ProTerra V4.1 – Forum Activity to Day 5 – Traceability

[master]

Case Study

Consider the information below:

Company	Super Soy
Location visited	Sorriso, Mato Grosso, Brasil
What the company does	Soybean farming and grain storage
Types of production	GMO and Non-GMO
Hectares planted to soy	150,000

At the audit to the above company you discover the following:

·          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.

·         There are invoices for purchased non-GMO seed.

·         Employees state planting and harvesting equipment is cleaned prior to use on non-GMO fields.

·         Farm records identify the fields planted with non-GMO seed.

·         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.  

·         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. 

Comment on the following regarding Principle 10- Traceability and Chain of Custody:

1.     Cite potential non-conformance(s) you identified.

2.     What type of visual evidence and/or documentation would you use to eventually confirm the potential non-conformance?

 

Good work!!

[Alejandra Bolanos]

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INFORMATION:
· 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?

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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)

[Alice]

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.

[Alice]

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.

[Alice]

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.

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