Following feedback from industry about the new version of GlobalG.A.P, Susan Pheasant has provided us this response:
Some questions have been raised with respect to ALL FARM 10.1 (especially within the tree fruit industry).
Some questions have been raised with respect to ALL FARM 10.1 (especially within the tree fruit industry).
The text below is provided to answer those questions.
Given that there are multiple scenarios of how business is actually transacted within the industry (i.e. tree fruit), I have attempted to provide a number of options in the “overall implementation” section. This is neither an exhaustive nor a prescriptive list; each grower will need to work with his/her warehouse to identify the best working solution in their particular situation.
If there are remaining unanswered questions (or if this generates more – which is not the intent), please let me know.
Please feel free to disseminate this to others in the industry who have similar questions about AF10.1.
Kind regards,
Susan
ALL FARM 10.1
CONTROL POINT:
Do all transaction documentation include reference to the GLOBALG.A.P Status (certified/not certified)?
COMPLIANCE CRITERIA:
Transaction documentation (e.g. sales invoices) and, where appropriate, other documentation include the GLOBALG.A.P Status of the product.
No N/A.
LEVEL:
Major Must
OVERALL INTENT:
Documentation exists for purposes of mass balance and traceability so as to eliminate the possibility of more product being sold as GLOBALG.A.P certified than is produced on the registered farm.
IMPLEMENTATION:
· Demonstrate that there is a control procedure in place for traceability that includes utilizing the GGN (GLOBALG.A.P Number).
o It is possible to maintain use of current industry (e.g. tree fruit) recognized traceability practices based on lot numbers. In this situation, there needs to be a document which ties the GGN of the producer to the lot number(s) of the producer. For example, this information could be included in the contract/agreement between the producer and the warehouse with an appropriate link to receiving records.
o It is possible to utilize the GGN as the communication means on appropriate documents for traceability.
o It is possible to utilize documents such as sales invoices.
o It is possible to have another system for implementation … refer back to “overall intent.”
· Grower would need to provide warehouse/packhouse with his/her GGN.
o A grower receives a unique GGN from the Certifying Body or Farm Assurer within 14 days of initiating registration process.
o A grower can begin the registration process at any time (i.e. do not have to specify date for audit at time of inspection).
o A grower must have a GGN (or in the case of a subsequent surveillance audit, renew their GGN) prior to the audit/inspection taking place. (General Regulations Part I – 4.3 Acceptance.)
· Sales invoices are one option (but not the only option) available to provide the necessary documentation. The sales invoices would be coupled with production records in order to be able to conduct a “mass balance” exercise such that quantity of certified product produced equals quantity of certified product sold (subject to normal shrink/waste).
· In situations where the producer is not in control of the product for produce handling functions (e.g. delivers product to warehouse/packhouse owned by another entity and product is sold at a later date), then a) producer needs to have written evidence (e.g. contract, agreement) that indicates he/she is not part of the sales process nor is produce returned to the grower when there is a dispute over product characteristics and b) producer needs to have documentation of delivery indicating quantity of product delivered and that these records are traceable back to the farm or block as is appropriate for the operation and the crop.
o In such a situation where produce handling is not included in the certificate, sales documents would most likely not be a useful means for documentation.
o It is possible to utilize a Chain of Custody Audit at the packhouse/warehouse level. (Both BRC and IFS have this component and an arrangement with GLOBALG.A.P to share this information if requested by the producer. GLOBALG.A.P also has a voluntary Chain of Custody available http://www.globalgap.org/cms/upload/The_Standard/IFA/English/CPCC/GG_EG_IFA_CPCC_CoC_V2-0_4_Jan10.pdf )
· Specific to Option 1 Individual Producer in situation of initial audit and no produce handling.
o Three months of records for first time involved in GLOBALG.A.P certification process.
o Demonstrate the produce comes from a farm source that is in the process of being certified.
o Demonstrate that there is a control process in place for traceability that includes utilizing GGN (GLOBALG.A.P Number).
· Specific to Option 1 Individual producer in situation of surveillance audit and no produce handling (i.e. audits that take place after the first year)
o Two years of records
o The aggregate of all certified crop receipts (i.e. from delivery records to the warehouse) does not exceed the quantity of certified product produced.
o May be possible to use sales records from previous crop year as it is the process that is being audited and producer is in a situation of renewing the certificate.
· Specific to an Option 1 producer for which produce handling is included.
o Sales documents would be the most likely method for demonstrating compliance with AF10.1 because the producer is fully responsible for production, harvest, handling, and sales (at least to another entity if not the retail buyer).
o Still need to be able to conduct mass balance exercise.
Remember, that use of the GGN is not synonymous with certification. It is the responsibility of the buyer (or the next entity in the supply chain) to confirm via the GLOBALG.A.P database that a given product has certified or non-certified status.
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