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· GMO and non-GMO crops are approximately respectively 70% and 30% of the total production.
· There are ten equal sized grain storage silos (1 to 10), numbers 4 and 5 are dedicated non-GMO and contain “Non-GMO only” labels -> Grain storage silos #4 and #5 are dedicated?
· There are invoices for purchased non-GMO seed -> Certified Seeds / PCR analysis reports?
· Employees state planting and harvesting equipment is cleaned prior to use on non-GMO fields -> Procedures and records of cleaning of non-dedicated equipments / tools?
· Farm records identify the fields planted with non-GMO seed -> Seeds from grain storage silos #4 and #5 came from what field?
· There are records of semi-quantitative GMO strip test analysis on harvested soybeans. Records demonstrate these tested soybeans are placed into the storage silos number 4 -> Results from semi-quantitative GMO strip from grains silo #4? grains from silo #5 were tested? Results?
· Last year’s invoices from Super Soy Farm to the local grain crusher (next economic operator) contain grain silo numbers 4 and 5 printed on the invoice -> Information of semi-quantitative GMO strip did not mention grains for silo #5? The organisation have certainty that those grains are Non-GMO?
Remembering that according to the information provided (case study) it is not possible to reach a conclusion, more evidence is needed.
The answers were formulated based on reasonable indicators.
1. POTENCIAL NON-CONFORMANCE(S):
5.1 GMOs and Genetically Engineered Organisms are excluded
5.1.2 The organisation does not prevent intentional or unintentional contamination of non-GMO grains by GMO’s.
Non-GMO control system is not able to assure compliance with non-GMO requirements of their target market (Targeted Threshold Tolerance / an adventitious GM presence level)
5.2 System of Identity Preservation and segregation
5.2.1 The organisation does not have in place an adequate system of segregation for non-GMO products.
5.2.2 The procedures and records in place does not to ensure segregation is maintained.
10.1 Chain of Custody System
10.1.2 The organisation`s documentation and records do not demonstrate complete traceability.
10.1.4 The organisation do not maintain chain of custody traceability during transfer of ownership of a consignment. Traceability Certificate of Compliance (TCC) was not available.
10.2 Mass balance
10.2.2 A mass balance do not demonstrate that volumes of non-GMO received are equivalent to non-GMO product dispatched.
10.3 Segregated chain of custody
10.3.1 The organisation do not consistently employ, standard operating procedures for maintaining full segregation for each lot of ProTerra certified product from GMO materials from the point of receipt to the point of transfer to the next economic operator in the supply chain.
10.3.2 Precautions, including physical labelling of facilities and conveyances, must be in place to prevent co-mingling of ProTerra certified material and other material during transport and during loading and unloading of conveyances.
10.3.3 Conveyances used to transport ProTerra certified material shall be inspected before loading to verify freedom from residues of materials that are not ProTerra compliant, and if residues are observed, the conveyance shall be cleaned before loading ProTerra certified materials. Inspection and cleaning of conveyances shall be documented.
10.3.5 Certified organisation shall comply with Principle 5 to demonstrate that genetically modified organisms are not used.
2. VISUAL EVIDENCE AND / OR DOCUMENTATION
– Strip test procedure;
– Strip test records;
– Sampling plan for PCR analyses.
– PCR analysis reports;
– Records of flushing or cleaning for product change in nondedicated sites, and
– Inspection checklist of trucks and other conveyances.
– Storage records: volume, number of silo or warehouse.
– Shipment records: crop type, weight, date, driver name, number of vehicle license plates, farm or warehouse of origin, as well as analytical results.
– Traceability Certificate of Compliance (TCC)