel costs may apply. Contact Kiwa ASI at info@asifood.com or call 1 (800) 477-0778 for a customized quote based on your specific operation.
Yes, you can transfer your USDA Harmonized GAP+ certification to Kiwa ASI from another USDA-approved certification body. Contact our team to discuss the transfer process and provide your current audit report and certificate details. We'll coordinate the transition to ensure continuity of your certification status. Reach out to info@asifood.com to get started.
Request a Quote for ISO 9001 Certification:
Our team will review your request and provide a detailed quote tailored to your specific ISO 9001 requirements.
All consulting services are offered through ASI Training and Consulting, LLC. All activity is conducted separately from our accredited certification body, ASI Food Safety, LLC, in order to safeguard against any conflicts of interest.