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