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Yes, the case study is not complete exactly to bring to discussion what additional information (made to auditee in the form of questions or additional documentation), would be necessary to fully understand the situation. What would you try to see?
You are correct with repect to the non compliances you cite. A more detailed discussion includes:
1. Cite potential non-conformance(s) you identified.
a) There was no mention of the transportation of the crops from the field to the silos. Potential NC on Indicator 10.3.1; 10.3.2; 10.3.3 and 10.3.4.
b) Assuming the yield of GMO and NON-GMO crops are equivalent and using the proportion of 70% of the crop to be GMO and 30% to be NON-GMO, there should be silos available to segregate the two crops in the same proportion. The Organization has 8 silos for GMO and only 2 silos for NON-GMO. There should be 7 and 3, instead. Potential NC on Indicator 5.2.1;
c) There was no mention of the record keeping on the purchasing of Non-GMO seeds. Potential NC on Indicator 10.1.2;
d) There was no mention of the record keeping of the cleaning equipment, potential NC on Indicator 10.3.1;
e) There is no information about how long the records are kept by the Economic Operator; Potential NC on indicator 10.1.1
f) There was no mention of the TCC, when the product was sold to the next economic operator; Potential NC on indicator 10.1.4
2. What type of visual evidence and/or documentation would you use to eventually confirm the potential non-conformance?
a) The auditor shall inspect cleaning records of the equipment used to GMO and Non-GMO crops. Harvesters, trucks must be cleaned between the use with GMO and Non-GMO crops. The existence of cleaning procedures and records must be inspected; 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.
b) The auditor shall inspect the Invoices of purchase of seeds, which should at least include supplier’s name, date of purchase, variety and/or brand name, quantity and lot number. If the seed invoice does not include the above-mentioned information, then information shall be recorded independent of the invoice;
c) The auditor shall ask for previous records all Pro-Terra indicators. The records shall be kept for 5 years or longer, if the local laws or regulations demanded.
d) The auditor shall ask and inspect the 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. Procedures and records may include, depending on the operation level:
• Sampling plan for immunologically based screening using strip tests;
• Sampling plan for PCR analyses;
• Strip test procedure;
• Strip test records;
• PCR analysis reports;
• Procedures of flushing or cleaning for product change in nondedicated sites.
e) The invoices issued by the auditee shall be inspected. The auditor shall as for the TCC’s issued, for certified organisations shall maintain chain of custody traceability during transfer of ownership of a consignment of ProTerra certified product by means of a Traceability Certificate of Compliance (TCC), specific for that transaction.
The auditor must inspect if the TCC’s contain the following information: volume of the consignment changing ownership; lot numbers and volumes of each lot of material contained in the consignment, identification of seller and buyer; date of the transaction and, where applicable; information verifying that the specific lot of material referenced in the TCC complies with the relevant threshold for GMO.