VERSION 6.0 SUPERVISION, SAMPLING AND WEIGHING Assurance/GTAS... · Where weight is to be...

SUPERVISION, SAMPLING AND WEIGHINGVERSION 6.0

Code of Practice for Supervision,Sampling and Weighing

Effective from: 1st April 2015

GTAS Supervision, Sampling and Weighing Manual.Published by Gafta: GTAS © Version 6.0

effective from 1st April 2015

SUPERVISION, SAMPLING AND WEIGHING


CONTENTS

GAFTA TRADE ASSURANCE SCHEME 1

2 Introduction2 Scope2 Definitions2 Loading and Discharge2 HACCP2 Supervision3 Contractual Provisions3 Sampling and Weighing Rules3 Gafta Register of Approved Superintendents3 GTAS Certified Superintendents 3 International Database for Transport of Feed (IDTF)4 Superintendents Operations4 Compliance with Rules4 Sampling4 Quality and Condition4 Cleanliness Inspection4 Weighing5 Fumigation/Disinfestation/De-naturing5 Phytosanitary/Veterinary/Radioactivity/Health Certificates5 Contracting out5 Risk Assessment5 Instructions5 Administration and Records5 Health and Safety Regulations for Employees5 Security of Samples5 Training6 Responsibility6 Code of Conduct7 Professional Indemnity Insurance7 Complaints Procedure7 Records

8 Appendix 1: General Definitions10 Appendix 2: Introduction to HACCP17 Appendix 3: Cleaning Methods18 Appendix 4: International Database for Transport of Feed (IDTF)

GAFTA TRADE ASSURANCE SCHEME2


1.0 Introduction Where goods are traded, stored, handled and transported there is a normally a contractual requirement to establish the quality and condition of goods and to monitor and independently oversee loading and discharging operations. The role of cargo superintendents is to observe and report the facts, to undertake inspections, to draw samples and to arrange analysis and finally to issue written reports and certificates. Thus cargo superintendents and surveyors have a vital role to play in establishing contractual compliance and the supply of safe food and feed.

These Rules and Code of Conduct are issued for Superintendents and Surveying companies that are GTAS certified and which are listed on the GTAS database, hereinafter referred to as "Superintendents".

A superintendent found to have acted contrary to any provision of these rules or this code or to their spirit may be subject to disciplinary action.

2.0 Scope This manual provides the best practice guidance for the supervising, sampling and weighing of goods. It is of paramount importance that the quality and integrity of any goods covered by this scheme will be maintained throughout; from where they are grown and/or produced, until delivery to final destination.

3.0 Definitions “Definitions” relating to this Manual are set out in Appendix 1.

Key Standards Standards marked with a "K" in the left hand margin indicate a "key" standard. If an assessor finds a major non-conformance against a key standard this shall result in suspension until rectified. See Scheme Operating Protocols in Scheme Overview.

Records Where an [R] appears in a standard this indicates that a record(s) must be kept in relation to that standard. See 23.0.

4.0 Loading and Discharge Loading and discharge operations can take place at port installations, primary processing plants, storage facilities, and elevators (including floating elevators, tank terminals and ship to ship transfers). The operators of these facilities will be responsible for the movement of the goods in terms of maintaining their quality and integrity during either the loading or discharge operation. In addition the responsibility of ascertaining the weight of goods will be within their remit. (See Gafta Weighing Rules No.123).

The key controls necessary for the load/discharge operators are: -

1. All goods loaded or discharged must be via a secure route and method. 2. Where weight is to be determined the goods must pass through the weighing equipment in a secure route. 3. Records must be maintained on the cleaning of handling and weighing equipment. 4. Records must be maintained on the checks/calibration of the weighing equipment. 5. All sweepings and or spillage must be uplifted and accounted for either by weighing or by mutual agreement between the contracting parties or their representatives. 6. All local and national health and safety legislation must be observed. 7. Special attention, when instructed by the owner of the goods, should be given to the handling of organic and genetically modified materials.

5.0 Hazard Analysis and Critical Control Points (HACCP) The application of a HACCP approach is central to the Gafta Trade Assurance Scheme with the aim of minimising losses, damage and contaminant risks.

Superintendents must demonstrate an awareness of the principles of HACCP and have a HACCP plan in place covering their activities. (See Appendix 2).

The HACCP plan should include a procedure for advising the relevant parties regarding any threats to food or feed safety as required by the relevant regulations.

6.0 Supervision Detailed provisions and requirements are made on the appointment of independent superintendents. Where goods are traded on Gafta contracts, traders are required by the contract to appoint superintendents from the Gafta Register of Approved Superintendents who comply with the Gafta Rules and Code of Conduct for Superintendent and Surveying Companies and are members of the Association. Where other types of contract are involved, traders are required to appoint superintendents from either the list of GTAS Certified Superintendents who comply with the GTAS Code of Practice for Superintendents or from the Register of Gafta Approved Superintendents. The GTAS Code of Practice is a summary of the minimum requirements to be adopted by Superintendents, when appointed by, or on behalf of Buyers and Sellers.

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7.0 Contractual Provisions7.1 Sampling and Analysis Where parties have agreed to trade on Gafta contracts, the requirements for supervision and sampling at ports of loading and discharge are contained within the standard Gafta Sampling and Analysis clause, which reads:

For ports of loading: “SAMPLING, ANALYSIS AND CERTIFICATES OF ANALYSIS- the terms and conditions of Gafta Sampling Rules No.124 are deemed to be incorporated into this contract. Samples shall be taken at time and place of loading. The parties shall appoint superintendents, for the purposes of supervision and sampling of the goods, from the Gafta Register of Superintendents. Unless otherwise agreed, analysts shall be appointed from the Gafta Register of Analysts.”

For ports of discharge: “SAMPLING, ANALYSIS AND CERTIFICATES OF ANALYSIS- the terms and conditions of Gafta Sampling Rules No.124 are deemed to be incorporated into this contract. Samples shall be taken at the time of discharge on or before removal from the ship or quay, unless the parties agree that quality final at loading applies, in which event samples shall be taken at time and place of loading. The parties shall appoint superintendents, for the purposes of supervision and sampling of the goods, from the Gafta Register of Superintendents. Unless otherwise agreed, analysts shall be appointed from the Gafta Register of Analysts.”

7.2 Weighing Where parties have agreed to trade on Gafta contracts, the requirements for weighing are contained within the standard Gafta Weighing clause which reads (inter alia): “the terms and conditions of Gafta Weighing Rules No. 123 are deemed to be incorporated into this contract.”

8.0 Sampling and Weighing Rules8.1 Gafta Sampling Rules Form No.124 The Gafta Sampling Rules Form No.124 is the key document that Gafta Approved Superintendents must follow. The rules set down the methodology for the drawing, mixing and sealing of contractual samples to be used for analysis tests or arbitration purposes, which are deemed to be representative of the entire contractual quantity. The rules cover the sampling operations at both loading and discharge.

8.2 Gafta Weighing Rules Form No. 123 The Gafta Weighing Rules require that weighing should be undertaken via a secure route through accurately calibrated weighing apparatus and sets out which types of weighing apparatus are acceptable and the procedures to be followed.

9.0 Gafta Register of Approved Superintendents Superintendents who have been certified by Gafta are included in the Gafta Register of Superintendents. The Register is freely available to members and non-members of Gafta on the Gafta website, www.gafta.com.

10.0 GTAS Certified Superintendents Superintendents who have been certified under GTAS are included in the GTAS database. The up-to-date database is freely available to members and non-members of Gafta on the Gafta website, www.gafta.com.

11.0 International Database for Transport of Feed (IDTF) The International Committee for Road Transport (ICRT) is a Committee of European Food/Feed Assurance Scheme owners that operates the International Database for Transport of Feed (IDTF).

The Committee adopts a harmonised view on types of materials that can be transported and stored under the codes of practice and agrees on suitable cleaning regimes. Where an agreement cannot be reached concerning the acceptability and appropriate cleaning regime of a material then these are recorded as a list of differences by scheme.

The IDTF is a database of over 3300 materials. www.icrt-idtf.com.

GTAS includes the IDTF which replaces the Exclusion List and Contaminant Sensitive List in previous versions of the scheme.

The IDTF includes 6 categories under the heading of cleaning regimes which are: (A) dry cleaning. (B) cleaning with water. (C) cleaning with water and a cleansing agent. (D) cleaning and disinfection. Forbidden. List of Differences.

In addition to those items that are classified on the database as being forbidden, any materials not classified in the IDTF are prohibited for storage or carriage.

See Appendix 3 for more information regarding Cleaning Methods.

See Appendix 4 for more information regarding ICRT/IDTF.



12.0 Superintendents’ Operations

12.1 A Superintendent is an organisation or company whose primary business activities are in the profession of inspection and who are appointed by (or on behalf of) Buyers and Sellers using or incorporating the terms and conditions of contracts. A Superintendent operates in accordance with agreed contract terms, sampling and weighing rules, this Code of Practice and this Code of Conduct, undertaking inspections, verifications, examinations, quality and condition assessment, sampling and measurements, of goods traded.

12.2 When a Superintendent issues reports and certificates relating to its operations they shall reflect the actual and true findings.

13.0 Compliance with Rules When a Superintendent is appointed to act by one of the parties to a contract incorporating standard terms, all operations it carries out shall comply with the appropriate Rules and Contract terms as applicable, unless otherwise instructed.

14.0 Sampling Whenever a Superintendent has to report and/or certify its findings and determinations, on samples drawn, it shall ensure the samples are drawn, collected and sealed as required by the agreed Sampling Rules. Where no sampling rules are agreed the Gafta Sampling Rules Form No. 124 shall apply. In any event, sampling must take at the time and place of loading and/or discharge, as applicable.

15.0 Quality and Condition A Superintendent may be limited in the analysis tests it can perform as required by the Contract and may reserve the right to submit samples for testing to a GTAS certified Testing Facility or a laboratory listed on the Gafta Register of Approved Analysts or other officially recognised and appropriately qualified authority, as appropriate. In this event the certificates may be delayed and the party(ies) should therefore be notified accordingly.

16.0 Cleanliness Inspection16.1 When required to do so by the parties, a Superintendent will visually and (as far as is practically possible and where safely accessible), physically inspect vehicles, vessels, storage areas and compartments to check and report whether they are clean, dry and free from foreign odour or matter and in these respects only, suitable to receive the cargo. 16.2 In the case of transport by sea and waterway it is essential for the safety of the goods that a Loading Compartment Inspection (LCI) of the cargo hold be undertaken prior to the commencement of loading.

16.3 The LCI must be executed by a recognised superintendent firm registered on the list of Gafta Approved Superintendents.

16.4 Before loading commences, the cargo hold must be empty, clean and dry, without any unsuitable odours and in these respects be suitable to receive the specific cargo. It must be free of any residues of the preceding cargo and/or cleansing activities and apparently free of vermin.

16.5 The results of the LCI, together with the information concerning the three preceding loads carried by the vessel as declared by the Master, must be recorded.

17.0 Weighing

17.1 Weighing must be undertaken in accordance with the Gafta Weighing Rules No. 123

17.2 A Superintendent, when called upon to supervise/oversee the weighing of the goods, shall ensure that the method used is in accordance with the instructions.

17.3 The Superintendent shall ensure that the weighing operations are carried out at the appropriate place and time in relation to the actual handling of the cargo.

17.4 The weighing records produced shall make reference to the following:

• The apparatus used. • Approval by the authorities of such apparatus. • Information concerning the calibration and verification of the functioning and accuracy of such equipment. 17.5 The Certificate or Report shall show the weight determined and when appropriate the method of weighing used; wherever possible, supported by documentary evidence.

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18.0 Fumigation/Disinfestation/De-naturing

18.1 Treatment of goods by fumigation or application of insecticide treatments shall be carried out by a GTAS certified company or a company certified under an assurance scheme approved by Gafta and/or a nationally approved company/operator in the country of loading or at discharge, appointed by the contracting party(ies) and/or national authorities. The Superintendent may issue certificates reproducing the information provided to it by the aforementioned.

18.2 If de-naturing of goods is required this must be undertaken by nationally approved companies/operators in the country of loading or at discharge, appointed by the contracting parties and/or national authorities. The Superintendent may issue certificates reproducing the information provided to it by the aforementioned.

19.0 Phytosanitary/Veterinary/Radioactivity/Health Certificates These are usually provided by the national governmental authorities in the country of loading and may be obtained by the Superintendent as required by the parties to the contract. Alternatively, the Superintendent shall draw and collect the sample material for such a test to be carried out by an approved laboratory of their choice. In any event whoever carries out such tests, the information may be recorded by the superintendent on its certificates.

20.0 Contracting out A Superintendent may only contract out an operation (which it has been appointed to carry out) to another Superintendent company certified under GTAS and/or from the Gafta Register of Approved Superintendents.

21.0 Risk Assessment A risk assessment must be carried out with the aim of identifying and controlling any hazards that might adversely affect the sampling and testing of goods being handled. [R] See also 5.0 HACCP and Appendix 2

22.0 Instructions

22.1 In order for Superintendents to perform their activities, precise instructions are needed from their principals at the time of receiving the order.

22.2 Superintendent companies shall nominate a suitably experienced person as a Technical/File Manager who shall be the responsible person for receiving instructions from a principal and who shall be responsible for forwarding the appropriate instructions to the field inspector(s). The Technical/File Manager shall be a permanent employee of the company and shall be responsible for ensuring that sufficient information has been received to enable the field inspector(s) to satisfactorily carry out his/their duties.

23.0 Administration and Records A Superintendent shall keep all necessary and relevant records, including but not limited to, the following: - • Copies of Certificates and Reports • Invoices • Weight or Tally Sheets • Sample Registration Records • Instructions from Principals • Complaints received

24.0 Health and Safety Regulations for Employees

24.1 A Superintendent is obliged to comply with all relevant local and national health and safety regulations of the country in which it is operating with regard to its employees and any other operatives under its control.

24.2 Superintendents must wear the appropriate Personal Protective Equipment. The items provided must be appropriate to the inspection activities being performed, must be in good order and within any applicable validity period or expiry date. Records should be retained for the issuance and receipt of such equipment to/by superintendents. [R]

24.3 Where superintendents are asked to perform their duties in an environment or in conditions deemed by them to be dangerous or unsafe, they shall be obliged to refuse to undertake said duties or operations until such time as the conditions are made safe to their satisfaction. Where a superintendent refuses to perform an activity or operation due to concerns regarding safety they shall immediately notify the principal accordingly. [R]

25.0 Security of Samples Samples shall be retained by the Superintendent either at their own premises or in the custody of a mutually agreed third party, for a minimum period of 3 months unless written instructions are received to the contrary. Samples that are retained must be kept in suitable storage conditions in order to preserve their condition, as far as this is practically possible.

26.0 Training The requirement for Superintendent companies to have a regularised training programme for its personnel in the technical and administrative aspects of their operations, are a vital component of this Code of Practice.

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26.1 Training programmes should be both regular and updated, as appropriate.

26.2 The requirement to attend training courses shall take into account the ability, experience and other qualifications held by each employee and shall be appropriate to their activities.

26.3 A written training structure shall be implemented by the company.

26.4 New and inexperienced employees are expected to adhere to the following minimum steps as part of their training: • Induction training period • Supervised working period with experienced operators • Continuing Professional Development Training

26.5 Records of the attendance at training must be recorded and kept by the company.

26.6 Training may be provided in one or more of the following ways: a) on an in-house basis, where a company utilises the experience and abilities of its own personnel, and/or b) employ a third party consultant(s) who is/are suitably qualified to provide the required training and/or c) attend courses run by a recognised provider of professional training services. e.g. Gafta and/or d) arrange for a suitably qualified permanent employee (e.g. Operations/Technical Manager) of the company to attend training courses as per points b and c above who, after reaching the required standard, will be considered suitably qualified to draw up and provide in-house training to other employees under point a above.

26.7 Training is recommended to cover at least, but not limited to, the following areas of activity as required by this Code of Practice and where applicable under Gafta contracts: i) Product knowledge ii) Gafta Contracts and Rules iii) Responsibilities of a cargo Superintendent iv) Load Compartment Inspections v) Basic understanding of fumigation and pest control operations vi) Basic understanding of Sanitary and Phytosanitary requirements vii) Health and Safety – PPE – entry into confined spaces etc. viii) Basic understanding of stevedoring and storage ix) Basic understanding of sustainability matters.

27.0 Responsibility

27.1 A Superintendent shall warrant that its work will be performed with due care and skill. It may limit its exposure to damages by express conditions that are reasonable.

27.2 A Superintendent shall be responsible for the performance of the it's duties whether carried out by its employees or by any other agent on its behalf and for any breach of these Rules by any such person.

28.0 Code Of Conduct

28.1 This Code deals specifically with standards of conduct required to be adopted by Superintendents in relation to the paramount issues of independence and neutrality.

28.2 A Superintendent shall be independent and free from any commercial, financial or other pressures which might affect its judgement. For the purposes of this Code of Practice, the term independent shall mean that the Superintendent company shall not be financially linked with or financially dependent upon a principal.

28.3 A Superintendent shall implement procedures to ensure that persons or organisations external to it cannot influence the results of operations it carries out.

28.4 A Superintendent shall be independent of the parties involved in the operation it carries out. In particular, the individual(s) responsible on behalf of the Superintendent for carrying out any operation shall not be the designer, manufacturer, supplier, installer or the user of any item involved in the operation nor the authorised representative of any of these parties.

28.5 A Superintendent shall not engage in any activities that may conflict with its independence of judgement and integrity in relation to its operations. In particular, it shall not become directly involved in the design, construction, marketing, use, operation or maintenance of items inspected.

28.6 A Superintendent shall report to Gafta any attempts by interested parties to influence the outcome of its operations.

28.7 A Superintendent shall be responsible for any breach of this code by its employees or any other agent instructed by it to carry out its operations on its behalf.


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29.0 Professional Indemnity Insurance Superintendent companies shall take out Professional Indemnity Insurance at a level of cover deemed sufficient by them to cover their contingent liabilities.

30.0 Complaints Procedure

30.1 The Superintendent must have a documented procedure for handling complaints. This procedure must include systems for: • The prompt documentation and investigation of complaints • The prompt feedback to the Company with findings • Deciding on internal actions required to prevent re-occurrence

30.2 Superintendents who have been certified as complying with the GTAS Code of Practice for Superintendents are bound by the GTAS Rules and Code of Conduct. A party or parties who appoint a superintendent listed in the GTAS database of superintendents can use the Gafta Complaints Procedure if it is believed that there has been a breach of the rules or code of conduct.

Full details on the GTAS Complaints and Disciplinary Regulations are contained in the Scheme Manual together with the Scheme Rules, Regulations and Codes of Conduct.

31.0 Records

31.1 Internally produced records must be signed by the person carrying out the task/activity. Where records are kept electronically the records will carry the name of the person carrying out the task/activity.

31.2 Records must be legible and kept in suitable conditions that allow ready retrieval and prevent deterioration.

31.3 Records must he kept for a minimum of five years unless there are additional requirements.

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For the purposes of this Code the following definitions shall apply: • Animal Feed Materials: shall mean raw materials and straight feeds, feed additives, etc., (as defined under the applicable Feedingstuffs Regulations) intended as an animal feed material.

• Biodiesel: a transport fuel usually made from vegetable oils used as a diesel replacer.

• Bio ethanol: a transport fuel made from sugar and cereal crops used as a petrol replacer.

• Biofuels: liquid or gaseous fuel for transport produced from biomass.

• Bioliquids: liquid fuel for energy purposes other than for transport, including electricity and heating and cooling, produced from biomass.

• Biomass: the biodegradable fraction of products, waste and residues from biological origin from agriculture (including vegetal and animal substances), forestry and related industries including fisheries and aquaculture, as well as the biodegradable fraction of industrial and municipal waste.

• Broker: - shall mean a person or company acting as an intermediary between buyer and seller and drawing an agreed commission for services rendered. A Broker does not act as a principal in the transaction.

• COSHH: - shall mean Control of Substances Hazardous to Health Regulations.

• Carrier: – shall mean the shipping company, haulage company or operator of any vessel under this code.

• Codex Alimentarius: – Latin, meaning Food Law or Code, is a collection of Internationally adopted Food and/or Feed Standards presented in a uniform manner.

• Combinable Crops: shall mean grain, pulses (peas and beans) and oilseeds (rapeseed and linseed, as-grown cereal seeds and herbage seeds (grass, clover, etc.), pulse seeds and oilseeds for seed processing.

• The Code Of Practice For The Control Of Salmonella: - shall mean the Code of Practice for the Control of Salmonella during the storage, handling and transport of raw materials intended for incorporation into, or direct use as, animal feedingstuffs, current in the country where the code is being applied. In the absence of any such national code, the Gafta Code of Practice for Salmonella shall apply.

• The Company: - shall mean any company who is a principal in a transaction or for whom a service is being provided.

• Contamination: – shall mean the undesired introduction of impurities of a chemical or microbiological nature or of foreign matter during production, sampling, packaging, storage or transport.

• Control (verb): To take all necessary actions to ensure and maintain compliance with criteria established in the HACCP plan.

• Control (noun): The state wherein correct procedures are being followed and criteria are being met.

• Control Measure: Any action and activity that can be used to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

• Corrective Action: Any action to be taken when the results of monitoring at the CCP indicate a loss of control.

• Critical Control Point (CCP): A step at which control should be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

• Critical Limit: A criterion which separates acceptability from unacceptability.

• derogated Protein:- shall mean fishmeal, dicalcium phosphate or tricalcium phosphate of animal origin or hydrolysed protein (as defined in the EU Transmissible Spongiform Encephalopathies [TSE] Regulations) which are prohibited in farmed animal feeds intended for ruminants but permitted in such feeds intended for non-ruminants;

• Desk Trader: - shall mean any trader, whether or not employing staff, but with no owned storage, laboratory or transport facilities.

• Deviation: Failure to meet a critical limit.

• Farmed Animals: - shall mean cattle, sheep, goats, deer, pigs, poultry, rabbits, horses, fish or any other animals which may be used for human consumption;

• Farmed Ruminants: - shall mean cattle, sheep, goats or deer.

• Feed” Or “Animal Feed: – shall mean any substance or product, including additives, whether processed, partly processed or unprocessed, intended to be used for oral feeding to animals.

• Food: – shall mean any substance or product, whether processed, partially processed, intended to be, or reasonably expected to be ingested by humans.

• Forbidden Materials: – shall mean materials classified in the International Database for Transport of Feed (IDTF) as being forbidden or materials that are not classified in the IDTF.

• Fumigants: – shall mean gases which are toxic to target infestations.

• Fumigator: – shall mean a contractor whose business it is to apply fumigants to eradicate infestations.

• Gafta Approved Analyst: – shall mean a laboratory engaged in the profession of sample analysis providing certificates of quality at loadports. They carry out analysis in accordance with the Methods of Analysis Form No. 130, the Gafta Rules and Code of Conduct for Approved Registered Analysts for commodities traded on Gafta contracts. They are members of GAFTA.

A P P E N D I X 1

General Definitions



• Gafta Approved Superintendent: – shall mean a company engaged in the profession of inspection. They carry out their duties in accordance with the respective contract terms, sampling rules and Code of Practice, inspection, verifications, examinations, quality and condition assessment, sampling measurements. They are members of GAFTA.

• Goods: - shall mean all animal feed materials, combinable crops, finished products and processed materials for food and/or feed purposes.

• Grower: - shall mean the farmer producer of the raw materials.

• HACCP: A system which identifies, evaluates, and controls hazards which are significant for food and feed safety.

• HACCP Plan: A document prepared in accordance with the principles of HACCP to ensure control of hazards which are significant for food and feed safety in the segment of the supply chain under consideration.

• Haulier: – shall mean the operator of any vehicle engaged in the transport of goods by road.

• Hazard: A biological, chemical or physical agent in, or condition of, food or feed with the potential to cause an adverse health effect to humans or animals.

• Hazard analysis: The process of collecting and evaluating information on hazards and conditions leading to their presence to decide which are significant for food and feed safety and therefore should be addressed in the HACCP plan.

• ICRT: - shall mean the International Committee (for) Road Transport

• IDTF: - shall mean the International Database (for the) Transport of Feed

• Load Compartment: – shall mean the sub-divided part of the load carrying area of a bulk vehicle or vessel into which goods are loaded and transported.

• Loading Inspector: – shall mean a person in a quality system who on the basis of training and experience has sufficient knowledge and expertise to inspect cargo spaces for suitability for loading the goods. The appointed person shall have certification or accreditation to perform this role.

• Merchant: - shall mean a trading business, employing staff operating with a combination of storage and/or laboratory and/or transport facilities.

• Monitor: The act of conducting a planned sequence of observations or measurements of control parameters to assess whether a CCP is under control.

• Principal: – shall mean the buyer or seller in a transaction.

• processed Animal Protein: – shall mean meat and bone meal*, meat meal*, bone meal*, blood meal*, dried plasma* and other blood products*, hydrolysed protein, hoof meal, horn meal, poultry offal meal, feather meal, dry greaves, fishmeal, dicalcium phosphate and tricalcium phosphate of animal origin, gelatin and any other similar products including mixtures, feedingstuffs, feed additives and premixtures, containing these products.*whether of mammalian or non-mammalian origin;

• Producer: - shall mean a farmer, grower, processor or manufacturer of food or feed.

• [R]: - the symbol [R] in the text indicates the requirement to keep a record.

• Recall: the process by which the removal of an unsafe or illegal goods/product in the possession of the consumer is made.

• Risk: – shall mean a function of the probability of damage to goods or an adverse health effect and the severity of that damage or effect, consequential to a hazard.

• Road Haulage: – shall mean all appropriate forms of transport including bulk tippers, bulk blowers, flat-beds, walking floor and bulk tanker vehicles used for any movement of goods by road.

• Step: A point, procedure, operation or stage in the supply chain including raw materials, from country of origin to country of destination.

• Store: shall include any building, shed, silo, bin, tank or other container used to store goods;

• Storekeeper: - shall mean the operator of any store used to store goods.

• Sustainability: an integrated approach to environmental, social and economic impact issues (both internal and external) leading to long term sustainable profit and growth without compromising the ability of future generations to meet their own needs.

• Testing Facility: – shall mean any facility that operates testing or analytical apparatus for the purpose of establishing quality criteria not relating to Gafta contracts.

• Trader: - shall mean a desk trader or a merchant.

• Transport: – shall mean any movement of goods by road, rail, inland waterway, shipment by sea or by container.

• Undesirable Substance: – shall mean 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 could adversely affect livestock production.

• Validation: Obtaining evidence that the elements of the HACCP plan are effective.

• Vehicle: – shall include trailers or other containers used to transport goods by road.

• Verification: The application of methods, procedures, tests and other evaluations, in addition to monitoring to determine compliance with the HACCP plan.

• Vessel: – shall mean ship, barge or coaster.

• Withdrawal: - The process by which the removal of an unsafe or illegal product from the supply chain is made, but does not involve the removal of product in the consumer’s possession.

A. Introduction When trading goods into certain markets, suppliers are often requested to implement quality assurance systems to their trading operations, many of which call for HACCP-based systems. Such markets will in addition seek the quality assurance operations to be independently audited/verified. This section aims to introduce the concept of HACCP.

The first section of this document sets out the principles of the Hazard Analysis and Critical Control Point (HACCP) system adopted by the Codex Alimentarius Commission. Codex Alimentarius Commission Code of Practice - General Principles of Food Hygiene. CAC/RCP 1 1969 Rev.4 - 2003 www.codexalimentarius.net

The section from “Guidelines for the Application of the HACCP System” onwards provides general guidance for the application of the system while recognizing that the details of application may vary depending on the circumstances of the logistics operation. It is this application that a trading company would be independently audited/verified against.

The HACCP system, which is science-based and systematic, identifies specific hazards and measures for their control to ensure the safety of food and feed products. HACCP is a tool to assess hazards and establish control systems that focus on prevention rather than relying mainly on end product testing. Any HACCP system is capable of accommodating change, such as advances in equipment design, processing procedures or technological developments.

HACCP can be applied throughout the food and feed chain from primary production to final consumption and its implementation should be guided by scientific evidence of risks to human and animal health.

The successful application of HACCP requires the full commitment and involvement of management and the work force. It also requires a multidisciplinary approach; this multidisciplinary approach should include, when appropriate, expertise in storage, transport, inspection, and analysis. The application of HACCP is compatible with the implementation of quality management systems, such as the ISO 9000 series, and is the system of choice in the management of food safety within such systems.

A P P E N D I X 2

Introduction to HACCP -Hazard Analysis And Critical Control Point System

Principles of the HACCP SystemThe HACCP system consists of the following seven principles:

• PRINCIPLE 1 Conduct a hazard analysis.

• PRINCIPLE 2 Determine the Critical Control Points (CCPs).

• PRINCIPLE 3 Establish critical limit(s).

• PRINCIPLE 4 Establish a system to monitor control of the CCP.

• PRINCIPLE 5 Establish the corrective action to be taken when monitoringindicates that a particular CCP is not under control.

• PRINCIPLE 6 Establish procedures for verification to confirm that theHACCP system is working effectively.

• PRINCIPLE 7 Establish documentation concerning all procedures and records appropriate to these principles and their application.





Guidelines for the Application of the HACCP SystemPrior to application of HACCP to any sector of the food and feed chain, that sector should be operating according to theGeneral Principles of Food Hygiene, the appropriate Codex Codes of Practice, and appropriate food safety legislation.Management commitment is necessary for implementation of an effective HACCP system. During hazard identification,evaluation, and subsequent operations in designing and applying HACCP systems, consideration must be given to theimpact of raw materials, ingredients, food manufacturing practices, role of manufacturing processes to control hazards,likely end use of the product, categories of consumers of concern, and epidemiological evidence relative to food safety.

The intent of the HACCP system is to focus control at CCPs. Redesign of the operation should be considered if a hazardwhich must be controlled is identified but no CCPs are found.

The HACCP application should be reviewed and necessary changes made when any modification is made in the product,process, or any step.

It is important when applying HACCP to be flexible where appropriate, given the context of the application taking intoaccount the nature and the size of the operation.

ApplicationThe application of HACCP principles consists of the following tasks as identified in the Logic Sequence for Application ofHACCP (Diagram 1).

I. ASSEMBLE HACCP TEAM The supply operation should assure that the appropriate commodity knowledge and expertise is available for the development of an effective HACCP plan. Ideally, this may be accomplished by assembling a multidisciplinary team. Where such expertise is not available on site, expert advice should be obtained from other sources. The scope of the HACCP plan should be identified. The scope should describe which segment of the supply chain is involved and the general classes of hazards to be addressed (e.g. does it cover all classes of hazards or only selected classes).

II. DESCRIBE PRODUCT A full description of the commodity should be drawn up, including relevant safety information such as: composition, physical/chemical structure, microcidal/static treatments (heat treatment, antioxidants, fumigation etc.), packaging, durability and storage conditions and method of distribution.

III. IDENTIFY INTENDED USE The intended use should be based on the expected uses of the product by the end user or consumer.

IV. CONSTRUCT FLOW DIAGRAM The flow diagram should be constructed by the HACCP team. The flow diagram should cover all steps in the supply operation. When applying HACCP to a given operation, consideration should be given to steps preceding and following the specified operation.

V. ON SITE CONFIRMATION OF FLOW DIAGRAM The HACCP team should confirm the actual supply operation against the flow diagram during all stages and amend the flow diagram where appropriate.

VI. LIST ALL POTENTIAL HAZARDS ASSOCIATED WITH EACH STEP, CONDUCT A HAZARD ANALYSIS, AND CONSIDER ANY MEASURES TO CONTROL IDENTIFIED HAZARDS (SEE PRINCIPLE 1) The HACCP team should list all of the hazards that may be reasonably expected to occur at each step in the supply chain from country of origin to the final country of destination.

The HACCP team should next conduct a hazard analysis to identify for the HACCP plan which hazards are of such a nature that their elimination or reduction to acceptable levels is essential to the supply of a safe food or feed material.

In conducting the hazard analysis, wherever possible the following should be included: • the likely occurrence of hazards and severity of their adverse health effects; • the qualitative and/or quantitative evaluation of the presence of hazards; • survival or multiplication of microorganisms of concern; • production or persistence of toxins, chemicals or physical agents; and, • conditions leading to the above.

The HACCP team must then consider what control measures, if any, exist which can be applied for each hazard. More than one control measure may be required to control a specific hazard(s) and more than one hazard may be controlled by a specified control measure.



B. DETERMINE CRITICAL CONTROL POINTS (SEE PRINCIPLE 2) There may be more than one CCP at which control is applied to address the same hazard. The determination of a CCP in the HACCP system can be facilitated by the application of a decision tree (e.g. Diagram 2), which indicates a logic reasoning approach. Application of a decision tree should be flexible, given whether the operation is for storage, loading, discharge, sampling, analysis, transport or other. It should be used for guidance when determining CCPs. This example of a decision tree may not be applicable to all situations. Other approaches may be used. Training in the application of the decision tree is recommended.

If a hazard has been identified at a step where control is necessary for safety, and no control measure exists at that step, or any other, then the operation or process should be modified at that step, or at any earlier or later stage, to include a control measure.

C. ESTABLISH CRITICAL LIMITS FOR EACH CCP (SEE PRINCIPLE 3) Critical limits must be specified and validated if possible for each Critical Control Point. In some cases more than one critical limit will be elaborated at a particular step. Criteria often used include measurements of temperature, quality and condition, undesirable substances and sensory parameters such as visual appearance, smell or odour.

D. ESTABLISH A MONITORING SYSTEM FOR EACH CCP (SEE PRINCIPLE 4) Monitoring is the scheduled measurement or observation of a CCP relative to its critical limits. The monitoring procedures must be able to detect loss of control at the CCP. Further, monitoring should ideally provide this information in time to make adjustments to ensure control of the process to prevent violating the critical limits. Where possible, process adjustments should be made when monitoring results indicate a trend towards loss of control at a CCP. The adjustments should be taken before a deviation occurs. Data derived from monitoring must be evaluated by a designated person with knowledge and authority to carry out corrective actions when indicated. If monitoring is not continuous, then the amount or frequency of monitoring must be sufficient to guarantee the CCP is in control i.e. undesirable substances monitoring. All records and documents associated with monitoring CCPs must be signed by the person(s) doing the monitoring and by a responsible reviewing official(s) of the company.

E. Monitoring of undesirable substances based on HACCP/Risk Assessment principles. Operators should implement a sampling and analysis plan within the HACCP framework for the testing for undesirable substances. The operator should determine the frequency of sampling and analysis for goods that are handled and stored in accordance with customer requirements. The Gafta Sampling Rules No. 124 are applicable where the goods are traded on Gafta contracts, otherwise sampling should be in accordance with another agreed internationally recognised method.

The principle of sampling and analysis frequency is related to quantity of goods handled. As the quantity increases the number of samples taken per tonne of goods decreases. The number of samples to be drawn and inspected over a period in which the goods are examined for presence of undesirable substances may be calculated using the formula:

Frequency = Volume x Chance x Seriousness 100

The standard value for chance is 1. The operator may raise or lower this value if valid reasons are given. Considerations that may affect the standard value for chance include: • History • Seasonal influences • Chances of re-contamination (eg microbiological parameters) • New source/new suppliers • Recent incidents

Operators may only select a chance value that is below 1 on the basis of supporting historical analysis data. Seriousness is an expression of the perceived degree of harmfulness of an undesirable substance. Where the level of seriousness is deemed to be high or very high a factor of 5 is used. Where the level of seriousness is deemed moderate then factor 3 should be used. If the seriousness level is judged to be low or small then a factor of 1 should be used. Where food and feed goods are concerned undesirable substances such as heavy metals, pesticies or mycotoxins should apply a minimum value of 3 but more likely 5. Operators must have a written down monitoring protocol with a documented system for the keeping of records.

The analysis of samples drawn under the monitoring protocol should be tested by analysts in accordance with contract requirements, ie analysts listed on the Gafta Register of Approved Analysts and/or GTAS certified Analysts and/or analysts accredited under ISO/IEC 17025 using officially recognised methods covered by the scope of the accreditation.



HACCP Scoring This is a simple means of assigning scores for • the likelihood of occurrence • the severity for each hazard that could be encountered in a Raw Material Haulage, or Raw Material Storage operation.

The HACCP team should assess each and every possible hazard that could be encountered.

The likelihood of occurrence is based on measurements and observations of previous situations and is assigned a score of 1 – 3 as per the table below.

A score of 1 would be a low risk of occurrence (practically impossible or not probable), 2 would be a medium risk (may occur, has been known to occur) and 3 is a high risk of occurrence (occurs regularly).

Similarly the severity of occurrence is based on the consequence of the hazard occurring and its likely impact is also assigned a score of 1 – 3. A score of 1 would be small(leading to minor injury or illness) 2 would be medium (leading to substantial injury) and 3 is high (leading to fatal consequences).

These two scores are then multiplied together to give an overall Hazard score for that Hazard.

It is suggested that Hazard scores of 5 or below should be considered within the pre-requisite programme.

Hazard scores of 6 or above should be considered as significant hazards and should be dealt with by Critical Control Points.

Nevertheless it is the responsibility of the HACCP team to consider and evaluate each hazard in the light of the business concerned.

F. ESTABLISH CORRECTIVE ACTIONS (SEE PRINCIPLE 5) Specific corrective actions must be developed for each CCP in the HACCP system in order to deal with deviations when they occur.

The actions must ensure that the CCP has been brought under control. Actions taken must also include proper disposition of the affected food or feed material. Deviation and material disposition procedures must be documented in the HACCP record keeping.

Definite (3) 3 6 9

Probable (2) 2 4 6

Possible (1) 1 2 3

Negligible (1) Major (2) Critical (3)

HACCP Scoring System

Like

liho

od

of

occ

urre

nce

Severity if it occurs

G. ESTABLISH VERIFICATION PROCEDURES (SEE PRINCIPLE 6) Establish procedures for verification. Verification and auditing methods, procedures and tests, including random sampling and analysis, can be used to determine if the HACCP system is working correctly. The frequency of verification should be sufficient to confirm that the HACCP system is working effectively. Examples of verification activities include:

• Review of the HACCP system and its records; • Review of deviations and material dispositions; • Confirmation that CCPs are kept under control. Where possible, validation activities should include actions to confirm the efficacy of all elements of the HACCP plan.



H. ESTABLISH DOCUMENTATION AND RECORD KEEPING (SEE PRINCIPLE 7) Efficient and accurate record keeping is essential to the application of a HACCP system. HACCP procedures should be documented. Documentation and record keeping should be appropriate to the nature and size of the operation.

Documentation examples are: Record examples are: • Hazard analysis; • CCP monitoring activities; • CCP determination; • Deviations and associated corrective actions; • Critical limit determination. • Modifications to the HACCP system.

An example of a HACCP worksheet is attached as Diagram 3.

Assemble HACCP Team

a. Diagram 1. Sequence For Application Of HACCP

1

Describe Product2

Identify Intended Use3

Construct Flow Diagram4

On site Confirmation of Flow Diagram5

List all Potential HazardsConduct a Hazard Analysis • Consider Control Measures

6

Determine CCPs (See Diagram 2)7

Establish Critical Limits for each CCP8

Establish a Monitoring System for each CCP9

Establish Corrective Actions10

Establish Verification Procedures11

Establish Documentation and Record Keeping12



Do control preventative measure(s) exist ?

Is the step specifically designed toeliminate or reduce the likely occurrence

of a hazard to an acceptable level ?

Could contamination with identified hazard(s) occur inexcess of acceptable level(s) or could these increase to

unacceptable levels ?

Will a subsequent step eliminate identified hazard(s) orreduce likely occurrence to an acceptable level ?

Is control at this stepnecessary for safety ?

Yes

Yes

Yes

Not a CCP

No Critical Control Point

Stop

No StopNot aCCP

Yes

Yes

No

No

No

Not a CCP Stop

Modify step, processor product

Q1

Q2

Q3

Q4

b. Diagram 2. Example Of Decision Tree To Identify CCPs (answer questions in sequence)



Describe Product1

Verification4

Diagram Process Flow2

List (example below)

Step Hazard(s) Control CCPs Critical Monitoring Corrective Record(s) Measure(s) Limit(s) Procedure(s) Action(s)

3

c. Diagram 3 Example Of A HACCP Worksheet



A P P E N D I X 3

Cleaning Methods

See also section 5.0

Any surface which comes into contact with food or feed must be clean.

Goods and materials listed in the International Database (for the) Transport (of) Feed (IDTF) that are permitted fortransport in load compartments used to carry goods covered by this scheme, are given a cleaning classification. Guidanceis given in this Appendix on how to apply these cleaning methods. The IDTF Classifications are:

(A) Dry Cleaning(B) Cleaning with water(C) Cleaning with water and a cleansing agent(D) Cleaning and disinfection.

The minimum level of cleaning required by the IDTF must be applied after carriage of the goods/materials howeverfollowing a risk assessed approach, in some circumstances additional cleaning may be required.

Cleaning applies to the load compartment, the cover sheet and any other surface that may come into contact with thegoods being transported. All must be drained and dry before re-loading.

(A) Dry Cleaning In most cases where the material is dry, thorough brushing or vacuuming is sufficient, however if the material is caked or damp washing will be necessary.

(B) Cleaning with water Washing with hot water (70-80c) is recommended wherever possible. Where this is not practically possible cold water may suffice. All surfaces must be dry before handling or coming into contact with goods.

(C) Cleaning with water and a cleansing agent Washing with a hot water (70-80c) solution of any combined food grade cleansing agent (food grade sanitiser/ disinfectant) diluted in accordance with manufacturer’s recommendations. All surfaces must be dry before handling or coming into contact with goods.

(D) Cleaning and disinfection Pressure clean with a hot (70-80c) solution of any combined food grade sanitiser/disinfectant diluted in accordance with manufacturer’s recommendations. All surfaces must be dry before handling or coming into contact with goods.

Additional cleaning options:

Steam Cleaning and Disinfecting Where appropriate following a risk assessment, compartments and surfaces may be steam cleaned and treated with an approved non-phenolic food grade disinfectant. All surfaces must be dry before handling or coming into contact with goods.

Infested goods Where infested goods have been transported, handled or stored and it is not possible or feasible to fumigate or spray and allow sufficient time for the treatment to be effective, all surfaces, including vehicle sheets, must be thoroughly steam cleaned. All surfaces must be dry before handling or coming into contact with goods.

The use of smoke bombs is not effective and is not recommended.



The IDTF is an initiative of the International Committee for Road Transport (ICRT) which includes the main food and feedassurance scheme owners in Europe covering the transport of goods (in the combinable crops and animal feed sectors).The seven members of the ICRT are:

• OVOCOM vzw, based in Belgium owner of the quality assurance scheme called GMP Animal Feed. • Qualimat, based in France, owner of the quality assurance scheme called Qualimat Transport. • QS Qualitat und Sicherheit GmbH (QS), based in Germany, owner of the quality assurance scheme called QS. • GMP+ International B.V., based in The Netherlands, owner of the GMP+ Feed Safety Assurance Scheme (GMP+ FSA). • COCERAL aisbl, based in Belgium, owner of the Good Trading Practice scheme (GTP). • Agricultural Industries Confederation, based in the United Kingdom, owner of the quality assurance schemes TASCC, UFAS and FEMAS. • Gafta, based in the United Kingdom with offices in Geneva, Beijing, Kiev, owner of the Gafta Trade Assurance scheme.

Launched in April 2012 the IDTF is a list of over 3300 goods, materials and products registered and maintained in aninteractive database (in 4 languages) that is freely accessible to all users.

The database is designed to enable quick and efficient consultation via the online facility and is particularly useful fortransport operators to check on goods or materials prior to carriage. Searches can be made using a range of criteria andcan be exported to excel spead sheets.

The purpose of ICRT/IDTF is the harmonisation of the requirements for bulk transport of products intended for animalfeed. The Committee classifies transported products based on hazard analysis and determines cleaning regimesnecessary to assure safe feed transport.

Each item on the database is allocated a unique IDTF number and can cross reference with common product names. Since the database is continually developing there are procedures in the IDTF to add new materials or to re-assessexisting listed items.

Procedures are available for re-instatement of load compartments in some circumstances following the carriage offorbidden materials. These involve treatment of load spaces on a risk assessed basis and independent verification.

The categories for classification and cleaning of load compartments are:

A dry clean (brush/vacuum) B clean with water C clean with water and cleansing agent D Cleaning and disinfection

Forbidden:Goods not allowed to be carried. NB: under the IDTF rules unclassified goods are forbidden for carriage.

List of differencesIn the majority of cases the members of the ICRT agree on the appropriate cleaning regime following carriage of listedgoods or materials, however in some cases this is not achievable, perhaps due to national legislation. In such cases thisappears as a “List of Differences” and the requirements of the individual scheme(s) are listed. The requirements of thescheme into which the goods are being delivered should be followed in such circumstances.

www.icrt-idtf.com

A P P E N D I X 4

International Database for Transport of Feed (IDTF)

LONDON9 Lincoln's Inn Fields,London WC2A 3BPUNITED KINGDOM

T: +44 20 7814 9666F: +44 20 7814 8383E: [email protected]: www.gafta.com

BEIJINGLeading International Center,No.1 Guang Qu Men NanXiao Jie, ChongWen District,100061, BeijingCHINA

T: +86 10 6712 1741F: +86 10 6712 1742E: [email protected]: www.gafta.com.cn

GENEVA8 Rue de la Cloche, 1201GenevaSWITZERLAND

T: +41 22 715 24 30F: +41 22 731 72 79E: [email protected]: www.gafta.com

KIEV8 Saperno Slobidska Street,Kiev, 03039UKRAINE

T: +380 44 524 0329F: +380 44 524 0231E: [email protected] W: www.gaftakyiv.com

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