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training nonGMO CBs

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hlehman02

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Posted 30 April 2014 - 06:50 PM

Hello,

Hopefully I have landed in the right area for some input. I am looking into creating a new set of interpretive guides and training for incoming CBs that have applied to certify to our standard - the Non-GMO Project standard. Having looked at how to ensure basic consistency across TAs, I am now turning to y'all to get input on this. We want all our CBs to be ISO 65 / 17065 certified and have some baseline competencies and experience in food safety and organics. The NGP standard relies on testing throughout the supply chain and is on a product by product basis. We are pretty demanding in terms of paying attention to microbial inputs etc, but we are focused on breaking ingredients down into high risk and low risk categories. We pretty much want documentation on all low risk with no need for testing and we want high risk items documented and have mandatory testing etc. Trouble is, we have had a problem with participants in our certification program unhappy with the variability of the process, being burdened with unnecessary documentation and / or testing on low risk ingredients, and an inability to address grievances with their CB. We don't want to compound this issue by bringing on more CBs without digging in with more training!

 

This is a HUGE topic, I know, but I am trying to find a balance where we are not micro managing a CB with insanely detailed requirements for processes but also not letting them come up with their own free form interpretation of the standard and relevant processes tht make it a nightmare for participants. For a little background detail: the NGP standard is new, the issue of GMOs is hotly contested, testing for changing GMOs and GM technologies like stacked traits is already problematic, and we pretty much follow the organic standard in regards to segregation and traceability. I have been talking with other standard owners about their experience, but our standard and our insistence on testing through the supply sets up for some unique issues. It is already a huge issue to confront the GMO issue in a supply chain for most producers, we don't want their experience with the CB to be overwhleming on top of that.

 

Okay, I am all ears!

H



fgjuadi

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Posted 01 May 2014 - 11:59 AM

I am not a standard owner, so I can't help you or answer your question at all,  but I will say our customer demand for certified non-GMO is *huge*, Sales won't get off my back!  You probably need more certifying bodies than two.   Testing was the most problematic and vague for me, although the process seemed shrouded in mystery.  Your presence here is that of an angel, filled with top secret non-GMO infos.  Other than micromanaging CBs, I'd be happy with a clearer definition of risk categories and testing frequencies along with a feedback & challenge process.


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cazyncymru

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Posted 01 May 2014 - 12:14 PM

I seem to be in an agreeable mood today, because I agree wholehearted with Magenta

 

Over the last couple of years, I'm being asked to justify a number of things and write policies and risk assessments;  aluminium, acrylamide, novel and to be honest, I have had to learn fairly quickly (and not always fully understood) about some of these things. I didn't even know that there was an ISO standard for GM's !!! :oops2:

 

I think we can help you, if you can help us

 

Can you tell us in laymans terms what the standard is all about, and we can tell you what we'd like to see from a CB?

 

Caz x



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hlehman02

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Posted 02 May 2014 - 05:24 PM

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.



fgjuadi

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Posted 02 May 2014 - 06:23 PM


 

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 ;)

 Personally, I would love to see a drinking contest between senior management and the auditors, with a mandatory karaoke round and "standard trivia".    Liquor factory's choice.

 

Cage fighting matches?   Mock trial!  Watermelon seed spitting / snail racing contest.  All night dance til you drop marathon.

 

I have a ton of serious answers,  but it's Friday Payday and I couldn't resist a lighthearted reply. 


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Snookie

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Posted 02 May 2014 - 10:13 PM

 Personally, I would love to see a drinking contest between senior management and the auditors, with a mandatory karaoke round and "standard trivia".    Liquor factory's choice.

 

Cage fighting matches?   Mock trial!  Watermelon seed spitting / snail racing contest.  All night dance til you drop marathon.

 

I have a ton of serious answers,  but it's Friday Payday and I couldn't resist a lighthearted reply. 

 

 

:roflmao:        :rofl2:  :roflmao:     :rofl2:     Magenta.....you Rock!!!   :rock:  


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fgjuadi

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Posted 09 May 2014 - 01:36 AM

Hi!
 

I didn't mean to kill your thread with my flippant remarks, here's a more for realz answer

 

It's mostly difficult because I am so far in the supply chain from the farm that I'm not sure what documentation I need for high risk.   Do I need a non-GMO statement (easily achievable)?  non-GMO in the spec sheet (easily achievable)?  PCR negative test results which follow the lot through a *ton* of hands (not feasible)?

 

For ex a major (>5%) ingredient with butter and corn syrup - Do I need proof that the corn to feed the cow who made the milk that churned into butter & the corn they made corn syrup of per lot + the ingredient manufacturer + non-GMO separation policies for each point in the chain + distributor + our own policies? 

 

Some tools that would really help me (but may be a lot of work for y'all) are

 

A calculator I can put ingredients & their sub ingredients in & get risk level and testing schedule

A table with ingredient, risk, and required documentation for supply chain level

A searchable vendor database where I can enter a vendor name a pull up a current certificate

 

As a nerd, I like numbers and measurable goals - ultra general standards or "as per your auditor's mood" turn me off of a standard pretty quickly.  Verifying by brand instead of product is annoying and adds another variable to manage. 

 

If I have a problem with an auditor, I'd generally contact the CB, not the standard owner.  I suppose if I had a standard I'd insist on training the auditors at first in one large "kick off" week .. in the bahamas :)  Okay, maybe at an exemplary factory for inspection training.  Annual "Train the trainer" for CBs after that.     I'd want a CB to have a solid dispute program, and report to me feed back specific to my standard.  I'd want a CB to rotate auditors so that the factory would be inspected with new eyes each visit.   


Edited by magenta_majors, 09 May 2014 - 01:37 AM.

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hlehman02

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Posted 09 May 2014 - 05:15 PM

Friday's comments were perfect, and this outline is even more helpful than you know!

 

thanks much for picking the thread back up again.

 

We run the verification product by product, are coming up with easier doc handling for low risk and high risk, and are beginning to get a real handle on making sure that there is consistency between all auditors instead of mood ;) I don't think we had a good handle on the mood issue until quite recently, and we are tidying up all the standard requirement documents for meeting threshold requirements.

 

The Non-GMO standard borrows most of its traceability and segregation details straight from the NOP organic standard, and I bet our documentation on that could be made clearer too...

 

Anything else you want to throw in here, I am happy to get.

 

~h







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