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Pro Terra only certifies non-GMO soybeans so only 30% crops of this farm. This means that crops must be kept separate by documenting, at agricultural production level, records regarding certified non-GMO seeds, information on planted areas and plots where non-GMO soybeans are sown, quantities of soybeans sown and analysis records.
Only if the following documents are not submitted or a total separation of GMO crops and non-GMO crops cannot be demonstrated, it can be considered non-conformance.
It must be demonstrated that non-GMO seed invoices presented, cover the entire area sown with non-GMO crops. For example, if the total number of non-GMO soybean seed purchased is not sufficient for the quantity of declared hectares non-GMO seed in used, this may lead the Auditor to request more evidences.
In addition to the seed purchase invoice, analyses must also be presented that confirm the absence of non-GMO seed using the methods recognized by the ProTerra standard.
The use of by-products, agricultural inputs, additives or other products used for soybean production must also be no GMOs; this must also be demonstrated.
As for the storage part, first each silo must specify what crops it contains and then if it is a non-GMO crop.
It must be demonstrated that all soybeans from non-GMO plots are stored in silos number 4 and 5 and not just silo 4, this can be considered non-compliance unless analysis of non-GMO soybeans collected and stored in silo 5 is also demonstrated.
It must also be shown that to get to silos 4 and 5 non-GMO soy arriving at the storage site follows a line totally independent of that used for GMO soybeans. For example, dryers, elevators that ensure total segregation of non-GMO ground certified material.
A record of storage operations must be maintained and then data regarding: weight, date, transport vehicle etc.
Since there are silos of non-GMO certified products and non-certified products, a mass balance must be maintained in which the incoming certified material corresponds to the outgoing certified material.
Talking to employees can be very helpful for the auditor to understand the conditions and ways of working. It is good that employees declare to clean the equipment before using it in non-GMO plots but a description of how this cleaning is carried out, whether it is carried out dry or with water, whether products are used and whether they are fine may be useful. It can also be useful to keep a record of the cleaning carried out by reporting the methods, date and other useful data. Viewing the location and tools used can also be helpful.
In the invoice of the previous year, the mill must be reported if the goods that have been delivered are certified ProTerra, if they are non-GMO material.
For each load of pro terra certified product that changes owner then must have a TTC Traceability Certificate of Compliance that contains: Volume of the consignment, lot numbers and volumes of each lot of material contained in the consignment, identification of seller and buyer, date of the transaction.
The auditor may request which products were contained in silos 4 and 5 the previous year, if it were already a non-GMO certified product.
In this case, 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, is the potential non-conformance i identifie.
About what type of visual evidence and/or documentation would you use to eventually confirm the potential non-conformance, the auditor could ask records to provide evidences like: Sampling plan for immunologically based screening using strip tests; Sampling plan for PCR analyses; Strip test records; PCR analysis reports.