You have developed and implemented your new Global Good Agricultural Practices program with your partners. Your partners have agreed to comply with the Agri-Chemical Hazard prevention requirements of the program e.g. pesticide, herbicides, and even the heavy metal standards. You have a Letter of Guarantee and signed an agreement for compliance.
They all also have provided their Global GAP or Primus Labs field audit reports. All audits scores are above 90%, happy days, right?
Are you receiving fresh or frozen agricultural products? It does make quite a difference due to the time it may take to obtain the testing results from a third party laboratory. Or are you going to depend upon the results from the partner’s laboratory?
What is the proficiency of the partner’s or third party laboratory? Did you try and run collaborative sample testing? How often are you expecting test results from your partner? Each lot? Monthly? Whether you realize it or not, you will be paying for any extra testing. You need to assure that the extra testing is for each different lot and the test results just did not have the lot number changed on the certificate of analysis.
Are you requiring the appropriate pesticide testing screen? Are you just testing for the chemicals used by the partner? Are you requiring a 100, 250 or 450 chemical screen? Do you include all four major pesticide groups in your screen? Heaven helps you if you do not take in account pesticide drift, contaminated water or soil, especially if you are organic.
So, if you have an internal testing program for the prevention of agrichemical contamination, are you testing for “show or go”, in other words, are you testing one sample per partner per year OR are you assuring that all lots are screened by you, partner or third party laboratory. In some cases, just getting one result as a year is a lot like getting a copy of an audit certificate and not bothering to read the actual audit report. Then again, testing every lot of product for agri-chemicals is extremely expensive and field application data review becomes increasing important.
When you do ask for the spray records for each field from the partner, will you then review which chemical was used, the amount and time before harvest application? If you do, will that be good enough?
Did you or are you constantly reviewing the import refusals and alerts for issues with your partners? Scan the horizon for potential issues prior to partner approval or to stop supply from the partner.
Does your partner supply to both the EU and USA? Each region has different allowable chemicals and limits for different crops. If you know a chemical not approved in the US is on the partner’s approved chemical list and you know from the spray records they used it, but did you choose to accept the lot of product as long as the testing method does not find it? Seems to be the same as shipping product from a facility that has positive Listeria food contact surface swapping results but negative product results.
Or when looking for the best partner, do you look for outside evidence that illustrates compliance to a greater standard due to past failures. For example, at one time Japan discontinued the supply of produce from China due to several pesticide contamination issues. Japan worked extremely close with China to identify and improve specific partners that could pass the Japanese certification program.
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