Hello, Long time lurker. USA
Residue Monitoring System- MRL
Currently switching from Global Gap option 2 to SQF v9 primary production modules 2, 7 and IPM addendum. Multi-Site.
It will be a super group after two entities merge into the new entity (whole other fun time). Overhauling everything right now.
Looking at how entity A (already SQF certified but will release its cert for the merge) did samples for their smaller operation doesn't work for us. While at the same time we feel the MRL sample size seem excessive with no legal exceedances noted in the history of either RMS program.
The residue monitoring system is one where there have been issues of interpretation on sample size in GG with auditors and CB.
SQF doesn't have any guidance when I have looked.
Previously it was set to the square root of each commodity of group members. For (not perfect) example 7 apple, 7 cherry and 7 pear. (both conv and organic sample lots taken)
Is there any real guidance on sample size?
Would providing the evidence of no incidences from the rms history's be allowed to factor in for a reduced sample size?
Note the growers have no decision on where their fruit goes to market. The warehouse tests the fruit, sales desk decides its MRLs are good for certain export markets.
side note:
It took forever to figure out FSMA requires just 1 water sample now, so orchards are set for 1 sample of water before harvest since SQF sides with legal regulation. Global gap required 3 and in the past FSMA was 4-5 samples.
Thank you in advance for your insight.
