Hi Caz,
Never been faced with this request myself. Some organisations appear to have decided that any "free" declaration is an unrealistic expectation, eg -
Unfortunately, “GMO free” and similar claims are not legally or scientifically defensible due to limitations of testing methodology.
http://www.nongmopro...nding-our-seal/
http://newhope360.co...ow-can-hurt-you
(any sampling limitation is obviously analogous to Salmonella where it tends to be ignored for most haccp purposes, accuracy is a different matter, no idea on that one)
For UK I noticed -
http://food.gov.uk/science/novel/gm/
http://www.food.gov....g/#.UmqRiHJ9gsY
I deduce UK has as yet no labelling option such as "GM-free" which is probably fortuitous.
I assume the (presumably somehow justifiable) tolerance of 0.9% is designed to avoid the zero-detection quagmire and maybe also incorporate sampling / detection capabilities. Analysis presumably at a significant cost (and maybe impossible to use in a routine way?). I suppose this would satisfy yr customers if available / affordable. An example of one procedure here -
Analysis of food sample for GMOs.pdf 342.62KB
99 downloads
The above situation would logically imply the justification in postulating a (regulatory) hazard due to unlabelled GMO material (albeit avoiding the definition of the actual hazard).
If analysis not feasible, it may appear necessary to reach an "understanding" of the interpretation of"GM-free" supplier certificates (validated how?) between you / yr customer and for any (postulated) HACCP prerequisite. Bit like allergens i suppose.
My guess is that most people opt for a prerequisite (as per allergens) and the preceding paragraph. It might be different if there are some validated GMO, UK prevalence statistics similar to the levels claimed in the upper links of this post.
I agree it's not very satisfactory from a haccp POV. On the other hand, there are some other questionable regulatory haccp CCPs in routine use already.
Rgds / Charles.C
Edited by Charles.C, 24 August 2014 - 09:52 AM.
1st uk link updated