To the General Manager and the contact person of the Quality Management

Transcription

1 SGF Am Hahnenbusch 14 b Nieder-Olm To the SGF/IRMA members: To the General Manager and the contact person of the Quality Management SGF International e. V. SURE GLOBAL FAIR Am Hahnenbusch 14 b Nieder Olm * Germany Tel (0) * Administration Tel (0) * IQCS/IRMA Fax (0) e mail: info@sgf.org web: August 22, 2012 SGF Certification from September 2012 Dear Sir or Madam, In our global industry, documentation of applied pesticides is an indispensable part of risk management. For many years, SGF/IRMA has provided successful support in this respect with the FRAPP initiative (Fruit Risk Assessment Programme for Pesticides). Meanwhile, FRAPP has become known and is appreciated by many organisations, including for example the European Commission, as an absolutely beneficial example of industrial initiative that is definitely worth supporting. It has been compulsory now already for a number of years for fruit processing companies to forward data to FRAPP pursuant to the implementing provisions of the Voluntary Control System. But in view of the fact that industrial reality does not always permit complete collection of all pesticide data, initially low minimum standards were stipulated for the documentation so as not to create unfair conditions with the certification process. However, in this day and age it is no longer contemporary and definitely risky to waive pesticide documentation completely, as indicated by the trend in other food branches. To explain: FRAPP aims to create a database about the use of all pesticides during the cultivation of fruit for processing. Statistical evaluation permits improved quality controls of specific fruits in specific regions on the basis of targeted analysis. Another, far more important aspect is that fruit processing companies are informed individually about the evaluation of the pesticides used in their products. Deviations in the national legislation become apparent between the production country and the importing country. It is possible to anticipate long term developments in the legal situation. The FRAPP participation certificate can be used to give customers proof of active risk management. To this end, please find enclosed once again a detailed presentation of the FRAPP programme in the FRAPP programme info. To support your proactive risk management with regard to product safety and the health image of processed fruit products without doubt two central points in our branch the SGF Executive Committee has decided to upgrade the SGF certificate in this respect. Mainzer Volksbank eg, SWIFT: MVBM DE 55; BLZ: KTO: IBAN DE /2

2 As from September 2012, successful certification will also require fulfilment of the following two criteria, in addition to the already known criteria: 1. signing of the enclosed declaration for the protection of consumer health and the branch image 2. submission of data for at least five main fruit suppliers for each type of fruit. Here it is necessary to name the substance used for a specific type of fruit together with the quantity of processed fruit. Prepared forms for entering the data can be downloaded in different languages from the website Analysis results are not required. Experience shows that companies who only supplied small data in quantities initially (because they cannot do otherwise) gradually expand the documentation in order to profit to the full from the benefits of FRAPP. Please also find enclosed a list of the advantages that you will have from participating in the FRAPP programme. You are kindly asked to take note of the enclosed declaration for the protection of consumer health and the branch image (as mentioned above) and to have it signed by the company management and returned to the SGF office as soon as possible (gladly by e mail to: moitrier@sgf.org or by fax: ). Needless to say, we are available to deal with any questions you may have, and we extend our thanks for your cooperation on behalf of the good image of our industry. With kind regards Alexandra Heinermann General Manager Enclosures: 1. Declaration for the protection of consumer health and the branch image 2. FRAPP programme information 3. FRAPP benefits Mainzer Volksbank eg, SWIFT: MVBM DE 55; BLZ: KTO: IBAN DE /2

3 Commitment for proactive protection of Consumer Health and Industry Image Safety and authenticity, both are basis for a healthy consumption of processed fruits and vegetables as well as for a good image of industrial fruit and vegetable products. Industrial processors are obliged to meet legal requirements for contaminants at all stages in the production chain from raw material to finished goods. In addition fruit processing participants of the Voluntary Control System of SGF/IRMA should take proactive actions to avoid problems caused by uses of chemical plant protection products. To minimise the risk for each individual producer and the image of the whole industry branch, pesticide documentation is obligatory according to SGF implementing provisions, paragraph 2.1.* By signing this commitment the company Company name: City: Country: confirms to be aware about the obligation for fruit processing SGF/IRMA participants to make reasonable and appropriate efforts to collect and to deliver data about applied chemical plant protection products. This concerns all pesticides and active chemical substances used during growing period of processed fruits. It is understood that data are handled confidentially and used in anonymous statistics of FRAPP (Fruit Risk Assessment Programme for Pesticides). Place, date Signature, stamp * Extract from SGF implementing provisions, paragraph 2.1.: Documentation of Pesticides and Plant Growth Regulators Companies processing fruit, fruit mash and vegetables require information from their pre suppliers with regard to the plant, fruit and vegetable treatment agents (pre and post harvesting treatments) used in fruit and vegetable cultivation and/or storage. This information must be documented. The documentation duty particularly applies to pesticides, including herbicides and growth regulators.

4 FRAPP (Fruit Risk Assessment Programme for Pesticides) Introduction a centralised strategy for a proactive food safety concept Since 2005 the Food Safety initiative FRAPP is collecting data about pesticide applications during the growth period for the fruit juice industry in the framework of the Voluntary Control System of SGF/IRMA. This data pool has been created with the initial intention to optimise analytical screening approaches. Due to very high blending rates in our industry for pesticide application a reasonable tree to bottle traceability is not possible in many cases; provided data would be too complex for suitable use in case of any problem. Therefore a mathematical approach was set up to provide a robust fruit and regional specific statistic of relevant safety parameters that have to be controlled. Nevertheless in a first step all individual data of applied substances must be compiled. Farmer Information about application of plant protection products Cooperative / Fruit Trader Fruit and regional specific Risk Matrix Fruit Processor = SGF/IRMA-Member Secondary Process Retail Consumer Information flow about applied plant production products from fruit cultivator to FRAPP database Today the FRAPP database contains information about 55 different types of fruits and vegetables growing in about 40 different countries. Beside a significant improvement of cost/benefit relation in quality control, the database provides also information about application of plant protection products which are not in accordance with European Safety Standards. Thus preventive and corrective actions can be carried out together with concerned companies. Collection of information about applied plant protection products Key information should be collected from farmers and fruit growers all over the world. Fruit processing companies play an important role as data trustee and they are the connection between agriculture structures and the industrial sector. In many cases fruits are purchased from very small suppliers or from collection points Page 1/3

5 representing a large number of individual farmers. The programme has the task to support the data collection and to provide solutions to overcome obstacles occurring in practice. The pesticides data collection is a particular traceability task in our industry. Different tools have been developed to simplify data compilation and transfer into the database. Language problems, a confusing international nomenclature for plant protection products as well as missing experiences with administration and utilisation of large amounts of technical data have been taken into account. Simple solutions are offered (see FRAPP Collection pesticide input form). The most important key of success is the awareness of fruit growers and fruit processors that risk assessment and risk management is necessary already at this early stage of the production chain to guaranty high quality, sustainable and healthy products of our industry. Development of infrastructure for data transmission During last years it became obviously that the success of FRAPP is closely linked to an intense and continuous communication with the IRMA members. Therefore the pilot project local heroes for the improvement of communication has been set up in Spain. There an independent and recognized pesticide laboratory represents SGF/FRAPP towards Spanish IRMA members. Separately from the routine control schedule of SGF the local hero contacts companies, explains the benefits and provides support for the collection and the data transmission. Partners could be e.g. research institutes, laboratories or consultants. Benefits for participating fruit processing companies Additional support and motivation is offered to FRAPP participants through a backflow of information in terms of the global, regional and individual agrochemical situation for a specific crop of interest. Such a comparison is precious knowledge for agronomists under different aspects, such as food safety, efficiency and cost effectiveness of own plant protection. Respective statistics are extracted regularly from the database and forwarded to fruit processors and their suppliers (see FRAPP feedback). The FRAPP feedback has become more detailed since last year comprising a differentiation between data of different years because in many cases data from the last season are the most relevant for the IRMA member. The feedback provides detailed information about the current legal status of applied pesticides. This is practical information giving additional motivation for FRAPP data collection. Worldwide the pesticide programme is joined continuously by new players and the permanently growing database has currently nearly 50,000 data entries. Example of FRAPP confirmation letter In principle the FRAPP feedback provides the opportunity to IRMA plants to demonstrate to their customers their commitment to safe and sustainable products. Since last year SGF has been distributing a document called FRAPP confirmation which proves the participation in the programme. Companies are recommended to ask their suppliers for this document. Page 2/3

6 Support for fruit growers and processors concerning legal requirements and active influence to the legislation process in EU A new proactive service has been started in summer FRAPP administration carries out a survey of scientific statements made by EFSA (European Food Safety Agency) and proposals for changes of MRL (Maximum Residue Levels) inside of the European Union. Due to the very complex and large amount of information which should be screened it would be impossible for most companies to do this on their own. Through a counter check of these proposals against information from the FRAPP database FRAPP can identify any company which could run into trouble if a specific MRL would be reduced. SGF/FRAPP informs companies individually and makes them aware of a problem which can occur in future. This enables the FRAPP participants to react on time. Official Experts (EFSA) Fruit Draft Preparation SGF / FRAPP (consultation of concerned producers) Draft Publication Revision 0 - X Comments from processing industry Publication of Regulation Processing Fruit Processing Fruit Furthermore, SGF with Company Processing Fruit Company Processing Fruit Company Processing Fruit Company Processing Fruit the support of AIJN (European Fruit Juice Associ Company Processing Fruit Company Processing Fruit Company Processing Company Processing Company Company ation) has built up personal contact to the EU Interaction of FRAPP information with the legislation process in the European Union commission which allows to put forward comments from the industry to the legislation process in Europe. Therefore IRMA members who get such early information from FRAPP should be encouraged to give their comment to SGF, which will be transmitted in a neutralised form. Fruit DG Sanco - EU Commission July 2012 SGF International e.v. Nieder Olm, Germany Page 3/3

7 Benefits for FRAPP participants Internal FRAPP Feedback - Always up-to-date information about MRL s (Maximum Residue Level) and status of pesticides in Europe - Information about applied pesticides not allowed in Europe or which will expire in the future. This enables corrective and proactive measures. - Analysis scope of laboratories can be optimised by comparison to the FRAPP data. - FRAPP feedback is suitable for the own HACCP system. - Producers of semi finished goods can use the FRAPP feedback for their own supplier assessment (supplier = e.g. farmer). - Comparison of own company data with regional data and data worldwide. Excellent support for agronomists to develop their spraying programme (e.g. information about expired pesticides). Early Information System about scheduled lowering of MRL - This enables proactive actions by informing concerned fruit suppliers or any other measure to avoid legal conflicts in the future. - Possibility of transmitting comments to the European legislator via the SGF about possible problems in agricultural practice and practices incompatible with international trade. External FRAPP Confirmation - This document can be provided to any purchaser of semi-finished goods as additional information to be used for the purchasers HACCP and their supplier assessment (supplier = fruit processor). - The participation in FRAPP improves the company s ability of a suitable risk assessment and risk management. It shows their commitment to the quality philosophy of the Voluntary Control System of the SGF. FRAPP Feedback (presentation only, data are not intended to be handed out) - Companies can show their commitment to a global, proactive and sustainable food safety concept through participation in the FRAPP programme. E. g. during third party system audits the benefits of FRAPP will become more evident and the work of data collection could be appreciated more easily.