Dear Scheme Manager, This is a special edition of the CB focusing only on the GRASP Add-On. This technical communication is uploaded to the CB Extranet and sent to the Scheme Managers of each approved and provisionally approved CB, to the Technical Committees, to the host of the National Technical Working Groups, to the GLOBALG.A.P. Board and to all Benchmarked Scheme Owners. You can ask us to add selected persons to the mailing list or to send this to all of your registered staff by sending your request to: Nadine Becker (becker@globalgap.org). More than 7,000 producers in around 20 countries participate already in the GRASP Add-On. The list of GRASP Observers on our website is constantly growing. GLOBALG.A.P. and the GRASP Stakeholder Committee are currently working on a revised version of the GRASP General Regulations and on an improved Checklist. We expect to publish the revised documents in 2015. In the meantime the GLOBALG.A.P. Secretariat wants to clarify some rules around the GRASP assessment. We are continuously working on the GRASP Add-on Rules your comments are welcome! TECHNICAL NEWS DECEMBER 2014 SPECIAL EDITION GRASP CONTENT 1 GRASP INTERPRETATION GUIDELINES... 3 1.1 AVAILABLE GRASP NATIONAL INTERPRETATION GUIDELINES... 3 1.2 GRASP IN A COUNTRY WITHOUT NATIONAL INTERPRETATION GUIDELINES... 3 2 GRASP RULES... 3 2.1. DEFINITION FOR CORE FAMILY MEMBERS... 3 2.2. GRASP NOT APPLICABLE FOR CHAIN OF CUSTODY (COC)... 3 2.3. ASSESSORS QUALIFICATION... 3 2.4. GRASP IN-HOUSE TRAINER... 4 3 DATA ACCESS: GRASP OBSERVER... 4 4 CLARIFICATION ON THE ASSESSMENT PROCESS... 4 4.1. PROTECTION OF PERSONAL DATA... 4 4.2. INTERVIEWS... 4 4.3. SELF-ASSESSMENT... 5 4.4. SAMPLING IN OPTION 2 FOR GRASP... 5 4.5. ADDING NEW GRASP MEMBERS TO A PRODUCER GROUP... 5 4.6. SUBCONTRACTORS... 5 4.7. PACK HOUSES... 5 Page: 1 of 6
4.8. MULTIPLE PACK HOUSES... 6 4.9. SUBCONTRACTED PACK HOUSE(S)... 6 4.10. UNANNOUNCED AUDITS... 6 4.11. CORRECTIVE ACTIONS... 6 4.12. INITIAL GRASP ASSESSMENT... 6 4.13. SUBSEQUENT GRASP ASSESSMENT... 6 Page: 2 of 6
1 GRASP INTERPRETATION GUIDELINES 1.1 AVAILABLE GRASP NATIONAL INTERPRETATION GUIDELINES There are currently 22 GRASP National Interpretation Guidelines published in our document center: à click here to view If you would like to develop a GRASP Interpretation Guideline or you are in the process of doing so, please note that the guideline needs to be validated by the GLOBALG.A.P. Secretariat and the GRASP Stakeholder Committee before publication. This template which is published on the website shall be used for developing a GRASP Interpretation Guideline. For further information, please contact Alexandra Denis: denis@globalgap.org. 1.2 GRASP IN A COUNTRY WITHOUT NATIONAL INTERPRETATION GUIDELINES Since December 2013 GRASP can be assessed in countries without National Interpretation Guidelines, if the CB applies with the GLOBALG.A.P. Secretariat and it provides evidence that the auditors/inspectors have additional qualification (experience with social auditing, à see GRASP General Regulations V 1.2 point 5.1). The CB shall provide a plan how to develop a National Interpretation Guideline. The application form is available in the scheme tracker of the CB Extranet. 2 GRASP RULES 2.1. DEFINITION FOR CORE FAMILY MEMBERS This is to define which workers have to be considered as employees and need a formal work contract. The current GRASP General Regulations define core family members as those relatives who are related in a direct line to the producer (this does not apply for employed company managers) and live in the same household as the producer. This definition includes parents, spouses, brothers/sisters and children, but does not include uncles, cousins or other relatives. GLOBALG.A.P. also accepts definitions of family members in National Interpretation Guidelines that relate to national labor legislation regarding the definition of family. If the company does not have any employees at any time of the year, the GRASP Add-on can become not applicable as a whole (e.g. a family-run business with no employees at any time of the year). In this case, all control points in the checklist shall be marked as not applicable and the fact that there are no employees shall be mentioned in the remarks. 2.2. GRASP NOT APPLICABLE FOR CHAIN OF CUSTODY (COC) The scope of GRASP will remain in primary production, so GRASP is not applicable with CoC. It is because the GRASP Add-On is based on the IFA standard that unlike Chain of Custodyincludes workers health and safety control points. 2.3. ASSESSORS QUALIFICATION In countries without a GRASP National Interpretation Guideline, auditors/inspectors without the additional qualifications as defined in the GRASP General Regulations V1.2, 5.1. can conduct GRASP assessments with the support of a social auditor. Requirements for social auditors (i) (ii) (iii) Minimum of 5 social audits in agriculture. Examples for accepted social audit schemes are: Fair Trade (FLO), SA8000, SEDEX SMETA, BSCI Primary Production, IMO Fair for Life and Experience in auditing labor issues in that country and Working language skills in the corresponding native/working language. Page: 3 of 6
The Certification Body must apply for an exception with the GLOBALG.A.P. Secretariat. The social auditor needs to provide proof of the required qualification to the GLOBALG.A.P. Secretariat. The social auditor needs to register in the GLOBALG.A.P. Database, receive a CB in-house training on GRASP and pass the GRASP online training test. The social auditor also needs to sign the GRASP assessment checklist. 2.4. GRASP IN-HOUSE TRAINER The concept of one GRASP In-House Trainer for each Certification Body was introduced instead of individual training of each auditors and inspectors. All GLOBALG.A.P. qualified GRASP auditors and inspectors can take the role as an In-House Trainer. The former GRASP face-to-face and online training for auditors and inspectors will be recognized. Please assign this role to one of your staff members in the User Management of the CB Extranet. The online training and the online exam for all auditors and inspectors remains mandatory. In 2015 GRASP will be included in the GLOBALG.A.P. Integrity Program, where the CBs' internal training processes will be checked. 3 DATA ACCESS: GRASP OBSERVER Currently all GRASP Observers see the full audit reports of all GRASP assessed producers and producer groups in the GLOBALG.A.P. Database. The GRASP Observer is a database user of a trader company who has signed the Terms & Conditions and Privacy Statement of the Bookmarking Application (general database access) and additionally the GRASP Terms of Reference (GRASP access). The GRASP Terms of Reference for GRASP Observers is the Annex III. of the GRASP General Regulation V1.2. The up-to-date list of the GRASP Observers is published on the GLOBALG.A.P. website. 4 CLARIFICATION ON THE ASSESSMENT PROCESS 4.1. PROTECTION OF PERSONAL DATA Employees have to agree that the auditor can access personal data of employees (e.g. contract, time records, pay-sheets). A template for that was developed by the Secretariat and translated into different languages. It is available in the GLOBALG.A.P. Documents Center (GRASP > Guidelines and supporting documents). Search for Declaration of Consent Personal Data - Sample. The template is available in several languages. Names and personal data (names of responsibles or employees) shall not be entered in the comment field of the GRASP Checklist. You can use instead the initials/other abbreviations, the position of the employee or internal codes/numbers assigned by the producer/company. 4.2. INTERVIEWS In order to ensure an appropriate interview setting, please inform the employees representative (ER) in advance about the interview: so that appropriate rooms and the persons you need to interview are available and that you can talk to persons without the company manager being present. The producer shall ensure that the representative is available on the farm on the date of assessment. Where the ER is not available, the assessment has to be conducted: - with the elected ER substitute or with a short-term nominated ER and putting comments (if there are missing documents, qualifications etc.) Page: 4 of 6
- Without the ER or substitute however, this GRASP Control Point (CP) has to be marked as not compliant This substitute shall be communicated beforehand to the Certification Body. The substitute cannot be part of the management or an external party. Also the substitute needs to be part of the workforce. Special rule: If a member of the management team is nominated as the ER, the CP is not compliant. 4.3. SELF-ASSESSMENT Currently the GRASP General Regulation requires that producer groups under Option 2 conduct a minimum of one internal inspection per annum of each GRASP registered producer within the producer group. A GRASP self-assessment by each member of the group is only required if it is an internal requirement by the group, but it is not a GLOBALG.A.P. requirement. However for Option 1 producers with GRASP, self-assessment is strongly recommended. This shall support the preparation of the producer for the external GRASP assessment. 4.4. SAMPLING IN OPTION 2 FOR GRASP Companies without employees (GRASP N/A) shall form part of the sample during assessments of Option 2 producers. The composition of the sample should reflect the percentage of family run businesses in the group. Example: A producer group has 100 members that register for GRASP. 20 companies have no employees. The CB takes the square root sample of the 100 producer members (that are 10 producers) and out of those 10 producers, two producers must be companies without employees. 4.5. ADDING NEW GRASP MEMBERS TO A PRODUCER GROUP For adding new GRASP members to a producer group within the 12 months of validity of an assessment the same principle as for IFA applies: If the new members are <10% of the members that are already in GRASP and are also <10% of the area in GRASP, they can be added without a new inspection. In any other case, the square root of the members shall be GRASP assessed. 4.6. SUBCONTRACTORS The minimum requirement is that producer and subcontractor agree in a contract that the subcontractor follows the GRASP requirements. The GRASP assessor shall be granted access to this contract which allows him to check the facilities and records of the subcontractor. Remarks shall explain the applicable subcontracting scenario. 4.7. PACK HOUSES If the producer group owns a pack house, the Certification Body enters the assessment result in the external checklist as one more member. Example 1: 25 producer group members in GRASP, producer group owns one pack house, 5 producer group members assessed (square root 25) and 1 pack house In the Form Client checklist the CB enters: 6. Example 2: Several producers own one pack house. The composition of the square root sample should reflect the percentage of producers with pack houses in the group, but at least one producer with a pack house shall be included. A producer with multiple pack houses shall always be included in the sample. Page: 5 of 6
100 producer group members in GRASP, 25 producers own pack houses: 10 producer group members assessed (square root 100), 3 producers with pack house shall be included in the sample. The results of the pack house assessments are included in the producers assessment checklist. In the Form Client checklist the CB enters: 10. 4.8. MULTIPLE PACK HOUSES The Certification Body conducts an external assessment with a sample (square root) of the pack houses. Multiple pack houses owned by one legal entity (one GGN) shall be included in the GRASP assessment within a maximum time frame of three years. If this is not fulfilled, for the producer group members there is no sanction by GLOBALG.A.P., however, whether this is accepted or not is the buyer s decision. Example 3: The producer group/one or more producers own multiple pack houses. There are 4 pack houses owned by one legal entity. The Certification Body checks 2 pack houses (square root). The Certification Body enters the number of the externally assessed members plus 2. 4.9. SUBCONTRACTED PACK HOUSE(S) If in a product cycle any subcontracted pack house has already been assessed by one Certification Body (producer sharing), the other Certification Body can accept the assessment result and does not need to reassess the pack house. 4.10. UNANNOUNCED AUDITS Contrary to the IFA General Regulations in GRASP, un-announced assessments are not required. 4.11. CORRECTIVE ACTIONS For corrective actions the same time period is set as in IFA. 4.12. INITIAL GRASP ASSESSMENT In case of non-compliances the producer then has 3 months (or less as agreed by the producer and CB) from the end date of the assessment to undertake corrective actions to rectify the situation before the final assessment results are uploaded to the GLOBALG.A.P. Database. The CB shall upload the GRASP Checklist within a maximum of 28 calendar days after closure of any outstanding non-compliances. 4.13. SUBSEQUENT GRASP ASSESSMENT In case of non-compliances the producer then has 28 days (or less as agreed by the producer and CB) from the end date of the assessment to undertake corrective actions to rectify the situation before the final assessment results are uploaded to the GLOBALG.A.P. Database. Have the non-compliances been corrected, the corrected GRASP Checklist will be uploaded to the GLOBALG.A.P. Database. The CB shall upload the GRASP Checklist within a maximum of 28 calendar days after closure of any outstanding non-compliances. Have the non-compliances not been corrected, the GRASP Checklist with all non-compliances, outstanding corrective actions and respective remarks will be uploaded to the GLOBALG.A.P. Database. This is then the final assessment report which is also issued by the Certification Body to the producer/producer group as the Proof of Assessment. For further questions, support or help, please feel free to contact Alexandra Denis (mailto:denis@globalgap.org?subject=grasp assessment guideline). Page: 6 of 6