FOOD SAFETY REQUIREMENT FOR THE GRAIN INDUSTRY (Excluding groundnuts) (Compiled by Grain South Africa) INDEX 1. MANAGEMENT PLAN TEMPLATE 2. COMPLIANCE CRITERIA MANAGEMENT PLAN TEMPLATE The Management Plan is intended as a guidance document which identifies and describes the policies and practices that are used on the farm for the production process. The management plan must also identify the risks associated with each process in the production cycle and seek to reduce, minimize or eliminate the risks. Using an integrated approach to the management of the production process is an effective way of minimizing risks. Suitable strategies must be developed in order to manage the risks. Factors to be considered in the management plan are: • Site management • Crop type & variety • Soil management • Crop protection • Irrigation • Fertiliser use • Environment • Human Resources The Management Plan should describe how each factor will be managed. For example: 1. Site management • The identification of the site – allocation of a unique reference number or code. • The location of the site – physical location marked on a map. • The size of the site. • The physical characteristics of the site –aspect, gradient and special features. • Risks associated with the site – e.g. soil erosion due to gradient and/or soil type; risks associated with the history of the site e.g. glass contamination from bottles or effluent from industrial activity etc. 2. Crop type & variety • Criteria used in the selection of the crop type and variety – in some cases varieties will be chosen by the customer. However, in some instances, varieties are chosen for agronomic reasons such as resistance to pests; adaptability to regional conditions etc. • Varietal characteristics – these are important as they determine management methods during the production cycle. For example same crop different variety may require a different fertiliser regime. • Origin of seed – important to manage from a commercial point of view. • Quality of seed – as above. • Risks associated with the variety e.g. susceptibility to particular pests; varietal characteristics that may jeopardize or influence quality in particular growing conditions. 3. Soil management • Soil type – determines crop/variety; microbial content; susceptibility to build up of pests and diseases. • Composition and nutrient content –determines soil treatment and handling regime. • Structure – used to determine cultivation methods. • Cultivation techniques – used to maintain soil structure. • Risks associated with soil management e.g. fragile structure; high clay content therefore poor drainage; low particle density therefore risk of fertiliser leaching and contamination of ground water. 4. Crop protection • Use of IPM – observation; intervention; prevention. Using the 3 pillars of Integrated Pest Management. Determination of IPM strategy – type and position of bait points; scouting method; recording method; setting of thresholds; determining intervention method and type of chemical to be used. • List of registered chemicals – a legal requirement as well as a customer requirement; used to determine crop protection strategy. • Use of competent and qualified advisor –selecting the right advisor and ensuring that he/she holds the correct qualifications and is competent to provide advice. • Selection of Crop Protection Products –made in conjunction with IPM strategy and advisor. • Pesticide Application personnel – who is going to apply the pesticide? Have they been trained? Are they competent to carry out the task assigned? ⇒ Application methods – equipment used ⇒ Storage of chemicals ⇒ Chemical use ⇒ Risks associated with crop protection e.g. residue build up in soil; increase in pest resistance to treatment etc. 5. Irrigation • Location and type of sustainable water source. • Abstraction permit (where applicable) • Abstraction method • Quality of irrigation water • Risks associated with irrigation – e.g. contamination of water; sustainability of water supply. 6. Fertiliser use • Determining requirement for application of fertiliser. • Advice on quantity and type of fertiliser to be used. • Method of application • Storage of fertiliser • Risks associated with fertiliser e.g. leaching; harm to humans (organic manure). 7. Environment • Using production methods that enhance or protect the environment. • Awareness of the effect that agricultural production has on the environment and implementation of steps to minimize the impact. • Identify fauna and flora; natural features; historical/archaeological features etc. • Risks to the environment e.g. destruction of fauna and flora; damage to existing habitats. 8. Human Resources • Health & safety of workers • Working conditions • Welfare • Social responsibility • Risks to human resource e.g. poor working conditions leading to injury; poor living quarters leading to poor health etc. COMPLIANCE CRITERIA Item Control Point Level Compliance Criteria Level 1 = Major must (100% compliance) 2 = Of high importance, is recommended 3 = Optional 1 VARIETIES AND ROOTSTOCKS 1.1 Seed treatments 1.1.1 Are seed treatments recorded, where applicable? 1 When the seed has been treated, there are records with the name of the product(s) used and its target(s) (pest and/or disease). 1.2 Genetically Modified Organisms 1.2.1 Are GMOs produced, registered in SA, and do they comply with legislation 1 The registered farm or group of registered farms have a copy of the legislation regarding their production? applicable, and comply accordingly. Unless no GMO varieties are used, N/A. 1.2.2 Are there documented records of the planting of any GMOs on the farm? 1 If GMO cultivars and/or products derived from genetic modification are used, documented records of planting, use or production of GMO cultivars and/or products derived from genetic modification are available. 2 APPLICATION OF FERTILISERS 2.1 Fertiliser Application Records 2.1.1 Have all dates of fertiliser applications been recorded? 2 The exact dates (day/month/year) of the application. 2.1.2 Have all production sites for fertiliser applications been recorded? 2 Records are kept of all fertilizer applications detailing the geographical area, the name or reference of the field where the registered crop is located. 2.1.3 Have the fertiliser types been recorded for all applications? 2 Detailed records of all fertilizer applications are the trade name, type of fertilizer (e.g. N, P, K) or concentrations (e.g. 17-17-17). 2.1.4 Have the applied quantities been recorded for all fertiliser applications? 2 Detailed records of all fertilizer application, is the amount of product to be applied in weight or volume. 2.1.5 Has the method of application been recorded for all fertiliser applications? 2 Detailed in the records of all fertilizer applications are the application machinery type used and the method (e.g. via the irrigation or mechanical distribution). 2.1.6 Has the name of the operator (team leader) been recorded for all fertiliser 3 Detailer in the records of all fertilizer applications is the name of the operator who has applications? applied the fertilizer. 2.2 Fertiliser storage (Inorganic /Organic) 2.2.1 Are fertilizers stored appropriately, taking into consideration the prevention of 1 All inorganic fertilizers, i.e. powders, granules or liquids are stored in a manner which water and environmental contamination? poses minimum risk of contamination to water sources, i.e. liquid fertilizer stores must be bunded (according to national and local legislation, or capacity to 110% of the biggest container if there is no applicable legislation), and consideration has been given to the proximity to water courses and flood risks, etc. 2.2.2 Are inorganic fertilisers stored separately from crop protection products? 2 The minimum requirement is an air space separated from crop protection products storage facilities, to prevent cross contamination between fertilizers and crop protection products. 2.3 Organic fertilizer / Inorganic fertilizer 2.3.1 Is manure, biosolids and other organic fertilizers treated using appropriate 3 Documentary evidence is available to demonstrate that the following potential risks techniques to reduce or eliminate pathogens (e.g., composting, heat drying, alkali have been considered: disease transmission, weed seed content, method of composting digestion, sun drying)? etc. 2.3.3 If organic fertiliser is used, is it supplied with documented information detailing 2 An analysis is carried out, which takes into account the contents of N-P-K nutrient in its origin, treatments used, tests performed and the results thereof? organic fertilizer applied. 3 IRRIGATION/FERTIGATION 3.1 Quality of Irrigation/Fertigation Water 3.1.1 Is a signed declaration by the producer available to indicate that untreated sewage 3 Untreated sewage water is not used for irrigation/fertigation. Where treated sewage water is not used on the farm? Where treated sewage water is used, is it done in water is used, water quality complies with the WHO published Guidelines for the Safe accordance with official guidelines? Use of Wastewater and Excreta in Agriculture and Aquaculture 1989. 4 CROP PROTECTION 4.1 Basic Elements of Crop Protection 4.1.1 Has the protection of crops against pests, diseases and weeds been achieved with 2 All crop protection product inputs are documented and include written justifications, the appropriate minimum crop protection product input? target and intervention thresholds. 4.2 Choice of chemicals 4.2.1 Are chemical products used for their specified use as indicated on the product 1 All chemical products applied to the crop are suitable and can be justified (according label? to label recommendations or official registration body publication) for the pest, disease, weed or target of the crop protection product intervention. 4.2.2 Does the producer only use chemical products that are registered in South Africa? 1 An up to date documented annual list is available of the commercial brand names of crop protection products (including their active ingredient composition, or beneficial 4.2.3 Does the producer have a current list from the Department of Agriculture (the 1 organisms) that are used on crops being, or which have been, grown on the farm under current season) of all chemical products that are approved for use? GAP within the last 12 months. (Act 36, www.nda.agric.za/docs/geneticsresources/geneticresources.htm) 4.2.4 When exporting, are chemical products used on crops registered in the importing 1 An updated accepted MRL list of country of import. country? 4.2.5 Is proof of competence of the technical adviser/producer on the use of chemical 1 Where the crop protection product records show that the technically responsible products available? person making the choice of the crop protection products is a qualified adviser, technical competence can be demonstrated via official qualifications or specific training course attendance certificates. 4.2.6 Is a spray instruction available indicating how the correct application rate has 1 There is documented evidence that shows that the correct application rate of the crop been calculated and how the chemical product must be prepared according to the protection product for the crop to be treated has followed label instructions and has label instructions? been accurately calculated, prepared and recorded. 4.3 Pesticide spray records 4.3.1 Has the date been recorded for all pesticide spray applications? 1 All crop protection product application records specify the exact dates (day/month/year) of the application. 4.3.2 Has the crop name (variety) been recorded for all pesticide spray applications? 1 All crop protection product application records specify the name, and variety of crop treated. 4.3.3 Has the production site been recorded for all pesticide spray applications? 1 All crop protection product application records specify the geographical area, the name or reference of the farm, and the field where the crop is located. 4.3.4 Has the trade name of the chemical product and the active ingredient been 1 All crop protection product application records specify the trade name and active recorded for all pesticide spray applications? ingredient(s). 4.3.5 Has the product quantity applied (concentration) been recorded for all pesticide 1 All crop protection product application records specify the total amount of product to spray applications? be applied in weight or volume, or the total quantity of water (or other carrier medium), and dosage in g/l or internationally recognized measures for the crop protection product. 4.3.6 Has the target pest/disease been recorded for all pesticide spray applications? 1 The common name of the pest(s), disease(s) or weed(s) treated is documented in all crop protection product application records. 4.3.7 Has the name of the spray operator been recorded for all pesticide spray 1 The operator applying crop protection products has been identified in the records. applications? 4.3.8 Has the spray application machinery/equipment been recorded for all pesticide 1 The application machinery type, for all the crop protection products applied (if there spray applications? are various units, these are identified individually), and the method used (i.e. knapsack, high volume, U.L.V., via the irrigation system, dusting, fogger, aerial, or another method), are detailed in all crop protection product application records. 4.3.9 Has the technical authorization (technical adviser/producer) for application been 1 The technically responsible person making the crop protection product recorded for all pesticide spray applications? recommendation has been identified in the records. 4.4 Application equipment 4.4.1 Is the application equipment calibrated at least on an annual basis? 1 The crop protection product application machinery has been verified for correct operation within the last 12 months and this is certified or documented either by participation in an official scheme or by having been carried out by a person who can demonstrate their competence. 4.4.2 Is the correct handling and filling procedures followed according to the product 1 Facilities, including appropriate measuring equipment, must be adequate for mixing label when mixing chemical products? crop protection products, so that the correct handling and filling procedures, as stated on the label, can be followed. 4.4.3 Are filling points suitably constructed for the filling of spray tanks? 2 Surplus mix or tank washings are disposed of according to the national or local legislation. SANS 10206 4.4.4 Are the mixing, filling and cleaning processes associated with spray equipment 1 When surplus application mix or tank washings are applied over an untreated part of done in a manner to prevent contamination of the environment and water the crop, there is evidence that the recommended doses (as stated on the label) have sources? not been exceeded and all the treatment have been recorded in the same manner and detail as a normal crop protection product application. When surplus application mix or tank washings are applied onto designated fallow land, it can be demonstrated that this is legal practice and all the treatments have been recorded in the same manner and detail as a normal crop protection product application, and avoiding risk of surface water contamination. 4.5 Maximum residue analysis 4.5.1 Is the producer/exporter able to provide records of maximum residue level 3 Current documented records are available of annual crop protection product residue (MRL) analyses traceable to the farm? analysis results, or documented evidence of participation in a third party crop protection product residue testing system, which are traceable to the farm. 4.5.2 Is the producer (or his customer) able to demonstrate that he has information 3 The producer or his customer must have available a list of current applicable MRL’s regarding the market in which he is intending to trade his produce, and he MRL for the market(s) where produce is intending to be traded in. The MRLs will be restrictions of that market? identified by either demonstrating communication with clients confirming the intended market(s), or by selecting the specific country(ies) where produce is intending to be traded in. 4.6 Storage of Pesticides 4.6.1 Is the pesticide store constructed of suitable material for the purpose? 2 The storage facilities are built of materials that are structurally sound and robust. (Refer to AVCASA guide) 4.6.2 Is the pesticide store fire-resistant? 2 The crop protection product storage facilities are built of materials that are fire resistant. (Minimum requirement RF30:30 minutes resistance). 4.6.3 Is the pesticide store locked? 2 The crop protection product storage facilities are kept secure under lock and key. 4.6.4 Is the pesticide store well ventilated? 2 The crop protection product storage facilities have sufficient and constant ventilation of fresh air to avoid a build up of harmful vapours. 4.6.5 Is the pesticide store well lit? 2 The crop protection product storage facilities have or are located in areas with sufficient illumination both by natural and by artificial lighting, to ensure that all product labels can be read easily on the shelves. 4.6.6 Is the pesticide store able to retain spillage? 2 The crop protection product storage facilities are retaining tanks or are bunded according to the volume of stored liquid, to ensure that there cannot be any leakage, seepage or contamination to the exterior of the store. 4.6.7 Is equipment available to deal with spillage? 2 The crop protection product storage facilities and all fixed filling/mixing areas are equipped with a container of absorbent inert material such as sand, floor brush and dustpan and plastic bags, that must be signposted and in a fixed location, to be used in case of spillage of crop protection product. 4.6.8 Are Group I (red band) pesticides stored in a separate locked compartment within 2 The crop protection product storage facilities comply with all the appropriate current the pesticide store? national, regional and local legislation and regulations. 4.6.9 Are only pesticides, measuring and spraying equipment stored in 2 Nothing other than the indicated may be found in the room. No food/personal the pesticide store? belongings etc. 4.6.10 Are there facilities for measuring and mixing pesticides? 2 The crop protection product storage facilities or the crop protection product filling/mixing area if this is different, have measuring equipment whose graduation for containers and calibration verification for scales has been verified annually by the farmer. 4.6.11 Is access to the pesticide store limited to trained and authorized 2 The crop protection product storage facilities are kept locked and physical access is personnel? only granted in the presence of persons who can demonstrate formal training in the safe handling and use of crop protection products. 4.6.12 Is an inventory (register) available for all pesticides in the 2 A stock inventory, which indicates the contents of the store, is available and it is pesticide store? updated at least every 3 months. 4.6.13 Are all pesticides stored in their original container/packaging? 2 All the crop protection products that are currently in the store are kept in the original containers and packs, in the case of breakage only, the new package must contain all the information of the original label 4.6.14 Is the pesticide store properly identified with appropriate 2 There are permanent and clear hazard warning signs on or next to signage (skull and crossbones)? the access doors of storage facilities. 4.6.15 Are obsolete chemical products stored securely and disposed of 2 There are documented records that indicate that obsolete crop protection products have by the appropriate authorities? been disposed of by officially authorized channels. When this is not possible, obsolete crop protection products are securely maintained and identifiable. 4.7 Protective clothing 4.7.1 Is appropriate protective clothing in accordance with label 1 Complete sets of protective clothing, (e.g. rubber boots, waterproof clothing, instructions supplied to workers who handle and apply protective overalls, rubber gloves, face masks etc.) which enable crop protection pesticides? product label instructions to be complied with are available and in good sate of repair. 4.7.2 Is protective clothing used for chemical spray applications 2 There are procedures in place to clean the protective clothing after use. washed on the farm after use? 4.7.3 Is protective clothing not stored in the pesticide store? 2 All the protective clothing and equipment including replacements filters etc., are stored apart and physically separate from the crop protection products in a well- ventilated area. 4.8 Empty Pesticide Containers The system used to dispose of empty crop protection containers ensures that persons 4.8.1 Are empty pesticide containers not reused, pierced, stored 1 cannot come into physical contact with the empty containers by having a secure securely and disposed of in accordance with national legislation? storage point, safe handling system prior to disposal by an environmentally responsible method. 5 HARVESTING 5.1 Transport & Hygiene 5.1.1 Has a hygiene risk analysis been performed for the harvest and 1 Must have a documented and up to date (reviewed annually) risk pre-farm gate transport process? assessment that covers the hygiene aspects of the harvesting operation as well as the transport process. 5.1.2 Does the harvesting process, hygiene procedure consider on 1 Farm vehicles used for transport of harvested produce that are also farm produce transportation? used for any purpose other than transport of harvested produce, are cleaned and maintained, and a cleaning schedule to prevent produce contamination is in place (e.g. soil, dirt, fertilizer spills), in accordance with the harvest hygiene risk assessment results. 5.1.3 Do workers involved in the harvesting process have access to 1 Complete sets of protective clothing, (e.g. rubber boots, waterproof hand washing equipment and appropriate clothing in the vicinity clothing, protective overalls, rubber gloves, face masks etc.) which of their operational activities? enable crop protection product label instructions to be complied with are available and in good state of repair. Fixed or mobile hand washing facilities are accessible to harvest workers within at least 500 meters and they are in a good state of hygiene. 5.1.4 Are First Aid boxes present in the vicinity of worker’s operational 2 Complete first aid boxes according to national regulation and activities? recommendations must be available and accessible in the vicinity of the work. Where there is a risk of theft, the supervisor may carry a first aid box with him/her or in his/her means of transport. 6 RECORD KEEPING 6.1 General 6.1.1 Are all records requested during the inspection accessible and 2 Farmers must keep up to date records for a minimum of 2 years, kept for a minimum of time of two years unless legally required to do so for a longer period. 7 TRAINING 7.1 General 7.1.1 Has formal training or instructions been given to all workers 2 Records indicate that the required instructions or training program operating dangerous or complex equipment? are in place and that there is a copy of the attendance certificates or a signed list of workers who attended a training course. Records must also include training for sub-contracted service providers.
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