I am thanking you already for starting feedback. Non-GMO has prioritized bringing on CBs as fast as we can as the demand for certification has rocketed -as you already know! Trying to revamp our "Requirements for CBs guide" and the "Interpretive guides" AND bring on CBs as fast as possible is the biggest fire we have.
The big goal for the standard is to help create a non GMO supply chain. This is a right to know issue and, for many, is also a health/hazard/environmental issue. The project focuses on right to know because it is a common ground even when fights over the safety of GMOs rage on. We utilize the european standard and testing threshold though the standard is also designed to begin implementing a more stringent threshold when and where it can be omplemented.
The feedback and challenge process development is something that we completely dropped the ball on and it is on my plate to remedy this as if my life depended on it. We are setting up methods for participant feedback directly to the project AND are going to require that the CBs have a feedback process in place. We are also looking at best means for grievance resolution and what to do if/when that process between participant and TA fails. All your thoughts appreciated on this one 
The risk categories are, broadly, low and high.
Low risk ingredients just need documentation for traceability - NGP is looking at standardizing the type/content of forms that CBs should use to help participants out and to help suppliers out as getting requests for letters and not a solid form seems to be causing some real nosebleeds for participants and suppliers. Low risk items are easy to track because they have never been candidates for GM...though that is something we watch with great care as the candidates for GM are "weird."
High risk is actually has two categories: moderate and high. You can see this breakdown here: http://www.nongmopro...re/what-is-gmo/
That said, there is no test we can do for animals for GMO directly so they are essentially in the high category by default because of feedstocks.
The standard is geared to drive testing to the most efficient but critical points of the chain. All our labs are ISO 17025, but variation of accreditation for certain test types often gets participants in to conversations with the CB about which lab is best for their product.
Any suggestions if there should be tighter guidance or documents on this for CBs is welcome.
Now, the real rub is that some ingredients have to be broken down into parts to trace GMO - yeast is a big one on our radar because most yeast production is done using a corn based substrate that is GMO AND produced itself with GMO enzymes, vitamins of course, dairy because of the way dairy is pooled... and we know this is something that most participants are thinking about for the first time and it causes stress. We have pretty rigorous testing req's because processed ingredients will often not trip an action threshold for GM - like soy lecithin - but the unprocessed soy itself is likely GMO.
Our standard has borrowed a lot of the traceability and segregation requirements from international organic standards, but we are not really a process based standard. NGP is product oriented and appropriate testing and accuracy is what we wrestle with a lot. Testing - real time PCR - is required for high risk category items and the sampling req's are per lot over the course of the certified period (annual renewal required). The sampling and testing schedules are variable to accomodate all sizes of participant's supply chain.
- Seed and Other Propagation Materials (see sections 2.7 and Appendix B): 0.1%.
- Human Food, Ingredients,Supplements, Personal Care Products, and other products that are eitheringested or used directly on skin: 0.5%
- Animal Feed and Supplements: 0.9%
- Packaging, Cleaning Products, Textiles and other products that are not ingestedor used directly on skin: 0.9%
The outline of testing is here, and sampling info too: http://www.nongmopro...ing/guidelines/
I will take any thoughts on this outline as to its clarity, usefulness for participants etc because...you guessed it...I need to go through it and see what kind of revisions I can make to it! I am wondering if this particular doc should be supplied as part of the "welcome" package for all participants because it seems that the CB is not covering this adeqautely upfront.
