GLOBALG.A.P. Option 2 Producer Group Case Study: Berries and GRASP

What was the producer group’s starting point?

A cooperative of blueberry and raspberry growers farming under tunnels in Souss-Massa, the region around Agadir, with a central packhouse. This is a composite case: it brings together situations met in primary production projects, without describing any real group, grower or retailer.

The cooperative has about a dozen members. Most are small family farms that hire seasonal workers for the harvest, partly through a labour provider. Three members already held an individual GLOBALG.A.P. IFA v6 Smart certificate. The packhouse receives, sorts and packs the fruit of all members for fresh export.

An importer offers to list the cooperative with a UK retailer for the following season. The retailer’s written specification asks for three things: an IFA v6 certificate under the GFS edition, a GRASP letter of conformance, and a residue testing plan that complies with the limits applicable in Great Britain. The question put to the gap analysis: can the cooperative be certified as a group in time for that season, and on what conditions?

Which decisions set the scope?

Four decisions, made in writing before any procedure was drafted.

1. Option 2. The cooperative is a legal entity that already contracts with its members and markets their fruit. It can therefore be the only certificate holder, as the producer group rules require, with the approved members listed in an annex.
2. The GFS edition. It is the one the retailer names. It changes sampling: at least 25% of the members audited selected at random, at least 20% of the members audited during the cycle with no notification, and no sampling for high-risk members.
3. What to do with the three Smart certificates. A producer cannot register the same product under two options, individually and as a group member. The three members chose to move into the group for their berries.
4. The packhouse in scope. The central packhouse is a product handling unit of the group: it is audited every year while in operation, and GRASP applies to it as to an additional member.

That left the question that weighed most on the budget: high-risk classification. Under the GFS edition, a member is high-risk when a high-risk product is combined with a high-risk process. Berries are among the high-risk products, so everything depends on each member’s processes.

These decisions were taken for the safety of the fruit, not to reduce the sample. The classification remains the certification body’s, which examines products and processes; the group submitted its own analysis at registration.

How was the group’s management system built?

Starting from the roles the General Regulations require, then from each farm’s records. The group appointed a quality management system (QMS) manager, an internal QMS auditor and two internal farm auditors, independent of the farms they check.

The qualifications called for a real training plan. Under the General Regulations, an internal farm auditor must show, among other things, HACCP training, food hygiene training and, for crops, training in plant protection, fertilisers and integrated pest management; the auditor is signed off after a one-day practical audit training, observing two audits and one successful witness audit by a qualified auditor. No internal auditor audits their own work, and an internal QMS auditor cannot evaluate a producer they have advised in the previous two years.

For plant protection products, each member was checked against the phytosanitary index of ONSSA, Morocco’s national food safety office, crop by crop. For residue limits, the UK Health and Safety Executive states that the limits applicable in Great Britain also cover imported produce and may diverge from the EU’s: the testing plan was built on the limits of each target market.

How was GRASP prepared?

As a workstream in its own right, member by member. Under the GRASP General Rules, all IFA-certified members are registered for GRASP, and the sample the certification body assesses is the same as for the IFA audit. No member can therefore be ready “for IFA only”.

Three rules shaped the work:

• Morocco is classified as high-risk. The GLOBALG.A.P. list valid from 31 May to 31 December 2026 includes Morocco. In a high-risk country, the interview rules require workers to be present on the day of the assessment; under Option 2, the complete absence of workers in the farm sample is a non-compliance of the group’s system.
• The labour provider is in scope. GRASP v2 applies to any subcontractor that supplies labour for the main farming activities, such as harvesting; the group must make sure the provider meets the requirements.
• The national guideline applies. The Technical News of November 2024 lists Morocco among the countries where the GRASP v2 national interpretation guideline is mandatory.

The social pre-assessment found four recurring gaps: seasonal workers from the labour provider with no time records available to the member, a worker representative the crews did not know, a grievance procedure posted only at the packhouse, and a human rights policy never communicated to the labour provider. Each is checked through interviews and documents, and the bar is high: 100% of “Major Must” and at least 70% of “Minor Must” requirements in the first year.

What did the mock audit show, and what are the lessons?

The mock audit took place at the height of the harvest, on a sample drawn as the certification body would draw it, plus the high-risk members. It showed that the system held on the farms, but not yet at the boundary between the packhouse and the members.

Lessons for a producer group aiming for Option 2 with GRASP:

• The buyer’s specification sets out in writing the edition, GRASP and the residue markets before any work starts.
  
• Each member has chosen a single option for each of its products.
  
• The high-risk processes of each member and of the packhouse are listed, and the analysis is shared with the certification body.
  
• Internal auditors are qualified, trained and independent of the members they audit.
  
• Every member and the packhouse have been audited internally before the first certification body audit.
  
• The labour provider is under a GRASP contract, and its crews will be present on the day of the assessment.
  
• Traceability identifies the member on every crate, from plot to pallet.
  

The rules for each option are set out in our GLOBALG.A.P. IFA v6 guide; what drives a group’s budget, in our article on GLOBALG.A.P. certification cost. Further down the chain, the case study of a frozen berry plant seeking BRCGS certification shows how a plant checks the GLOBALG.A.P. edition of its growers.