GLOBALG.A.P. Inspection Preparation: IFA v6 Checklist for the Souss

Where do you start when preparing for a GLOBALG.A.P. inspection?

With the self-assessment, on the official checklist of your edition, Smart or GFS. According to the General Regulations for individual producers, it is mandatory every year, before the certification body audit, and it covers all sites, products and processes in scope, packhouses included.

It is not filled in at a desk. It is done in the field, during activity: greenhouses, orchards, the plant protection product store, the packhouse, the crews’ toilets. Three rules make it useful:

• An evidence comment for every requirement that is non-compliant or not applicable, “Major Must” and “Minor Must” alike. “Not applicable” without a justification is the easiest finding to avoid.
• The completed checklist stays available on site at all times. The auditor reads it and cross-checks it.
• The compliance calculation is done before the audit. You need 100% of “Major Must” and 95% of “Minor Must” requirements. The number of non-compliances allowed is calculated on the applicable “Minor Must” requirements and rounded down: with 50 applicable requirements, 2.5 becomes 2.

In a producer group, the self-assessment is replaced by internal audits of each member and of the management system. Our GLOBALG.A.P. IFA v6 guide explains the options; this how-to applies to a producer or a packhouse preparing its audit.

Below, we quote the principles and criteria of the GFS edition for fruit and vegetables, version 6.0. If you are aiming for the Smart edition, check each point against its own checklist.

Which records will the auditor ask for?

Those that prove the system has run through the current season. For a first audit, you need records from the date of registration with the certification body, covering at least three months; records of a harvest before registration count for nothing. The IFA v6 control points require them to be kept for at least two years, or longer if the law requires it.

Test traceability on a real lot, in both directions, before the auditor does. The auditor will start from a pallet or an invoice and ask you to trace it back to the greenhouse and its treatments.

The certification body may offer a two-stage audit: an off-site document review no more than four weeks before, then the visit. This helps for a farm far from Agadir, but total audit time stays the same and everything is then verified on site.

How do you prepare the plant protection products section?

Start from Moroccan law, then the destination markets. IFA v6 requires that only products authorised in the country of production are used. In Morocco, placing agricultural pesticides on the market falls under Law No. 42-95, and the phytosanitary index of ONSSA (Office National de Sécurité Sanitaire des Produits Alimentaires, the national food safety office) lists registered products. In case of doubt, only registration or sales authorisation certificates are proof.

What the auditor almost always checks:

• Every product used is authorised for the crop and the target, and applied according to the label; an up-to-date list of products used, biocides and post-harvest treatments included, is kept.
• Every application is recorded, with the weather conditions at the time of treatment.
• The pre-harvest interval is respected, which the auditor checks by comparing the records with harvest dates.
• Storage has enough capacity, respects the label temperatures and has a procedure in case of accident.
• Empty containers are rinsed, never reused, kept in a secure place and then disposed of through the official collection scheme where one exists.
• Invoices make it possible to rule out illegal or counterfeit products.

Residues are handled through a risk assessment. IFA v6 requires the list of maximum residue limits (MRLs) for each target market, an assessment of the risk of exceedance per crop and evidence of compliance. The limits of the country of production apply even to exported produce: in Morocco, ONSSA’s MRL index is based on Joint Order No. 156-14. For the European Union, the Commission sets the maximum residue levels for all foodstuffs. Laboratories must work to ISO/IEC 17025, and a written action plan states what to do in case of exceedance.

How do you justify water management?

With a written risk assessment, then the analyses that follow from it. Several of these requirements are “Major Must”. The IFA v6 control points require:

• a food safety risk assessment of the water used in production and post-harvest, reviewed every year or whenever something changes;
• a water management plan;
• the abstraction permits issued by the competent authority, and compliance with their conditions;
• analyses at a frequency consistent with the risk assessment, and the corrective actions that follow the results;
• suitable water where it touches the product during or after harvest, recycled or treated water included;
• records of irrigation and fertigation volumes.

Under the GFS edition, water in contact with the edible part, or water used after harvest, is one of the high-risk processes. For a packhouse that washes produce, the risk assessment must therefore be particularly robust.

What should you prepare for workers and seasonal crews?

Evidence for every person on site, seasonal workers and subcontractors included. The IFA v6 control points on health, safety and welfare require a written risk assessment, health and safety procedures, basic training for all staff, accident and emergency procedures, first aid kits, at least one person trained in first aid, suitable protective equipment that is actually worn, access to drinking water, a clean place to eat and safe transport.

In the Souss, seasonal workers arriving mid-season are the classic weak point. Plan hygiene and safety training before they start work, recorded on the same day, with materials everyone can understand.

If your buyer asks for GRASP, prepare the social assessment too: in Morocco, which GLOBALG.A.P. classifies as a high-risk country, workers must be present on the day of the assessment. The evidence expected is set out on our GLOBALG.A.P., SQF and PrimusGFS hub, and the case study of a producer group preparing Option 2 with GRASP shows how to organise it.

Which mistakes make a first inspection fail?

Six mistakes keep coming back on farms and in packhouses:

1. A self-assessment ticked without comments. The auditor compares it with the field in the first hour.
2. Records started too late. A harvest brought in before registration cannot be certified.
3. A registered product, but not for that crop. Check the use in the phytosanitary index, not just the trade name.
4. Water analyses without a risk assessment. The frequency must follow from the risk, and every out-of-limit result must have a follow-up.
5. Seasonal workers with no record of training. They are the people the auditor interviews in the field.
6. A system that is only ready on the announced day. For subsequent audits, each producer has a 10% chance of an unannounced audit; under the GFS edition, it comes with no notice.

Checklist for the last two weeks:

• The complete self-assessment is dated, signed, commented and available on site.
  
• The compliance calculation gives 100% of “Major Must” and at least 95% of “Minor Must” requirements.
  
• Every plant protection product in stock and in the records appears in the ONSSA index for the crop treated.
  
• The application records are up to date, weather and pre-harvest intervals included.
  
• The list of residue limits for target markets and the exceedance risk assessment are up to date.
  
• Analysis reports come from laboratories working to ISO/IEC 17025.
  
• The water risk assessment, the management plan and the abstraction permits are available.
  
• A traceability test on a real lot has been carried out in both directions.
  
• Every seasonal worker on site has recorded hygiene and safety training.
  
• A person trained in first aid is present on every site in operation.
  
• For the packhouse: the ONSSA health authorisation or approval covers the activity.
  

To have this work checked by an outside eye before the certification body, see our audits and inspections. To budget the project, read what drives the cost of GLOBALG.A.P. certification.