15 OCTOBER, KÖLN GERMANY TABLE OF CONTENTS
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1 ROUND TABLE DISCUSSIONS GLOBALGAP SUMMIT 15 OCTOBER, KÖLN GERMANY TABLE OF CONTENTS A. SMALLHOLDERS 2 B. AUDITOR COMPETENCE AND TRAINING 3 C. OPERATIONAL HEALTH AND SAFETY AND SOCIAL RISK ASSESSMENT 4 D. INTEGRATED PEST MANAGEMENT 7 E. MICROBIOLOGICAL ISSUES 9 F. AQUACU LTURE ISSUES 10 G. LIVESTOCK ISSUES 11 Page 1 of 11
2 A. SMALLHOLDERS Experts: Reiko Enomoto and Jochen Neuendorff COMMENTS: Even if smallholders get certified, it does not mean that they can sell their products, as quantity and quality may not be sufficient to make it commercially viable. Smallholders often cannot maintain their certificates in the year after development funding is withdrawn. Maintenance of the QMS is (too) costly. Retailers should be involved from the beginning of a big project such as this. If not, all these smallholder projects would be struggles in isolation from the market. When the market demand is made clear, strategies also become clear (naturally). QUESTIONS: Is the Smallholder GLOBALGAP CPCC going to be another document that farmers have to read, on top of the current normative document? What happened to the smallholder proposal that was created during the conference in Frankfurt earlier in 2008? How can we take part in the GLOBALGAP s project on smallholder implementation tool development? Page 2 of 11
3 B. AUDITOR COMPETENCE AND TRAINING Experts: Jan Kranghand and Andrea Niemann-Haberhausen COMMENTS Mechanisms should be in place world-wide to control competence criteria. Stakeholders should set detailed competence/criteria and train auditors. GLOBALGAP Online training: good, but can be improved with more examples. CIPRO: Good idea, but CBs need feedback and time to move to the acceptable levels. Perhaps rely more on ISO The personal certification of the auditors/inspectors is the responsibility of the CBs. Feedback from the ABs are necessary There must be open discussion between GLOBALGAP and the CBs so that the CBs can contribute, have time to change and learn how to deal with the problems. The requirement for experience in each sub-scope + 2 years of experience is too much. Auditor qualification should be per scope (not sub-scope). GLOBALGAP (and all other scheme owners) should have guidance notes available for inspectors. GLOBALGAP could give more training practical training with local examples in the workshops and TTS. Training on local interpretations must be improved. If social questions will be included in the CPCC we need to put social auditing skills to the qualification requirements as well. Page 3 of 11
4 C. OPERATIONAL HEALTH AND SAFETY AND SOCIAL RISK ASSESSMENT Experts: Jenny Heise and Kerstin Uhlig QUESTIONS: asked regarding GRASP (GLOBALGAP Risk Assessment on Social Practices): 1. WHAT IS THE RELATIONSHIP BETWEEN GRASP AND THE GLOBALGAP SHRIMP-STANDARD? The Social Annex of the Shrimp standard is based on the GRASP criteria. Additional input from NGOs made sure that Shrimp specific criteria (i.e. relations with surrounding communities) are also reflected in the annex. The annex will be assessed in each Shrimp-audit. Results from the first years of implementation will be reflected in the next version of the Shrimp standard. 2. WHAT IS THE TIME FRAME FOR THE GRASP PROJECT? The now starting phase of the GRASP project began in August 2008 and is designed to run for 18 months, covering regional adaptation and implementation in at least 4 pilot projects. The first pilot project is scheduled for November 2008 in Spain. Other regions like Latin America, Africa and Asia will follow in WHAT IS THE RELATIONSHIP OF GRASP WITH OTHER SOCIAL INITIATIVES, AS SEDEX, SA 8000, BSCI AND ETI? HOW CAN DOUBLE CONTROLS BE AVOIDED? The GLOBALGAP Risk Assessment on Social Practice is not a full social audit and can not replace such an approach. GRASP is rather a tool that helps implementing a Social Management System in mainstream agriculture. Its findings can serve to assess whether a full social audit may be necessary. The synergies and terms of cooperation with other initiatives are important to be formalized, with a Memorandum of Understanding with BSCI already being in preparation. 4. WILL THE AUDITORS BE ESPECIALLY TRAINED? A training programme has been developed to train GLOBALGAP approved auditors to conduct GRASP Assessments. Before conducting such an assessment, the successful participation in such a training programme is mandatory for the auditor. The first GRASP training is scheduled to take place on October 31 st in Madrid, Spain. 5. DOES THE GRASP REQUIREMENTS COVER THE ILO CONVENTIONS? Yes, the requirements of the ILO conventions are covered in the 14 control Page 4 of 11
5 points of the GRASP Module. Additional to this, it covers the implementation of communication channels between workers and farm management, the correct payment of at least minimum wages and overtime and the schooling of all children living on the farm. Please directly consult the GRASP Module for more details. 6. HOW DO LOCAL LABOUR LAWS INFLUENCE THE GRASP REQUIREMENTS? The 14 control points of the GRASP module are formulated in a generic way, often referencing to national labour legislation. For their successful implementation, local implementation guidelines will be elaborated by GLOBALGAP and discussed with local stakeholders. 7. HOW IS THE GRASP MODULE CERTIFIED? The GRASP assessment will NOT form part of the accredited certification. The GRASP Assessments are conducted on a voluntary base in conjunction with the annual GLOBALGAP audit the additional audit costs are minimized. However, when a GRASP Assessment is conducted, its results will be made visible in the GLOBALGAP database. COMMENTS REGARDING GRASP: Regarding the project partners: include also exporters, wholesalers and traders in the project, as they are important to run the chain Role of public law enforcement: In some countries, the controls being already run by the government are very effective. It may not be necessary to implement the GRASP Module in such regions regional guidelines should make sure that the module and assessments are adapted as much as possible to local circumstances. Benchmarking: GLOBALGAP should open possibilities to benchmark already existing schemes with social modules to the GRASP module in order to avoid duplication COMMENTS REGARDING WORKER HEALTH, SAFETY AND WELFARE CHAPTER AF.3 CPCC Its implementation has been feasible without major problems. However, the issue of subcontractors is still not sufficiently clarified. A clear definition is needed on who shall be considered as a subcontractor (e.g. transport services?). It is difficult for the farms to have this information on subcontractors available on Page 5 of 11
6 the farms. It shall be made possible to directly send the auditor to the subcontractor s office. Further on, a definition needed on how to apply this control point to family members working on the farm. The scenario of shared labour shall also be addressed. Other CPCCs Guidance is needed on the issue of washing the protective clothing (AF 3.4.2). A case was described where workers were asked to shower with the protective clothing still worn. The definition of good practice may be helpful. Page 6 of 11
7 D. INTEGRATED PEST MANAGEMENT Experts: Karel Bolckmans and Ricardo Adonis COMMENTS: Develop a Guideline with examples to stimulate producers to change and start working with IPM. Guideline to be available as 1) Annex to the GLOBALGAP Control Point and Compliance document and 2) separate document on the GLOBALGAP webpage. Develop Management plans for IPM Change the level of the Control Points related to IPM from Minor Must to Major Musts. Although this is very strict because if the producer is surrounded by conventional producers he might not always be able to comply and therefore won t be able to get certification. Need to be very careful on these points. Identify and add other Control Points related to IPM, like nutrition to have stronger, more tolerant plants that requires perhaps fewer PPP applications. Reinforce specific IPM training: Producer level NTWG level not so easy Auditor/inspector level DISCUSSION: IPM is important and must be strengthened as much as possible while still remaining practical. The question remains whether one or all control points must be upgraded to Major Musts, or should the amount of activities in CB.7.2 to 7.34 be increased (that the producer must be able to show more than one activity per category). An analysis to determine if there are any specific challenges with complying with the current control points needs to be done (especially on CB.7.1 to 7.4) It would be ideal if the guideline were based on global knowledge (that means involving more experts from various countries) and than adapted for local application. GLOBALGAP cannot prescribe which specific practices a producer must implement. Globally only general principles can be provided. The situation of the different producers in the developed and developing world Page 7 of 11
8 must be taken into account as well as the huge differences between crops and pest, outdoor and indoor plants, climate (temp, humidity) differences even from year to year. The work of the CPWG in terms of how the guideline paper on how to minimise MRLs exceedance could be incorporated into V4. The roles of the NTWGs are important, but it must be remembered that these function on a voluntary basis. It is potentially true that the countries without NTWGs are also the countries where IPM is not as advanced and even if there is a NTWG in a country it does not necessarily represent all the products and further development of IPM guidelines within the NTWG might not help those who need it the most. A wider group of experts needs to be consulted (not necessarily part of the subgroup, only consultation). This should include, but is not limited to: Universities, IOBC, ECPA, PAN, consultants, etc. (USA (look at the Sysco checklist), Africa (perhaps Real IPM from Kenya who is GLOBALGAP members, India? China???) Page 8 of 11
9 E. MICROBIOLOGICAL ISSUES Experts: Richard Yudin and Xavier Cilla COMMENTS: Water quality is critical irrigation water, spray (plant protection product) solutions, as well as post-harvest washing water. What means are there to control the water quality of irrigation? A recommendation for a kill step and its documented efficiency can be incorporated into the standard. Transportation between producer and client is out of the scope of GLOBALGAP currently. Bad practices and no control during transportation is the cause for many of the microbiological contamination issues. Challenge with auditing practices off farm (moving into the supply chain) is the logistics can it be audited practically and what other auditor requirements are necessary? Organic compost and substrates need to be addressed, especially the use in sensitive crops such as lettuce. How can contamination by birds be controlled? Rapid Alert System: Is it robust enough to cover the issues on a global scale? Auditor competence and the knowledge relating to micro issues need to be re-evaluated. Cannot expect all auditors to be microbiologists. The Control Points and Compliance Criteria must be clear and cover a generic assessment of contamination on field level. A guideline for producers that explains the minimum of what have to be done on farm level has to be developed. A gap analysis of what is covered by BRC/IFS/SQF 2000 in terms of all aspects relating to micro issues is needed to see if GLOBALGAP can cover the black hole. Harmonisation of standards are important. Micro issues during field-packing must be strengthened How to control the contamination carried by birds? Risk categories: HACCP Risk categories were proposed in the presentation. It was commented that it might not be that easy with the huge crop list that GLOBALGAP has. What happens when a product changes its risk category? This will usually only happen when there is processing involved and this is beyond the scope of GLOBALGAP. The intended use of products are important: Drying of spices or herbs can have an impact and the scope of certification needs to be clear! Page 9 of 11
10 F. AQUACULTURE ISSUES Experts: Mark Nijhof and Sandhya Chaudhury COMMENTS Chain of Custody: Why only applicable to Aquaculture scope? Rainbow trout: evaluation of all systems inclusion requested for V4. Shrimp stakeholder involvement during history of development clarified. ISEAL requirement for public stakeholder consultation: GLOBALGAP follows the 120 days in two rounds requirement, currently for Tilapia and Pangasius. Positive view the fact that trial audits makes part of GLOBALGAP standard setting procedure. Tilapia: approach of sex reversion. WWF Tilapia draft that was recently launched requires that, all-male populations, is not to be allowed. Sex reversion not only obtained via hormones. Further clarification is needed about the requirement: either not use of hormones, or not sex reversion. Both WWF and GLOBALGAP will coordinate further investigations. Wild sourcing: Currently for GLOBALGAP Shrimp standard requirement for wild sourcing is strict in only wild sourcing. Brood stock needs refreshment from time to time. These criteria are considered in both GLOBALGAP Tilapia and Pangasius drafts and will be also considered in the Shrimp module in next edition update. Seedling criteria strictness with regard to only non-wild sourcing remains a main pillar of GLOBALGAP Aquaculture scope. Hatcheries: The water quality aspect is very important and comments are expected on these criteria during the current public stakeholder consultation in terms of applicability. Effluent discharge: How to plan the water quality parameters? GLOBALGAP clearly encourages best practices in Aquaculture activities. Pangasius: Concern about water quality sourcing, where in many locations the Vietnamese legislation is stricter than incoming water to the farms. Will the EU use GLOBALGAP as tool of approval? By when will Shrimp standard be worldwide able to be complied within a representative farmers group? Expected by Are there initiatives between FDA and GLOBALGAP? Yes. Request for new species: Sea bass and sea bream. Fin fish standard is a target for V4. Page 10 of 11
11 G. LIVESTOCK ISSUES Experts: Roland Aumüller and Dr. Dorit Boeckmann COMMENTS GLOBALGAP Livestock standards must be promoted within the retailer community. The Livestock Sector Committee must be promoted. Will V4 include new requirements on labelling and animal welfare issues? How much longer will that make the inspection and what will be the impact on certification cost? If animal welfare requirements are included, will they be higher or will it be compliance with legislation? Answer: it will be more than legislation. This is acceptable as long as the global nature of GLOBALGAP is kept in mind as not all EU legislation can be implemented everywhere. What is the consultation process for developing the animal welfare criteria? The Compound Feed Manufacturing standard is necessary. There is currently a problem in many countries with complying as the feed standards are not certified or benchmarked. What is the conclusion on GMOs? Can they be included in certification? Animal transport must be included as this is part of the processes that take place on farm. Antibiotics: A very hot topic in the UK. The responsible use of antibiotics must be described as it does show a benefit if used responsibly. Framework: Use antibiotics responsibly, only when needed. Aim should be optimum use for animal, human and resistance issues. There is a potential problem in the harmonisation of MRLs. A passport for each animal could be a solution. Genetic resistance of animals should also be taken into account when looking at the use of antibiotics and all other treatments. It was stated that all Dutch retailers will require GLOBALGAP certification Page 11 of 11
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