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1. Cite potential non-conformance(s) you identified.
Is soy non-GMO only in silo 4 or also in silo 5?
Given that the two silos were reserved for non-GMO soy, why did the changes occur along the way?
What kind of soy is in silo 5?
Why weren’t the silo 5 tests done?
Were the two harvests mixed together?
Why do both silos appear on last year’s invoices from Super Soy Farm to the local grain crusher (next economic operator)?
2. What type of visual evidence and/or documentation would you use to eventually confirm the potential non-conformance?
ProTerra only certifies non-GMO soybeans. In cases where a ProTerra certified material can be mixed with other non-GMO material, or with material that does not have commercial GMO varieties, a mass balance shall be maintained to demonstrate that volumes of ProTerra certified material received are equivalent to ProTerra certified material dispatched.
Certified organisations shall have procedures and records in place to ensure segregation is maintained and documented. At least the following procedures and records to provide evidences that segregation is maintained. All for silo numbers 4 and 5.
• Sampling plan for immunologically based screening using strip tests;
• Sampling plan for PCR analyses;
• Strip test procedure;
• Strip test records;
• PCR analysis reports;
• Records of flushing or cleaning for product change in nondedicated sites, and
• Inspection checklist of trucks and other conveyances.
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 information contained in the TCC shall include the following:
• 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.
• The TCC shall be retained by both economic operators.