GTP certification scheme - Control Union Code... · GTP certification scheme ... Code Section 2:...
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GTP certification scheme GTP certification scheme Good Trading Practices for safe, transparent and reliable supply version 1.3A - April 2014
Transcript of GTP certification scheme - Control Union Code... · GTP certification scheme ... Code Section 2:...
GTP certification schemeGTP certification schemeGood Trading Practices for safe, transparent and reliable supply
version 1.3A - April 2014
Version 1.3A April 2014
Changes highlighted
NOTE: Although this Standard may be translated into various languages for the convenience of users, the English version remains the definitive reference document in the event of any dispute.
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CONTENT
1. INTRODUCTION ....................................................................................................................................... 5
1.1 The European GTP Code main purpose and structure .................................................................... 5
2. SCOPE AND DEFINITIONS ........................................................................................................................ 7
2.1 Scope and boundaries .................................................................................................................... 7 2.1.1 Trade operators in the food-processing industry .......................................................................... 8
2.2 Legal definitions ........................................................................................................................... 10
2.3 Other definitions .......................................................................................................................... 11
2.4 The regulatory requirements ....................................................................................................... 13
3. Code Section 1: Good Hygiene Practice Recommendations for Collection, Storage, Trading and/or Transport Operators ....................................................................................................................................... 14
3.1 Chapter I - General Good Trading Practices .................................................................................. 14 3.1.1 Management responsibility ......................................................................................................... 14 3.1.1.1 Management commitment, responsibility and policy .............................................................. 14 3.1.1.2 HACCP team leader: responsibility, authority and communication ......................................... 14 3.1.1.3 Management review ................................................................................................................ 14 3.1.2 Resource management ................................................................................................................. 15 3.1.2.1 Human resources ...................................................................................................................... 15 3.1.2.2 Infrastructure ........................................................................................................................... 16 3.1.3 Maintenance ................................................................................................................................. 17 3.1.4 Traceability ................................................................................................................................... 17 3.1.5 Documentation ............................................................................................................................. 18 3.1.6 Food and feed safety monitoring plan ......................................................................................... 19 3.1.6.1 Sampling and analysis requirements ........................................................................................ 19 3.1.6.2 Laboratories requirements ....................................................................................................... 22 3.1.6.3 Monitoring plan on dioxin in fats, oils of vegetable origin and products derived thereof for use in feed ……………………………………………………………………………………………………………………………………………..22 3.1.7 Non-conforming products ............................................................................................................ 25 3.1.8 Rework .......................................................................................................................................... 26 3.1.9 Waste ............................................................................................................................................ 26 3.1.10 Glass policy ............................................................................................................................... 27 3.1.11 Crisis management – Withdrawal and recall for safety reasons ............................................ 27 3.1.12 Internal audits .......................................................................................................................... 27 3.1.13 Complaints ............................................................................................................................... 28 3.1.14 Management of monitoring and measurement equipment .................................................. 28 3.1.15 Corrective actions .................................................................................................................... 29
3.2 Chapter II- Good Hygiene Practices for Trading Operations ......................................................... 30 3.2.1 The Domain ................................................................................................................................... 30 3.2.2 Registration of operators ............................................................................................................. 30 3.2.3 Requirements for purchasing ....................................................................................................... 30 3.2.3.1 Sourcing from assured sources................................................................................................. 30 3.2.3.2 The gatekeeper procedure ....................................................................................................... 30 3.2.4 Recording of movement ............................................................................................................... 34 3.2.5 Labelling and accompanying documents ..................................................................................... 34 3.2.6 Quality monitoring or Stock Inspection ....................................................................................... 34 3.2.7 Goods with specific regulations ................................................................................................... 34
3.3 Chapter III- Good Hygiene Practices for Collection / Receipt Operations...................................... 36 3.3.1 The External Environment ............................................................................................................ 36 3.3.2 Receipt of goods ........................................................................................................................... 36 3.3.2.1 Crop deliveries by farmers ........................................................................................................ 36
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3.3.2.2 Control at receipt ..................................................................................................................... 36 3.3.3 Pre-storage and Drying ................................................................................................................. 37
3.4 Chapter IV- Good Hygiene Practices for Storage Operations ........................................................ 38 3.4.1 The premises ................................................................................................................................. 38 3.4.1.1 The construction or modification of storage and handling premises and galleries ................. 38 3.4.1.2 The layout of the storage and handling premises and galleries ............................................... 38 3.4.1.3 Storage of samples (own samples or ordered by the product owner) ..................................... 39 3.4.2 The pits, handling and sorting equipment ................................................................................... 40 3.4.3 Traceability ................................................................................................................................... 40 3.4.4 Packaging ...................................................................................................................................... 40 3.4.5 The Waste ..................................................................................................................................... 40
3.5 Chapter V - Good Hygiene Practices for Dispatch/Delivery and Transport Operations ................. 42 3.5.1 General rules (applying to all kinds of transport) ........................................................................ 42 3.5.2 Own road transport ...................................................................................................................... 45 3.5.2.1 General rules ............................................................................................................................ 45 3.5.2.2 Infrastructure ........................................................................................................................... 46 3.5.2.3 Basic requirements ................................................................................................................... 46 3.5.2.4 Loading compartments ............................................................................................................. 47 3.5.2.5 Loading ..................................................................................................................................... 47 3.5.2.6 Transport .................................................................................................................................. 47 3.5.2.7 Unloading ................................................................................................................................. 48 3.5.2.8 Cleaning .................................................................................................................................... 48 3.5.2.9 Traceability and registration ..................................................................................................... 48 3.5.3 Road transport carried out by a subcontractor (chartered or hired trucks) ............................... 49 3.5.3.1 By a carrier with a GTP certificate or equivalent/recognised ................................................... 49 3.5.3.2 By a carrier without a GTP certificate or equivalent/recognised certification ......................... 49 3.5.4 Transport via inland waterway, by sea and by train ................................................................... 50 3.5.5 Road Transport for which third parties are responsible (such as EXW or FCA or FOB sales) ..... 51 3.5.6 Minimum requirements for Road Transport: Cleaning Regimes ............................................... 52 3.5.6.1 Introduction .............................................................................................................................. 52 3.5.6.2 Acceptance of the order and cleaning regime ......................................................................... 52 3.5.6.3 Check during loading ................................................................................................................ 53 3.5.6.4 Cleaning .................................................................................................................................... 53 3.5.6.5 Monitoring and measuring ....................................................................................................... 54 3.5.6.6 Registration .............................................................................................................................. 54 3.5.6.7 Corrective actions .................................................................................................................... 54 3.5.6.8 Cleaning regimes and sequences............................................................................................. 55
4. Code Section 2: Application of the HACCP System ................................................................................ 68
4.1 HACCP - Hazards Analysis and Critical Control Points ................................................................... 68
4.2 Prerequisites ................................................................................................................................ 68
4.3 HACCP Team ................................................................................................................................ 68
4.4 Product Specifications .................................................................................................................. 69
4.5 Purchasing Process ....................................................................................................................... 69
4.6 Definition of Process Steps ........................................................................................................... 70
4.7 Hazard Analysis / Identification (CODEX principle 1) .................................................................... 70
4.8 Determination of Critical Control Points (CODEX principle 2) ....................................................... 70
4.9 Establishing Critical Limits (CODEX principle 3) ............................................................................ 70
4.10 Monitoring (CODEX principle 4) ................................................................................................... 71
4.11 Preventive / Corrective Actions (CODEX principle 5) .................................................................... 71
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4.12 HACCP System Reviews (CODEX principle 6) ................................................................................ 71
4.13 Documentation (CODEX principle 7) ............................................................................................ 71
REFERENCE 1. ARE YOU IN/OUT OF THE GTP TRANSPORT CERTIFICATION (VERSION 1.0) .............................. 74
REFERENCE 2. LIST OF GTP EQUIVALENT AND RECOGNISED SCHEMES .......................................................... 74
REFERENCE 2.1. GTP EQUIVALENT SCHEMES .................................................................................................. 74
REFERENCE 2.2. SCHEMES RECOGNISED BY GTP/COCERAL ............................................................................. 75
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1. INTRODUCTION Placing on the market safe food and feed products is first and foremost a question of good management practices at each stage of the food and feed chain from primary production to final processing. It is therefore the responsibility of each operator in the food and feed chain to implement good practices to ensure the safety of the goods that he handles. Regulation (EC) No 183/2005 on feed hygiene as well as Regulation (EC) No 852/2004, on the hygiene of foodstuffs acknowledge the positive contribution of good hygiene practices to achieve the objectives laid down in the EU food and feed safety legislation and encourages the development of national or Community guides to good practice by food and feed business sectors, in consultation with any interested party.
1.1 The European GTP Code main purpose and structure
The European Union produces on average some 300 mio t cereals, 16 mio t oilseeds and 2.5 mio t protein crops. Moreover, the EU imports some 10-15 mio t cereals, 15 mio t oilseeds and 35 mio t feedstuffs. Over 20 mio t of grains are exported to third countries. The marketing of this production as well as imports and exports are done by the members of COCERAL. COCERAL is the voice representing the European cereals, rice, feedstuffs, oilseeds, olive oil, oils and fats and agro-supply trade. The members of COCERAL are the national trade organisations of most of the EU Member States, who for their part represent collectors, distributors, exporters, importers and agribulk storers of the above mentioned commodities. The members are composed of essentially private traders and in some countries also farmers' cooperatives. Furthermore, COCERAL has associate members in Switzerland and Serbia. The GTP Code, to be applied voluntarily, constitutes a progress tool supporting collection, storage, trading and transport operators in the day-to-day management of the food and feed safety; it was written by and for collection, storage and trade professionals, in collaboration with the other parties concerned (partners of the industry, control administrations etc.) to help them to:
Comply with good hygiene practices relating to operating sites, premises, equipment,
transport, waste and staff. Identify risks which have a decisive influence on the consumer's safety and establish
appropriate procedures for controlling them based on the principles of the HACCP system (hazard analysis, critical control points).
The Code is built around 4 complementary and autonomous modules (with the exception of the module on transport) allowing us to identify the covered activities carried out by one or more operators themselves or by a sub-contractor:
Trading Collection
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Storage Dispatch / delivery including road, river, sea or rail transport
These GTP modules are complemented at the end of this document by a list of GTP-equivalent and/or recognised certification schemes to be fulfilled mandatorily by operators.
Non-binding annexes to the GTP Code aiming at giving further detailed guidance to operators on how to fulfill specific legal requirements and good trading practices, can be found in separate documents.
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2. SCOPE AND DEFINITIONS
2.1 Scope and boundaries The present European GTP Code (hereafter referred to as the “Code”) proposes good hygiene practices for operators whose activity consists of collecting, storing trading and transporting cereals, oilseeds, protein crops and other plant products as well as by-products resulting from them intended to be used as food and/or feed by professional users (farmers or stock breeders), manufacturers of primary processing (maltsters, millers, feed compounders…) or other traders.
The Code applies to all operators carrying out the mentioned activities included in or with Europe.
The Code is not applicable to farmers with own storage facilities. Nevertheless, farmers with storage facilities are welcome to voluntarily apply the good hygiene practices described in the present Code. It does not cover either the commercial characteristics of the products as they are an integral part of the contractual provisions.
Road transport activities alone cannot be certified under this Code.
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2.1.1 Trade operators in the food-processing industry
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All of the technical processes are developed with a view to trading the goods with the
COCERAL GTP code of practice.
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2.2 Legal definitions
Accreditation: attestation by a national accreditation body that a conformity assessment body meets the requirements set by harmonised standards and, where applicable, any additional requirements including those set out in relevant sectorial schemes, to carry out a specific conformity assessment activity (Regulation (EC) No 765/2008)
Batch (or lot): an identifiable quantity of food and feed determined to have common characteristics, such as origin, variety, type of packaging, packer, consignor or labelling, and, in the case of a production process, a unit of production from a single plant using uniform production parameters or a number of such units, when produced in continuous order and stored together (Regulation (EC) No.767/2009)
Cereals: list of products as per Chapter 10 and 11 of Council Regulation (EEC) No 2658/87 as last amended
Certification: third-party attestation related to products, processes, systems or persons (Commission Communication on EU best practice guidelines for voluntary certification schemes for agricultural products and foodstuffs)
Food (or foodstuff) : Any substance or product, whether processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans (Regulation (EC) No 178/2002).
Feed hygiene: Means the measures and conditions necessary to control hazards and to ensure fitness for animal consumption of a feed, taking into account its intended use (Regulation (EC) No 183/2005).
Food Hygiene: Means the measures and conditions necessary to control hazards and to ensure fitness for animal consumption of a feed, taking into account its intended use (Regulation (EC) No.852/2004)
Feed materials: means products of vegetable or animal origin, whose principal purpose is to meet animals’ nutritional needs, in their natural state, fresh or preserved, and products derived from the industrial processing thereof, and organic or inorganic substances, whether or not containing feed additives, which are intended for use in oral animal-feeding either directly as such, or after processing, or in the preparation of compound feed, or as carrier of premixtures (Regulation No. 767/2009);
Hazard: Biological, chemical or physical agent in, or condition of, feed with the potential to cause an adverse health effect (Regulation (EC) No 178/2002).
Operator (food/feed): means the natural or legal persons responsible for ensuring that the requirements of food and feed law are met within the food and feed business under their control ((Regulation (EC) No 178/2002 and Regulation (EC) No.183/2005).
Oilseeds: list of products as per Chapter 12 of Council Regulation (EEC) No 2658/87 as last amended, entries 1201, 1204, 1205, 1206, 1207, 1208 of this chapter.
Protein crops: list of products as per entries 0713 and 0714 10 00 of chapter 7 of Council Regulation (EEC) No 2658/87 as last amended, entries 1201, 1204, 1205, 1206, 1207, 1208 of Chapter 12 as well as entries 2302, 2303, 2304 and 2306 of Chapter 23 of this Regulation.
Risk: A function of the probability of an adverse health effect and the severity of that effect, consequential to a hazard (Regulation (EC) No 178/2002).
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Traceability: Ability to trace and follow a feed or substance intended to be, or expected to be incorporated into a feed, through all stages of production, processing and distribution (Regulation (EC) No 178/2002).
Undesirable substances: Any substance or product, with the exception of pathogenic agents, which is present in and/or on the product intended for animal feed and which presents a potential danger to animal or human health or to the environment or could adversely affect livestock production (Directive 2002/32/EC).
2.3 Other definitions
Accredited Laboratories: any laboratory which is accredited according to ISO/IEC 17025.
Aflatoxins Mycotoxins produced by Aspergillus species of Fungi, mainly A. Flavus, A. Parasiticus and A. Nomius.
Aspergillus Very common type of mould, the control of which is of great sanitary and economic importance to the food-processing industries. Several species are toxigenic.
Bin Individualized grain storage unit of varying capacity, in which cereals and oilseeds are stored.
Bringing into line with contractual standards: Preparation of the grains according to the contractual specifications (assembly, grading, cleaning).
Calibration: Operation used to check that a measuring device indicates a precise value via an appropriate procedure.
Certified sources / Assured sources: food and feed materials originating from suppliers which are certified against an equivalent or recognised food and/or feed safety quality assurance as laid down in the list of equivalent/recognised schemes at the end of the present Code.
Collection (as used in this CODE): Receiving section of the raw material. Control point: Point, stage or procedure which ensures the hygienic control of a
process. C.C.P. (critical control point) in accordance with standard XP V 01-002: Stage at
which a control measure can be applied and where it is essential to prevent or eliminate a hazard jeopardizing the safety of foods or bring the safety to an acceptable level.
Cleaning Operation which aims to remove various impurities (husks, straw, soil etc.) which have a negative effect on the grains’ storage life. The cleaners work on the principles of suction and/or grading (gratings).
Corrective actions: Actions to be carried out when the results of the monitoring applied to the C.C.P. indicate a loss of control.
Contaminant: Any biological or chemical agent, any foreign matter or any other substance which is not intentionally added to a product which could compromise its safety or healthiness
Contamination/Cross-contamination: The undesired introduction of impurities of a chemical or microbiological nature or foreign matter during production, sampling, packaging or repackaging, storage or transport.
Critical limit (or critical threshold): Criteria which distinguishes acceptability from non-acceptability
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Control measures (or preventive measures): Actions or activities which can be implemented to prevent or eliminate a hazard which jeopardizes the safety of foods and feed or bring it to an acceptable level.
Grading: Mechanical operation which sorts through a given species to ensure compliance with the customer’s specifications (example: grading of brewing barley).
HACCP (Hazard Analysis Critical Control Points): System which identifies evaluates and controls significant food and feed safety hazards
Hazard analysis: Measure consisting in gathering and assessing the data on hazards and the conditions that lead to their presence to decide which of them are significant in terms of food and feed safety and should therefore be taken into account in the HACCP plan.
HACCP plan: Document prepared in compliance with the HACCP principles to control significant food and feed safety hazards in the food industry segment considered.
Handling equipment: System used for mechanically or pneumatically moving the grain in bulk.
Hopper: Small capacity bin in which goods are stored for a short time. Inter-bin transfer: Operation which consists of transferring a mass of grains from one
bin to another, for example to homogenize them or to prevent solidification. Pesticide treatment: Operation which consists of applying pesticides in solid, liquid
or gas form on grains or onto the silo walls. Maintenance: Maintenance consists in keeping a tool in working order so that it can
carry out the service for which it was designed. Two types of maintenance are practiced: Corrective, which consists in repairing as required, and Preventive which is planned, scheduled.
Mycotoxins: Toxic metabolites produced by certain species of mould which are dangerous to humans and to animals that consume the food and feed on which this mould has developed.
Monitoring: Action which involves carrying out a scheduled series of observations or control parameter measurements to assess whether a C.C.P. is controlled.
Nebulization: process consisting of coating the moving grain with an extremely fine mist, it ensures the pesticide treatment is applied more consistently than with spraying of an environment.
Normalized methods: methods which are published as international, EU or national standards.
Official laboratories: national reference laboratories performing analysis of official samples in accordance with internationally approved procedures or criteria-based performance standards and use methods of analysis that are normalized or, as far as possible, have been validated. The activities of reference laboratories should cover all the areas of feed and food law and animal health.
Operating method: Specified method for carrying out a task pH (hydrogen potential): Unit between 1 and 14 characterizing the acidity (< 7) or
alkalinity (> 7) Pathogenic: Something which causes diseases. Pests: Birds, rodents, insects and other animals able to directly or indirectly
contaminate foodstuffs and feedstuffs. Pit: Receipt equipment in which the grain falls by gravity. Procedure: Specified method of carrying out an activity or process.
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Raw material: Basic substance in its natural, modified, or semi-processed state, used as an input to a production process for subsequent modification or transformation into a finished good.
Record: Document recording results obtained or providing evidence that an activity has been carried out.
Rework: utilization of non-conforming and returned materials suitable for re-processing (e.g. from rejects, customers’ returns or spillage).
Smell: Abnormal odour (other than the grain’s normal odour). Specifications: Informative or contractual document between the supplier and the
customer which determines the quality objectives of a product or service and criteria for assessing this quality (hygiene requirements etc.).
Silo thermometry: System used to measure the temperature in the mass of a bin using sensors.
Sorting: Mechanical operation which sorts between two different species (example: sorting of a batch of wheat containing rape).
Thermodynamic activity of water (Aw): Concept introduced in 1936 by Lewis who talked of the “Activity of Water” (hence the universally used abbreviation Aw). It concerns the water available in foodstuffs for microorganisms. The activity of pure water is equal to 1.
The 5 Ms method [the five words below begin with M in French]: Mnemonic method used in order to be thorough in research. For each stage in the silo diagram, the team asks itself the question: “Does a hazard stem from the Raw material entering the stage, the Equipment used for the stage, the labour used in this stage, the Environment (working environment) or the Method (of working)?”
Validated methods: methods which are not (yet) normalized but which have been validated as a procedure compatible with requirements of chapter 5.4.5 of standard ISO/IEC 17025
Verification: Application of methods, procedures, analyses and other evaluations in addition to those used for monitoring, to determine whether the HACCP plan is complied with.
Ventilation: Operation aimed at cooling the grain and maintaining it at a sufficiently low temperature to ensure its good storage. Ventilation is carried out via the forced circulation of the ambient air towards a mass of cereals (the air is forced or extracted using a ventilator, sent to the grain via pipes, then distributed in the mass by a distribution shaft system).
2.4 The regulatory requirements The European Union has revised all of its food and feed legislation to implement a single, transparent hygiene policy applicable to foodstuffs as well as feedstuffs and all food and feed business operators. The good practices set out in this Code originate from the application of the HACCP method and meet the requirements of the “food and feed hygiene regulations”. The main regulations taken into account in the drafting of this code are listed in Annex 5.
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3. CODE SECTION 1: GOOD HYGIENE PRACTICE RECOMMENDATIONS FOR
COLLECTION, STORAGE, TRADING AND/OR TRANSPORT OPERATORS
3.1 Chapter I - General Good Trading Practices
3.1.1 Management responsibility
3.1.1.1 Management commitment, responsibility and policy
The operator must be committed to the implementation of the Code in order to help ensuring food and feed safety of products. The operator must ensure that responsibilities and authorities are defined, documented and communicated within the organisation.
The operator must:
Establish a food and feed safety policy, ensure that objectives are established and communicate the policy throughout the organisation
Ensure that these objectives and policies are in compliance with this Code and regulatory requirements
Define and document the scope of the HACCP system, by identifying the product categories, processed used and outsourced activities which are covered by the system.
3.1.1.2 HACCP team leader: responsibility, authority and communication
Management must appoint a HACCP-team leader who, irrespective of other responsibilities, must organise the work of a HACCP-team and must have the responsibility and authority to:
Ensure that the management system is established, implemented, maintained and updated in accordance with this Code
Report directly to the organisation’s management on the effectiveness and suitability of the management system
The operator must train the staff in charge of the development and maintenance of the HACCP plan and adequate records of such training must be available. Training can be done by competent and experienced internal staff if available.
The HACCP-team leader must be a management representative or have direct access to management.
Management must provide adequate resources for the establishment, implementation, maintenance, updating and control of the food and feed safety management system. Adequate communication must be in place to inform the HACCP team (leader) of significant changes in products or processes.
3.1.1.3 Management review
The management must document verification measures taken to ensure that the food and feed safety management system is working effectively. These must include planning, implementation and monitoring of processes which demonstrate product conformity.
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Monitoring processes must include collection of measurements, analysis of data and, if relevant, measures to improve the effectiveness of the system.
A documented procedure must define the structure(s) to identify and manage corrective measures, including:
Preventive measures Analysis of the cause of the non-conformity Definition of the corrective measure Tracking of the realisation of the measure Verification of the effectiveness of the measure, where appropriate.
All of the above steps must be demonstrable by e.g. records or minutes of meetings.
Annually, the management must review the implementation, effectiveness and validity of the food and feed safety management system by evaluating:
Actions resulting from previous management reviews Results of internal and external audits Results of the HACCP-verification Complaints and other customer feedback Implementation of major corrective and preventive measures Changes that could have an impact on the validity of the food and feed safety
management system.
The output of the review must address:
Conclusions on the implementation, effectiveness and validity of the food and feed safety management system
Actions and objectives to improve the food and feed safety management system.
The report of the review must be readily available.
3.1.2 Resource management
3.1.2.1 Human resources
A. Organisational chart
The operator must have an organigram at each site defining the tasks and responsibilities in the framework of this scheme. This document should also give the contact details of the person responsible for GTP.
B. Competency, awareness and education
All personnel carrying out activities affecting food and feed safety must be competent and have the appropriate education, training, skills and experience according to the job description. Training programs should be routinely reviewed and updated, where necessary.
The management must:
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Identify and define clearly the necessary skills and competences for personnel whose activities have an impact on food and feed safety in the job description;
Provide the necessary education and/or training according to the job description to ensure and maintain the fulfillment of these necessary skills;
Ensure that personnel responsible for monitoring food and feed safety processes are trained in proper monitoring techniques and the necessary actions to be taken when there is a loss of control of the processes;
Evaluate the effectiveness of the activities above; Ensure that the personnel are aware of the relevance and importance of their
individual activities in contributing to food and feed safety; Ensure that personnel are aware of the necessity of effective communication; Maintain appropriate records of education, training, skills and experience of all
personnel having an impact on food and feed safety.
Staff executing the commercial operations must be aware of the internal management and recording procedures, evolution in rules and commercial uses, the legislation concerning the contaminant thresholds and, more generally of hygiene, traceability, sampling and analysis rules.
C. Behaviour at work The management must ensure that:
Instructions relating to compliance with this code must be available to staff by the most appropriate means
Maintenance instructions for internal and external services must be in place stating the need for systematic cleaning after maintenance work and ensure that they are implemented
Appropriate work wears such as protective clothing and safety footwear should be provided where necessary and maintain them in hygienic conditions
Smoking, eating and drinking must be banned in the product handling and storage areas and staff must be reminded of this obligation with signs and instructions
Visitors and externals must be made aware of and respect hygiene rules in the visited areas and sign an appropriate form.
3.1.2.2 Infrastructure
The management must provide facilities and equipment of the appropriate lay‐out, design,
construction and size, be such as to avoid contamination, cross‐contamination and any generally adverse effects on the safety of foods and feeds.
A. The premises, other facilities and product handling areas
The management must provide appropriate work environment in line with local, National and European Regulations to achieve product conformity.
The management must provide, where necessary, ceilings and overhead fixtures designed, constructed and finished to prevent the accumulation of dirt and to reduce condensation,
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the growth of undesirable microorganisms and the shedding of particles that can affect the safety and quality of food and feed materials.
If necessary to keep rooms free of excessive steam and condensation, ventilation of sufficient capacity must be provided.
Water, steam and air used in food and feed materials manufacture must be of suitable quality.
The management must be sure that the water or the steam which is used during the cleaning of the food and feed materials is safe for animals. The management must ensure that the water or steam used should not oppose any harm to the health of the animals.
Sanitary facilities for the staff must be provided and they must be maintained and well cleaned.
Changing rooms for staff or private cupboards must be provided.
Appropriate lighting of the premises must be installed.
Non-drinking water must be distributed in a separate pipeline system.
Drainage facilities must be adequate for the purpose intended; they must be designed and constructed to avoid the risk of contamination.
B. Equipment
The management should provide equipment, located, designed, constructed and maintained to suit the collection, storage, transport and trade of safe food and feed materials. Where applicable, equipment must be placed away from walls to allow easy access for cleaning and to prevent pest infestation.
3.1.3 Maintenance
The operator must provide planned maintenance at his facilities under his control and covered by the scope of the present Code. A maintenance program must be in operation and address all relevant areas and equipment. Maintenance activities must not provide any safety risk for food and feed materials. A record must be kept of the work carried out. Lubricants used have to be food grade, where applicable.
3.1.4 Traceability
The traceability of food and feed materials must be established at all stages. Food and feed business operators must be able to identify any person from whom they have been supplied with a food and feed materials. To this end, such operators must have in place systems and procedures which allow for this information to be made available to the competent authorities on demand.
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Food and feed business operators must have in place systems and procedures to identify the other businesses to which their products have been supplied. Food or feed which is placed on the market or is likely to be placed on the market must be adequately labelled or identified to facilitate its traceability, through relevant documentation or information in accordance with the relevant requirements of more specific provisions.
3.1.5 Documentation
The operator must draw up a documentation system which aims to ensure proper traceability of food and feed materials. The documentation of the food and feed safety system required by the present Code must include the following:
Documented statements of the involvement of the management in the food and feed
policy and objectives; A hand book or quality manual; Documented procedures required by the GTP scheme; Documents required by the operator for the achievement of effective planning and
implementation of the different modules of this Code; Records required by the GTP scheme; All relevant legally required permits, records and certificates required by law.
The documents required by the present Code must be controlled. To this end, a documented procedure must be implemented in order to:
Approve documents with regard to their appropriateness prior to their submission Assess documents, to update them as required, and to reapprove them (e.g. in case
of technical changes); Ensure that changes and the current editing status of documents are made visible Ensure that valid versions of the appropriate documents are available for the various
work areas in which the activities are carried out; Make sure that documents can be found at any time, that they are easy to read and
that they are and remain easy to recognise; Ensure that documents of external origin are marked and that their distribution is
controlled; Avoid the unintended use of obsolete documents and to ensure that they are
suitably marked in case they have to be stored for whatever reason.
All above mentioned data must be reported to the operator and documentation must be kept for minimum 3 years, unless otherwise specified by law.
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3.1.6 Food and feed safety monitoring plan A plan for monitoring the identified hazards that can affect the safety of new and existing products and/or the processes must be defined, documented and duly implemented by the operator (see Section II of the present Code).
3.1.6.1 Sampling and analysis requirements
The operator must draw up and implement a sampling and analysis plan based on its own risk assessment carried out by the staff and based on the HACCP system. The operator determines what analysis and how often analysis are to be performed in order to guarantee that safety of food and feed materials is controlled and that compliance with the legal norm is ensured. This evaluation is carried out according to latest technical and scientific developments. The HACCP study also takes into consideration the impact of the agricultural raw materials and the role played by the storage/processes. The product's final destination and the data from monitoring plans are also considered. The trader is expected to have a clear and documented HACCP approach for the selection of suppliers (see also paragraph 4.5), the need to monitor the various products traded on a yearly basis and take the appropriate additional measures for maintenance of the gatekeeper principle as soon as the traded food or feed materials enter the GTP and/or equivalent/recognised good practices chain. Unless otherwise specified by law or by a specific GTP monitoring protocol (e.g. GTP addendum 1 on aflatoxin B1 monitoring in maize from south and Eastern Europe), sampling should be done as per rules and conditions such as those described in the GAFTA n° 124 in case of grains, meals and food or feed products and/or as per FOSFA rules in the case of vegetable oils or oilseeds, or as per other commonly used national or local sampling rules recognised/acknowledged by the sector. The placing on the market of grains, seeds and other food and feed materials and their by-products requires sampling and analysis based on the quantity of product marketed. As the quantity of products increases, the number of samples to be tested per ton will proportionally decrease. The below-mentioned formula may be used to calculate the minimum number of analysis to be carried out for each identified hazard (on a yearly basis). This formula is based on the volume and makes use of the following two criteria: Severity (S) and Frequency (F)
Formula = √
Frequency (F) corresponds to the hazard's appearance, and Severity (S) refers to the consequences of the hazard on the consumer's food and feed safety. Contamination,
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survival and multiplication factors may also be considered to quantify the severity (see also annexes 1, and 2 of the present Code).
The value for (F) and (S) are quantified using a score of 01 to 3 depending on the (very) low, medium or high scale of the two respective criteria. The risk score therefore ranges from 0 to 9 as a result of the multiplication between the two criteria
Risk Assessment Frequency (F)
Very low (0) Low (1) Medium (2) High (3)
Severity (S)
Low (1) 0 1 2 3
Medium (2) 0 2 4 6
High (3) 0 3 6 9
Guidance The operator may give the standard value of 1 for Severity (S) and Frequency (F). For undesirable substances and contaminants (e.g. heavy metals, veterinary medical products, pesticides, mycotoxins, microbiological contaminants), the operator applies a fixed Severity score of 2 or 3. Dioxin, salmonella and aflatoxin are typically ranked as 3 and other contaminants may be ranked as 2. The standard value for frequency (F) may be increased or decreased according to the following considerations:
- History; - Recent incidents; - Seasonal influences and/or weather conditions; - New source / new suppliers; and - Chance of recontamination (e.g. microbiological parameters).
Although the formula is to be used for each hazard on a yearly basis, the practical examples provided below list the number of analysis to be carried out are based on the following standard volumes per type of transport: 50 000 tons for seagoing transport (Panamax), 2000 tons for inland waterway and 1500 tons for rail transport (train).
Scenarios (S x F)
Number of analysis to be carried out for each hazard
Seagoing waterway transport
(50 000 tons)
Inland waterway (2000 tons)
Rail transport (1500 tons)
1x0 or 2x0 or 3x0 0 0 0
1x1 0,75 0,15 0,13
2x1 1,05 0,21 0,18
3x1 1,29 0,26 0,22
2x2 1,49 0,30 0,26
3x2 1,83 0,37 0,32
3x3 2,24 0,45 0,39
1 The new monitoring plan for purchase from primary producers in GTP Code Version 1.3A is highlighted in yellow and is
applicable as from 1st
September 2014
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The results found when applying the formula should always be rounded up to the nearest whole number (e.g. o.x --> 1 analysis).
For road transport, the number of analysis to be carried out is risk-assessed by the operator case by case, based on relevant information at disposal of the GTP operator. The number of analysis may increase or decrease depending on whether the products are coming from the same origin/supplier or not. The number of analysis must be such as to ensure that the operators place on the market safe goods.
When directly sourcing from primary producers, at receipt, the operator will perform a plan for monitoring which is based on his risk analysis (see table ‘risk assessment’ page 20) and inspired by its HACCP taking into consideration at least the parameters as defined under 3.2.3.2.E. The monitoring plan shall be based on the formula defined in point 3.1.6.1. If the operator participates in a sectorial or a regional monitoring plan, the total volume of the monitoring plan can be taken into account in defining the level of monitoring; on the condition the (anonymous) results are available to all participants. In case a company wishes to apply a company’s based monitoring plan, this is only possible on the condition that the number of analysis per identified hazard is at least equal to the number of analysis identified by using the formula defined in point 3.1.6.1.
In case an operator is sourcing directly from primary producers, the operator may choose to not perform the above-mentioned monitoring (partly or completely) on the received primary products, but to apply this monitoring (partly or completely) later on in the process on the outgoing products in order to verify both, the hazards already present in the primary products as well the non-controlled hazards introduced during the processes.
In case of testing of microbiological criteria, the following requirements must be followed in order to ensure that sampling is aseptic.
Taking samples - Be as close as possible to the vessels holds from a moving stream
Instruction to superintendents - Be as close as possible to the vessels holds from a moving stream - Use hand scoops disinfected with alcohol - Whenever the scoops are not used, keep them in a protective bag, provide sterile gloves for staff - Keep the increment samples in PE (polyethylene) bags
Equipment - Hand scoop of stainless steel. - 95% alcohol to clean the scoop to the flame - Bottles: sterile glass or polythene tube of 500 cc - Smaller: polyethylene bags of 1.5 liter
Samples - Keep the samples as described above. - Mix them in a sterile place and under sterile conditions - Forward them in a sterile bottle or a bag as described above - Avoid contact with heat / sunlight / humidity / the facilities - Forward the samples immediately for analysis
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3.1.6.2 Laboratories requirements In the frame of the HACCP risk analysis:
External testing and analysis must be performed by laboratories accredited according to ISO/IEC 17025 applying appropriate official normalized methods covered by the scope of the accreditation, whenever available. All laboratories must only be used if they are regularly and successfully participating in inter-laboratory proficiency tests (ring tests).
For in-house testing, the laboratories or testing facilities must use all methods that are traceable to officially normalized methods, whenever available, or quick testing methods as used and recognised by the food/feed sector.
Unless otherwise specified by law or by a specific GTP monitoring protocol (e.g. GTP addendum 1 on aflatoxin B1 monitoring in maize from south and Eastern Europe), the operator is indeed not required to use official methods and he can choose the most appropriate methods adapted to the accuracy of controls that he defined in his HACCP risk analysis.
The operator must set up an appropriate record and documentation system adapted to its monitoring plan.
3.1.6.3 Monitoring plan on dioxin in fats, oils of vegetable origin and products derived thereof for use in feed
The following GTP minimum monitoring requirements on “dioxins” are applicable to traders of vegetables oils and their derived products2, pure or in blends and intended for use in feed3. The importers of these products must be registered under Feed Hygiene Regulation. Food and Feed Business Operators must in any event comply with the maximum levels for dioxins, dioxin-like PCBs and non-dioxin-like PCBs in feed and foodstuffs as per relevant legislation referred to in annex 5 of the GTP Code. Sampling and analysis taken from homogeneous and clearly identified lots must be performed by relevant accredited laboratories according to the legal requirements. Laboratories performing dioxin analyses are required by law to report results exceeding the maximum permitted limits referred to in Directive 2002/32/EC not only to the Feed Business Operator but also to the relevant competent authority. This does not exempt the Feed Business Operator from his obligation to inform the competent authority. When the laboratory having performed such analysis is located in a third country, the operator will inform the competent authority of the Member state where he is located and provide evidence that the laboratory performs the analysis in accordance with the legal requirements.
2 Products derived from vegetable oils” means any product derived from crude or recovered vegetable oils by oleochemical
or biodiesel processing or distillation, chemical or physical refining, other than the refined oil. Glycerol, lecithin and gums are excluded though. 3 Although oils and fats may be of animal and mineral origins, only oils and fats referred to in the tables below are covered
by the GTP certification. Operators must also be aware that the mixture of at least two feed materials is considered by regulation (EC) No 767/2009 as a compound feed, thus out of the GTP certification.
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If the operator can demonstrate that a homogenous consignment is bigger than the maximum batch size according to paragraph 2 of Regulation (EU) 225/2011 (dioxins in feed monitoring) and that it has been sampled in a representative way, then the results of the analysis of the appropriately draw and sealed sample will be considered as acceptable. The minimum monitoring frequency varies according to the type of products at stake as summarised in the table below:
Category
1 2 3 4
Not allowed for feed
Products which require further processing before use in the food/feed chain
Product for use in feed Product for use in feed
Monitoring frequency
Dioxin possible: 100% monitoring
Dioxin possible: 100% monitoring
Dioxin highly unlikely: monitoring based on the company’s internal risk assessment
Table 1: Crushing of oil seeds and refining of oils, including imported products
Processes and products
1
Description
Pal
m
Pal
m k
ern
el
Rap
e s
ee
d
Soya
be
an
Sun
flo
we
r se
ed
Co
con
ut2
Gro
un
dn
ut
Lin
see
d
Mai
ze
She
a ke
rne
l
Saff
low
er
Sesa
me
Wal
nu
t
Co
tto
nse
ed
Cas
tor
be
an
Oth
er
oils
Crude oil/fat
Oils and fats from pressing/extraction
4 4 4 4 4 2 4 4 4 4 4 4 4 4 4 2
(partially) degummed oil/fat
Oil treated to remove gums/lecithin
4 4 4 4 4 4 4 4 4 4 4
Lecithin 4 4 4 4 4 4 4 4 4 4 4
Tank bottom
Viscous, solid remains on the bottom of a tank
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
Physical refining
Refined oil/fat
3
Oils/fats treated to remove colour, odour and off taste
4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 3
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Fatty acid distillates
Distillate from deodorization of physical refining
3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3
Hydrogenated palm fatty acid distillates
Palm fatty acid distillate, hydrigenated
3
Chemical refining
Refined oil/fat
Oils/fats treated to remove colour, odour and off taste
4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 3
Soap stock and acids oils
Caustic soda refining and soap stock splitting
3 3 3 3 3 2 3 3 3 3 3 3 3 3 3 2
Deodistillates
4
Distillate from deodorization after chemical refining
2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2
1
In case of mixing of products (for instance fatty acids from physical and chemical refining), the monitoring regime of the fraction with the highest monitoring frequency applies 2 Based on actual monitoring results, low levels of dioxin could be present in crude coconut oil. The source can be
environmental pollution. Further, a potential source of dioxin can be the drying of copra (the dried meat of the coconut from which the coconut oil is obtained). 3 Edible fats includes interesterficated fats, hardened and refined fats and olein/stearin fractions
4 Deodistillates from chemical refining are not to be sold for feed applications without further processing, unless dioxin
analysis shows that this product complies with legal limits set
Table 2: Oleochemical processing and biodiesel production, including imported products
Fats from vegetable used as raw material for oleochemical or biodiesel production
Processes and products
Use
d C
oo
kin
g O
il
Pal
m o
il
Rap
ese
ed
oil
Soya
be
an o
il
Oleochemical production
By products 1 2 2 2
Biodiesel production
Fatty acids with methyl esters (fatty matter)1 1 1 1 1
Glycerol2,3
1 4 4 4
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1 Fatty acids with methyl esters (also called fatty matter) collected after methanol recovery at biodiesel production are
prohibited for feed purposes since lipophilic additives used in biodiesel production concentrate in the fatty acids. 2
Glycerol from biodiesel, produced from raw material that is approved for animal feed is allowed for use in feed. 3 Glycerol from biodiesel, produced from raw material forbidden to use in animal feed (like UCO) are forbidden to use in
feed.
Table 3: Fat blending4,5
Processes and products Vegetable
mixture
Mixing of lots
Mixing of lots that all have dioxin analysis and 100% separation between feed/food and technical
products. On the location dedicated piping and tanking are
used
4
Mixing of fats with at least one of the lots missing dioxin analysis
2
Additionally, for products imported and/or marketed for feed uses in the EU, the concerned operators shall:
Keep all products intended for feed physically separated from products intended for other purposes unless these products comply with article 4(2) of EC Regulation (EC) No 852/2004 and with annex 1 to Directive 2002/32/EC;
Label the concerned products with a clear indication whether they are intended for feed or other purposes. If the producer has declared that a certain batch of a product is not intended for feed or food use, such a declaration shall not be subsequently altered by any operator at a later stage of the chain
Ensure that containers which are to serve for storage or transport of blended oils of vegetable origin or products derived thereof intended for use in feed shall not be used for the transport or storage of products other than these unless the products comply with the requirements of “Regulation (EU) No 225/2012 on dioxins in feed monitoring” or of article 4(2) of Regulation (EC) No 852/2004 and annex I to Directive 2002/32/EC;
Ensure that the products will be kept separate from any other cargo where there is a risk of contamination, and, if this separate use is not possible, ensure that the containers shall be efficiently cleaned so as to remove any trace of product if those containers were previously used for products not meeting the requirements of the “Regulation (EU) No 225/2012 on dioxins in feed monitoring” or of article 4(2) of Regulation (EC) No 852/2004 and annex I to Directive 2002/32/EC.
3.1.7 Non-conforming products
The management must establish a documented procedure for dealing with products which do not comply with intended requirements.
4 Pay attention that certain mixtures of fats/oils may be derived from animal products and therefore they are out of the
GTP scope 5 If a mixture of fats/oils is considered as a compound feed (mixture of minimum two raw materials for animal feed), it is
out of the GTP scope
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The procedure should include:
Identification Segregation of affected batches Provision for disposal of products where appropriate Evaluation of the root cause of the non-conformance Documentation of non-conformance, root cause analysis, corrective actions and
verification Recording of internal information of relevant parties.
Responsibility for review and disposal of the non-conforming product must be defined.
A non-conforming product should be reviewed in accordance with documented procedures and actioned in one of the following ways:
Rework Reclassification (e.g. as a product intended for industrial use) Dispensation (not in case of a food or feed safety issue) Rejection and subsequent destruction or disposal according to waste disposal
procedures.
3.1.8 Rework
The management must handle rework in a way to ensure that product safety, traceability and regulatory compliance are maintained. Rework can only be done by a GTP operator if such a rework is included in the GTP certification scope.6 The approval and use of reworks (e.g. from rejects, customer returns or spillage) must be considered within the HACCP system. Potential reworks which are not approved for the intended use are managed in accordance with non-conforming product and in case they become waste material, they should be dealt with according to waste disposal procedures, unless they are directed to an industrial application.
3.1.9 Waste
The operator must control waste and materials containing hazardous levels of contaminants or other hazards. These must be disposed of in an appropriate way to prevent contamination of the product.
Where necessary to prevent such hazards:
Dispose in a manner which avoids contamination Store waste in closed or covered containers at defined waste accumulating areas Waste containers should be clearly marked Waste must be disposed of according to local Regulations and in a manner which
ensures that equipment and the safety of food and feed materials are not affected.
6 This rework handle by the GTP company may include the following actions on the products: sieving, calibrating, cleaning,
drying and fumigation.
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3.1.10 Glass policy
The operator must have a program in place to prevent, control and detect contamination. It must include measures in order to prevent physical, chemical and microbiological contamination.
The lighting at all the facilities must be flame proof and shatter proof.
Any glass from the facilities that is not required must be removed.
All remaining glass should be logged and checked on a weekly basis to ensure no breakage has taken place.
In case of any incident related to glass, a responsible person must be placed in charge of the clean-up operation to ensure no glass can contaminate any other part of the facility. Any material contaminated must be clearly identified and destroyed.
3.1.11 Crisis management – Withdrawal and recall for safety reasons
The management must implement a documented withdrawal and recall procedure that ensures customers, regulatory authorities and the concerned certification body can be informed promptly in the event of any irregularity that may adversely affect food and feed materials safety.
If the management considers or has reason to believe that a food or feed material which it has collected, stored, traded or transported does not satisfy the food or feed safety requirements it must immediately initiate procedures to withdraw and if necessary, recall from users of the food or feed material this latter from the market and inform the competent authorities thereof:
The withdrawal and recall procedure must be documented Responsibility must be defined for notifying customers and regulatory authorities Responsibility within the operation for product withdrawal and recall(s) must be
defined All relevant contacts (including relevant authorities) must be listed and kept up-to-
date. Food and feed materials which are considered unsafe will be handled as non-conforming product. Yearly, the recall procedure must be tested by a simulation to ensure its validity.
3.1.12 Internal audits
Without prejudice to specific internal audit requirements for multisite certification (Annex 1 to the GTP Certification Rules), the management must ensure that internal audits are performed to verify that the food and feed safety management system is:
Effectively implemented and maintained In compliance with regulatory and other defined requirements.
Internal audits must be carried out in such a way as to ensure objectivity and impartiality of the audit process and conclusions. The internal auditor can therefore not audit its own working tasks. The employee performing the internal audit must be qualified for this with appropriate education, training (internal or external) and experience.
Note For very small size companies with limited staff or isolated site (e.g. collection silo), it is
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difficult to form a team and not to internally audit his/her own working tasks. In order to address this problem , the responsible person will, at regular intervals, exchange ideas with other persons (in family circle, with colleagues, a service of a professional federation, etc.) to confirm or refute each step of his HACCP-plan.
The internal auditor will document his findings, possible recommendations and conclusion and report to the management. The management shall review the findings and ensure the necessary follow- up of the non-conformities and corrective actions.
Internal audits may also be used to identify potential opportunities for improvements.
All relevant activities are audited internally at least once a year. The planning for internal audits as well as the results of such audits must be documented.
3.1.13 Complaints
The management must document the procedure for handling complaints. This procedure must include systems for:
Prompt recording and investigation of complaints Prompt feedback to the complainant with findings Recording of the internal actions required to prevent recurrence.
3.1.14 Management of monitoring and measurement equipment
The operator must determine before implementation of the monitoring plan which monitoring and measurement equipment is required to demonstrate the food or feed safety of the product. The monitoring and measurement equipment must be registered.
The operator must establish processes to ensure that the monitoring and measurement can be carried out and that it is carried out in a way which matches the monitoring and measurement requirements.
If it is necessary to achieve valid results the measurement equipment must be:
Calibrated or verified at specified intervals or prior to use in accordance with measurement standards which are derived from international or national measurement standards; if such standards do not exist the basis used for the calibration or verification must be recorded and inspections will be in accordance with standardised checklists
Adjusted or re-adjusted if necessary Identified so that the calibration status can be determined Secured against adjustment which would make the measurement result invalid Protected against damage and deterioration during handling, maintenance and
storage.
The operator must also assess and record the validity of the previous measurement results if it appears that the monitoring and measurement equipment does not function in accordance with the requirements. The operator must take suitable measures with respect to the equipment and any product which is influenced by it. Records of the results of calibration and verification must be maintained.
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If computer software is used in the monitoring and measurement of specified requirements its capacity to comply with the intended application must be confirmed. This must be done before initial use and re-confirmed if necessary.
3.1.15 Corrective actions
The operator must ensure that non-conformities to the requirements in this standard are recorded and controlled in order to prevent unintentional use or delivery of the product. The controls and associated responsibilities and competences for dealing with non-conformities must be defined in a documented procedure.
The operator must deal with non-conformities in one or more of the following manners:
By taking measures to put an end to the observed non-conformity By permitting use, release or acceptance with the approval of the client and/or the
relevant authority By taking measures to exclude the originally-intended use or application
If there have been contaminations with food or feed residues, undesirable substances and/or germs in the facilities of transport means, there must be cleaned so that no contamination can spread out or take place again. Records of these actions must be available.
Records of the nature of non-conformities and any measures taken later, including approvals obtained, must be maintained.
If a non-conformity is corrected then there must be verification again of whether there is compliance with the requirements.
This control must provide for identification, documentation, evaluation, segregation (when practical), and disposal of non-conforming products and for notification to the involved parties, both internal and external.
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3.2 Chapter II- Good Hygiene Practices for Trading Operations
3.2.1 The Domain
The scope and boundaries of the operator’s activities must be clearly defined and documented (such as an internal handbook).
3.2.2 Registration of operators
The operator must be duly registered and/or approved for its activities in the food and feed sector according to current legislation.
3.2.3 Requirements for purchasing
The operator must ascertain the following:
Legal and governmental requirements with regard to the food and feed materials; Any other requirements laid down by the operator, especially with regard to the
obligation of safety assurance; The requirements defined by the customer with regard to delivery and activities
following delivery; The requirements not stated by the customer which are, however, necessary for the
defined or intended use as far as is known.
3.2.3.1 Sourcing from assured sources
The desirable situation is that products demonstrably originate from a fully certified chain. Each link (from the 1st collector through the final processor) provides the required guarantee in this situation and is therefore certified. Therefore GTP certified operators are committed to purchase certified incoming materials from a recognised system, audited and certified by an independent third party (for GTP mutual equivalent/ recognised schemes, see the list at the end of the Code). Suppliers, and service providers must be identified and their certification status verified on at least an annual basis and before taking effective delivery of incoming food and feed materials. The actual certification status of the supplier can be found on the respective scheme owner’s website. An exception is in place for direct farmer’s supplies.
3.2.3.2 The gatekeeper procedure When a supplier is not yet certified according to an equivalent and/or recognised feed or food safety scheme, the GTP operator should:
ask the supplier to initiate without delay the implementation of the appropriate GTP recognised food or feed safety assurance scheme, based on the HACCP principles in
31
order, if possible, to get within 18 months the requested certification7, and while waiting for the establishment of such a certified food or feed management system,
ensure through extended checks (detailed below) and on the basis of sampling and analysis based on an appropriated risk analysis for the products / origin concerned, that the goods purchased comply with the standards and requirements of the European Regulations.
In case the supplier has decided not to go for any certification within the 18 months’ timeframe, the GTP operator can either reiterate its request for certification to its suppliers or change supplier or origin.
In the situation where food and feed materials cannot be purchased from an assured source, the GTP operator shall thus implement the gatekeeper procedure as described below.
A. Scope of application of the gatekeeper procedure Cereals and grains products and their by-products from all countries; Oilseeds and their by-products (meals, vegoils) from all countries; Protein crops and their by-products from all countries; Other unprocessed food and/or feed materials of vegetable origin and their by-products
from all countries.
B. Implementation of the gatekeeper procedure
When purchasing from non-assured sources, the GTP operator becomes the start of this chain and a gatekeeper procedure becomes a pre-requisite. The operator can buy or receive products from non-assured sources provided that the operator ascertains that the products brought into the food and feed chain comply with GTP gatekeeper clause requirements.
The gatekeeper implements a control plan for the concerned products traded based on its own risk assessment and in compliance with the minimum sampling and analysis requirements laid down further below in section 3.2.3.2 D and E.
The GTP operator carries out its own hazard analysis. On the basis of this hazard analysis and the guarantees which are provided by the previous links in the chain, the operator makes a selection of the relevant suppliers and draws up a monitoring program which, at least, complies with the relevant section of the recognised feed or food safety schemes.
The GTP operator must gather all relevant documents related to the purchase which must be available at delivery. In accordance with this procedure, the lot must be inspected and sampled at receipt of delivery. The transportation of the lot must be defined, for example the hold of a sea vessel, a coaster, a truck or train. A sample must be taken for each defined lot by a qualified person, using a method that complies with recognised sampling methods.
The monitoring analysis must be made lot by lot on the basis of available risk analysis models such as those of the GMP+ International, OVOCOM, QS Qualität und Sicherheit, AIC-FEMAS, EFISC or of FOSFA, which must demonstrate that those risks are properly controlled and require special attention for such hazards:
Pesticides residues;
7 This can be sent as a specific request to implement this type of procedure in the contract or sent as a separate letter or
email.
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Microbiological safety; Mycotoxins; Heavy metals; Botanical impurities.
On the basis of this risk assessment and possible presented guarantees, if any, the shipper must develop a monitoring plan as follows, the content and frequency of analysis being determined by the HACCP team.
C. Sampling and visual inspection frequency
Sampling frequency: at least one representative final sample will be constituted for
each train, each sea vessels or barges hold, or for the full vessel (composite sample) depending on whether or not the hazards under scrutiny are or not uniformly distributed. The size of the lots is depending on the purchasing and loading conditions.
Visual inspection frequency: all samples will be inspected.
D. Sampling methods
During loading of the vessel, train or truck sampling should be done as per rules and conditions such as those described in the GAFTA n° 124 in case of grains, meals and food or feed products and/or as per FOSFA rules in the case of vegetable oils or oilseeds, or as per other commonly used national or local sampling rules recognised/acknowledged by the sector. Examples of such rules can be found in Annex 6.
A control plan based on the gatekeeper’s risk assessment defines the minimum parameters sampling rules and frequency of analysis. All sample related data and analysis results should be recorded.
Reception conditions, sanitary and hygiene safety requirements must be made available to suppliers.
The traceability plan must include procedures for withdrawal or recall of products (see section 3.1.11 on crisis management). This must be part of the HACCP plan (see Annex 1) but must include prompt recording, investigation and feedback to the complainant of the findings.
Upon taking delivery / storage and delivery of goods, all instructions must be confirmed in writing. Delivery notes must mention the following information:
Name and address of the supplier or customer Place of origin/loading Date of delivery The nature and type of goods Quantity delivered / loaded Means of transport and signatures.
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E. Minimum analysis to be performed
The table below provides mandatory minimum analysis requirements for unprocessed food/feed materials applicable when implementing the gatekeeper procedure. This does not prevent the gatekeeper operator to perform, where appropriate, additional analysis based on its own risk assessment. Additional analysis on hazards not covered explicitly in the following table can be carried out based on the company’s own risk assessment. Processed products (processing plant8) are also subject per se to these minimum analysis requirements. The operator shall monitor the presence of a specific hazard in a processed product (e.g. processing plant; salmonella in oilseed meals).
Parameter Cereals Oilseeds and protein crops
Sorting residues9
Pesticides residues (CI-, P-, N-)
X
X
X
Heavy metals : - Arsenic - Cadmium - Lead - Mercury
X X X X
X X X X
X X X X
Dioxins10 Dioxin Sum of dioxins and dioxin-like PCBs
X
X
X
X
X
X
PCBs X X X
PAHs X X X
Mycotoxins: - Aflatoxin B1
11
- Deoxynivalenol (DON)
- Zearalenon (ZEA)
- Fumonisin (FUM)
- Ochratoxin A (OTA)
- Ergot of rye
X
12
X13
X
14
X15
X
16
X17
- - - - - -
X X X X X X
Salmonella18 X - X
8 Processed products subjected to gatekeeper procedure only if the processing plant that has produced the processed
product is not GTP equivalent/recognised certified 9 Sorting residues means a by-product arising from the application of the following processes: “decortications (peeling,
shelling)”, “sieving/sifting” or “cleaning” as defined in the feed catalogue as per Commission Regulation (EC) 68/2013. 10
Only applicable in case of direct artificial drying. For dioxin monitoring of oils and fats destined to feed, please refer to § 3.1.6.2 of the GTP Code. 11
For the specific monitoring of aflatoxin in maize from a certain origin, please refer to mandatory requirements laid down in GTP addendum 1, latest version. 12
Only applicable to wheat, barley, maize, rye, rice and triticale. 13
Only applicable to wheat, barley, maize, rye, and triticale. 14
Only applicable to wheat, barley, maize, rye, and triticale. 15
Only applicable to maize. 16
Only applicable to wheat and maize. 17
Only applicable to rye. 18
This may be subject to adjustment based on HACCP and operator’s risk assessment or as per national legislation, if any.
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3.2.4 Recording of movement
The provisions for the record of movements (receipt and delivery including inter-silo transfers) must be adapted and implemented to each site. Movements must be recorded and documented.
3.2.5 Labelling and accompanying documents
Each movement of goods must be accompanied by appropriate documentation including at least:
The names and addresses of the supplier and the customer The date and place of dispatch The nature and type of goods The quantity loaded / delivered
The operator must ensure that labelling meets legal requirements (Regulation (EC) No 767/2009 on the marketing and use of feed; Directive 2000/13/EC on the labelling, presentation and advertising of foodstuffs).
3.2.6 Quality monitoring or Stock Inspection
The operator must ensure that the staff in charge of the loading and outloading of the goods is aware of the technical criteria requested for the execution of contracts regardless of:
The location of premises from where goods are loaded out (i.e. delivering/loading out the goods on a transport mean out of a storage facility)
Whether the staff members are internal or delegated.
Product condition is controlled and documented based on a risk assessment and the monitoring plans.
A plan of the facilities referencing each storage bin must be available at each site.
Samples must be taken during reception and on delivery according to contract terms and/or monitoring plan.
Samples must be identified and stored appropriately.
Non-conformities and corrective actions must be recorded, documented and verified.
3.2.7 Goods with specific regulations
Management rules for goods with specific regulations must be defined and implemented in compliance with the legislation in force
In case of co-existence of goods with specific regulations and other goods, the operator must:
Make the staff aware of the technical and administrative specifications of the goods Keep specific accounting records for the stored goods Organise any certification needed and record the certificates Communicate relevant information to the concerned parties Provide and establish procedures for specific labelling and accompanying documents Keep a clear physical separation, which must be documented.
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The management rules must include in the purchasing information the requirement for the absence of GMO non-authorised in the EU in the purchasing information. In case the incoming material comes from a country or region with a risk of comingling with non EU-authorised GMOs the management must apply the appropriate analytical monitoring, based on a risk assessment.
In the event of delivery of goods, within the scope and boundaries of the operator’s GTP certification, to GTP certified customers or to customers who are certified against another certification scheme which has been declared to be equivalent to the GTP Code, the status of goods from non GTP or non GTP equivalent certification need to be mentioned in contracts or, by default, on some other written form by the time of delivery.
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3.3 Chapter III- Good Hygiene Practices for Collection / Receipt Operations
This unit applies to the collection facilities which belong to the operator.
If the operator uses hired collection silos to a service provider, preference should be given to a GTP certified or equivalent/recognised collection service provider (see the list at the end of this Code – Reference 2). If this is not the case, the operator will ask them to apply the terms set out in this chapter and it will include the collection service provider in its HACCP plan. This is only applicable provided that the operator is in charge of the collection management and that everything in the store belongs to the GTP certified operator or equivalent/recognised.
The operator must ensure that any collection provider complies with this chapter.
3.3.1 The External Environment
The operator must maintain the buildings surroundings clean to avoid harboring pests and other potential contaminants.
Drainage of rainwater and run-off water must be adequate to avoid damages or deterioration of the products.
Adequate pest and rodents control plans must be documented and implemented.
3.3.2 Receipt of goods
3.3.2.1 Crop deliveries by farmers
Farmers must be reminded of their obligations regarding the internal and external cleanliness of the transport used to carry goods covered under the scope of the GTP. They should also be reminded of the importance to maintain records especially if the mean of transport has to be cleaned after a previous transportation of a product other than cereals or oilseeds.
Farmers should be advised to adhere to the recommendations contained in the good hygiene practices guide or guides for arable crops, particularly regarding rules on cleaning and succession of transport, reference is made to EU and/or national guides on arable crops which are already published or will be published.
3.3.2.2 Control at receipt
When products are received, for each unit delivery, operator must:
Identify the delivery (provider, product etc.) and record it Establish whether post-harvest pesticide treatments have been applied to the grains
prior to the delivery to the operator's premises Sample according to sampling program Carry out an olfactory and visual inspection of the delivered batch Check the product condition (such as moisture) of the delivered batch and record it Set criteria for classifying and allocating the products received Avoid spillage and, when accidental spillage occurs, undertake adequate cleaning
(only applicable when the operator has its own storage and handling equipments - otherwise adequate instructions to be given to the service provider).
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3.3.3 Pre-storage and Drying
The operator must define and apply monitoring parameters for his pre-storage (for instance duration).
The operator must define, apply and record the parameters of control and monitoring of drying operations.
Dryer design and source of energy must be adapted to its use and avoid risk of product contamination.
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3.4 Chapter IV- Good Hygiene Practices for Storage Operations This unit applies to the storage facilities which belong to the operator.
If the operator uses hired storage facilities to a service provider, preference should be given to a GTP certified or equivalent/recognised storage service provider (see the list at the end of this Code – Reference 2). If this is not the case, the operator will ask them to apply the terms set out in this chapter and it will include the storage service provider in its HACCP plan. This is only applicable provided that the operator is in charge of the storage management and that everything in the store belongs to the GTP certified operator or equivalent/recognised.
The operator is the guarantor for the hygiene quality of the goods they market. These goods may be contaminated during storage by the premises, equipment, staff, transport and waste. Materials which are not suitable for food and feed use are kept segregated and identified.
The operator must ensure that any storage providers comply with this chapter.
3.4.1 The premises
3.4.1.1 The construction or modification of storage and handling premises and galleries
Construction and design of stores must minimize any contamination of the stored product by foreign material or undesirable substances.
Control of sanitary safety risks must be one criterion for the choice of investments for any building or modification of premises and equipment.
3.4.1.2 The layout of the storage and handling premises and galleries
A. Prevention of cross contamination
The operator must ensure that layout of the storage and handling premises and galleries:
Prevents the mixing of GTP or equivalent/recognised schemes with non-assured goods. If non-assured materials come in contact with GTP or GTP equivalent/recognised schemes assured materials, then the whole batch is non-assured and must be recorded by the operator in possession of the goods (see the list of schemes at the end of the Code).
Prevents any cross contamination of grains by the applied pesticide treatment or pest & rodents poison
Allows identification and/or detection and separation of substances considered as being dangerous or inedible
Prevents entry into the storage areas of non-allowed vehicles. B. Maintenance and cleaning
Premises must be kept in good condition and maintained and this must be documented (in particular roofing, storage bins).
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Equipment must be maintained in good condition.
A cleaning plan must be defined, applied and recorded and must include the water quality and cleaning chemicals used. The operator must demonstrate that water and steam used during cleaning are safe for food and feed and is of suitable quality.
Food/feed grade cleaning agents must be used and stored according to the manufacturer’s instruction(s), clearly labelled, separately stored from incoming materials and applied properly to avoid contamination of materials.
When using certain products such as biocide, storage insecticides and detergents, the operator must pay attention to national/EU approvals for the placing on the market of these products at national level. This means that some of these products are approved in one country and not in another one.
Handling and storage premises as well as galleries must be cleaned at least once a year.
Areas where batches of contaminated (insects, mould) goods have been detected must be thoroughly cleaned and if necessary treated before further use and all actions must be recorded.
C. Ventilation and inter bin transfer
The operator must define and apply parameters for the use of ventilation (especially temperatures objectives and temperature differences). In case of the absence of a ventilation system, the operator must define his modalities of product conservation (inter-bin transfer, transfer between sites). The operator must define, apply and record the parameters of his storage control.
D. Pest Control
Pest and rodents in the storage facilities and their surrounding areas must be controlled.
Control of harmful organisms such as birds, insect, pest and rodent must be established and implemented.
Storage and handling premises as well as galleries must be cleaned and treated, especially at points where dust and stored products can stagnate.
Details of treatments applied to stored products and premises must be recorded. Pesticides treatment equipments are frequently supervised checked and maintained.
3.4.1.3 Storage of samples (own samples or ordered by the product owner)
Samples of stored product must be stored in places appropriate to the storage duration.
These places must be kept clean and protected from pests.
The storage conditions must prevent any deterioration or damage to the samples.
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3.4.2 The pits, handling and sorting equipment
Pits, handling and sorting equipment must be kept clean and in good condition and maintenance be applied.
A cleaning plan must be defined, applied and recorded.
Areas where batches of contaminated (insects, mould) goods have been detected must be thoroughly cleaned and if necessary treated before further use and all actions must be recorded.
Those equipments should preferably be equipped with adequate metal detectors or magnets or other adequate equipments for avoid /remove physical “contaminants” such as metal parts or stones.
3.4.3 Traceability
The storekeeper must receive, for taking delivery / storage and delivery of goods, all instructions in writing. Delivery notes must mention the following information:
Name and address of the supplier or customer, Place of origin/loading, Date of delivery, Type and nature of the goods, Quantity delivered / delivered, Means of transport and signatures.
All above mentioned data must be reported to the operator and documentation must be kept for minimum 3 years, unless otherwise specified by law.
3.4.4 Packaging Unpacked products must be shipped in clean and dry vehicles in order to prevent any contamination of the products by chemical, microbiological or physical contaminants. Where the products are shipped in bags or other types of packaging, it must be ensured that the packaging is suitable for maintaining the quality of the products.
3.4.5 The Waste The waste storage area must be located in a place that is separated from the product storage facilities.
Waste collection must be scheduled with appropriate frequency.
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Example plan of a silo: "West Indies Illustration"
Stages of the grain's progress:
Mechanics of the silo: 1. Receipt A. Belt or chain conveyors 2. Drying B. Bucket elevators 3. Cleaning and separation C. Dust suction system 4. Storage bin before dispatch D. Vacuum equipment with air outlet 5. Ventilation of the grain 6. Dispatch by lorry 7. Dispatch by train 8. Dispatch by barge
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3.5 Chapter V - Good Hygiene Practices for Dispatch/Delivery and Transport Operations
Raw materials intended for human food or animal feed are transported by road, river, rail or sea.
Goods must be transported in compliance with the regulations specific to transport, particularly the provisions relating to food and feed safety. Whatever means of transport used, the transport contractor and the transporter are responsible for ensuring the equipment conforms to food and feed safety requirements.
The presence of foreign bodies, impurities or residues in the containers (due to insufficient cleaning or other bad practices) is a source of contamination.
The operator must ensure that any internal or external transport providers for trading purposes and to transfers between storage sites comply with this chapter.
Operators transporting food or feed products in the EU must be registered within its local authorities as requested by Regulation (EC) No 183/2005 (feed hygiene) and by Regulation (EC) No 852/2004 (food hygiene) and must also comply with local legislation applicable to transport operators.
Under this code, road transport, in combination with the above scopes (section 3.2 Chapter II Trading, section 3.3 Chapter III- Collection/Receipt Operation as and section 3.4 Chapter IV-Storage Operations), can be certified for own feeds and/or foods. The requirements necessary for this are included in the GTP Code.
A decision tree clarifying what is in/out GTP transport certification is provided at the end of the present Code.
Note The GTP certification of transport activities can only take place for own products. Transport as a service to third parties cannot be certified under this code.
3.5.1 General rules (applying to all kinds of transport)
All transport of food and/or feed (by sea, by inland waterway shipping, by road transport, by rail, in containers or by way of some other transport system), irrespective of whether this is carried out within the control of the operator or is outsourced, must be controlled in the correct way specifically with respect to hygiene and potential contamination. Loads which are transported together with raw materials and foods or feeds may not adversely affect the safety of the raw materials or foods or feeds. The operator may be responsible for the transport of foods and/or feeds to buyers who work in accordance with a different quality assurance program (other than GTP). The operator must in that case ensure that in addition to the relevant transport requirements of this standard that there is also compliance with the specific demands and requirements of that program.
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If the foods and/or feeds to be transported are packed it is possible to make use of non-certified transport. In that case the operator must acknowledge all possible hazards and control them. In any event the transport of packed products must take place in a clean and dry loading compartment. As a general rule, bulk foodstuffs in liquid, granulates and powder forms are to be transported in receptacles and/or containers/tankers reserved for the transport of foodstuffs 19 . However, where conveyances and/or containers have been used for transporting anything other than foodstuffs or for transporting different foodstuffs, there is to be effective cleaning between loads to avoid the risk of contamination. For transport of bulk liquid oils and fats by sea vessels, special derogation and list of authorised previous cargoes are laid down in Commission Directive 96/3/EC granting a derogation from certain provisions of Council Directive 93/43/EEC on the hygiene of foodstuffs as regards the transport of bulk liquid oils and fats by sea, as amended. If a third party carries out this transport on behalf of the operator then the operator must make demonstrable agreements about this. Products must be protected against rain and other contamination during transport. All means of transport used for each dispatch must be recorded, including the name and identification of the materials (the IDTF reference numbers of the products can be used for the records). Staff authorised and/or supervisor to undertake compartment checks before loading must be identified and trained. Before any loading, all loading compartments must be visually checked that:
They are clean, dry (and/or dried in case of dry subsequent loads), odorless and correctly maintained so that food and feed may not be mixed in transit or during transportation. A cleaning plan must be defined, applied and recorded and must include the water20 and chemicals (appropriate to the use and the applicable regulations of the country of origin and/or destination) used to clean the areas defined;
They do not contain pests and rodents in the widest sense of the term; They do not contain residues from previous loads and/or cleaning products; They are compatible with the loading and transport of the specific products.
The conformity of control results must be recorded and documented.
Non-conformities and corrective actions must be recorded, documented and reported to the responsible unit.
19
In the EU, such request is described in Chapter IV of Annex II of Regulation (EC) N° 852/2004 dd 29 april 2004 on the hygiene of Foodstuff 20
Water used for cleaning should be if possible and available of potable quality, as defined by local legislation, or having been assessed as appropriate for the concerned use so that no contamination of the products stored or transported would occur as a result of the use of such water for cleaning operations.
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Summary note
For the transport of food and/or feed in general, the loading compartments must, before loading, be completely empty, clean, dry and free of remains and odours from previous loads in order to prevent contamination of the load or carry-over. This means:
a. Free of possible ‘agribulk unfriendly elements’ such as remains of previous loads and/or cleaning activities
b. Free of vermin in the broadest sense of the word (insects, mammals, dead or alive).
The following table shows which section applies for the operator and for which forms of transport:
The road transport of own foods or feeds can be certified via this code. For the requirements see section 3.5.2. If use is made of service providers (subcontracted or hired trucks) for this road transport then the requirements of section 3.5.3 apply.
N.B. If use is exclusively made for the transport of own foods or feeds of certified carriers then the operator does not of course need to be certified for transport. This is part of the purchasing requirements
See also the requirements for transport by inland waterway shipping, sea or rail in section 3.5.4. Actually, for the operator who is responsible for these kinds of transport, these requirements mean that he must additionally apply another standard.
In conclusion: If the operator is not responsible for the transport of his foods or feeds then the relevant requirements in section 3.5.5 still applies.
Form of transport Section
3.5.2 Section
3.5.3 Section
3.5.4 Section
3.5.5
Road transport of own foods or feeds X X
Road transport of own foods & feeds by a service provider (sub-contracted or
hired trucks) X
Transport by inland waterway shipping, sea or train
X
Road Transport for which third parties are responsible (i.e FOB or FCA or EXW
sales) X
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If the operator also carries out the road transport of foods or feeds from third parties then the operator will be considered to be a carrier providing a service and such activities are not covered by the GTP code for time being.
3.5.2 Own road transport 3.5.2.1 General rules
For bulk own road transports, products must be transported in accordance with the requirements detailed in the section 3.5.6 setting rules for cleaning procedures according to the safety status of the previous cargo transported in the loading compartments. Such requirements for the transporter must be documented and communicated by the operator. The safety status of a previous cargoes can be found on the website of “International Database Transport (for) Feed” available on the ICRT website (http://www.icrt-idtf.com/). Such IDTF database (International Database Transport (for) Feed), is a database created by the ICRT (International Committee Road Transport) association, grouping together the following organisations: Qualimat Transport, Ovocom, GMP+ International, QS, GTP, AIC and Gafta. In November 2013 two new associations from the UK were welcomed to the ICRT to increase the number of member organisations to seven.
Aiming at assuring of feed safety throughout the Animal Feed Sector, the members are harmonizing their safety requirements as regards bulk transport by road, intended for animal feed.
All products, not classified in the IDTF, are prohibited as road loads for means of transport transporting products used for animal feed. Road transport having previously transported such “prohibited previous cargoes” can be re-authorized after application of the procedure described in point 3.5.6.8 E)”procedure for acceptance of loading compartments after transport of forbidden loads”
This IDTF database also delivers detailed product sheet for each product so that the operators can better take into account the potential hazards in their risk assessments and also on possible contractual requirements or other specific rules..
In case that the IDTF database mentions differences of cleaning regimes applicable to some products depending on the concerned FEED safety scheme, the GTP Operator should apply the cleaning regime mentioned by the safety scheme of the customers or, in case of doubts, the more stringent one.
A user manual of this database is available at the following address:
http://icrt-idtf.com/en/downloads/user_manual_idtf_eng.v2.pdf
For road transport of Foodstuffs, this database can also be used for most cases, keeping in mind that the GTP operator should take into consideration in their risk assessments, the possible specific other food contaminants or allergens risks as well as the need to use, in most case, dedicated transport means.
In case of a previous cargo not being listed in this DRTL list, the operator will have first:
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To request the GTP Code Manager to risk assess this product in accordance with the ICRT-IDTF rules , and
To get, if possible, a provisional authorization and product categorization. These checks by the operator must be carried out prior to loading and transport of this cargo.
For all road transport, the driver must be able to present the logbook stating the 3 previous loads and, if relevant, any cleaning operations that have been carried out. All other information such as the quantities, types, loading and unloading addresses, coding of bulk compartments, are kept by the GTP operator.
3.5.2.2 Infrastructure
The operator must determine, provide and maintain the infrastructure needed for the safe transport of food and/or feed. Infrastructure includes, as applicable:
Buildings, working areas and associated; Means of transport and/or loading compartments; Process equipment (both hardware and software); Supporting services (for example communication).
3.5.2.3 Basic requirements
The operator will ensure that the means of transport:
Are made of appropriate materials which can be effectively cleaned and maintained to avoid contamination of the food and/or feed. This applies in particular to materials and surfaces which come into direct contact with food or feed;
Are in good technical condition; Are appropriate for their intended use and function in accordance with their
intended use; Make good hygiene production/practices possible; Are free on the outside, including the chassis, from visible particles from prior loads; Before loading it must be visually checked that there are no hydraulic fluids or fuel
leaks. The tarpaulin covers used must be clean and watertight Where necessary, conveyances and/or containers used for transporting the food or
feed stuffs are to be capable of maintaining the transported product at appropriate temperatures and allow those temperatures to be monitored.
For transport of foodstuff in the EU, appropriate labels and markings should be used.
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3.5.2.4 Loading compartments
The operator must always ensure that loading compartments:
Are dry21, clean, fully emptied, free of load residues and free of the odour of previous loads
Are covered unless the operator demonstrates that not covering the loading compartment does not involve any risks of product contamination
3.5.2.5 Loading
A visual inspection must be carried out before the foods or feeds are loaded to determine whether the loading compartment is clean and dry22.
In addition, the outside of the vehicle, including the chassis, must be free of all visible remains of the previous load if these remains entail a risk for the products to be transported by way of cross-contamination.
3.5.2.6 Transport
Foods or Feeds must (in combined transports) not become mixed together unintentionally or mixed with other products and effective separation of the products should be ensured.
The operator will ensure that the loading compartments are covered during transport. Penetration of rainwater, contamination by the excrement of birds or other forms of contamination of the loading compartments must be prevented even if the loading compartment is empty.
If the covering of loading compartments is not possible then the loading compartment must be sprayed clean and dry23. Tarpaulins to be used for covering loading compartments must be clean before bulk loading and before loading with dry foods or feeds and are also to be dry.
Guidance Remember to properly cover with tarpaulin the various loading compartments to protect the load from being contaminated by dust of other loading compartments of the truck. If the absence of tarpaulin does not trigger any risk of food or feed contamination then the operator may omit the covering.
21
As derogation to the general obligation to keep loading compartments dry, drying operations are not required in the specific case of two consecutive loads of wet products of the same type provided that the local temperature is low and stable in between the two consecutive loads. 22
As derogation to the general obligation to keep loading compartments dry, drying operations are not required in the specific case of two consecutive loads of wet products of the same type provided that the local temperature is low and stable in between the two consecutive loads. 23
See foot note 20.
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3.5.2.7 Unloading
After unloading the operator must visually check the loading compartment for remains of the load. If applicable, the operator must remove the load remains as much as possible.
On reception of the products, the operator will carry out an entry inspection. He will verify that the products received comply with the requirements (specifications). He must also check that the transport complies with the stated requirements (minimum check on the application of ICRT-IDTF rules, certification of the carrier, compliance with the requirements with respect to loading sequence, previous loads and implementation of the necessary cleaning regimes). This is however not applicable to farmers having their own transport means.
The operator must also ensure that incoming food and feed materials are verified according to procedures and requirements referred to in section 4.5 on purchasing process.
3.5.2.8 Cleaning
Cleaning and, if necessary, disinfection must take place before loading the foods or feeds. The operator must put into practice the relevant requirements and the prescribed working method as described in section 3.5.6 Loading Sequences and Cleaning Regimes.
After each cleaning, at least a visual inspection must be carried out.
Each cleaning program drawn up for a certain loading compartment must be checked for effectiveness.
If the loading compartment is used for repeated transport of the same food or feed then it is permissible to establish by way of a hazard analysis which is the suitable cleaning frequency.
3.5.2.9 Traceability and registration
In the event of bulk transport the details of the last three prior loads must be available for each means of transport including all the cleaning work done afterwards. Legally required documents must also be present. Management of the document must be done in compliance with the provisions laid down in section 3.1.5.
Note If a mean of road transport is used for the transport of foods or feeds, then the individual loading compartments must be documented separately. For road vehicles this may mean the registration number or the trailer number. If loading compartments are split into sections then the individual sections must be documented separately.
Guidance At least the following details must be available: a) In the case of bulk transport the loads must be maintained by way of a separate journey sheet for each loading compartment and for each vehicle or means of transport. The details of the previous three loads are available for checking. Details of the cleaning regimes applied should also be known unless it is specifically determined in the hazard analysis that the
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previous loads do not form a potential hazard. This may be the case, for example, if a certain vehicle is only used for a specific type of food (‘dedicated’ transport) or if it used the same day for successive transports of the same product from a unique lot without disruption. b) The legally-prescribed documentation including the way bill. c) The cleaning and disinfection measures carried out for each compartment of the bulk vehicle (not applicable if the previous cargoes were not bulk products) d) The results of the cleaning and disinfection measures are visually checked and recorded on the journey sheet (not applicable if the previous cargoes were not bulk products). It is allowed to maintain the journey sheet digitally (for example on a hand computer in the vehicle).
3.5.3 Road transport carried out by a subcontractor (chartered or hired trucks) 3.5.3.1 By a carrier with a GTP certificate or equivalent/recognised
Road transport to a GTP certified operator must be carried out preferably by a carrier with a GTP certificate or equivalent/recognised for the relevant scope, i.e. transport activities (see the list at the end of the Code).
3.5.3.2 By a carrier without a GTP certificate or equivalent/recognised certification
Alternatively, it is also possible to make use of non-certified carriers for road transport to non-GTP certified operators or equivalent/recognised safety schemes. In this case, the operator must apply the requirements of this section. Such a possibility can also be used for road transport of foodstuffs for which there is no equivalent or recognised certified carriers:
These external carriers must at least apply the relevant transport requirements as laid down in section 3.5.2. This must be recorded in a contract.
This must be checked by the operator by way of an audit.
The external carrier (without a GTP or equivalent/recognised certificate) who is sub-contracted must be able to demonstrate the following with respect to the transport of the foods or feeds:
A record for each loading compartment with details of at least 3 previous loads Details for each loading compartment about the cleaning and disinfection procedures
which are carried out (not applicable if the previous cargoes were not bulk products) Details of the cleaning inspection which was carried out prior to the loading of the
loading compartment (not applicable if the previous cargoes were not bulk products) Details of the inspections carried out for each loading compartment.
If the result of the inspection is positive then the loading compartment is approved for the transportation of foods or feeds. This inspection must be carried out by a loading inspector.
A 'loading inspector' is a position for which the details are specified in the quality system of the operator. This role is fulfilled by an employee who, on the basis of training and experience, has the knowledge and skills required for the inspection of a loading compartment for its suitability for the loading of foods or feeds.
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Guidance: If an operator does not have his own loading inspector then he may be hired from an independent certification body of inspection agency. The loading inspector must of course meet the criteria set.
3.5.4 Transport via inland waterway, by sea and by train
Boat men and wagon drivers must be able to present a logbook listing their successive transports (type and nature of goods, type and date of cleaning carried out). For the description of the goods (nature and type), the IDTF number of the products can be used.
The hold, hatch covers and hatches of the ships (sea or ocean vessels or barges) used to transport products must be clean, watertight, dry, odorless, and in perfect maintenance condition
For trains, transport of food and feed materials in bulk should only be made with wagons that are exclusively intended for transporting raw or semi-processed agricultural products. Such wagons must be clean, watertight, dry, odorless, and in perfect maintenance condition. In the event of transport by rail, only the last load and the last cleaning operation must be recorded, when available.
Before loading the products, operators using a ship (sea or ocean vessel or barges) approved for transporting their products must be informed about the three previous loads and the cleaning procedure applied for the last cargo.
Guidance: When products are transported by sea, waterway or rail under the operator's responsibility, the loading compartments must be inspected and a Load Compartment Inspection report (LCI) issued before loading, along with a description of the three previous loads and the cleaning procedure applied for the last cargo. This inspection has to be carried out by a recognised inspection operator operating in accordance with internationally recognised standards or qualified person (freight forwarder) recognised as a qualified loading operator. If an operator does not have his own loading inspector then he may be hired from an independent certification body of inspection agency. The loading inspector must of course meet the criteria set.
The GTP operator that issues an order for an LCI must supply the control organisation or the loading inspectors with all needed instructions to fulfill all needed controls and reporting’s into the LCI, enabling a correct identification and traceability of the cargo (name, date, location, quantity, shipper, consignee, destination, contact details, BL N°, etc..) , and information’s such as:
the results of the visual inspection of each load compartment (LC) , aimed to assess its suitability its suitability for the storage and the transport of the goods to be loaded,
ensure that the load compartments are clean, empty, dry, odorless assess the absence of residues and of any unfriendly elements that could
contaminate the cargo,
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verify the absence of insects and vermin (dead or alive) check that the LC are closable and in good conditions so that the cargo can be
transported correctly and against outside influences describe any non-conformities and corrective actions mention at least, for each hold, the last three previous loads and the cleaning
operations performed after them: The LCI report must be unambiguous and contain the information which is relevant for the acceptance of the load compartment. The LCI should be signed /vised by the Inspector and by the master or his representative. The findings of this LCI Report should be made known to the GTP Operator as quick as possible after completion.
Note: When products are directly transported via inland waterway to an operator certified against a scheme requiring the mandatory use of certified barges (e.g. GMP+, GMP/Ovocom), the GTP operator will have to make use of a certified barge if he wants to supply his customers and benefit from mutual recognition between the GTP and those concerned schemes. The use of GMP+, GMP/Ovocom or approved barges can be negotiated on a case by case basis between the GTP operator and his customer. As such approved barges are not systematically available on certain inland waterways of European countries, the GTP operator therefore should: - Ask the barge’s owner to initiate without delay the implementation of a relevant inland waterway transport certification in order, if possible, to get within 18 months the requested certification24, and - While waiting for the establishment of such a certification, the GTP is made aware about this scarcity of offer of certified barges in a determined area and information is transferred to scheme requiring the mandatory use of certified barges (e.g. GMP+, GMP/Ovocom)
In case of use of non-certified barges by the GTP operator, the use of a LCI combined with the application of the correct cleaning procedures for the last previous cargo should be complied with (see more details in § 3.5.4). Only GTP certified company or non-certified operator can therefore be supplied.
3.5.5 Road Transport for which third parties are responsible (such as EXW or FCA or FOB sales)
If a third party is responsible for road transport then the operator must take reasonable precautions to prevent potential hazards.
If foods or feeds must be loaded into a vehicle which has been arranged by a third party then the operator must check that the proposed means of transport is suitable for the product to be transported.
If the operator is instructed by a customer to load a batch in a means of transport which is not considered by the operator to be suitable then the operator must inform the buyer of
24
This can be sent as a specific request to implement this type of procedure in the contract or sent as a separate letter or email.
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this and obtain written confirmation from the customer before loading. Copies of the correspondence in question must be kept.
Guidance If use is made of a loading facility at which nobody is physically present to inspect the loading compartment for transport, the operator can ask a written confirmation from the customer that loading may be done without a visual inspection.
3.5.6 Minimum requirements for Road Transport: Cleaning Regimes
3.5.6.1 Introduction
The transport of food and/or feed must be carried out in such a way prevent contamination of the load with residues from previous loads.
The operator must ensure this by, after every load, cleaning, inspecting and checking in the correct way and recording everything properly. Food or feed must (in combined transports) not become mixed together.
Transport of packaged products must take place in a clean and dry loading compartment. The loading compartment should be completely emptied and free of load remains and odour from previous loads.
There must be supervision of the absence of undesirable substances and other contaminants which are harmful to the health of humans or animals and proper control strategies must be available to make the risk as small as possible.
3.5.6.2 Acceptance of the order and cleaning regime
The operator must have at least a documented procedure for the acceptance of an order for the transport of food and/or feed.
The operator must determine the following before accepting the transport order:
What product will be transported? Which cleaning regime applies? For this the operator should request information
from the client with the transport order about the cleaning regime which applies. Before loading, the cleaning regime of the previous loads and of the new load must be determined, in order to assess which further requirements for cleaning and disinfection and the loading sequence need to be used.
In order to be able to establish this, the operator must be aware of the nature of the product and of the specific product characteristics including its (chemical) composition if needed. If deviations are observed during loading or during transport then the operator should carry out corrective actions.
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3.5.6.3 Check during loading
Prior to every food and/or feed transport, a visual check must be carried out as to whether the load compartment is clean, which means completely emptied and free of material residue and odour from previous loads, and dry25. The driver should visually check the product during loading.
3.5.6.4 Cleaning
After the transport, cleaning and/or disinfection must be carried out in accordance with the cleaning regimes established and prescribed in section 3.5.6.8
The operator must draw up a cleaning program for this which demonstrably complies with the legal requirements and the additional requirements for cleaning (and disinfection) of means of transport as laid down in section 3.5.6.8
The cleaning programs will include as a minimum:
The responsibilities with respect to cleaning The cleaning methods The frequency and times of cleaning The use of the various cleaning and disinfection regimes depending on the previous
load The critical items for attention per type of means of transport where there must be
an indication of which parts must be disassembled before the start of cleaning (these are, for example, places which are difficult to clean such as pipes, hoses, hinges, pumps, places which cannot be reached, etc.)
Cleaning and disinfection agents. These must be appropriate for the purpose for which they are used. They must also not form any risk to the safety of the food or feed which are being carried in the means of transport. The residues of cleaning and disinfecting agents must be kept as small as possible. Links to various European member states list of authorized cleaning agents are also available on the IDTF website (http://icrt-idtf.com/en/links.php)
Each cleaning program drawn up for a certain loading compartment must be checked for effectiveness (validated). Then this cleaning program can be adopted as the official cleaning method for each similarly constructed loading compartment.
After each cleaning, at least a visual inspection must be carried out. The result of this inspection must be registered in the logbook, together with the registration of the transported loads, the applied intervening cleaning regimes with the cleaning and disinfecting agents used.
25
As derogation to the general obligation to keep loading compartments dry, drying operations are not required in the specific case of two consecutive loads of wet products of the same type provided that the local temperature is low and stable in between the two consecutive loads.
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3.5.6.5 Monitoring and measuring
A. Checking the effectiveness of cleaning and disinfection regimes
The operator must review the effectiveness of the cleaning and disinfection methods used by way of additional checks. The operator must draw up a control program which includes the minimum frequency for carrying out these checks.
B. Management of monitoring and measurement equipment Please refer to point 3.1.14 of Chapter I
3.5.6.6 Registration
All transport, cleaning and inspection operations must be registered. This includes the following specific checks:
Loads should be recorded by the driver in the event of bulk road transport for each loading compartment in a journey sheet, which may be in electronic form, on the means of transport. The registrations of the three prior loads in the loading compartment) should be available for checking (with the driver or at the transport operator). The data in the vehicle journey reports must be transferred to the logbook at the offices of the transport operator. The registration of loads can use the IDTF numbers for easier convenience.
The legally records including the waybill should be available The cleaning and disinfection actions for each bulk load compartment must be noted
in the consignment note by the driver, whether or not in electronic form. The result of the cleaning and disinfection actions must be checked visually and recorded in the consignment note, along with the previous loads and the cleaning and disinfection actions
The prescribed inspections and checks and also any other inspections and checks must also be registered.
The carrier must be able to demonstrate that in the past no 'prohibited loads' have been transported in a loading compartment. Following carriage of a prohibited load, no food or feed may be transported, unless the means of transport and/or loading compartment has been released according to the procedure specified in section 3.5.6.8.
3.5.6.7 Corrective actions
If there have been contaminations with food or feed residues, undesirable substances and/or germs in a bulk loading compartment, then this latter must be cleaned so that no contamination of the next load can take place. Records of this must be available.
Records of the nature of non-conformities and any measures taken later, including approvals obtained, must be maintained.
If non-conformity is corrected then there must be verification again of whether there is compliance with the requirements.
This control must provide for identification, documentation, evaluation, segregation (when
55
practical), and disposal of non-conforming products and for notification to the involved parties, both internal and external.
Please also refer to general rules described in section 3.1.15 of this Code.
3.5.6.8 Cleaning regimes and sequences
A. Introduction
This paragraph proposes a categorisation procedure for bulk products transported by road, based on the risk levels they present for the subsequent load.
For transport of bulk products by trucks, the cleaning procedures are based on the rules set by the ICRT (international Committee for Road Transport), jointly developed and regularly updated by GMP+ International, OVOCOM, “Qualimat Transport ®, QS Qualität und Sicherheit and by the Coceral GTP Code with a positive list of products available on the ICRT-IDTF database:
http://www.icrt-idtf.com
In case of a previous cargo not being listed in this ICRT list, the operator will have to:
Request the GTP secretariat to risk assess this product based on the ICRT-IDTF internal procedures (see section 3.5.6.8. F) and
Get a provisional authorisation and product categorisation.
Note A GTP certified operator can also use short “extracted lists” of products from the Database of Road transport Loads for its day-to-day operation and update them on a regular basis each time the Database is updated. The User’s manual of this database gives all needed information’s on how to prepare and extract such “short lists”.
This database provides detailed product sheet on each products and also defines the required cleaning levels to be applied. It also gives a list of differences if cleaning regime for some products between the various safety scheme owners so that the GTP Operator can decide which one to implement based on a case per case basis.
Each ICRT scheme has also its own procedures to reallocate and validate containers or trucks that have transported “forbidden” products in the previous load.
On this basis the GTP operator can:
Access to each product sheet and verify its potential hazards Get the cleaning regime indication that needs to be applied Ensure that appropriate cleaning and/or washing and/or disinfection procedures are
applied to bring the risks of contamination to an acceptable level
Any packed and/or packaged product can be transported in such road transports in accordance with current regulations without need to follow such cleaning rules, but traceability still needs to be respected.
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B. Determination of the cleaning regime
Prior to the acceptance of a transport commission, the operator should verify with the driver and with the ICRT-IDTF database (on-line or using an extracted list) the cleaning regime that needs to be applied based on the previous transported product.
Section 3.5.6.8 D contains the instructions relating to the cleaning and disinfection regimes. The GTP operator should follow these instructions for cleaning and disinfection of the road load compartment prior to loading new products.
The following basic principles apply:
Before every food or animal feed transport there must be a visual check that the loading compartment is clean which means that it is completely empty and free of remains and odors from previous load and is dry26
The IDTF Database indicates for each product the minimum Cleaning Regime requested by each Safety scheme participant and the GTP Certified operator should choose the cleaning regime determined by the recipient party in case of differences and should follow the instructions for loading sequences, cleaning and disinfection adapted to the concerned previous cargo
The IDTF database is regularly updated and the GTP operator should closely monitor and take into account any changes.
Products that do not appear in the IDTF Database with one of the cleaning categories A, B, C or D are prohibited as previous loads for means of road transport of food or feed materials in bulk. A GTP Certified operator who wishes to enter a new product cleaning regime into the IDTF Database or to modify an existing one should refer to the procedure described in paragraph 3.5.6.8.F “Procedure for the (re)classification of product’s cleaning regime.
Special care should be taken when previous cargoes are by-products of animal origin regulated by (EC) Regulations No 999/2001 or (EC) Reg. No 1069/2009 or (EC) Reg. No 142/2011 as amended.
After a prohibited load, foods or animal feeds may no longer be transported. Only after a release of the means of transport by an independent loading compartment inspector, foods or animal feeds may be transported again in the loading compartment in question (see the procedure in paragraph 3.5.6.8 E Procedure for acceptance of a loading compartments after transport of prohibited loads)
Operators carrying out liquid food or feed transportation using bulk tankers should wet clean these tankers at least once per quarter.
C. Cleaning and disinfection regimes
Four basic principles can be distinguished with respect to cleaning and disinfection. The minimum necessary cleaning regime is established on the basis of the risk of contamination that the previously loaded product would create for the intended cargo to be loaded.
The four basic principles for cleaning are:
26
As a derogation, loading compartments should not be dried in case of two consecutive loads of identical wet products
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Dry cleaning Cleaning with water Cleaning with water and a cleansing agent Disinfection after one of the previous cleaning regimes (a, b or c)
a) Cleaning regime A (dry cleaning)
Application:
In the case of transport of dry „neutral‟ substances only, dry cleaning may be sufficient and beneficial both practically and microbiologically.
The general cleaning regime is as follows:
1. Clean the means of transport by extraction, blowing out or sweeping 2. Manual cleaning of places which are difficult to reach 3. If there are still remains after dry cleaning then use additional wet cleaning
EXPLANATION
In dry cleaning the preference is for suction because there is then no spreading of dust or dirt.
b) Cleaning regime B (cleaning with water)
Application:
After the transportation of products with cleaning regime B there should always be wet cleaning before the first transport of animal feeds.
Companies carrying out transportation using bulk tankers should wet clean these tankers at least once per quarter unless it can be demonstrated that there are no remains present in the bulk tanker.
Cleaning with water is necessary after transport of, for instance, damp or sticky substances or possibly harmful chemicals.
The general cleaning regime is as follows:
1. Remove residue from the previous load as much and as dry as possible 2. Pre-rinse with cold water, or warm if necessary, and clean difficult places
manually 3. Manual cleaning 4. High-pressure cleaning with water 5. Dry through ventilation or hot air dryer.
Explanation With open vehicles it is best to use a high-pressure cleaner with a flat nozzle with at least 25 bar pressure or higher. If chemicals need to be removed, (e.g. chemical fertilizers) warm water should be used at a temperature of at least 60°C, to dissolve the chemicals more easily.
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Places that are difficult to reach should if necessary be cleaned separately with additional means such as brushes. It is important that the water can be drained.
c) Cleaning regime C (Cleaning with water and cleansing agent)
Application:
In case of load containing protein or grease, it is necessary to use a cleansing agent.
The general cleaning regime is as follows:
1. Remove residue from the previous load as much and as dry as possible 2. Pre-rinse with hot water (max. 60 °C) and clean difficult places by hand 3. Foam or gel with a cleaning agent for tippers open wagons or flush with
CIP cleaning agent at 80 °C in the event of tank cleaning 4. Rinse with water at approx. 60°C 5. If necessary dry through ventilation or hot air dryer
Explanation: A raised water temperature is required to remove fats more easily. This may however not be higher than 60 degrees Celsius to prevent the protein from coagulating and thereby sticking to surfaces. To facilitate the removal of protein and greases it is advisable to use a medium to strong alkaline cleansing agent, using the dosage prescribed by the manufacturer. In open systems it is best to use a foaming degreasing agent. In the case of tank cleaning with spray balls, no foaming agents may be used. It is then better to use a so-called Cleaning in Place (CIP) agent at a high temperature. In specific cases, such as the removal of calcareous substances, an acid cleansing agent is preferable.
d) Cleaning regime D (Cleaning with water and cleansing agent and disinfection)
Application:
After the transportation of products with cleaning regime D there should always be cleaning
and disinfection before the first load of animal feeds or food in bulk. Disinfection is only
necessary if preceding loads are microbiologically unacceptable (detectable signs of decay),
or if it is known that they carry micro-organisms that cause disease, such as Salmonella.
The general cleaning regime is as follows: 1. Cleaning in accordance with cleaning regime A, B or C 2. Disinfection with a legally-permitted disinfectant (approved for the
foodstuff industry) at a dosage indicated in the instructions for use. 3. If necessary wet rinsing 4. If necessary dry through ventilation or hot air dryer.
The ICRT-IDTF Website gives, in its “useful links page” (http://icrt-idtf.com/en/links.php ) , some links to lists of authorized disinfection agents in various EU member states.
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Explanation: Another form of disinfection (e.g. dry) may only be applied if its effectiveness has been established.
A distinction can be made between disinfectants tested for bactericidal and fungicidal effect and those tested for bactericidal, fungicidal and virucidal effect. The latter may only be used in the livestock sector. For food or animal feed transport vehicles, use of a disinfectant approved for the food industry is the only other alternative.
Use of a combined cleansing and disinfecting agent containing active chlorine is only possible on smooth surfaces that are easy to clean, such as stainless steel.
In all other cases it is better to clean first and then disinfect, in which case, for the disinfection of open vehicles disinfectants containing active chlorine are advised. In some cases it is not advisable to use agent containing chlorine, such as for materials which corrode easily or after an acid cleansing due to the forming of toxic chlorine gases. In this case quaternary ammonium compounds may be used, except for tank cleaning with spray balls due to foam forming. Their advantage is that they adhere better and therefore work longer. The disadvantage is that they are more difficult to remove.
For closed tankers, the use of acetic acid can be considered. Its advantage is that it activated less by residues than active chlorine is. The penetrating odour and the harm it does to rubber are a disadvantage. Disinfectants must be given at least five minutes to take effect.
The food industry prescribes rinsing after disinfecting. In order to avoid the risk of residues, it is advisable to apply this to transport vehicles as well, unless it can be demonstrated that residues do not constitute a risk. In some cases, removing the disinfectant can lead to the development of surviving bacteria if the surface re-mains wet for too long.
After cleaning loads containing animal proteins, a check may be carried out for residues of components of animal origin in animal feeds according to the microscopic screening methods laid down in the legal requirements..
Other additional checks will be carried out to assess the effectiveness of the cleaning and/or disinfection method used. In order to assess the cleaning, ATP (Adenosine Tri Phosphate) measurements can be used. ATP is present in all animal and vegetable cells and can thus be used as an indicator for the extent of biological contamination left on surfaces. The ATP measurement itself is very easy and can yield a result within minutes. The application of ATP is not useful in most cases of transport of chemicals. In order to verify the effectiveness of a particular disinfection technique in use, agar stamps can be used, which can deter-mine the numbers of surviving micro-organisms. This technique takes a day to produce results, which means that any necessary adjustments to the disinfection process can only be made afterwards. This technique provides results only after a period of one day so that any required modification of the disinfection process can only take place later.
More advanced methods may be used for checking on chemical residues and pesticides such as HPLC and Mass Spectrometry (MS).
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D. Instructions for transport sequence, cleaning and disinfection
Rules of cleaning and disinfection based on previous loaded cargo
Instructions for transport sequence, cleaning and disinfection
Previous load Following load
Cleaning regime
Description of the product
State of the bulk loading compartment
Animal Feed or Food Product
Animal feed products for
laying poultry
Forbidden load Very high-risk materials n/a
Not allowed. Requirements for the release of transport means for the
transport of animal feed or food are set in procedure "3.5.6.8 E "for the
acceptance of loading comparments after the transport of prohibited loads
Cleaning method
approved by the competent
authority or inspection by
the competent authority
"(Products containing) certain animal products
as per regulation (EC) No 999/2001 (*)
n/a
Feed for Ruminants.
Requirements for the release of transport means for the transport of
animal feed are set in Re. (EC) No 999/2001 and by the competent
authority
Cleaning method
approved by the competent
authority or inspection by
the competent authority
"(Products containing) certain animal products
as per regulation (EC) No 999/2001 (*)
Feed for non-ruminants
After unloading A
Residue after dry cleaning
B
(odour) residue after cleaning with water
C
D
Microbiologically contaminated materials
(for example Salmonella) or
perceivable signs of decay (for example abnormal odours)
After unloading A+D
Residue after dry cleaning
B+D
(odour) residue after cleaning with water
C+D
C
Material constituting a physical and/or
chemical risk, not or badly soluble in water
load containing protein or grease
After unloading C
(odour) residue after cleaning with water and cleaning agent
Additional cleaning until (odour) residues are removed
B Material constituting a
physical and/or chemical risk
After unloading B
(odour) residue after cleaning with water
C
A Neutral materials After unloading A
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Residue after dry cleaning
B
(odour) residue after cleaning with water
C
Compound feeds and premixes with
nicarbazine and medicated feeds with
sulpha agents
After unloading A A **
Residue after dry cleaning
B B**
(odour) residue after cleaning with water
C C**
Cleaning regime
A. Dry cleaning C. Cleaning with water + cleansing agent
B. Cleaning with water D. Disinfection after applying cleaning regime A, B or C
(*) By "(Products containing) certain animal products in accordance with Regulation (EC) no.
999/2001" is meant: Processed animal proteins(as defined in Regulations (EC) No 1069/2009 and
142/2011) Blood products Hydrolysed proteins Dicalcium phosphate and tricalcium phosphate (of animal origin) Gelatin from ruminants Feeds which contain these animal products
This does not include (if designated as processed category 3 material): Milk and products on the basis of milk and colostrum Colostrum Eggs and egg products Hydrolysed proteins from parts of non-ruminants or from skins of ruminants (the
hydrolysed protein must be produced in an establishment or plant which has been approved as per Regulation (EC) No 1069/2009, using a method that meets at least the standards referred to in Reg. (EC) No 142/2011, Section 5, sub. D (Hydrolysed protein derived from ruminant shall have a molecular weight below 10,000 Dalton)
Gelatin from non-ruminants Collagen
Definition of processed animal proteins:” according to Regulation (EC) No 142/2011 Annex I :
Animal proteins that were derived fully from category 3 material and that were processed in accordance with Section 1 of Chapter II of Annex X (including blood meal and fishmeal) so as to render them suitable for direct use as feed material or for any other use in feedingstuffs, including petfood, or for use in organic fertilisers or soil improvers; however, it does not include blood products, milk, milk-based products, milk-derived products, colostrum, colostrum products, centrifuge or separator sludge, gelatine, hydrolysed proteins and dicalcium phosphate, eggs and egg-products, including eggshells, tricalcium phosphate and collagen.
As a general rule, the concerned GTP operators must comply with legal requirements as laid
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down in (EC) Regulation No 999/2001 of 22 May 2001 laying down rules for the prevention, control and eradication of certain transmissible spongiform encephalopathies as amended.
(**) The specified cleaning instructions only apply when the manufacturer can show that
the end feed remains under the total carry-over norms (factory carry-over including the carry-over during transport). For the carry-over of nicarbazin/sulpha’s during transport 0.03% may be assumed if use is made of a bulk tanker where the compartments are pressurised during unloading. If an operator is unable to show that the end feed remains under the total carry-over norms then a very penetrating and strict cleaning procedure should be used. It must be demonstrated with very clear documentation in what manner the carry-over is controlled (for example by way of flush batches).
E. Procedure for acceptance of loading compartments after transport of
forbidden loads
For the release of a loading compartment a carrier may choose from two possibilities after the transport of a prohibited load:
1. Release by a control organization or certification/inspection body
The following steps must be taken in the following order to obtain access to a loading compartment after the transport of a prohibited load:
Cleaning specific to the nature of the prohibited load must be carried in accordance with a protocol previously detailed by the operator
Assessment of the loading compartment - at the expense of the operator - before loading with feed or food materials and after the above cleaning by an independent control organisation or certification/ inspection body with a certified or accredited status with respect to loading compartment inspections
The release must be done by a loading inspector who meets one or more of the following requirements:
He/She is employed by a certification/inspection body which is accredited in accordance with ISO 17020 (with a specialization in animal feeds/foods/grains or liquid agri-bulk) and/or accredited in accordance with EN 45011 (where the inspection of loading compartments is part of the accredited scope)
He/She is employed by an organisation operating in accordance with a recognised certification system such as ISO 9001:2008 or an equivalent where the inspection of loading compartments is demonstrable mentioned as a part of the certified scope
The controlling body will use a log book to find out which previous loads have been transported and which cleaning and disinfections have been carried out. The loading area of the vehicle is then visually checked for any residue, especially in places that are difficult to clean.
Issuing by the loading inspector of a declaration (at the inspection address) that must indicate whether the means of transport of the loading compartment can be used for the transport of foods or feeds materials in bulk
Depending on the previous loads and the results of the visual inspection, further hygiene tests can be carried out- in the judgment of the loading inspector - using for
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example ATP measurements or agar stamps, at the operator’s expense.. Another possibility is the analysis of the flushing water (for more information see item 2).
2. Release by a loading inspector from a GTP certified operator
The following steps must be taken in the following order to obtain access to a loading compartment after the transport of a prohibited load27 .
After the transport of a prohibited load, the operator should carry 5 neutral loads (with cleaning regime A, B or C) in so far as no foods or feeds materials are involved) in the means of transport in question before it may be released for road transport of food or feed materials;
A cleaning operation must be carried out, based on a protocol specifically adapted to the concerned prohibited load, with water (and disinfectant) according to a protocol previously developed by the operator. The operator should demonstrate the carrying out of the cleaning and/or disinfection by way of a European Cleaning Document (ECD) or a comparable cleaning certificate from the cleansing/flushing station.
Assessment of the loading compartment before loading with food or feed and after the cleaning and disinfection referred to above by an (own) loading inspector from the GTP or another recognized/equivalent safety standards certified operator which will load the next GTP load into the loading compartment. The food or feed operator is not permitted to release its own means of transport in this way.
The loading inspector referred to above will use a log book to find out which previous loads have been transported and which cleaning and disinfections have been carried out. The loading area of the vehicle is then visually checked for any residue, especially in places that are hard to clean or difficult to access.
Issuing by the loading inspector of a declaration (at the GTP-certified operator loading address) that must indicate whether the means of transport or the loading compartment can be released (used again) for the road transport of foods or feeds materials in bulk.
Note:
A loading inspector is a loading inspector employed by a GTP. This is a position in the quality system which is held by an employee who on the basis of training and experience has the knowledge and expertise to be able to inspect the loading compartment for its suitability for loading with foods or feeds, or
Depending on the previous loads and the results of the visual inspection, further hygiene tests can be carried out using ATP measurements or agar stamps, at the operator’s expense, and this will be assessed by the loading inspector. Another possibility is an analysis of the latest flushing water (at the expense of the operator).
27
List of existing Prohibited loads can be find in the ICRT-IDTF Database http://icrt-idtf.com/en/index.php. See also item 3 here-below
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3. The following loads are excluded from release via the procedure described above: a. Loads (products with) processed animal proteins. These loading
compartments must also, in the EU, be released by the competent authority in accordance with the requirements of Reg. (EC No 999/2001
b. For the following forbidden loads, release is only allowed by a loading inspector from a certification /inspection body and/or control organization (as described in item 1):
1. Category 1, 2 and unprocessed Category 3 material - Regulations (EC) No 1069/2009 and (EC) Reg. No 142/2011 2. Gas oil 3. Lubricating oil 4. Mineral clay that has been used for detoxification 5. Radioactive material 6. Domestic waste and all fractions derived from this 7. Untreated food remains 8. Sewage sludge
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The release procedure can be schematically described in the following diagram: F. Procedure for the (re)classification of product’s cleaning regime
Previous cargoes products and materials which are not included in the IDTF Database and have therefore no cleaning regime set are prohibited as loads for loading compartments which are used for foods or feeds.
Release procedure option 1:
Transport of a prohibited load
Cleaning/disinfection tailored
specifically to the nature of the
prohibited load.
Release by a loading compartment
inspector of a control organization of
certification/inspection
Issue statement that the loading
compartment can be used again for
feeds or foods materials in bulk
Release procedure option 2:
Transport of a prohibited load , with exception of loads listed under item 3
Transport of 5 neutral loads (with
cleaning A, B or C with the exception of
food or feed materials) in loading
compartments where prohibited load
have been transported.
Cleaning/disinfection tailored to the
nature of the prohibited load
demonstrably via a European Cleaning
Document (ECD) or an equivalent
cleaning certificate from a
cleaning/flushing station.
Release by a compartment inspector
before loading with food or feed material
in bulk by a operator inspector of a GTP
certified operator (or from a
recognized/equivalent safety scheme)
Issue statement that the loading
Compartment can be used again for
road transport of feeds or foods
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A GTP certified operator which wishes to classify or reclassify a product’s cleaning regime should submit a request to the GTP Code manager and use the application form template available on the ICRT-IDTF website at: http://icrt-idtf.com/en/procedures.php The procedure will take about three months. If for some reason the decision-making is going to take longer, then the applicant will be informed of this in good time.
a. The basic principles of the IDTF (International Database Transport for Feed) and GTP with respect to decision making as a result of the request will be based on the following parameters to be supplied by the applicant operator:
The applicant is a GTP certified operator The operator specifies the desired cleaning regime The operator specifies the current cleaning method in the event of
reclassification The operator specifies the usual type of transport means for which the loading
category is being applied for The operator specifies the risk of residual values or constituent parts of the
product in question after the cleaning method used by the operator (sup-porting material)
b. The operator draws up the application form (see ICRT-IDTF website) as specified above with, among other things, the following:
- the product composition (if possible accompanied by a product sheet / safety information sheet [MSDS] with the complete chemical analysis including impurities and contamination) - the findings and analysis results of the residue sampling carried out after cleaning - a sample of the product in question (c. 500 gr). This latter may be sent to COCERAL – 98 rue du Trône 98 – B-1050 Brussels – BELGIUM - Att GTP Code Manager
The operator should make use of the application form and send it directly to GTP by using the mail address [email protected]
c. The GTP will inform, in English, the operator of the classification advice from the IDTF following reception of the complete dossier.
If the GTP considers the dossier not to be complete then the operator will receive notice of this within 14 days (by E-mail, fax or letter)
If the IDTF on the basis of its expertise is unable to give a classification ad-vice on the basis of the dossier then the operator may follow the procedure described in d.
If a classification advice is given then see item g. d. If the IDTF on the basis of its expertise is unable to provide a classification advice on the basis of the dossier then the operator may at its own expense request an expert institute to provide an advisory report with supporting arguments (based on a risk assessment) in which there is an indication of into which cleaning regime the product in
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question may be classified. e. The expert institute should assess the safety risks for the product for foods or feeds (incl. feed materials and other feeds) which will be transported after the product in question and after cleaning in accordance with the prescribed method of cleaning in the same loading compartment. This includes both the safety risks for animals which consume the subsequently transported feed and for consumers of the products from the animals in question or from the loaded food product.. f. In the provision of advice relating to the classification with a cleaning regime the expert institute should also take into account the cleaning and disinfection regulations as laid down in paragraph 3.5.6.8 D “instructions for Transport sequence, Cleaning and Disinfection”. g. The advisory report of the expert institute should be sent to the GTP Code secretariat for the attention of the GTP Code IDTF contact ([email protected]). The GTP Code manager will inform the operator on receipt of the advisory report of whether the classification advice of the IDTF will be followed. The GTP Code retains the right to make use of the knowledge arising from the expert advice for the accumulation of expertise in its institutes but guarantees the confidentiality of the advice of the experts.
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4. CODE SECTION 2: APPLICATION OF THE HACCP SYSTEM
This section deals with establishing a control and monitoring system for the food and feed risks specific to the collection, storage, trade and transport of cereals, oilseeds, protein crops and their co-products by applying the principles of the HACCP method.
4.1 HACCP - Hazards Analysis and Critical Control Points As requested by EU Food and Feed Hygiene Regulations (EC n° 178/2002,, EC n° 183/2005 and other related regulations) the operator must carry out a formal risk assessment in accordance with recognised HACCP principles such as those outlined by the Codex Alimentarius Commission of the World Health Organisation in ‘Recommended International Code of Practice General Principles of Food Hygiene – CAC/RCP 1- 1969, Rev. 4 – 2003’.
The risk assessment must aim to identify and control hazards that might adversely affect the safety of any products supplied.
The scope of the HACCP must cover all aspects of the operator’s business including where applicable collection, trading, storage and transport.
4.2 Prerequisites The operator is recommended to put in place a documented and effective prerequisite program for the HACCP system they implement. These are specified, formal procedures that control potential hazards on a site-wide basis, such as: pest control, glass policies, training, waste management, raw material and food and feed ingredient specifications, etc.).
Where prerequisites are used, they must be defined as part of the HACCP Plan and included in any auditing schedule established as a result of the HACCP Plan.
4.3 HACCP Team In order to establish a risk assessment system, the operator must appoint a HACCP Team to produce an effective HACCP Plan.
The HACCP Team must include:
Staff from all of the relevant operations and functions within the operator At least one member with demonstrably effective HACCP training Where operators delegate key activities to third parties, it is desirable for
representatives of the third party organisation to be included in the HACCP Team.
The composition of the HACCP Team and competence of the members must be documented. It is acceptable for individual personnel to fulfill multiple roles in the HACCP Team or to use resources from outside of the operator, provided that the role of the Team remains effective.
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4.4 Product Specifications Each product traded must have a written specification that is made available on request to purchasers and potential purchasers of the food and feed materials offered by the operator.
Specifications must be amended when any relevant changes take place. In order for the hazards associated with a particular product to be assessed, the written specification must include:
Analytical characteristics Precise identification of the product supplied (by name or as per EU Feed Materials
Catalogue28 or relevant Food legislation29) Origin/source Any processing of the food or feed materials Any special characteristics that may affect or restrict the potential use Hazards or limitations for intended use, where these apply.
4.5 Purchasing Process The operator must ensure that purchased food and/or feed and services comply with the specified purchasing requirements. This should be described in a documented procedure. The method of control which is used on the purchased product and the supplier must be dependent on the effect of the purchased product on subsequent product realization or on the end product.
The operator must assess suppliers and choose those suppliers who are able to deliver a product which complies with the requirements of the operator. The following requirements must at least be met with respect to the above.
a) The operator purchases products or services for which there is a GTP standard only from suppliers who are GTP or equivalent certified at the moment of delivery b) Contrary to paragraph a), the operator may also take products or services from suppliers which are certified based on a standard approved in a GTP equivalent scheme c) Contrary to paragraph a), certain products and services may also be bought without one of the above certificates. Separate gatekeeper requirements referred to in section 3.2.3 must be complied with
Prior to the purchase of other products (other than feed) or services (other than storage and transshipment, transport or laboratory) the operator must carry out its own risk assessment based on HACCP principles. Based on this risk assessment and also the quality assurance, which is applied by the supplier, the operator must make a selection of suppliers and must adjust his (entry) check accordingly. Criteria for selection, assessment and reassessment of the supplier must be established. Records of the results of the review and any required actions arising from the review must be maintained.
Purchasing data must describe the product or service to be purchased. This includes in any event and where applicable a description of requirements for approval of the product,
28
Commission Regulation (EU) No 68/2013 of 16 January 2013 on the Catalogue of feed materials 29
Regulation (EU) No 1169/2011 on the provision of food information to consumers
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procedures, processes and equipment. The operator must establish and implement the inspection or other activities which are required in order to ensure that the purchased products and services comply with the specified purchasing requirements.
4.6 Definition of Process Steps The HACCP Team must identify and record all of the steps involved in their operations from procurement and supplier approval, through to the point at which products are transferred to a purchaser (process analysis).
The process analysis must be illustrated using a flow diagram that shows each step of the process / operation. Flow diagrams must include clear identification of each step which must be documented.
Changes in operations must be identified and records maintained.
Changes in operations must be reviewed, verified and validated, as appropriate, and approved under the HACCP Plan before implementation. The review of changes must include evaluation of the effect of the changes on food and/or feed safety.
4.7 Hazard Analysis / Identification (CODEX principle 1) The HACCP Team must identify, categorise (severity & frequency), evaluate, record and document any possible chemical, physical or microbiological hazards that could adversely affect the food and/or feed safety of products supplied. Consideration must be given to the characteristics and intended use of the products in accordance with recognised HACCP principles.
The operator must carry out a separate hazard analysis for each product/ product type.
For each process step, the operator must either specify or reference the system / procedure in place to control potential hazards at that process step (control measures), and record these in the HACCP Plan.
Control measures must be sufficiently robust to prevent the occurrence of new hazards or detect / eliminate the presence of existing hazards.
4.8 Determination of Critical Control Points (CODEX principle 2) Control measures that are essential in detecting and eliminating hazards (that is the hazard would not be detected or removed at any later stage in the operation) must be regarded as Critical Control Points (CCPs) and must be identified as such within the study.
CCPs must be recorded in the HACCP Plan.
4.9 Establishing Critical Limits (CODEX principle 3) The HACCP Team must identify the critical limits at the CCPs for all of the hazards that have been identified.
Critical limits must be set at levels such that the food and/or feed safety of the products is
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assured.
The operator must have a permanent system to monitor regulatory developments concerning food and/or feed safety to ensure critical limits meet legal requirements as appropriate.
4.10 Monitoring (CODEX principle 4) The CCPs in the operation must be monitored to ensure identified hazards remain under control.
Monitoring must be implemented in accordance with a documented schedule. All results must be recorded.
Note It is acceptable for the monitoring of some hazards to be organised and/or compiled on an industry or sector-level in order to establish background data and spread the efforts and cost of monitoring.
4.11 Preventive / Corrective Actions (CODEX principle 5) The operator must take suitable, prompt and effective remedial action when information shows that hazards are not within critical limits.
The operator must record action taken when critical limits are breached and ensure that actions deal with both the cause of the problem and the consequences of the problem.
4.12 HACCP System Reviews (CODEX principle 6) At least one complete HACCP review must be carried out each year and must include all prerequisites established as part of the HACCP Plan.
The HACCP Team must carry out regular reviews to verify the requirements of the HACCP plan are being met in practice and that the plan effectively and consistently ensures the safety of products traded.
HACCP reviews showing the HACCP Team findings and any action implemented must be recorded, documented and implemented in the HACCP Plan.
The operator must carry out an internal audit annually and ensure that any non-conformances are addressed with corrective actions. The results of the HACCP review may form part of the internal audit.
4.13 Documentation (CODEX principle 7) The operator must establish a documentation system which as a minimum contains:
The HACCP documents, referring to each of the stages (control plans, procedures, operating methods etc.) forming the HACCP plan;
The records cited in the HACCP plan.
The operator must ensure that all documents and records produced within the context of
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the HACCP system are validated, stored and archived for an appropriate period of time.
Records must be kept for a minimum of 5 years unless there are additional requirements.
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YES NO YES NO YES NO YES NO YES NO
YES NO YES NO
YES NO
YES NO
YES NO Covered/allowed by the GTP certification
Not covered by the GTP certification
ARE YOU IN/OUT OF THE GTP TRANSPORT CERTIFICATION? (Version 1.0)
Own road transport
(GTP Code § 3.5.2)
Sub-contracted road transport
(GTP Code § 3.5.3)
Road transport under third party’s
responsibility (GTP Code § 3.5.5)
Rail transport
(GTP Code § 3.5.4)
Inland waterway
(GTP Code § 3.5.4)
No
GTP
GTP if combined
with collection,
storage and/or
trading GTP modules
Is transport carried out by a company carrying
out only transport activities?
Is the subcontractor certified against a
scheme equivalent or recognised by the GTP?
Is the certified
sub –contractor compliant with GTP
Code §3.5.3.?
Is the non-certified sub -
contractor compliant with GTP
Code § 3.5.2 and is the
GTP company compliant with GTP
Code §3.5.3.2?
GTP and no application of the gatekeeper protocol
No
GTP
No
GTP Are these goods destined to non-certified
customers?
No
GTP
GTP
GTP operator is requested to make use either of customer’s trucks or
service provider’s ones
GTP
Is rail transport carried out by a dedicated rail transport company?
Are these goods directly shipped to a certified
company?
No
GTP
GTP, if combined
with collection,
storage and/or
trading GTP modules
Are these goods
transported via certified
barges?
GTP goods can be delivered to GTP
companies and operators certified against scheme
requiring mandatory certification of barges
0
GTP, if minimum provisions of § 3.5.4
are complied
with
GTP goods can be delivered to a GTP
certified or non-certified companies if minimum provisions of § 3.5.4 are
complied with
Seagoing transport
(GTP Code § 3.5.4)
Are these goods transported by a
charterer complying with GTP Code §3.5.4?
No
GTP
GTP
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REFERENCE 2. LIST OF GTP EQUIVALENT AND RECOGNISED SCHEMES
REFERENCE 2.1. GTP EQUIVALENT SCHEMES The food and/or feed safety assurance schemes listed hereafter are considered as equivalent to GTP further to a successful benchmarking exercise and the signing of mutual recognition agreement. Supplies from companies certified against one of the above-mentioned schemes do not require the application of the gatekeeper procedure.
You will find hereafter the detailed conditions and modalities of such agreements with other scheme owners. In case of doubt on the limit and the boundaries of mutual recognition please contact GTP at [email protected]
Scope of activities Range of products Destination(s)
GTP / GMP+-FSA Full mutual recognition for the collection, storage, trading and transport
Full mutual recognition for unprocessed and processed feed materials of vegetable origin
Feed
GTP / GMP-Ovocom Full mutual recognition for the collection, storage, trading and transport
Full mutual recognition for unprocessed and processed feed materials of vegetable origin
Feed
GTP / FEMAS Full mutual recognition for the collection, storage, trading and transport
Full mutual recognition for unprocessed and processed feed materials of vegetable origin
Feed
GTP / UFAS Full mutual recognition for the collection, storage, trading and transport
Full mutual recognition for unprocessed and processed feed materials of vegetable origin
Feed
GTP / TASCC Full mutual recognition for the collection, storage, trading and transport
Full mutual recognition for unprocessed and processed feed and/or materials of vegetable origin
Food & Feed
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REFERENCE 2.2. SCHEMES RECOGNISED BY GTP/COCERAL The food and/or feed safety assurance schemes listed hereafter are all recognised by GTP as valuable certification schemes ensuring good level of food and feed safety. However, no benchmark exercise and no mutual recognition agreement were formally carried out and signed between COCERAL and these scheme owners until the date of publication of GTP version 1.3.1 For certain schemes such as EFISC and FAMI-QS, no mutual recognition agreement can be formally reached as the respective schemes do not cover the same activities. These schemes are nevertheless considered by GTP as key reliable market players covering the production of feed ingredients and feed additives.
Scope of activities Range of products Destination(s)
CSA-GTP (Coop de France Métiers du grain/FNA / Synacomex)
Collection, storage, trading and transport
Unprocessed food & feed materials of vegetable origin Food & Feed
EFISC (EFISC Europe) Production, manufacture, processing
Oilseed crushing, oil refining and starch processing Feed
FAMI-QS (FAMI-QS) Production, manufacture, processing
Feed additives, premixtures and specialty feed ingredients
Feed
Qualimat (Qualimat) Road transport All type of goods, including feed materials Feed
Qualiwag (Qualiwag) Rail transport All type of goods, including food & feed materials Food & Feed
QS (Qualität und Sicherheit)
Trading Unprocessed feed materials of vegetable origin Feed
Please note that this annex will be subject to continuous improvement and update in order to reflect the most up-to-date state of mutual recognition with other certification schemes. The various updates of this document will be made available on the GTP website. In case of doubts or questions, please contact us at: [email protected]
