STANDARDS NON-GMO GRAIN TRACEABILITY .................................................................................... 1900 Hendon Avenue, St. Paul, MN 55108 ~ tel 612-625-7766 ~ fax 612-625-3748 ~ [email protected] ~ www.mncia.org PURPOSE: This voluntary program provides third party verification that a quality management system for grain production and handling is being utilized. MCIA verifies that the system is capable of producing products that meet the specific quality needs of grain buyers and end users. In addition, MCIA utilizes audits and inspections to verify compliance with system requirements at specified stages of production. Enrolled production is traceable from the farm to a pre-determined end point in the production process. Product meeting the standards shall be eligible for a certificate of compliance of Non-GMO Grain Traceability Program. 1. RESPONSIBILITIES: 1.1. The applicant shall: 1.1.1. Be a member in good standing of the Minnesota Crop Improvement Association. 1.1.2. Meet Federal and State requirements relating to sales of grain products. 1.1.3. Attend specified sessions required to participate in this program. 1.1.4. Submit information required for participation in the program. 1.1.5. Ensure that all required inspections are completed prior to harvest. 1.1.6. Use marks of conformance properly to identify grain that has met program requirements. 1.1.7. Permit access to production, conditioning and storage site(s) and records. 1.1.8. Retain records of customer satisfaction. 1.1.9. Condition grain at a MCIA approved facility. 1.1.10. Provide a copy of customer(s) quality trait requirements. 1.1.11. For each lot shipped, retain a 2 lb product sample for one year. 1.1.12. Conform to all program requirements. 1.2. MCIA shall: 1.2.1. Provide training sessions to educate applicant in program requirements. 1.2.2. Evaluate company program documentation for completeness. 1.2.3. Perform program audits. 1.2.4. Determine applicant’s conformance to standards. 1.2.5. Issue a certificate of compliance. 1.2.6. Monitor the effectiveness of the system in achieving the program objectives. This may include unannounced inspections. 2. REQUIRED REFERENCES Current versions of the following references must be in the program participant’s possession or readily accessed online: 2.1. Non-GMO Grain Traceability Standards 2.2. Non-GMO Grain Traceability Fee Schedule 2.3. Non-GMO Grain Traceability Application 2.4. Non-GMO Grain Traceability Instructions 2.5. MCIA Approved Seed Conditioner Requirements Standards – Non-GMO Grain Traceability Controlled Version – 3/17/16 Identity Preserved Page 1 of 4 Print Date: 7/31/2017 © 2016 Minnesota Crop Improvement Association 3. QUALITY MANAGEMENT SYSTEM 3.1. Applicant shall have a Quality manual. 3.2. Applicant shall have a Quality objective. 3.3. Applicant shall have a Document control method. 4. CROP PRODUCTION AND HANDLING REQUIREMENTS 4.1. Grower Requirements 4.1.1. Grower shall be supplied with grower requirements/procedures prior to planting season. 4.1.2. Grower training documents shall be retained. 4.1.3. Producers of the grain shall thoroughly clean all equipment used for planting, harvesting, conveying, storing, and handling. 4.2. Seed Standards 4.2.1. Proof of seed source - invoice including lot numbers shall be retained. 4.2.2. Seed shall be from an eligible variety list provided by the applicant. 4.2.3. All seed used must be tested to provide proof of non-GMO content. Type of test(s) performed and results of Non-GMO seed test analysis shall be retained for each lot. 4.3. Field Standards 4.3.1. Field shall be assigned a unique field number. 4.3.2. Field maps shall be retained. 4.3.3. Identity of seed stock used in each field shall be recorded. 4.3.4. Field size shall be recorded. 4.3.5. Previous crop cannot be of the same kind unless the previous crop was grown from a Non-GMO variety. 4.3.5.1. If previous crop grown was a GMO variety of a different kind, volunteers must be controlled in the field. 4.3.6. Isolation 4.3.6.1. If crop is self-pollinated, it shall be separated from adjacent GMO fields by a distance adequate to prevent mechanical mixture. 4.3.6.2. If crop is cross-pollinated, it shall be separated from adjacent GMO crosspollinated crops by a minimum distance of 660 feet (distance may be reduced if methods of reduced pollen drift exist in the field). 4.4. Field Inspection 4.4.1. Fields shall be inspected by a trained inspector or a third party agent. 4.4.2. Fields shall be inspected a minimum of once a year prior to harvest. 4.4.3. Inspections shall include: varietal purity, previous crop, potential GMO volunteers, isolation, confirmation of field location and size, and general comments about crop appearance. 4.5. Harvest, Storage and Handling 4.5.1. Bins shall be cleaned prior to filling and shall be recorded. 4.5.2. Harvested amounts shall be recorded. 4.5.3. Stored product must be identified at all times. Bins must be labeled. 4.5.4. Records shall be maintained of on-farm grain storage. 4.5.5. Record of all grain movement from farm to approved facility shall be maintained. 4.6. Conditioning shall be at a MCIA Approved Facility 4.6.1. Facility shall be in good standing with MCIA. 4.6.2. Facilities shall be maintained and operated utilizing procedures adequate to perform required functions without contamination or loss of grain identity. 4.6.3. Equipment shall be sufficient to perform required conditioning functions in accordance with program specifications and end-user requirements. Standards – Non-GMO Grain Traceability Controlled Version – 3/17/16 Identity Preserved Page 2 of 4 Print Date: 7/31/2017 © 2016 Minnesota Crop Improvement Association 4.6.4. 4.6.5. 4.7. Scales used shall be accurate based on regular calibration. Applicant shall provide proof of proper calibration. Facility records of all required activities shall be maintained. Sampling and Testing 4.7.1. A representative sample of each conditioned lot shall be drawn by an authorized sampler according to the designated sampling procedures found in the MCIA Approved Seed Conditioner Requirements. 4.7.2. The sample shall be submitted to a MCIA approved laboratory for testing. 4.7.3. Grain quality standards shall be pre-determined in accordance with program specification and end-user requirements. 4.7.4. Test results shall be evaluated by the applicant (or its agent) for conformance to grain quality standards. 4.7.5. Procedure for handling non-conforming products shall be maintained. 4.7.6. Sampling records shall be maintained 4.7.7. Grain samples shall be stored for one year following final sale of the lot. 5. RECORD REQUIREMENTS 5.1. Applicant shall retain records for three years following final sale of the lot. 5.2. Records of all operations relating to the program shall be complete and adequate to account for all incoming product and final disposition of product. 5.3. Conditioning facility shall permit review by MCIA of all records pertaining to the Non-GMO grain product. 5.4. Required records: 5.4.1. Buyer (end-user) contract. 5.4.2. Grower training materials and documents. 5.4.3. Variety(s) Eligibility listing. 5.4.4. Proof of seed source – invoice including lot numbers. 5.4.5. Non-GMO test of seed source – type of test and results. 5.4.6. Field information including field number and map of field locations. 5.4.7. Planting records – previous crop, GMO status of previous crop, and planted acres. 5.4.8. Field inspection criteria and records 5.4.9. Harvest records including dates, amounts, storage location, and any destroyed product. 5.4.10. Storage records including assigned bin numbers. 5.4.11. Records of product movement – scale tickets and clean truck affidavits. 5.4.12. MCIA Approved Facility report or certificate of approval 5.4.13. Final product sampling and testing records – Non-GMO test (type of test and results), other required test(s), and retained sample. 5.4.14. Packaging and shipping records, such as scale tickets, bill of lading, and seal numbers 5.4.15. Labeling records – MCIA Certificate of compliance, 5.4.16. Current inventory of eligible product. 5.4.17. Record of disposition of any non-conforming product. 5.4.18. Sales records. 6. APPROVAL PROCESS 6.1. MCIA personnel shall verify the applicants Non-GMO Grain Traceability program through audits and inspections of procedures, documents, and records. 6.1.1. MCIA personnel shall identify areas of non-conformity in an audit report. 6.1.2. Applicant must implement changes to comply with program standards 6.1.3. MCIA shall verify and approve any changes to insure the system meets the requirements. Standards – Non-GMO Grain Traceability Controlled Version – 3/17/16 Identity Preserved Page 3 of 4 Print Date: 7/31/2017 © 2016 Minnesota Crop Improvement Association 7. MARK OF CONFORMITY – CERTIFICATE OF COMPLIANCE 7.1. Following verification that the process meets the program requirements, MCIA shall issue a Certificate of Compliance of Non-GMO Grain Traceability Program. Certificate shall include the Applicant company name, variety/brand name and crop kind of approved product, the minimum non-GMO purity level met, and the purchasing client’s name. 7.2. Product shipped without proof of conformity shall not have met Program requirements and will be deemed to be non-conformant. 8. SANCTIONS FOR MISCONDUCT 8.1. It is the responsibility of each Program participant to abide by the rules, adhere to the standards and report irregularities or violations. 8.2. Intentional violation of program requirements and/or misuse of marks of conformity may result in suspension from program participation. 8.3. Decisions to suspend participation in the program due to misconduct shall be made by MCIA Board of Directors. 8.4. Appeals or petitions for reinstatement shall be directed to MCIA Board of Directors. 9. FEES 9.1. Fees required for participation in the Non-GMO Grain Traceability Program shall be assessed by MCIA. 9.2. Applicants shall be responsible for all Non-GMO Grain Traceability Program participation fees as specified on the Non-GMO Grain Traceability Program Fee Schedule. Standards – Non-GMO Grain Traceability Controlled Version – 3/17/16 Identity Preserved Page 4 of 4 Print Date: 7/31/2017 © 2016 Minnesota Crop Improvement Association
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