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VERSION 6.0

BULK STORAGE AND HANDLINGVERSION 6.0

Code of Practice forBulk Storage and Handling

Effective from: 1st April 2015

GTAS Bulk Storage and Handling Manual.Published by Gafta: GTAS © Version 6.0

effective from 1st April 2015

BULK STORAGE AND HANDLING

2 Introduction2 Definitions, Scope and Store Eligibility2 Biomass2 EU Renewable Energy Directive3 International Database for Transport of Feed3 Records3 Loading and Discharge Handling Operations4 Statutory Requirements4 Food and Feed Premises Registration Regulations4 Registration of Storekeepers under EU TSE Regulations4 HACCP4 The Store5 Cleaning the Store6 Contracting Out6 Insurance6 Storage Operations7 Liquid Feed7 Requirements for Feed Material Packing Operations in Assured Stores9 Pest and Vermin Control9 Store Management of All Goods10 Drying, Cleaning, Conditioning and Blending of Goods11 Simple Processing11 Monitoring of Undesirable Substances12 Use of Pesticides and Fumigants12 Customer Requirements12 Acceptance of a Storage Order12 Incoming Goods13 Outgoing Goods13 Personnel14 Training14 Security14 Procedures and Instructions14 Self-Assessment Procedures15 Material Recall and Crisis Management15 Complaints Procedure15 Arbitration

16 Appendix 1: General Definitions18 Appendix 2: Introduction to HACCP25 Appendix 3: Cleaning Methods26 Appendix 4: Salmonella Sampling and Testing Procedure27 Appendix 5: EU Renewable Energy Directive Manual33 Appendix 6: International Database for Transport of Feed (IDTF)34 Appendix 7: Guidance Note for the Control of Birds


CONTENTS

GAFTA TRADE ASSURANCE SCHEME 1

1.0 Introduction Goods that are traded within the international grain and feed trade are handled and stored a number of times. The manner in which this takes place is vital to maintain the original quality and condition of the goods and the prevention of contamination that might render the goods unfit for their intended use.

2.0 Definition, Scope and Store Eligibility This Code of Practice comprises a set of minimum standards which storekeepers must achieve when storing and handling goods, including imports and exports, which are, or may be, intended for human consumption after processing or which are intended to enter the food chain either for direct feeding to livestock or for incorporation into animal feedingstuffs.

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 6.0.

2.1 This Code of Practice is intended for premises that are dedicated to the storage of animal feed materials, (raw materials and straight feeds, feed additives, etc., [as defined under the applicable Feedingstuffs Regulations] intended as an animal feed material), combinable crops, (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,finished products and processed materials for food and/or feed purposes.

2.2 Stores that are not dedicated to the storage of combinable crops or animal feed materials shall be eligible for approval under the following conditions:

a) Stores that have stored non food/feed material must be thoroughly cleaned/disinfected. Risks posed by previously stored materials must be included in the store HACCP plan. [R]

b) No building previously used for housing of livestock of any kind or stores that have stored forbidden materials (see 5.0) shall be used for the storage of goods unless the whole of the inside of the building including floors, walls, roofs, roof trusses and fittings, have first been thoroughly cleaned to remove all organic material followed by a thorough pressure cleaning with a hot (70-80C) solution of any combined food grade detergent/disinfectant, diluted in accordance with manufacturer’s recommendations dried and then approved by the Scheme Verifier before use. [R]

c) No building previously used for other purposes that might possibly lead to contamination, taint, infestation or transmission of disease must be used for the storage of goods until adequate and appropriate cleaning and disinfecting has been carried out in accordance with 2.2 b) [R]

2.3 Declaration and approval of store facilities is by each individually identifiable store. Any new shed/store wishing to be certified must be notified to the certification body before introduction into the scheme. [R]

3.0 Biomass

3.1 Goods suitable for food and/or feed purposes that are intended for biomass use may be stored in the same way as goods intended for use for food and/or feed.

3.2 Other materials intended for biomass use that are not suitable for use as food and/or feed may be stored in premises certified under this Code of Practice after completion of a HACCP Risk Assessment form (available from Gafta) to be submitted to Gafta for approval.

3.3 Risk Assessment forms must be specific regarding the source and description of the biomass commodity (for which permission to store is being sought) since there may be variation between goods of the same general description from different origins.

3.4 Approval where given is specific to each biomass commodity and for each source or origin of the material for which the application is made. The completed HACCP risk assessment form and written approval from Gafta must be retained and made available during any audit. There is no limit to the number of applications that can be made or approvals given. [R]

4.0 EU Renewable Energy Directive The EU Renewable Energy Directive 2009/28/EC came into effect on 5th December 2010. This legislation introduced targets for renewable energy in EU member states and enables the supply of feedstocks for biofuels and bioliquids. The legislation applies to all goods intended to be classified as “sustainable”, for use as biofuel

GAFTA TRADE ASSURANCE SCHEME2


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and bioliquid in the EU which are intended to count towards national renewable energy targets.

Traders who procure and deliver goods for biofuels or bioliquids must be able to provide evidence that the requirements of RED are being met, by production of a proof of sustainability, certificate or equivalent issued under an EU approved certification scheme, for each consignment of goods supplied.

RED compliance is demonstrated by clearly annotated documentation accompanying goods in transit and by cross checking compliance status with on-line databases. Where RED goods are involved the requirement to operate a RED compliant mass balance system applies.

For detailed information about obtaining certification for compliance with the requirements of RED see Appendix 5.

5.0 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. GTAS includes the IDTF which replaces the Exclusion List and Contaminant Sensitive List in previous versions of the scheme. www.icrt-idtf.com

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 6 for more information regarding ICRT/IDTF.

6.0 Records An important part of this Code of Practice is the need for verification that essential activities have taken place at the appropriate time and by an appropriate person. Therefore it is essential that records (computerised and/or hard copy) are kept and are available at all times for audit inspection.

6.1 An [R] in the text indicates where there is a requirement to keep a record. This is not an exhaustive indicator and there may be a requirement for other records to be kept.

6.2 Internally produced records must be signed and dated by the person carrying out the task/activity.

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

6.4 Records must be kept for a minimum of five years, unless there are additional requirements.

7.0 Loading and Discharge Handling Operations Such 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 agricultural commodities in terms of maintaining their quality and integrity during either the loading or discharge operation. In addition, the responsibility of ascertaining the weight of agricultural commodities will be within their remit. (See Gafta Weighing Rules No.123).

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

7.1 All goods must be loaded or discharged via a secure route and method.

7.2 Where weight is to be determined, the goods must pass through the weighing equipment in a secure route.

7.3 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. Where sweepings and or spillage has come into contact with extraneous matter which may cause contamination, for example spilt oil, bird droppings or dirt of any kind they must not be re-introduced into the original goods but must be disposed of in a safe manner in agreement with the owner of the goods. [R]

7.4 If instructed to do so by the owner of the agricultural commodities, special attention should be given to the handling of organic and genetically modified materials. [R]




7.5 Handling and storage should be performed by operators with clear management systems and rules as laid down in the Gafta Trade Assurance Scheme, and take into consideration the legal requirements of the competent authorities.

7.6 All handling equipment must be kept clean through application of a routine cleaning programme and free from leakage at all times. Operators should be observant regarding checking for leaks. [R]

7.7 Premises and equipment must be accessible for the control of on-going operations.

7.8 Adequate loading and unloading equipment should be available for the different means of transport (trucks, railcars, barges etc) accepted by the facility. 7.9 In case of bad weather conditions adequate measures must be taken in order to prevent damage to the goods.

7.10 When different loading and/or discharging operations are being carried out at the same time the conveyor/belt systems must be secured to prevent co-mingling of goods. It is essential that equipment including belts and conveyors are inspected to ensure there is no material remaining before changing to a different material. Belts and conveyors should be run for a pre-determined period to remove any traces of previous materials.

7.11 Each operation must be recorded. [R]

8.0 Statutory Requirements

8.1 The storekeeper must at all times exercise due diligence in the care of the goods, and must be conversant with and comply with the legislative requirements of the country in which they are operating. This includes (inter alia) any local and national health and safety legislation.

8.2 Storekeepers must comply with a recognised Code of Practice for the Control of Salmonella. In the absence of such Code of Practice, the Gafta Monitoring Code for the Control of Salmonella shall apply. [R]

8.3 Storekeepers must demonstrate the actions taken to store goods in accordance with applicable legislation and customer requirements.

9.0 Food and Feed Premises Registration Regulations

9.1 Storekeepers operating within the European Union should note that before storing any goods which may be destined for human and/or animal consumption, that they must apply to their local authority to register their premises (Food Hygiene Regulation EC Reg 852/2004, Feed Hygiene EC Reg. 183/2005). The respective registration number, or written confirmation of the registration, issued by the local authorities will be checked as part of the certification audit. [R]

9.2 Storekeepers located outside the European Union are advised to check with their local authorities whether such requirement exists. [R]

10.0 Registration of Storekeepers under EU TSE Regulations Storekeepers operating within the European Union should note that registration with the official authorities is required for the storage of dedicated bulk, animal-derived dicalcium phosphate and hydrolysed protein. Storekeepers located outside the European Union are advised to check with their local authorities whether such requirement exists. [R]

11.0 Hazard Analysis and Critical Control Points (HACCP) The importance of HACCP and the requirement for a HACCP plan for any storekeeper or grain handling facility cannot be overstated. It is a statutory requirement for all food and feed businesses in the EU to put in place a permanent written procedure(s) based on HACCP principles. Regulation EC 183/2005 laying down requirements for feed hygiene states:

“(the) primary responsibility for feed safety rests with the feed business operator."

11.1 A formal risk assessment must be carried out, implemented and maintained with the aim of identifying and controlling any hazards that might adversely affect the integrity of stored materials. [R]

11.2 Risk assessments must be carried out in accordance with recognised HACCP principles. See appendix 2 [R]

12.0 The Store 12.1 The storage facility must be secure, soundly constructed of durable materials, fully enclosed, and proofed against birds and rodents, sufficient to protect the goods from damage, water ingress, and contamination. The area immediately surrounding the store site must be designed and maintained to limit contamination of stored goods.

12.2 Roofs must be sound and leak proof.

12.3 Floors and walls of the store must be impervious to liquids. All openings such as manholes, inlets, outlets,


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drainage points, etc., must be sealed effectively. The layout of the store and of any necessary plant therein should be such as to avoid the creation of uncleanable recesses. No unnecessary plant should be kept in the store.

12.4 Floors or walls that are sealed or coated in bitumen or where a bituminous filler is used, must not come into contact with stored materials.

12.5 Stores must be maintained in a clean, dry state, free from taint and abnormal odour.

12.6 There must be adequate and effective drainage.

12.7 There must be sufficient clean hard standing at the store entrances to prevent tracking of water and mud into the store.

12.8 Each separate store should be clearly identified by name, initial, or number. Where the store is subdivided into bays, each bay must also be separately and clearly identified. In the case of vertical silo bins each bin should be individually numbered.

A plan of the store/silo, including identification of bays, bins, silos or tanks, must be kept up to date so that goods can be easily identified. [R]

Signs must be fixed to the exterior of the store identifying the premises as a “Food Store”

12.9 The ventilation facilities must be adequate to prevent the build-up of hot air or condensation. External ventilation and aeration openings must be proofed against the entry of birds and vermin.

12.10 Switches, wiring, lighting, etc., must be sited well clear of all stored materials. All light bulbs and fluorescent tubes must be covered with non-glass fittings and/or approved protective coating, and any windows and/or glass roof lights must be guarded to prevent the possibility of glass contaminating the stored goods.

12.11 Glass must be excluded from the store in all forms including vehicles and other equipment. (see HACCP Glass audit)

12.12 Where heating facilities are required for certain liquids, the means of heating must be appropriate for the goods being stored. Heating equipment must not leak, be kept in good repair, be monitored and controlled. [R]

12.13 Weighbridge(s) and any other weighing equipment must be calibrated annually by a recognised (suitably qualified) external company and any calibration certificates retained. Nb: If a public weighbridge is used there must be evidence available that these have also been calibrated annually. [R]

12.14 Testing equipment used for stores monitoring purposes must be calibrated to manufacturer’s instructions at least annually. [R] .

12.15 Store entrances, exits and gangways must allow access to stored goods in case of heating or fire.

13.0 Cleaning the Store 13.1 Stores must employ a routine cleaning programme covering all parts of the store and structures within it, in particular roof trusses, ledges, all dust collecting surfaces and all handling and weighing equipment [R]

13.2 Outside of the routine cleaning programme, stores must ensure that floors are kept clean and dry at all times.

13.3 The entire store, including all structures, must be subjected to a regular thorough cleaning programme when empty preferably on an annual basis. [R]

13.4 The storage and disposal of waste material produced during cleaning operations must be considered as part of the store HACCP plan. [R]

13.5 Stores must be thoroughly cleaned before a changeover between different groups of commodities stored for example between: • Combinable crops • Marine derived goods • Minerals • Moist feeds • Vegetable commodities

13.6 Any store that has held goods contaminated with salmonella must be disinfected, swabbed and tested to confirm clearance before further use. [R]

13.7 On cleaning, tanks must be fully drained of wash medium prior to refilling and the wash water must be disposed of in an environmentally acceptable manner. The tank must be emptied and cleaned before a switchover between vegetable and marine commodities. [R]

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13.8 Cleaning schedules must be developed and implemented to minimise the risk of salmonella and where appropriate in accordance with the applicable Code of Practice for the Control of Salmonella.

13.9 Any equipment used to load, unload or otherwise handle or sample goods must be suitable for the purpose and must be routinely maintained in a clean condition appropriate for the handling of crops. A daily inspection sheet should be kept evidencing that visual checks have been made of any mechanised handling equipment to ensure that there is no damage to glass or there are any leaks of fluid etc. [R]

13.10 Any equipment used to handle goods which could be a source of contamination, must be thoroughly cleaned before being used to handle other goods. [R]

13.11 Equipment used for the handling of goods must not be used for the handling of any IDTF forbidden materials. [R]

13.12 In areas where goods are stored particular attention must be paid to checking for leaks from handling equipment and vehicles.

13.13 Vehicles and equipment, which are not required in the handling of the goods or cleaning of the store, must be excluded from the store and stored/parked in designated area(s). Any vehicles or motorised equipment parked inside the store must have drip trays placed underneath to catch any oil leakages.

13.14 Non-phenolic food grade disinfectants and approved pesticides and fumigants are the only products which may be used and must be applied by equipment capable of achieving the correct application. [R]

14.0 Contracting Out Only storage companies that are certified under GTAS or a scheme recognised by GTAS can store goods under this Code of Practice. If a storage company is unable to fulfil an obligation to store goods for legitimate reasons they can, after prior reference to and approval from the owner of the goods, contract out the obligation to another storage company that is certified under GTAS or a scheme recognised by GTAS. This is often referred to as sub-contracting. [R]

15.0 Insurance Storekeepers must demonstrate that they have adequate and appropriate insurance in place to cover any claims that may arise as a result of liability in respect of goods stored. Levels of cover will differ significantly depending on the type of goods stored and the scale of risks involved. Insurance may be covered through commercial or private (self assurance) channels and must cover public and product liabilities. The extent of cover should be appropriate for the value and the nature of the goods being stored and should take account of customer terms and conditions where appropriate. [R]

16.0 Storage Operations 16.1 Mammalian Meat and Bone Meal (MMBM) must not be stored on the same site as goods or additives which could enter the human/farmed animal feed chain, unless physically separated. Adequate physical separation will be determined by risk assessment on a case-by-case basis.

16.2 No IDTF forbidden or unlisted goods or materials can be stored in the same store as goods under this code.

16.3 Fishmeal intended for non-ruminant livestock feed within the EU is only allowed to be stored in bulk in dedicated, registered stores and, where possible, dedicated equipment should be used to handle fishmeal.

16.4 If any handling equipment or vehicle is used for fishmeal and is subsequently used for other products, it must be thoroughly cleaned, sanitised and inspected before and after the handling/transport of the fishmeal. This should be considered in the store HACCP plan. [R] 16.5 Bagged or bulk minerals must not be stored in the same store as other goods covered by this Code.

16.6 If flammable materials are stored on the same site as goods covered by this code of practice these must be kept physically separated by a barrier and/or at a safe distance away from the goods.

16.7 Moist Co-Products Buildings that have stored moist co-products must be cleaned and disinfected with a food grade disinfectant before storing dry products. [R]

16.8 Infested Products Buildings which have stored infested products must be thoroughly steam cleaned. Proof will be required to be given that appropriate cleaning operations have been undertaken and they must be recorded. The use of smoke bombs is not likely to be effective and is not recommended. [R]

16.9 Fishmeal Where applicable, in accordance with EU Animal By-Products Regulations, only fishmeal which has been produced in plants authorised by the competent authority is permitted to be stored under this Code.


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If a building is used for the storage of fishmeal and is subsequently used for the storage of other products, it must be thoroughly cleaned and disinfected. [R]

16.10 Allergens Certain materials or goods are classified as allergens as they can cause severe allergic reaction in humans. In some cases this can be fatal. EU Directive 2007/68/EC identifies 14 groups of allergens known to induce allergic reaction. These include: • Crustacean and products thereof • Eggs and products thereof • Fish and products thereof • Peanuts and products thereof • Milk and products thereof • Nuts: Almond/Hazelnut/Walnut/Cashew/Pecan/Brazil/Macadamia and products thereof • Celery and products thereof • Mustard and products thereof • Sesame seeds and products thereof • Sulphur dioxide and sulphites at concentrations of more than 10mg/kg or 10 mg/litre expressed as SO2 • Lupin seeds and products thereof • Molluscs and products thereof.

For the full list please see EU Directive 2007/68/EC

Where materials known to cause allergic reaction (excluding cereals) are stored (or intended to be stored) in the same store as goods which may be destined for human consumption, the owner of the goods must be informed in writing and approval obtained. Dealing with allergens should be considered in the store HACCP plan. [R]

16.11 Naturally Occurring Prohibited Substances (NOPS) These are substances which can be found naturally in some raw materials and may cause problems if fed to horses involved in competition/racing etc. NOPs may be found in bakery and biscuit products, confectionary, poppies and sprouting barley.

Those involved in the production, storage or handling of equine feedingstuffs should inform their customers/suppliers if any of these products are being handled. [R]

17.0 Liquid Feed

17.1 Storage tanks for liquid feed must be inspected and cleaned on a prescribed basis, depending on the nature of the liquid being stored and whether a tank is dedicated to storage of a particular type of material. The frequency of complete emptying and cleaning will depend on the physical and microbiological storage stability of the material. [R]

17.2 Where common plant and equipment (pipelines, pumps etc.) are used for handling different liquid feed goods, an efficient line cleaning system must be used.

17.3 Exposed ends of flexible hoses should be kept capped when not in use.

17.4 For liquid storage thermometers, sampling equipment and tank content gauges must be appropriate and the equipment be maintained. [R]

17.5 Liquid filters and strainers must be inspected at regular intervals and cleaned in accordance with a formal cleaning programme. [R]

18.0 Requirements for Feed Material Packing Operations in Assured Stores

18.1 Packaged Feed Ingredients A stock rotation system must be in place, in agreement with the owner of the goods. [R]

A system must exist to identify out of date stock and to segregate it so that it cannot be inadvertently put into circulation. [R]

Fork lift operators must be instructed regarding the importance of avoiding breakages.

Store staff must be instructed on how to deal with breakages in a safe and hygienic manner.

Storage areas must be checked when empty and cleaned if necessary. [R]

18.2 Equipment Each item of feed related fixed equipment and (if applicable) associated bulk storage must be shown on a flow diagram which is updated when any changes take place. [R]



All equipment must be constructed and operated so that feed ingredients are protected from contamination. There must be a maintenance plan and record for any equipment relating to feedingstuffs. [R]

Weighing, measuring and monitoring equipment must be calibrated to recognised national standards at intervals not exceeding 12 months. Regular and recorded cleaning and calibration must take place according to a written schedule. [R]

All equipment which is used to handle feed ingredients must be kept clean. Records of cleaning and disinfecting must be maintained. [R]

Equipment used for the handling of feed ingredients must never be used for the handling of forbidden materials such as mammalian meat and bone meal, toxic or hazardous materials.

18.3 Waste Waste packaging material must be collected into suitable and clearly identified receptacles for removal to identified collection points away from the production areas.

18.4 Packaging Operations When feed materials are being packaged, care must be taken to avoid contamination during the packaging process.

Packaging must be appropriate to the product type and to maintain contents for their intended shelf life.

Weighing machines and other equipment must be cleaned when changing between feed ingredients. [R]

Where paper or plastic sacks are used these must not have had any previous use.

18.5 Big Bags and Containers If “big bags” (0.5 tonne or 1 tonne) are used it is permissible to use clean containers which have been previously used for human food ingredients providing that these are inspected and seen to be free from residue and that the food ingredient is one which would be suitable for use for the species and applications for which the feed ingredient is intended.

Big bags which have been previously used for deliveries to farm cannot be re-used.

Single trip bags must not be re-used.

Big bags that have been used for feed ingredients other than fish meals or animal proteins but have not been used on farms can be re-used after inspection.

Big bags which have been used to carry forbidden materials, medicated feedingstuffs, or those containing specified feed additives, cannot be re-used.

Rigid bulk containers which can be satisfactorily cleaned must be inspected and if necessary cleaned before filling.

Before receiving any deliveries by container, storekeepers must have received and act in compliance with the requirements of the relevant trader/merchant or customer Risk Assessment. The Risk Assessment should include reference to: • inspection of the container's construction, cleanliness and previous use • pressure cleaning and disinfection • the use of liners for protection of the goods • other specific requirements. Records of inspection, cleaning operations, disinfection etc., as required by the Risk Assessment must be maintained. [R]

18.6 Pallets Pallets must be serviceable, clean and dry.

All pallets which are returned must be inspected and if necessary cleaned before re-use.

18.7 Labelling Care must be taken to use the correct labels on all packages and label details must conform to current legislation.

Information given on packages, labels and leaflets and by other means must be correct and not misleading.

Redundant labels must be disposed of safely so that mis-labelling or confusion between batches is avoided.

Each package must be labelled in such a way that the batch or run of the packaging operation to which it belongs can subsequently be identified. [R]

Records must be kept which link the package label to an identified batch or batches of feed material in order to retain traceability and to aid in defining the scope of any recall. [R]


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18.8 Packaging Records The following information must be recorded for each batch of feed ingredient packaged, as an aid to traceability: • Ingredient or product name • Origin/manufacturer/supplier • Quantity packaged • Date of packaging • Batch record/number (as shown on the package label)

18.9 Storage of bagged feed materials or containers of liquid feed materials Stores that only handle bagged feed materials or liquid feed materials in sealed containers may store other types of material not covered by this code provided that: • There are designated storage areas for feed and non-feed materials with suitable physical separation between the materials. • Special care is taken to ensure liquid products in store cannot contaminate dry feed materials. Unless suitable controls are in place, liquids must not be stored above dry feed materials. • Any forbidden materials such as those containing mammalian meat and bone meal (including pet food), toxic, or hazardous materials are not stored above or in close proximity to feed materials. • Controls are in place for any split bags paying particular attention to contamination risks and weights and measures legislation.

Stores that handle bulk and bagged feed materials cannot store any non-feed materials unless covered by a biomass risk assessment.

All liquids must be within a suitably bunded or protected area (or have equivalent protection against cross contamination).

The HACCP risk assessment must consider the hazards arising from materials held in store. The study must include cross contamination risks between bulk and bagged materials and must include if necessary hazards from materials derived from genetically modified DNA contaminating non-GM materials or conventional commodities contaminating organic materials. Any risks identified must be adequately managed by separation of bulk and bagged products. Issues associated with spillages and breakages of bags or pallets must also be satisfactorily controlled.

19.0 Pest and Vermin Control

19.1 Measures must be taken to exclude rodents from the vicinity of the site. [R]

19.2 The control measures must be designed to ensure that poison baits cannot contaminate the goods. Where practical, baits should be outside the actual storage area. If shooting of vermin is part of the control programme, non-toxic ammunition must be used.

19.3 A plan of the location of bait stations (numbered for cross referencing on the plan) must be kept and any bait stations must be securely attached to a fixed point to prevent movement or loss. [R]

19.4 Stores should have a person on site that holds a recognised Pest Control qualification, and records of training and certifications relating to those persons must be kept. Alternatively stores must have a vermin/pest control contract with a suitably qualified external company which is a member of a recognised Association. In either case this should cover the safe use of rodenticides. [R]

19.5 Records must be kept of any corrective actions, the amount and type of bait used, and frequency of checks. [R]

19.6 Waste and scrap materials, old pallets, vegetation or other materials which can encourage and harbour rodents, must be removed from the proximity of the stores. [R]

19.7 Precautions must be taken to discourage birds from the vicinity and to prevent their entry into stores. Wire masks must be put over ventilators and windows. (See Appendix 7) [R]

19.8 Animals of any description must be excluded from stores.

20.0 Store Management for all Goods

20.1 Regular temperature checks of not less than once per week must be made and recorded for each stack, bulk or silo of dry goods. Temperature checks should be made across the whole bulk and to a range of depths, where possible, to give an accurate record of the consignment and to identify any hot spot areas. Where there are sudden changes in temperature from week to week, or where measured temperatures within the bulk exceed 20 degrees celcius in excess of ambient temperature or in the case of animal feed materials exceeds an agreed level, the cause must be investigated and the owner of the goods must be notified as soon as possible. Once stored goods are below 15oc, the frequency of temperature checks may be extended to not less than once per two weeks or as agreed with the principal for whom the goods are being stored. [R]


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20.2 For each stack of dry goods evidence must be recorded of any action taken. [R]

20.3 Copies of temperature records must be made available to the owners of dry goods if requested. [R]

20.4 Any aeration fans should be run regularly when conditions are suitable in order to prevent the heating of combinable crops in store, and/or the build up of anaerobic conditions. Where no aeration facilities are available the storekeeper shall notify the customer/owner of the goods accordingly. [R]

20.5 Aeration fan running times must be recorded. Interference to fan running as a result of adverse weather conditions or mechanical faults should be recorded and made available to customer/owner of the goods if requested. [R]20.6 The operator responsible for taking temperature readings of goods in store must complete the record of the readings. [R]

20.7 Where temperature monitoring of goods in store is not possible due to the structure of the store or for health and safety reasons, the store shall provide a risk assessment for the safe storage of the goods plus an ongoing assessment establishing continued safe storage. This should be considered as part of the store HACCP plan. [R]

20.8 Storekeepers are required to show documentary evidence that the owner(s) of the goods in question accept storage without normal temperature monitoring but with ongoing safe storage risk assessment if applicable. [R]

20.9 Where a risk of rising temperature or deteriorating condition is identified, including unusual odours and visual signs such as mould, steam, insect migration, (or foaming, lumps, or crusts in liquids) these must be investigated and reported to the owner(s) of the goods plus any corrective action taken agreed with the owners of the goods. [R]

20.10 Insect infestation must be reported to the owner of the goods immediately on discovery. Any disinfestation procedures to be used must be advised to and approved by the owner of the goods each time before they are carried out. In the event of failure by the owners to respond within 48 hours, the storekeeper must take appropriate action. [R]

20.11 Water entry through leakage must not be allowed, as it can cause damage – for example heating, and microbial activity. If, in spite of all precautions, stored goods do become wet, they must be segregated at the earliest opportunity.

20.12 Smoking or naked lights must not be permitted within storage areas or near to goods.

20.13 Welding or other “hot work”, such as burning, riveting or any other potentially combustible activity, must not be allowed in the store, unless full precautions are taken to avoid the risk of fire or explosion.

20.14 The use of explosive bird scaring devices must not be allowed within stores.

20.15 Handling methods must be such as to minimise the production of dust. This precaution is necessary to minimise the risk of fire or dust explosion, to prevent contamination and to control the spread of Salmonella. 20.16 There must be no deliberate admixture or contamination of the goods and so far as is possible the accidental admixture or cross-contamination of the goods must be prevented. [R]

20.17 Individual shipments of goods must be stored separately. However, storekeepers must keep formal records when the owner of the goods instructs them to store goods from one consignment with goods from other consignments.[R]

20.18 Doors must be kept shut at all times unless loading, ventilation or other operations are taking place. 20.19 If assured and non-assured goods are mixed for storage, the whole bulk must be regarded as being non- assured. [R]

20.20 If GM and non-GM goods are mixed for storage, the whole bulk must be regarded as being genetically modified. [R]

21.0 Drying, Cleaning, Conditioning and Blending of Goods

21.1 Where drying, cleaning, conditioning or blending is undertaken, HACCP procedures must ensure that any adverse effect on the goods being dried, cleaned, conditioned or blended is minimised.

21.2 Any drying operations on goods in store must be recorded, including details of where any dried goods are placed in store prior to out loading to final destination. [R]

21.3 All practical steps must be taken to exclude/remove all traces of gases and exhausts from combustion, from the storage area(s) to minimise any deleterious effects of exposure to dioxins and PCB's on the goods. Combustion gases include all fumes and exhausts whether from lorries, handling and moving equipment, drying equipment etc.


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21.4 Drying equipment must be regularly (annually) serviced and maintained by a demonstrably competent person in accordance with manufacturer’s recommendations. For the purposes of this clause “regular” shall mean as necessary to ensure that the equipment operates at optimum efficiency and that contamination build up of residues within the equipment is avoided. [R]

21.5 Fuel used in oil-fired driers must meet accepted industry fuel standards and should be sourced from reputable suppliers. Waste oil must not be used under any circumstances. Full records must be kept of all fuel oil deliveries including their origin and specification. [R]21.6 Screenings or cleanings which are to be identified or sold as ‘Assured‘ must be produced only from goods which are compliant with an assurance scheme. Records must be kept of the operations producing the screenings or cleanings in order to demonstrate traceability of the goods. [R]

21.7 HACCP must be applied to the production and composition of screenings or cleanings which are to enter the feed or food chain to identify any potential hazards. Screenings or cleanings that contain hazardous levels of materials must not enter the feed/food chain either by blending or directly and must be disposed via an approved disposal route. Records of such disposals must be kept. [R]

21.8 Seed plants, marketing seed processing by-products/screenings must ensure that the HACCP Risk Assessment considers controls to ensure that materials treated with Seed Dressings are not allowed to enter the food/feed chain. [R]

21.9 A sample must be taken of each load of screenings or cleanings at the time of loading when the screenings are to be supplied for feed/food use. Samples must be retained for a minimum of three months. [R]

22.0 Simple Processing Store keepers may apply simple processing operations to goods in store. In this context simple processing is defined as a physical change to the form of the goods, for example flaking, rolling, cutting or grinding/micronising without the adding of any other material including water. The application of heat or steam is not permitted as simple processing.

This can be for use on site or for sale/delivery to a third party.

Processing operations must only be carried out by trained operators. Training records must be kept to confirm the competency of the operators. [R]

Processing operations must be considered in the store HACCP plan. This should include a regular cleaning plan for any processing equipment. [R]

Records must be kept of all processing operations and movements of processed goods within the store.

23.0 Monitoring of Undesirable Substances

23.1 Salmonella Requirements for sampling and testing of goods for the presence of salmonella may vary from country to country and operators must comply with any national requirements. Operators in the EU must comply with the requirements of the EU Zoonoses Regulation (EC) No. 2160/2003. For goods stored in the UK the DEFRA Code of Practice for the Control of Salmonella during the Production, Storage and Transport of Compound Feeds, Premixtures, Feed Materials and Feed Additives applies. Where no national code of practice exists Appendix 4 of this manual applies.

23.2 Other undesirable substances In EU legislation undesirable substances are any substance or product, with the exception of pathogenic agents, which are present in product intended for animal feed which presents a potential danger to animal or human health or to the environment or could adversely affect livestock production. Reg 2002/32 EC applies.

A principal in a storage or handling contract may require that storekeepers undertake sampling and to submit for analysis samples for the testing for undesirable substances. [R]

A number of Feed Safety Assurance Schemes operating in the trade incorporate requirements for testing of contaminants. Where such testing is required a monitoring plan should be drawn up between the parties involved in the storage contract. Sampling and analysis is generally influenced by risk assessment and product data sheets are required. Risk assessment of commodities for storage and handling are likely to be affected by material and origin specific risks. The monitoring plan should include: a) The procedure for and the frequency of the sampling (see also Gafta No. 124 Sampling Rules) b) The Analysts which are chosen for the analyses in question. c) The frequency of analyses, checks and inspections. d) The instructions for carrying out inspections and checks. e) The personnel who are responsible for carrying out the monitoring activities. f) The personnel responsible for releasing the goods.


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23.3 Mycotoxins Where testing for the presence of mycotoxins is required a monitoring programme must be agreed between the parties. [R]

Results of analyses obtained from the monitoring programme must be made available to the storekeeper and to the owner of the goods.

24.0 Use of Pesticides and Fumigants

24.1 Where it is necessary to use pesticides or fumigants on stored goods, only chemicals approved for food or feed contact can be used and applied according to the manufacturer’s instructions. Storekeepers must notify and check that products proposed to be used are also approved by the owner of the goods.

24.2 Pesticide use must be recorded, and must be declared on documents accompanying the goods, e.g. the Post Harvest Declaration Form. [R]

24.3 Pesticides stored on site must take account of best practice guidance on storing pesticides in the country in which this Code is being applied.

See also the GTAS Fumigation and Pest Control manual.

25.0 Customer Requirements Within the trade there are a number of safety schemes for food and feed in operation. Requirements of food/feed safety schemes may vary in relation to specific conditions under which storage must take place. Storekeepers and handling facilities must ensure that they understand and comply with any specific requirements of the relevant food/feed safety scheme in which the goods are being stored. It is the responsibility of the principal in a contract for storage (the customer) to give precise instructions regarding any specific requirements that exist if these are not already covered by this Code of Practice. This may include introducing a sampling and analysis plan for the analysis of goods for the presence of undesirable substances (see 17.0). [R]

26.0 Acceptance of a Storage Order Storekeepers must have a documented procedure for accepting a storage order. The procedure must include details of the type of goods to be stored (data sheets etc), the IDTF number and any cleaning requirements. The order should also take into account any special requirements of the customer with regard to food and/or feed safety schemes into which the goods will be delivered or special buying terms that are relevant to the storage of the goods. [R]

27.0 Incoming goods

27.1 All delivery vehicles must be visually inspected on arrival for general cleanliness. Vehicles must be sheeted on arrival. Trailer identification numbers must be recorded. [R]

27.2 The previous three loads carried by the delivery vehicle must be checked against the IDTF database. Note: generic terms (including trade names) are not suitable for recording previous loads carried, the proper description of the goods should be used. Where a delivery vehicle has carried a material that is forbidden (or unlisted) under the IDTF, the load must be rejected and the owner of the goods notified by the storekeeper. Where the carriage of certain materials requires a specific cleaning regime, the storekeeper must check the cleaning records. Where cleaning records are not available for checking, the load must not be tipped until written clarification has been received by the storekeeper or owner of the goods and a risk assessment has been made. [R]

27.3 All deliveries must be accompanied by correctly completed and appropriate delivery documentation. Where such documentation lists treatment of the goods with pesticides these must be checked against the relevant approved list of pesticides (if applicable). The correct information regarding previous application of pesticides can only be provided by the supplier of the goods. Where applicable this may include details of mycotoxin scoring and RED status. Note: in the UK the appropriate document is known as the "Combinable Crops Passport" (Grain Passport). For deliveries of imported goods a delivery document is still required. Unless the imported goods can be demonstrated to have come from assured sources then the document should be marked “non-assured” goods. [R]

27.4 For ease of administration during harvesting periods where a volume of goods is moving in multiple phases from field direct to store by identified tractor/trailer it is acceptable for a single document (passport) to cover the total amount delivered per trailer per farm per day. Where this applies, each document should list the individual weighbridge ticket numbers and gross/tare weights for each delivery. If a break in deliveries occurs or the trailer is changed then a new document (passport) is required. [R]

27.5 The use of stickers on collection and delivery documents to denote the status of the goods is common practice as a time saving device. This method can be used to identify assured goods or RED certified goods (see RED manual).


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27.6 Only combinable crops grown under a recognised grower assurance scheme and clearly identified as such on the delivery documentation (often by the affixing of an assurance sticker), may be considered as being assured and stored and re-delivered accordingly.

27.7 For logistical reasons during harvesting periods some grower assurance schemes allow use of temporary storage facilities, normally for a maximum period of time. Goods being delivered from a temporary store must be identified on the delivery note usually by affixing a sticker denoting that the goods are Production Only status. Goods should not be accepted if they are outside the agreed time period. Note: UK Red Tractor Assured Crops have until 31st October to deliver goods under PO stickers. [R]

27.8 Where delivery vehicles are to be analysed they must be sampled and tested in accordance with agreed, written procedures and in accordance with instructions received from the owners of the goods. Goods sampled for salmonella testing must be sampled in accordance with the applicable Code of Practice for the Control of Salmonella (see Appendix 4). [R]

27.9 The storekeeper must clearly advise the driver of the delivery vehicle where to proceed to offload. Larger storage facilities with multiple sheds and/or silo bins should provide drivers with written confirmation of where to offload or other physical means of identification (eg tokens).

28.0 Outgoing goods

28.1 Vehicles arriving to collect goods must be sheeted on arrival and inspected before loading and a record kept confirming that they are in a clean and dry state, including the load carrying area and, where appropriate, blowing equipment. It should be checked that the trailer is correctly displaying identification marks on both sides and rear.

28.2 Where IDTF goods and materials have been carried and the trailer has not been cleaned in accordance with the IDTF requirements, the storekeeper must not load the vehicle until written clarification has been received by the storekeeper or owner of the goods and a risk assessment has been made. [R]

28.3 The previous three loads must be recorded and assessed for compatibility by a competent person. Generic terms like “biomass” should not be accepted. The description of goods should be as precise and detailed as necessary to accurately describe the goods. [R]

28.4 Should the lorry be deemed unfit for carrying the goods that cannot be remedied by simple brushing or sweeping, the storekeeper should immediately contact the holder of the delivery order. [R]

28.5 Exposed ends of blower/tanker hoses must be capped when not in use. [R]

28.6 Loaded vehicles must not be allowed to leave the site until covered with sound, clean and dry sheets. On vehicles carrying liquids, tank lids must be securely closed prior to leaving the site.

28.7 All deliveries and collections of goods must be accompanied by an appropriate collection or delivery note (UK - grain passport). Where a pesticide has been applied to the goods in store this must be declared on the collection note. Stickers applied to collection notes to identify goods that are “assured” may only be applied to combinable crops that can be demonstrated to have been grown under a recognised grower assurance scheme.

28.8 Storekeepers must have a written procedure for taking and retaining samples of loads delivered into and loaded out of store. Ideally representative samples should be retained of all loads received and loaded out of store by road. Goods delivered to store direct from ship or being loaded direct to ship do not require samples to be retained as the goods will be independently sampled and tested by the cargo superintendent.

If due to large volumes of goods being handled it is practically impossible to retain samples from every load out of store by road it may be satisfactory to aggregate samples by bin or other identifiable store separation. The minimum requirement in such circumstances should be an aggregate bulk sample per commodity per bay per day. [R]

28.9 The storekeeper must issue clear instructions to the loader which store/silo/bay the goods to be loaded are to come from. Larger storage facilities with multiple sheds and/or silo bins should provide drivers with written confirmation of where to load or other physical means of identification (eg tokens).

28.10 Representative samples of load(s) entering and leaving premises by road must be retained for a minimum period of 3 months. Samples of loads taken at the point of intake/delivery must be bulked in accordance with the requirements for Salmonella testing as set out in the appropriate Code of Practice for the Control of Salmonella. [R]

28.11 A recordable system for the traceability of all loads delivered and collected must be in place within the store. This must take into account the assurance status of the goods. [R]


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29.0 Personnel

29.1 Personnel must be made aware of the importance of this document, all relevant regulations and the relevant Code of Practice for the Control of Salmonella.

29.2 Proper toilet and washing facilities must be near to their workplaces, and must be kept clean.

29.3 Eating and drinking should only be permitted in designated areas.

29.4 Storage facilities should be designated as "No Smoking" areas. Operators may designate a smoking area that is within the storage site but outside the area where goods are actually stored.

29.5 No person known to be suffering from a communicable enteric disease should be employed in the handling of goods. “Return to Work” forms should be completed for any staff returning to work after being absent through illness or travel abroad under the communicable enteric disease section.

29.6 Operators and contractors using pesticides applied in any manner must be aware of the appropriate national regulations for the Control of Pesticides Regulations and if required have the necessary Certificate of Competence. [R]

29.7 Operators’ non-disposable clothing must be contract cleaned or laundered regularly for the control of Salmonella. For the purposes of this clause “regularly” is not precisely defined since cleaning should take into account the conditions of usage of the non-disposable clothing. More frequent cleaning will be required for clothing exposed to very dirty conditions. [R]

29.8 Personnel must be trained in the relevant standards of safety and hygiene. [R]

29.9 Visitors and contractors must be informed of the hygiene requirements of the site and sign an appropriate form. [R]

29.10 All non-essential personnel to store operations or store maintenance, or not directly involved in collection or delivery of goods or materials, should be excluded from the store.

30.0 Training The successful operation of this Code of Practice cannot be achieved without training of personnel. This covers all permanent and temporary staff involved at the site. Storage operators should identify the training needs and ensure that the appropriate training is provided. Such training should include as a minimum: • a full understanding of the purpose and detailed requirements of this Code of Practice • any in-house procedures for the implementation of this Code of Practice • basic awareness of food safety and hygiene disciplines • personal hygiene • Code of Practice for the Control of Salmonella

30.1 Training must take place regularly (normally on an annual basis), be kept up-to-date and documented. Training records should be signed by the trainer and trainee together with the date of the training. [R]

30.2 Training may be carried out on an in-house basis.

30.3 Training must be included in the store HACCP plan.

31.0 Security

31.1 The storekeeper must be able to demonstrate the safety and security of the goods in his care.

31.2 The storekeeper must ensure that the appropriate release is given and collection documents provided before the goods are released. [R]

32.0 Procedures and Instructions

32.1 A designated person must have authority and responsibility for the implementation of the requirements of this Code of Practice.

32.2 The designated person must ensure that all staff covered by the scope of the Code of Practice are provided with written instructions that confirm their duties and the procedures. [R]

32.3 The designated person shall keep an organisational chart listing all staff employed, their positions and their functions within the store operation.

33.0 Self-Assessment Procedures

33.1 Storekeepers must have a documented procedure for self-assessment. [R]


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33.2 The procedure must require the storekeeper to carry out a programme of planned self-assessments to check that internal systems are operating as intended and are also effective. Such self-assessments must encompass: • Compliance with the requirements of this Code of Practice • Compliance with the requirements of the storekeeper’s HACCP system • Compliance with the storekeeper’s formal procedures • Compliance with applicable legislation pertaining to Feed and Food safety and quality • Satisfaction of specified customer requirements • Recording of non-conformances and steps taken to prevent re-occurrence. • A documented procedure for controls, associated responsibilities and competences for dealing with non-conformances. • A written procedure to notify the scheme auditors before introducing a new store into the scheme to enable suitable auditing and acceptance before being used for storage.

33.3 The programme of self-assessments must ensure that all relevant activities are audited at least once a year.

33.4 All personnel carrying out self-assessments must be experienced, and be able to demonstrate their effectiveness in the role.

33.5 Self assessments must be formally reported to those with responsibility for the area audited and record any aspects where the operations are not in compliance with operational requirements. Such areas of non- compliance must be corrected within an agreed timescale and the report records updated by an authorised person to indicate that problems have been corrected satisfactorily.

Once the self assessment has been completed the HACCP plan should be reviewed and any non-conformances raised during the self assessment addressed (if required) by producing an updated or revised HACCP plan. [R]

34.0 Material Recall and Crisis Management

34.1 In the event of a problem occurring which may threaten the safety and security of the goods delivered from store, and/or the safety of the feed chain and/or may present a threat to human health, storekeepers must have adequate records to enable them to identify all goods potentially at risk and provide the owner with sufficient information to notify all those customers who may consequently be affected. [R]

34.2 The responsibilities and mechanisms for issuing warnings or recalls of goods must be clearly defined and the required traceability tested at least annually for adequacy. Records of such tests must be kept and any corrective actions that arise must be implemented and recorded. [R]

34.3 Goods that have been rejected, recalled or returned should be placed in separate and adequately segregated storage to prevent cross contamination of other goods in store. [R]

34.4 Traceability must be tested at least once a year and any corrective actions raised must be implemented and recorded. This should be a part of the self assessment protocol. [R]

Once the self assessment has been completed the HACCP plan should be reviewed and any non-conformances raised during the traceability test addressed (if required) by producing an updated or revised HACCP plan. [R]

35.0 Complaints Procedure The storekeeper must document the procedure for handling complaints. [R] This procedure must include systems for: • The prompt documentation and investigation of complaints • The prompt feedback to the Company with findings • Deciding on the internal actions required to prevent re-occurrence.

36.0 Arbitration In the event of a problem, and in the absence of an arbitration agreement, recourse for settlement of claims will be to the appropriate Court. Alternatively, the parties in dispute may agree to arbitration in accordance with the Gafta Simple Dispute Rules Form 126 (available as a separate document).


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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.

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.

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.

A P P E N D I X 2

Introduction to HACCP -Hazard Analysis And Critical Control Point System




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.

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

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.

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, underside of the cover sheet and any other surface that may come intocontact with the goods 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 aim of the monitoring is to check on the environmental hygiene of the premises, equipment, incoming and outgoing productsand, if necessary, take corrective action.

The buildings, environment, plant and equipment, as well as incoming and outgoing product, must be subject to appropriatemonitoring. Sampling schedules should take account of: 1. Intended use; 2. Inherent bacteriological risks; 3. Nature and sources; and 4. Past results

Please refer to the Salmonella code for full details, the following is a suggested appropriate sampling regime.

1. Storekeepers must arrange for samples to be taken from goods and analysed, where this is not done by the owner of the goods, as follows:a. Incoming goods. The frequency of sampling should be based on high, medium and low risk- composite samples are acceptable by product type. Data may already be available from the supplier or owner of the goods. For high risk products every load should be sampled. From a historical analysis of Defra data, isolations (weighted by tonnage) have been most frequent in rape, fishmeal, cocoa and soya beans and their derivatives.

b. Outgoing goods. Manufactured products by product or process type-composite samples are acceptable, frequency based on high, medium and low risk also taking into account the processing carried out.

c. Samples must be drawn into a new clean bag using the “reverse bag” sampling method as a minimum. A minimum sample size of 60g is required but the exact requirement should be agreed with the testing laboratory.

2. Storekeepers must arrange for the following samples to be taken and analysed as follows:a. Buildings. Samples from ledges, walls, floors, storage bin tops and outloading areas and where health and safety rules allow- samples from dust units, vacuum cleaners and the inside of storage bins may be included. Samples of dust can be taken direct into a “reverse bag” or sterile pot or, if quantities are too small, by using swabs. Dust samples are normally much more effective than swab samples and are therefore preferred. The sampling points must be determined using HACCP risk assessment principles. Samples from common equipment areas such as vacuum cleaners and dust units are useful to determine the overall salmonella risk in the storage area.

b. The best method of sampling is to take approximately 20g bulked samples comprising dust from at least ten places around the building. These can be taken into an inverted polythene bag or with new disposable plastic gloves. Where dust levels are insufficient for 20g then a greater number of sampling places may be used. The use of a brush is not recommended to help collect samples unless it can be washed in a sterilising solution and fully dried; a plastic scraper washed in a sterilising solution and dried may help in the sample collection.

c. If swab samples are utilised they must be taken with sterile swabs according to the supplier’s instructions. Swabbing normally consists of wiping of the swab (after removal from its transportation tube) over as large and representative an area as practicable until the swab is well coated with dust, or accumulated aggregate within equipment.

Disposable wooden scrapers or plastic spoons can also be used to sample adherent material. The sample is returned to the tube and labelled with details of the sample area and date of sampling.

d. Frequency of sampling should be based on risk assessment. For a high risk product weekly testing is recommended. If the risk status of the product cannot be determined it should at least initially be considered as high risk.

e. Plant and equipment. Loading equipment, elevators, conveyors, dust filters, intake and loading areas in stores - either dust or swab samples. Frequency of sampling based on risk assessment - weekly suggested when materials are of unknown or high risk.

f. Vehicles. Buckets and vehicle bodies of loading shovels – dust or swab samples.

3. Analysis a. Samples must be tested in accordance with approved methods laid down in The Animal By-Products Regulations 2005 (SI No 2005/2347) at a Defra listed laboratory that is approved under those regulations or to ISO 17025 standards.

4. Action to be taken following isolation a. The following should be advised of isolations of Salmonella: i. Defra and, where appropriate, the relevant devolved administrations (the Zoonoses Order 1989 requires laboratories to report all isolations of Salmonella from animal/poultry feedstuffs and ingredients to Defra). ii. If incoming goods are found to be positive then the storekeeper must immediately discuss remedial action with the owner of the goods.

b. Where there is contamination with a regulated serovar*, or where the same serovar is regularly detected over time, then detailed investigation to identify the source or to ensure there is no ongoing contamination is recommended. If there is persistent contamination samples should be taken and tested after any remedial action.

c. Increasing the level of testing of the product should be considered.

d. Further actions are detailed in the Defra Code of Practice for the Control of Salmonella and will depend on the circumstances of isolation.

* Regulated serovars are those of major public health significance. Currently these are S. Enterditis, S. Typhimurium, S. Infantis, S. Virchow and S. Hadar.

A P P E N D I X 4

Salmonella Sampling and Testing Procedure(UK DEFRA October 2009 version)

multimedia.food.gov.uk/multimedia/pdfs/committee/copsal.pdf


Certification for compliance to the EU Renewable Energy Directive (RED) for feedstocks certified under voluntary farmassurance schemes approved by the EU as RED compliant.

A. Introduction The EU Renewable Energy Directive 2009/28/EC came into effect on 5th December 2010. This legislation introduced targets for renewable energy in EU member states and enables the supply of feedstocks for biofuels and bioliquids. The legislation applies to all goods intended to be classified as “sustainable”, for use as biofuel and bioliquid in the EU which are intended to count towards national renewable energy targets.

Guidance: It is not prohibited to produce or sell unsustainable biofuels in the EU (ie not counting towards renewable targets and support) and RED does not apply for goods intended for other purposes.

B. Scope In order to supply the biofuels markets, European legislation requires independent verification of compliance with various sustainability criteria. This manual provides a set of minimum standards of best practice for companies and individuals operating as Traders or Merchants, who trade and handle goods [including imports and exports] intended for use as biofuels or bioliquids and for which demonstration of compliance with the requirements of the EU Renewable Energy Directive is a requirement. The standards apply to goods moving from farm gate to the first gathering point (store/silo/mill), subsequent gathering points (inc points of import/export) and to first processor.

The Gafta Trade Assurance Scheme applies to operators in the supply chain. It covers the trading, handling and transportation of goods. It enables the trading of all types of combinable crops and animal feed materials for food and feed purposes and for use as biofuels or bioliquids. GTAS therefore applies to RED compliant and non RED compliant goods, also assured and non-assured goods, organic and non-organic etc. RED compliance is demonstrated by clearly annotated documentation accompanying goods in transit and by cross checking compliance status with on-line databases. Where RED goods are involved the requirement to operate a RED compliant mass balance system applies. The chain of custody must be kept separate and the HACCP systems audited accordingly. Where applicable RED compliant goods may be separately stored.

Traders who procure and deliver goods for biofuels or bioliquids must be able to provide evidence that the requirements of RED are being met, by production of a proof of sustainability, certificate or equivalent issued under an EU approved certification scheme, for each consignment of goods supplied.

For the purposes of EU RED legislation, GTAS is classified as a “voluntary scheme” that covers some of the sustainability criteria of the Directive. The auditing and certification of companies under an EU recognised voluntary scheme fulfils the criteria for evidencing sustainability as set out in Directive 2009/28/EC.

This Appendix is intended to be applied internationally in countries where goods are grown and certified under a European Community recognised farm assurance scheme.

Operators that are RED certified are identified on the GTAS on-line database checker. Database references are operator and site specific, if multi site operations apply. The on-line database is updated daily and the onus rests with parties to check regularly the status of the parties. Goods should not be unloaded at a store or at end user premises without first checking the status of the transport company and chain of custody online.

The Gafta Trade Assurance Scheme recognises other voluntary schemes that have been approved as being RED compliant by the European Commission and which recognise the full range of land criteria as set out in the Directive (Art. 17 (3) – (5). The list of approved voluntary schemes can be viewed on the EC website using the following link: http://ec.europa.eu/energy/renewables/biofuels/sustainability_schemes_en.htm

Note: GTAS recognises those schemes that fully comply with the land criteria (without exceptions) to Art. 17 (3) – (5) of the Directive and these can be found listed in the “Overview table including information on updates of recognised voluntary schemes”. A list of schemes is available on the Gafta website.

1.0 Contracts with growers. Growers must provide evidence that crops have been produced on land that meets the new sustainability criteria. This is designed to protect land that is classified as being highly bio diverse, and/or has high carbon stock and the protection of other sensitive land environments like undrained peat land.

Evidence provided by growers must be verified (audited) before confirmation can be made available that the sustainability criteria have been met by individual producers on the crops supplied into the biofuel and bioliquids chain. Independent verification for growers can be achieved (inter alia) as part of the certification of Assured Crops/Farm Assurance schemes that have been approved by the EU as meeting RED requirements. The normal method by which third parties can check the certification of growers that are members of Assurance Schemes is via an online database facility. Where RED


A P P E N D I X 5

EU Renewable Energy Directive



compliance is certified this must be separately annotated for the avoidance of doubt. Growers may be fully or partially compliant or not compliant/not participating in supply of feedstocks for biofuels. Partially compliant growers must keep their own records and be able to demonstrate that the quantity of feedstocks supplied do not exceed the verified percentage of partial compliance.

1.1 Goods intended for use as biofuels, biomass or bio liquids for the production of renewable energy in Europe must comply with the main principles set down in RED. The three main principles may be summarised as:

1st principle: the goods must not have been produced on land that has a high biodiversity value or from land with a high carbon stock. Crops must have been produced on land that meet the sustainability criteria of the Directive as laid out in Art. 17 (3) – (5).

In accordance with Art. 17 (3) this is land with a high biodiversity value, namely land that had one of the statuses (as follows) in or after January 2008, whether or not the land continues to have that status: a) primary forest and other wooded land, namely forest and other wooded land of native species, where there is no clearly visible indication of human activity and the ecological processes are not significantly disturbed; b) areas designated: (i) By law or by the relevant competent authority for nature protection purposes; or (ii) For the protection of rare, threatened or endangered ecosystems or species recognized by international agreements or included in lists drawn up by intergovernmental organizations or the International Union for the Conservation of Nature, subject to their recognition in accordance with the second sub paragraph of Art. 18(4). unless evidence is provided that the production of the raw material did not interfere with those nature protection purposes; c) highly biodiverse grassland that is; (i) Natural, namely grassland that would remain grassland in the absence of human intervention and which maintains the natural species composition and ecological characteristics and processes; or (ii) Non-natural, namely grassland that would cease to be grassland in the absence of human intervention and which is species-rich and not degraded, unless evidence is provided that the harvesting of the raw material is necessary to preserve its grassland status.

In accordance with Art. 17 (4) this is land with high carbon stock, namely land that had one of the following statuses in January 2008 and no longer has that status: a) wetlands, namely land that is covered with or saturated by water permanently or for a significant part of the year; b) continuously forested areas, namely land spanning more than one hectare with trees higher than five metres and a canopy cover of more than 30%, or trees able to reach those thresholds in situ; c) land spanning more than one hectare with trees higher than five metres and a canopy cover of between 10% and 30%, or trees able to reach those thresholds in situ, unless evidence is provided that the carbon stock of the area before and after conversion is such that, when methodology laid down in part C of Annex V is applied, the conditions laid down in paragraph 2 of this Article would be fulfilled.

Note: the provisions of Art. 17 (4) do not apply if, at the time the raw material was obtained, the land had the same status as it had in January 2008.

In accordance with Art. 17 (5) this is land that was peatland in January 2008, unless evidence is provided that the cultivation and harvesting of the raw material does not involve drainage of previously undrained soil.

2nd principle: the goods were produced in compliance with all applicable national and regional laws and international treaties

3rd principle: that good management practices were applied

1.2 Only feedstocks certified as being RED compliant under an EU recognised voluntary farm scheme are permitted. Self declaration is not allowed.

2.0 Mass Balancing.

2.1 The directive enables all economic operators in the chain of custody of biofuels and bioliquids to apply a mass balance (MB) system. This allows consignments of raw materials or biofuels/bioliquids with different sustainability characteristics to be mixed on a “site basis” (this is defined as one geographical location with precise boundaries which can include a farm store, commercial/merchant storage site, co-operative site, flat store bays, silo bins or vessel). Sustainability characteristics could include: evidence showing compliance with RED sustainability criteria or a statement that the raw materials used were obtained in a way that complies with RED’s land related sustainability criteria or the statement “production has been awarded a certificate of type X from a recognised voluntary scheme Y” etc. Sustainability characteristics should always include information about country of origin.

2.2 Where mixing takes place, it requires that information about the sustainability characteristics and size of consignments remain assigned to the mixed bulk and provides for the sum of all consignments withdrawn from the mixed bulk to be described as having the same sustainability characteristics, in the same quantities, as the sum of all consignments added to the mixture. Records must be kept of the mass balance of materials being delivered into and out of stores. In order to be considered RED compliant, Storekeepers must be audited for correct application of mass balance accounting. This includes the demonstration that the MB calculation has been correctly applied (balanced) over a designated or justifiable time period.



2.3 For traders, merchants and commercial storage and handling facilities in the first year of operation Mass Balancing shall not exceed a twelve month period (a marketing or crop year). Thereafter the mass balancing period(s) shall not exceed three months.

2.4 Under the mass balancing system the averaging of GHG values is not permitted. If consignments are aggregated administratively the worst GHG performance shall be taken for the whole consignment. Disaggregated values can be declared.

2.5 Traders and merchants who supply raw materials to buyers to be used for biofuels and bioliquids must be able to demonstrate that where mass balancing was applied to the goods delivered, that the facility has been certified as competent in mass balance accounting. This can be done by referring to the stores sustainability certification using the appropriate scheme on-line database. Traders and Merchants must be able to supply records to confirm the mass balance of the materials delivered into and out of each store/gathering point in the chain of custody.

2.6 Where a merchant/trader owns and operates a “dependant” storage facility the mass balance shall be determined by the owner/operator for which certification as being RED compliant is required.

2.7 3rd party commercial storage and handling facilities intending to operate mass balancing operations are required to be certified as being RED compliant for this purpose.

2.8 Segregation and Mass Balance options

2.8.1 Complete physical separation. Where individual batches of sustainable and unsustainable goods are physically handled, stored and re-delivered separately and there is no mixing of sustainable goods with differing GHG values, then each batch is deemed to keep its ID and individual values and MB does not apply; in other words Identity Preservation (hard IP).

2.8.2 Physical separation of sustainable and unsustainable goods; common bulks of goods with same GHG value; no mixing of lots of differing GHG value. Not strictly mass balance, normal record keeping should suffice.

2.8.3 No physical separation of sustainable/unsustainable goods. Mass Balance methodology allows the mixing of sustainable (with or without differing GHG values) and unsustainable goods in a common bulk. Where this occurs a MB account must be kept. The MB accounting must specify the time period to which it applies.

2.8.4 Economic operators are not permitted to operate a single mass balance approach over more than one geographical location.

Guidance: where mass balancing is done by audited and certified companies (and verified on a scheme online database such as the GTAS web checker) it is probable that evidence of the actual calculation will not be required by the chain of custody, only the outcomes. Storekeepers and others who do this however must be in a position to provide this nformation to bona fide companies if requested. This is more likely to form part of a contractual agreement than an ad hoc request.

3.0 Responsibility for Compliance under RED. RED places the responsibility for compliance on the economic operator that benefits from support or is under a blending obligation. Without the proper evidence in the chain the Member State may not give support or allow goods to count towards quotas. Technically the compliance attaches to the feed stocks themselves, which is evidenced by accompanying certification and this information must be carried up the chain of custody to the end processor/user.

4.0 Assessment requirements

4.1 Applicants are required to pass an initial audit before being allowed to participate in the scheme.

4.2 After the initial audit, routine surveillance audits are carried out annually at any time during the year.

4.3 Applicants must have an auditable system for the evidence related to the claims they make or rely on.

4.4 All documentary evidence must be kept for a minimum period of 5 years.

4.5 Applicants must accept responsibility for preparing any information related to the auditing of evidence related to the claims they make or rely on.

4.6 Unless otherwise agreed, the auditable system shall be a quality system covering (inter alia) information flows, documents and control systems.

4.7 Scheme verifiers are required to undertake at least annual retrospective audits of a sample of claims made by individual economic operators under the scheme. The economic operators in the sample will vary from one period to another. The scheme verifiers will establish the size of sample required to reach the necessary level of confidence for issuing certificates.



4.8 Mass balance – operators in a chain of custody must be able to demonstrate where any intermediate mass balancing operations have taken place for which they are responsible. Verification of MB systems must be performed simultaneously with verification of correctness of the scheme criteria (ie examination of systems used for the purpose of complying with the requirements of MB system).

5.0 Greenhouse Gas Emissions.

5.1 Calculation of the greenhouse gas (GHG) impact of bio fuels and bio liquids (GHG balance). The basis of RED is the assumption that energy produced from biofuels and bioliquids represents a GHG saving over other types of fuel (eg fossil fuels). GHG savings will be reduced in the case of inefficient production of biofuels/bioliquids and therefore RED requires evidence of the actual savings. This is a complex calculation when taken through the entire supply chain and therefore Art 19 of RED sets out the principle of “Typical” “Default” and “Disaggregated Default” values for biofuels and bioliquids (if produced with no net carbon emissions from land use change).

5.1.1 Annex V of RED is a table of rules and values for the calculation of GHG impact.

5.1.2 Where GHG default values are used and accompanying load documentation identifies the address of the grower and/or assurance scheme membership number and/or NUTS2 region code, this is deemed sufficient evidence to identify the origin for the purposes of final declaration of default value. Therefore under these circumstances it is not a requirement to declare GHG values on the documents accompanying the goods. Likewise there is no requirement for GHG default values to be notified from seller to buyer even if the origin of the goods is identified as only the final economic operator can do this once the bio fuel has been produced.

5.1.3 GHG values can be advised by sellers to buyers as part of the usual contractual documents exchanged in the normal manner. This includes contract notes and confirmations, delivery notes, invoices and other types of document. It is not envisaged that a separate or new document is required for this purpose.

5.1.4 The averaging of GHG values is not permitted. If consignments are aggregated administratively the worst GHG performance should be taken for the whole consignment. In other words aggregating GHG values may not be used to raise the level of non compliant GHG values to levels of compliance. Disaggregated GHG values can be declared.

5.2 Default GHG Values Economic operators are able to use default GHG values set by the EU instead of actual values for calculating GHG impacts, to reduce the administrative burden of calculating actual values. The predetermined default values are not location specific. Default values are set by feedstock, but for EU biofuels/bioliquids the default values can only be used if the feedstock was cultivated in a NUTS2 region where the typical GHG emissions from cultivation of agricultural raw materials can be expected to be lower than or equal to the emissions reported under the heading “Disaggregated default values for cultivation” in Part D of Annex V of RED. Default values are subject to updating depending on scientific and technical advances every two years starting in 2010.

5.3 Imported feedstocks Documents going forward in the chain of custody should contain the statement “For GHG declaration purposes these feedstocks have been imported from a third country and were landed in (place of discharging in the EU)”.

Guidance: the regional default values for GHG emissions at NUTS2 level (basic regions for the application of regional policies) are available for EU member states following this link: http://ec.europa.eu/energy/renewables/transparency_platform/emissions_en.htm Information regarding NUTS nomenclature is available following this link: http://epp.eurostat.ec.europa.eu/portal/page/portal/nuts_nomenclature/introduction Please note: some NUTS2 regional GHG values are not compliant with Annex V RED minimum GHG requirements.

6.0 Mandatory documents

6.1 The provision of documents in the chain of custody establishes the required traceability and verification regarding the feed stocks going forward through the chain. This is generally referred to as the “Statement of Conformity” or “Sustainability Declaration”. This must relate to an identifiable consignment (or lot) of goods.

6.2 There are two types of document chain in operation, those that identify and travel with the goods on a load by load basis and those passing from seller to buyer on a contract by contract basis.

6.3 Documents travelling with the goods are issued initially by the grower and thereafter from store to store or end user/export facility, and are well established. They are issued on a load by load basis. Delivery documentation must include a RED declaration. For example: “this load (consignment) has been grown on land which meets the requirements of the Renewable Energy Directive sustainability criteria”. Growers certified under an assurance scheme must clearly show their scheme ID or identifying mark/sticker on the delivery documentation.

6.4 Normal documents passing from sellers to buyers include copies of delivery notes and invoices on a contract by contract basis. Such documents shall contain a statement declaring they are considered to be of a sustainable nature, for example: “these goods are certified as sustainable in accordance with Directive 2009/28/EC.”



6.5 For ease of administration, parties to a contract may agree that the GHG default values (not actual values - even if available) will be used. This is acceptable practice under the Directive.

6.6 Documents relating to the goods may be used to pass on information that is relevant to the GHG calculation including the geographic area the goods came from. Additionally and if provided by the EU recognised farm assurance scheme, all information about the annualised emissions from carbon stock changes caused by land use change must be passed on in the chain of custody.

6.7 The information required by economic operators from the place of first gathering (storage facility) on a load by load basis may be summarised as:

Name and address coordinates of grower Name of first gathering point Unique ID/Ref number for consignment (eg weighbridge ticket) RED scheme ID/mark/sticker Contract number/purchaser of goods from grower Description of goods intended for biofuel/bioliquid Date of delivery to gathering point Tonnage delivered GHG value declared (state actual or default) - see 6.6 above. Mode and ID (vehicle registration number etc) of transport

6.8 The information to be stated on the documents passed from seller to buyer (Sustainability Declaration) going forward must include:

Name and address coordinates of customer Name of first gathering point Unique ID/Ref number for consignment (eg weighbridge ticket) Contract number and customer (buyer) Description of goods intended for biofuel/bioliquid Date of outloading from gathering point Tonnage outloaded GHG value per MB calculation (state actual or default) – see 6.6 above Mode and ID of transport (as above)

7.0 Records Records of all relevant documents must be retained for a minimum period of 5 years as required by the EU legislation.

8.0 Simplified step procedure The following step procedure will apply where an EU recognised RED compliant scheme is in operation and the grower is a member of a recognised voluntary farm Assurance Scheme approved by the EU as being RED compliant.

8.1 Grower is certified as RED compliant under his farm assurance scheme. This is recorded on scheme database for verification use by 3rd parties.

8.2 Grower makes general RED compliance self declaration to country Trader/Merchant (the first gatherer). This is likely to be a requirement that precedes a contract for the purchase of goods.

8.3 Country Merchant/Trader is audited annually and certified for RED compliance (eg GTAS, ISCC etc). Certified operators are recorded on the relevant scheme database for verification by 3rd parties. The office audit of operators will include a percentage of “dependant” (ie owned/exclusively operated) silos/elevators/warehouses where these are not certified as RED compliant in their own right. Group auditing may be possible for multi site operators that follow a common quality management system. GTAS participants can only accept evidence of compliance with an EU recognised voluntary scheme and this applies only to those schemes recognised by the EU for all land-related criteria and only the version and scope of a scheme that is recognised by the EU. The country merchant/trader holds contracts with growers. Receives and files self declarations from growers. Country merchant/traders who operate dependant stores keep records of any mass balancing operations they undertake.

8.4 Storekeeper/handling facilities are audited for RED compliance if mass balancing is to be applied. This is recorded on the scheme online database for verification use by 3rd parties. Storage and handling facilities that are RED compliant are issued with a GTAS RED scheme ID and/or identifying number/mark or sticker.

8.5 Transport of goods is arranged using transport companies certified under GTAS or other recognised assurance scheme. This is recorded on the scheme database for verification by 3rd parties.

8.6 For each load/consignment of goods leaving the grower’s premises a loading document is provided to accompany the load, including a statement that “this load (consignment) has been grown on land which meets the requirements of the Renewable Energy Directive sustainability criteria”. Farm Assurance Scheme identification number/mark or sticker is applied to document. Loading document should clearly state the grower’s location/Assurance scheme ID.

8.7 For each load arriving at a storage/handling facility (gathering point) the Storekeeper receives goods accompanied by the



loading document quoting the RED statement. Storekeeper cross checks certification status of grower by using the scheme database. Once this is confirmed the goods are stored in accordance with requirements. Goods may be stored separately or in a common bulk.

8.8 Where goods for biomass are co-mingled the storekeeper is required to follow mass balancing accounting principles. Mass Balance calculations are recorded.

8.9 Where goods are transported from 1st gathering point to 2nd gathering point/ bio-mill/converter facility or export facility the storekeeper must complete the load documentation to accompany the goods including the RED declaration as provided by the grower. GTAS RED identification numbers/marks or stickers will be applied to the delivery document.

8.10 1st processor/bio-mill/converter facility receives goods for energy production from a gathering point. Intake operator must cross check that the storage facility is RED certified by checking the relevant scheme on-line database.

8.11 Storekeepers/handling facilities with RED certification that are operating mass balancing must keep detailed records of goods received and out loaded for the various MB calculations on a maximum balancing period of three months. If a bona fide request is received, storekeepers will make their MB calculations available.

8.12 Sellers provide buyers in the chain of custody - on a contract by contract basis - with a “Sustainability Declaration” eg “these goods are certified as sustainable in accordance with Directive 2009/28/EC.” in respect of all loads delivered. Where mass balancing has occurred sellers must advise buyers of the GHG Default values after receipt of this information from the relevant stores.

8.13 Storekeepers and trader/merchants are audited for compliance with RED annually (see GTAS Storage and Trading Codes)



A P P E N D I X 6

International Database for Transport of Feed (IDTF)

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



1. Newcastle Disease (‘Fowl Pest’), Avian Influenza, Avian Tuberculosis and other diseases may all be carried by wild, domestic and feral birds. In addition, birds can be carriers of Salmonella and other pathogens harmful to both livestock and humans. It is therefore crucial to take all reasonable precautions to exclude birds from areas where goods are produced, handled, stored or consumed.

1.1 The presence of any species of bird in the vicinity of goods must be considered potentially hazardous in risk assessment studies.

1.2 Birds may be attracted to areas for three main reasons: availability of food; availability of shelter and roosting sites; availability of nesting sites. Wherever possible birds must be denied these.

1.3 Making a site unattractive to birds is likely to be more effective in the long-term than trying to control birds already active on the site.

1.4 Wherever possible, birds should be deterred rather than destroyed. Destruction of any bird species must always be a last resort and is not acceptable for any protected species. Where shooting is necessary as a last resort, lead-free ammunition must be used.

1.5 Where netting is used to deter birds, wire netting is preferable to string netting, as it is less likely to tangle birds.

2. Circumstances will vary with individual situations, but in general terms the following guidelines will be applied by assurance schemes:

2.1 The presence of birds, or evidence of nesting or roosting sites in process and storage buildings is not acceptable.

2.2 Where birds are a problem, active programmes must be in place to reduce access to food and shelter.

2.3 Doors must be kept closed whenever possible. It is recognised by the industry that operators of flat stores may need to keep doors open for extended periods. Should birds enter stores at these times, they must not be allowed to settle and must be removed as promptly as possible.

2.4 Where necessary, the eaves of buildings must be proofed against bird access.

2.5 Windows that are habitually left open must be screened or caged to prevent access by birds.

2.6 Spillages of goods must be promptly removed to avoid attracting birds.

2.7 Containers utilised to hold edible waste, such as skips and bins, must be covered to prevent access to birds.

2.8 Any birds gaining access to buildings must not be allowed to settle and must be removed as promptly as possible. Access points must be discovered and effective remedial action taken.

2.9 Intakes and loading points must be enclosed or covered when not in use.

A P P E N D I X 7

Guidance Note for the Control of Birds

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