12 replies to this topic

[PremixBelle]

Hello:

 

We have an auditor who would like me to tell him more about our non-GMO certification process. Our quality department does not have a non-GMO certification process; however, raw materials are identified/maintained via regulatory review.

 

Does anyone have any advice on how to respond? Should we implement a non-GMO certification process?

 

Thank you for your time. I am very nervous about this and do not know how to respond because I do not fully understand what the auditor is looking for. Any feedback is GREATLY appreciated!

 

Warmest Regards,

D

[Charles.C]

Hello:

 

We have an auditor who would like me to tell him more about our non-GMO certification process. Our quality department does not have a non-GMO certification process; however, raw materials are identified/maintained via regulatory review.

 

Does anyone have any advice on how to respond? Should we implement a non-GMO certification process?

 

Thank you for your time. I am very nervous about this and do not know how to respond because I do not fully understand what the auditor is looking for. Any feedback is GREATLY appreciated!

 

Warmest Regards,

D

 

Dear premixbelle,

 

A relevant answer may depend on what yr process actually is, and the standard involved.

 

Rgds / Charles.C

[moskito]

Hi,

 

I never heard something about a non-GMO certifikation process. Which company has an accreditation on that? Based on what?

In Germany we have a claim "keine Gentechnik" ("No Genetic Engineering") which is legally regulated.

 

Rgds

moskito

[fgjuadi]

The easiest answer is :

"No, Sir/Ma'am, we do not make non-GMO claims"  and maybe "Here is our labeling SOP that says we do not make non-GMO claims."

 

-MM

[hlehman02]

Hi,

 

I never heard something about a non-GMO certifikation process. Which company has an accreditation on that? Based on what?

In Germany we have a claim "keine Gentechnik" ("No Genetic Engineering") which is legally regulated.

 

Rgds

moskito

 

I am new to these boards, but I thought I would take a moment to respond to Non-GMO certification. While it is scientifically impossible to guarantee GMO free, there is a great and achievable standard that is emerging for Non-GMO based on good science and processes. It is utilizes much of the European standard details, and the certification process is rapidly expanding across North America. For more informtion, see http://www.nongmoproject.org/

 

best,

Heather

[Charles.C]

Dear hlehman,

 

I could not see any mention of yr "standard" being officially approved by anyone since it's inception in (apparently) 2007 ?

 

I presume this is why you refer to the "program" as a Project.

 

Please elaborate.

 

I also found the size of the "DONATE" button somewhat disquieting.

 

Rgds / Charles.C

[WowQC]

What we have done is use both our supplier approval program and a verification test. Our suppliers guarantee the ingredients are non-GMO. We do a test on one of the ingredients that has a high-risk for GMO contamination. We also send a finished product for testing of the presence of GMO on a quarterly basis. This is called self-verification.

 

We originally looked at the Non-GMO Project, or the Cert-ID non-GMO verification program, but they were pretty much the same as our BRC audit requirements, the only difference being a finished product test, so we did this ourselves.

[hlehman02]

Dear hlehman,

 

I could not see any mention of yr "standard" being officially approved by anyone since it's inception in (apparently) 2007 ?

 

I presume this is why you refer to the "program" as a Project.

 

Please elaborate.

 

I also found the size of the "DONATE" button somewhat disquieting.

 

Rgds / Charles.C

 

 

Charles. C. though the standard is newer, it is recognized across North America. Also, NonGMO certification is ony now being addressed in the North American context and the Non-GMO Project is the only robust standard available. There are others beginning to push in to non-GMO certification but they have no standard and rely only on end of production testing.

 

The name of the standard holder IS the Non-GMO Project, we have a certification program utilizing third party certifiers and part of the reason I am on this board is to listen and learn and discuss third party certification in the food safety and quality context. We are expanding the number of technical adminsitrators and developing more minimum requirements beyond ISO 17025 and ISO 65 compliance as we learn and grow. Our growth has been rapid and not insubstantial, and as the standard holder we want to make sure that we proceed appropriately.

 

As far as the donate button goes, I assume you are unfamiliar with the non profit organization landscape. Pretty standard for non profit organizations, especially in the NA context where organic standards and non-GMO standards are a hot issue. The US does not have a regulatory standard for non-GMOs, instead we have USDA, EPA, FDA regulating safety of GM entities.

 

So I will ask right back, who would you ideally like to see a standard be officially recognized by? Does it help that we are moving towards ISEAL membership?

 

Also, the BRC requirements mentioned are on the European standard, obviously, and their limits for non-GMO are less stringent than what are standard is upholding.

 

I am all ears for you input at this point, as that is why I leapt in here.

 

best,

Heather

[hlehman02]

Dear hlehman,

 

I could not see any mention of yr "standard" being officially approved by anyone since it's inception in (apparently) 2007 ?

 

I presume this is why you refer to the "program" as a Project.

 

Please elaborate.

 

I also found the size of the "DONATE" button somewhat disquieting.

 

Rgds / Charles.C

 

And, just for officalness, I did want to mention that our standard is FSIS approved too.

 

cheers,

Heather

[Charles.C]

Dear hlehman,

 

Thks yr reply.

GMO related issues not really my area of expertise but I can offer a few comments –

 

(1) Re – FSIS approval,  I guess this relates to –

 

http://www.nongmopro...d-egg-products/

http://www.nytimes.c...ducts.html?_r=0

 

I note from yr website that NGP standard sets  appropriate product  threshold levels for GMO  content.. Are these FSIS originated  standards or ? ( I could not find any data ascribed to USDA on the IT). I noticed that historically the numbers used have (not surprisingly) caused considerable debate, eg this 2007 article –

 

http://www.non-gmore...GMO_project.php

 

I also noticed this later comment in a (2014) USDA conference paper –

 

 GE claims.pdf   288.43KB   44 downloads

 

It frankly seems to me that some caveats exist regarding the scope of the  FSIS approval for the NGP standard (at least in FSIS's opinion ).

 

(2) As I understand NGP standard typically uses a threshold level of 0.9% GMO material stated to be in alignment  with EU regulations.

This assumption may not be fully correct.  For example –

 

http://www.food.gov....gm/gm_labelling

 

and (for certain situations) -

In order to address the LLP issue, a partial solution has been adopted by some countries. For example,

EU regulation No 619/2011, in force since July 2011, lays down the methods of sampling and analysis for

the official control related to GMOs in feed. This regulation sets a threshold level of 0.1 percent for feed,

a so-called “technical solution”. However, for food and seed this threshold is 0 percent.

(FAO, 2014)

 

 

(3) I noticed that the confidence level mandated for the sampling procedure in NGP standard is 90%. IMEX this is rather unusual, ie 95% is more common, although the exact choice is, AFAIK, arbitrary.

 

It is obvious that an enormous amount of work has been put into developing the NGP standard / website and the content transparency is rather impressive IMO for such an emotive  topic.

 

For information only, I noticed this (2010) critical survey of GMO issues within USA.  Accuracy unknown.

 

 The GE Scene,2010.pdf   313.37KB   22 downloads

 

Regarding yr accreditation query, maybe UKAS ? (if you can't beat them, ........)

 

Rgds / Charles.C

[SQFconsultant]

We have an auditor who would like me to tell him more about our non-GMO certification process. Our quality department does not have a non-GMO certification process; however, raw materials are identified/maintained via regulatory review.

 

Does anyone have any advice on how to respond? Should we implement a non-GMO certification process?

 

Thank you for your time. I am very nervous about this and do not know how to respond because I do not fully understand what the auditor is looking for. Any feedback is GREATLY appreciated!

---------------------

Dear D,

 

My advice on how to respond: "Mr/Ms. Auditor... thank you for asking, however we don't have a NON-GMO certification... followed by next question!

 

Seriously, if you don't have it how can you tell him/her about it.

 

From our client base we have a growing number of inquires for assistance on meeting the requirements for Non-GMO certification.  Based on our research we found that best one called The Non-GMO Project and that is the one we suggest our clients go for and the only one that we provide consulting on.

 

It would be helpful however if the Non-GMO Project folks could be a bit more helpful to consultants that are promoting their certification.

[hlehman02]

 

We have an auditor who would like me to tell him more about our non-GMO certification process. Our quality department does not have a non-GMO certification process; however, raw materials are identified/maintained via regulatory review.

 

Does anyone have any advice on how to respond? Should we implement a non-GMO certification process?

 

Thank you for your time. I am very nervous about this and do not know how to respond because I do not fully understand what the auditor is looking for. Any feedback is GREATLY appreciated!

---------------------

Dear D,

 

My advice on how to respond: "Mr/Ms. Auditor... thank you for asking, however we don't have a NON-GMO certification... followed by next question!

 

Seriously, if you don't have it how can you tell him/her about it.

 

From our client base we have a growing number of inquires for assistance on meeting the requirements for Non-GMO certification.  Based on our research we found that best one called The Non-GMO Project and that is the one we suggest our clients go for and the only one that we provide consulting on.

 

It would be helpful however if the Non-GMO Project folks could be a bit more helpful to consultants that are promoting their certification.

 

Agreed that if you don't have a cert. then you should not have to run it through an audit!

 

Since I am with the NGProject I will say a big "thanks!" and let oyu know I am also ready to listen to how we can be more helpful to consultants; especially ones promoting our certification! As an emerging standard, we certainly do need to make sure that we aren't cutting off comms with consultants so let me know.

 

best,

H

[BrionacVII]

Lately clients have sent me questionnaires wondering if our products are GMO or if we perform some kind of validation that effectively demonstrates that they are not. Interesting Topic.