version 6.0 trading and merchanting · trading and merchanting 6.0 hazard analysis and critical...

TRADING AND MERCHANTINGVERSION 6.0

Code of Practice forTrading and Merchanting

Effective from: 1st April 2015

GTAS Trading and Merchanting Manual.Published by Gafta: GTAS © Version 6.0

effective from 1st April 2015

TRADING AND MERCHANTING

2 Introduction2 Definitions and Scope2 Trading Operations3 Food and Feed Premises Registration Regulations3 Registration of Operators under EU TSE Regulations3 HACCP4 EU Renewable Energy Directive4 International Database for Transport of Feed 4 Assured Goods4 GM Goods4 Organic Goods5 Transport by Road5 Combinable Crops Passports5 Transport by Sea, Waterway, Rail and in Containers6 Sampling6 Monitoring of undesirable substances7 Loading and/or Discharging of Goods7 Weighing7 Insurance8 Arbitration8 Records8 Procedures and Instructions8 Suppliers, Service Companies and third party Contractors9 Complaints Procedure9 Personnel and Training9 Recall and Withdrawal9 Gafta Dispute Resolution Rules

11 Appendix 1: General definitions13 Appendix 2: Introduction to HACCP20 Appendix 3: Cleaning Methods21 Appendix 4: Salmonella Sampling and Testing Procedure23 Appendix 5: Code of Practice for Brokers24 Appendix 6: EU Renewable Energy Directive Manual30 Appendix 7: International Database for Transport of Feed (IDTF)


CONTENTS

GAFTA TRADE ASSURANCE SCHEME 1

1.0 Introduction Traders and Merchants (the company) buy and sell goods intended for food and feed and are the drivers of the industry. They are required to perform to the highest standards in the trading and handling of goods that include imports and exports.

Traders and/or Merchants use suppliers of third party services that must meet the high levels of good practice that are required by the trade.

2.0 Definitions and Scope This manual provides a set of minimum standards of best practice for companies and individuals operating as Traders or Merchants, who trade and/or handle goods including imports and exports intended for use as food or feed.

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 21.0. 3.0 Trading Operations

3.1 The Contract A contract or confirmation of business document must be raised on all transactions. [R]

The contract or confirmation should address at least the following key contract terms: • The Parties to the Contract • Brokerage (if applicable) • Description of the Goods traded • Quantity: including margins ("tolerances") • Quality: place and means of ascertainment and allowances, if any • Weight: place and method of measurement • Shipment/Delivery Position • Price • Payment Terms • Parity: i.e. FOB/CIF/CIFFO • Applicable Gafta or Other Standard Trade Contract Form

3.2 The Parties to the Contract The parties to the contract (the ‘Principals’) are the sellers and buyers. The full and correct title of each party and their business address must be clearly identified.

3.3 Brokerage The parties are free to engage brokers and agree who shall be responsible for the amount and payment of their commission. See Appendix 5 for the Code of Practice for Brokers operating in the trade.

3.4 Description of Goods The goods should be accurately described.

3.5 Quantity The contractual quantity must be clearly identified in the contract terms.

Any agreed tolerance and which party has the option of using the tolerance, should be clearly identified.

3.6 Quality Traders and Merchants who handle goods must have in place a ‘Quality Manual’ outlining company policies and procedures relating to product and food safety. [R]

Traders and Merchants must set out in their contract confirmations precise quality specifications, including any acceptable allowances. [R]

The sampling of goods for contractual analysis purposes under this Code of Practice must be undertaken by Superintendents who are registered as Gafta Approved Superintendents.

The assessment of the quality of goods supplied under this Code of Practice for Gafta contractual purposes must be established by using Analysts who are registered as Gafta Approved Analysts.

GAFTA TRADE ASSURANCE SCHEME2


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The assessment of the quality of goods supplied under this Code of Practice for any other purpose must be established by using a testing facility which is GTAS Assured or equivalent and/or has accreditation for the services provided. [R]

A record must be kept of all rejections and claims for deliveries out of specification along with the action taken. [R]

3.7 Standard Trade Contract Terms Where standard trade contract terms, for example Gafta standard trade contract forms, are to be incorporated into the contract these must be clearly recorded in the contract. [R]

3.8 Customer Requirements Within the trade there are a number of food and feed safety assurance schemes in operation into which goods may be traded and delivered. Requirements of individual schemes may vary. Schemes may impose specific purchase conditions and supplier qualifications e.g. goods must originate from assured sources and only from producers certified by that scheme. Traders and Merchants must ensure that they understand and comply with any specific requirements of the relevant scheme into which the goods are being delivered.

3.9 Recognition and equivalence of Assurance Schemes Gafta recognises other trade assurance schemes that have equivalent system requirements and standards to GTAS, and which are considered to provide the same levels of food and feed safety control. Agreements of equivalence allow the flow of goods into and from other certified chains.

Gafta recognises the following schemes in accordance with the relevant scopes as per signed mutual recognition agreements:

Agricultural Industries Confederation (AIC): UFAS (Universal Feed Assurance Scheme) Merchants; TASCC (Trade Assurance Scheme for Combinable Crops) Merchants, Road Haulage, Storage, Testing. www.agindustries.org.uk

Belgian Feed Chain Platform (OVOCOM); GMP Animal Feed Scheme; trading, storage, transport by road, waterway and sea. www.ovocom.be

GMP+ International B.V.: GMP+ Feed Certification (GMP + FC) Scheme; Trading, storage, transport by road, waterway and sea. www.gmpplus.org

3.10 It is the responsibility of the principal in a contract for the delivery of goods to give precise instructions to their suppliers or to suppliers of third party services, e.g. transport by road and/or storage, regarding any specific requirements that exist if these are not already covered by this Code of Practice. [R]

3.11 Fumigation of goods Where a party to a contract agrees to undertake fumigation of the contracted goods the requirements should be agreed in writing by the parties. Gafta Rules No. 132 are available for this purpose. Parties adopting these rules are required to appoint fumigators that are approved by Gafta and/or by the appropriate national authorities and therefore meet a set of minimum standards. GTAS certified companies must be used whenever possible.

3.12 Licences The responsibility for the obtaining of any required export or import licences, certificates of origin or other licences or certificates, must be clearly set out in the contract and the time within which such licences are to be obtained must be identified.

4.0 Food and Feed Premises Registration Regulations

4.1 Operators within the European Union should note that before storing, handling or transporting goods which may be destined for human and/or animal consumption, 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 issued by the local authorities will be checked as part of any certification audit. This will include a merchant in the event that they handle loads of goods, receive rejected goods, undertake cleaning/screening operations on their sites, which may be delivered into the food or feed chain. [R]

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

5.0 Registration of Operators under EU TSE Regulations

5.1 Operators within the European Union should note that registration with the official authorities is required for the storage, handling or transporting of dedicated bulk, animal-derived dicalcium phosphate and hydrolysed protein.

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



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6.0 Hazard Analysis and Critical Control Point (HACCP)

6.1 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. [R]

Traders and Merchants must demonstrate an awareness of the principles of HACCP and have an HACCP plan in place covering the movement and storage of goods. (See Appendix 2)

6.2 Traders and Merchants that handle assured and non-assured goods should include in their HACCP plan procedures to ensure that goods of different status cannot accidently be mixed.

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

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

Traders and Merchants 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 a chain of custody, evidenced by clearly annotated documentation accompanying goods in transit and by cross checking compliance status with on-line databases.

For detailed information about obtaining certification for compliance with the requirements of RED see Appendix 6.

8.0 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 on a List of Differences.

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

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

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

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

See Appendix 3 for more information regarding Cleaning Methods

See Appendix 7 for more information on ICRT/IDTF

9.0 Assured Goods

9.1 Where goods have assured status (i.e. have been produced under a recognised assurance scheme) this must be clearly stated on the contract/delivery note.

9.2 The assured status of supplier(s) must be confirmed. [R]

9.3 Assured and non-assured commodities must be identified as such and kept separate at all times. [R]

9.4 The assured status of the goods must be passed on to the buyer with evidence where required. [R]

9.5 Where assured and non-assured goods are combined, the entire bulk must be classified as being non-assured. [R]


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10.0 GM Goods (EU only)

10.1 Goods that have been genetically modified or have been produced from GM sources must be notified by the sellers to the buyers in a document accompanying the goods, or where agreed on the contract. The information regarding GM events must be provided from seller to buyer in accordance with the applicable legislation. [R]

10.2 GM and non-GM goods must be identified and kept separate at all times. [R]

10.3 Where GM and non-GM goods are combined, the entire bulk must be classified as being GM. [R]

11.0 Organic goods

11.1 Goods with ‘Organic’ status (i.e. have been produced under a recognised organic scheme), must be identified accordingly and kept separate at all times from non-organic goods. [R]11.2 Where organic and non-organic goods are combined the entire bulk must be classified as non-organic. [R]

12.0 Transport by Road

12.1 All goods that are transported by road must be in vehicles that comply with the GTAS Transport of Goods by Road Manual (or equivalent standard).

12.2 A collection or delivery note is required for each vehicle transporting goods. [R]

13.0 Combinable Crops Passports

13.1 A Passport is a paper collection/delivery form that the farmer and/or storekeeper must have in his possession for completion and presentation to the driver of the vehicle collecting the goods prior to departure. The form must be completed and originally signed by the farmer and/or storekeeper with the relevant details for each individual load and must accompany the load to the point of delivery. This applies to imported goods as well as home grown goods. Drivers of vehicles are warned that a load that is not accompanied by a properly completed Passport is unlikely to be accepted at its destination/delivery point.

13.2 The driver must check to ensure that each section of the Passport is correctly completed and must not leave the loading premises without a fully completed and signed form. If in doubt the driver of the vehicle should inform his office for instruction. [R]

13.3 The completed Passport must be handed over with other relevant documents to the authorised person at the place of discharge/unloading.

13.4 A section of the form should relate to a Load Compartment Inspection (LCI) that must take place prior to loading. This must be jointly undertaken by the driver and the person responsible for the loading of the goods. Both parties are required to make a visual inspection only and the driver is required to sign to the effect that this has been satisfactorily completed. The driver must sign this section of the form and no other. [R]

13.5 The farmer and/or storekeeper or his authorised representative is required to complete and sign the whole form, ensuring that the vehicle trailer identification is inserted and that any applicable assurance scheme stickers and/or identifying marks (eg RED certification) are applied to or appear in the space provided on the form. [R]

14.0 Transport by Sea, Waterway, Rail and in Containers

14.1 Loading Compartment Inspection A Loading Compartment Inspection (LCI) of the cargo spaces must be undertaken prior to the commencement of loading by a recognised superintending firm registered on the GTAS and/or Gafta Approved Superintendents Scheme.

Before loading commences, the interior of the cargo spaces must be empty, clean, and dry, without any unsuitable odours and in every way be suitable for loading and transport of the goods. They must be free of any residues of the preceding load, any cleansing activities, smell, insects or vermin.

The results of the LCI, together with the information concerning the three preceding loads carried by the vessel, and records of any cleansing operations must be recorded and retained by the Trader or Merchant arranging the transport. [R]

14.2 Cleaning Requirements Means of transport presented for carriage of goods under this Code of Practice must be clean, dry, free from smell and generally in a fit condition to carry the goods. This requirement extends to any part of the vessel or rail wagon that the goods will come in contact with during loading or discharge.

Cleaning operations in load spaces must meets the requirements of the IDTF.

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The goods must not be loaded until the compartment spaces have been inspected to establish that they are in a suitable condition to receive the goods. Where necessary, further cleaning and drying must take place.

Once loaded, any loading hatches should be securely closed and sealed if appropriate.

It is prohibited to load goods covered by this Code of Practice into a compartment space which has previously carried any of the goods or materials listed as forbidden (or not listed) under the IDTF. Exceptionally, the parties may agree to the loading of goods in such circumstances after following the procedures set out in the IDTF for acceptance of loading compartments after the transport of prohibited loads.

14.3 Carriage by Sea Vessels fixed to transport goods under this Code of Practice by sea must be mechanically self-propelled vessels of steel construction suitable for the carriage of the contract goods, excluding tankers and vessels classified in Lloyds Register or Lloyds Shipping Index as Ore/Oil vessels. Vessels must be classed with a Classification Society which is a member of the International Association of Classification Societies (www.iacs.org.uk). Where vessels are engaged exclusively in the coastal trading of that nation (including trading on an inter-island route within an archipelago of which that nation forms part) vessels may be classed by a National Flag Society (defined as a Classification Society which is domiciled in the same country as the owner of the vessel in question which must operate under the flag of that country).

14.4 Fumigation In the event that fumigation of goods is (or may be) required, it is the responsibility of the principal to ensure that the suitability of the carrying vessel and the appropriate permissions regarding the operation of fumigation on board a vessel are agreed and acceptable to the Master/Owners by incorporating suitable terms in the contract of affreightment (Charter Party). [R]

14.5 Carriage By Rail LCI – where goods are being carried by rail wagons the LCI may be undertaken by a Loading Inspector approved for the purpose. [R]

On completion of loading operations the discharge slide of each rail wagon must be sealed.

14.6 Containers Where goods are being transported in containers, traders and merchants must keep a record of all containers owned and/or acquired second hand or hired and/or leased. Records must include the container ID Number, date of use and/or hire period. Dates of entry and removal from the scheme must also be recorded. [R]

Traders and Merchants must keep a documented Risk Assessment. [R] This may be produced by the trader or merchant or obtained where appropriate from another source. The Risk Assessment must include:

• Previous use of the container • Construction of the container • Inspection required prior to loading • Details of cleaning/disinfection required before loading • The use of container liners for protection of the goods being carried • Any customer specific requirements

A copy of the completed Risk Assessment must be forwarded to the storekeeper or handling facility responsible for loading and/or receiving the container. [R]

Before loading an empty container an inspection must take place by the trader or merchant, or by another competent person, to establish that the loading space is clean and dry, free of any residues of the preceding load, any cleansing activities, smell, insects or vermin, or is properly lined. [R]

Evidence of the appropriate cleaning and inspection of the load space must be kept. [R]

Where a customer provides a trader/merchant with containers to be loaded, a record of the customer requirements detailing the controls required for inspection, cleaning, disinfecting, lining and loading of the container, must be obtained and recorded. [R]

15.0 Sampling

15.1 An agreed set of sampling rules must be incorporated in the contract. Where goods are traded on Gafta contracts the Gafta Sampling rules are incorporated. Where other types of contract are used, rules for sampling must be in accordance with methods laid down in internationally recognised rules (See Gafta Sampling Rules No.124).

15.2 Where goods are traded on Gafta contracts, Traders and Merchants are required to appoint superintendents to undertake sampling from the list of Gafta Approved Superintendents (See Manual Supervision, Sampling and Weighing and the Sampling Rules No. 124).


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15.3 Where other types of contracts are involved, Traders and Merchants are required to appoint superintendents from the list of Gafta Approved Superintendents or the list of Superintendents who comply with the GTAS Code of Practice for Superintendents.

16.0 Monitoring of undesirable substances Monitoring and control procedures for biological, physical and chemical contamination must be established. Biological, physical and chemical contamination must be in accordance with Maximum Residue Limits fixed by the legislation in country of destination. Where no national limits have been set the Maximum Residue Limits set by the Codex Alimentarius Commission shall apply.

16.1 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 3 of this manual applies.

16.2 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.

16.3 Mycotoxins Where testing for the presence of mycotoxins is required a monitoring programme must be agreed between the parties.

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

17.0 Loading and/or Discharging of the Goods Loading and/or discharge operations can take place at one or more of the following facilities: 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 primarily responsible for the movement of the goods and the maintaining of their quality, condition, safety and security, during either the loading or discharge operation.

17.1 Operators of loading and discharge facilities are required to provide the cargo superintendent with evidence of the cleanliness of the handling equipment prior to the commencement of loading and/or discharge operations. [R]

17.2 The parties should agree and identify clearly the intended place of loading and/or discharging of the goods.

17.3 Where more precise information is to be provided after the conclusion of a contract, the date and time by which any additional information should be provided, and by which party, should be clearly agreed and stated.

17.4 As a matter of best practice, Traders and Merchants are advised to familiarize themselves with the port facilities and operations for loading and discharge - as the case may be - to identify the method and equipment used at the port, before making transport arrangements.

17.5 Unless otherwise agreed, the loading and discharging operations of goods by road or rail are expected to be as fast as practically possible in accordance with the method customarily used in the port or facility.


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18.0 Weighing The parties can agree the method of weighing and may incorporate into their contract the appropriate rules for weighing. Gafta standard contract forms incorporate the Weighing Rules Form No. 123 (See Manual Supervision, Sampling and Weighing and Gafta Weighing Rules Form No.123).

19.0 Insurance The parties should identify at the time of negotiating the contract who is responsible for taking out insurance cover and insuring the goods, at any given stage.

19.1 Marine Insurance Gafta standard contract forms stipulate the minimum marine insurance cover required, the detail terms of which are set out in the Gafta Insurance Clauses in Form No.72. (See Part 3 – ‘Rules’ for Form 72 and Part 3 – ‘Annexes’ for the Gafta A to Z of Insurance).

19.2 Goods in Transit Insurance The party responsible for insuring the goods in transit will provide insurance cover for loss or damage to the goods whilst in transit. In certain circumstances it is possible for a company to undertake "self insurance" where they can demonstrate that the company has sufficient resources to adequately cover this risk. [R]

19.3 Product Liability Insurance The parties should assess the risks within their daily business to determine whether product liability insurance is required and if so the level of product liability insurance cover required.

19.4 Where a trader is responsible for premises, vehicles, machinery and equipment etc., public liability insurance cover must be taken out.

In any event all Traders and Merchants should consider public liability risks and the need to carry product liability insurance for all their operations.

20.0 Arbitration In the parties' own short form of contract it is good practice to set out an arbitration agreement for the settlement of any disputes which may arise out of the sale/purchase of the goods. (See Gafta Arbitration Clause).

21.0 Records

21.1 An [R] in the text indicates the requirement to keep a record.

21.2 Comprehensive records must be kept showing information regarding the purchase and sale of contract goods; in particular from whom the goods were bought and to whom they were sold - also known as the ‘one up, one down’ system. This is especially important in the event of a product recall or withdrawal. Records should include details of all loads/consignments collected and delivered against a contract and must enable any load or consignment to be traceable back to its source. These should include the assurance status of the goods, relevant undesirable substance/mycotoxin information, GM or organic status etc. Records should include any suspensions or withdrawals from certification schemes. [R]

21.3 Internally produced records must be signed by the person carrying out the task/activity.

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

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

22.0 Procedures and Instructions

22.1 A designated person must have responsibility for the implementation of the requirements of this Code of Practice.

22.2 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. Procedures must be periodically reviewed, amended where necessary and re-issued to ensure that they remain current and effective. [R]

23.0 Suppliers, Service Companies and third party Contractors

23.1 A list of approved suppliers, service companies and third party contractors to the Trader and Merchant must be made available along with current evidence of certification/inspection/audit status. [R]

23.2 Any supplier [or trading partner] of goods under this Code of Practice must be GTAS Assured or must be assured under an assurance scheme approved by Gafta or must be audited by the company annually for compliance with the scheme requirements. Such assessments should be carried out by a designated person with proper training in the requirements of the code. All non-conformances raised in audit must be closed out before using a supplier approved in this manner. [R]


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23.3 Any owned, managed or contracted store or handling facility for the storage or handling of goods supplied under this Code of Practice must be GTAS Assured or must be assured for the storage and handling of goods under an Assurance Scheme that has been approved by Gafta. [R]

23.4 Any owned, managed or contracted means of transport for the carriage of goods by road under this Code of Practice must be GTAS Assured or must be assured for the transport of goods by road under an Assurance Scheme that has been approved by Gafta. [R]

23.5 Where goods are traded on Gafta contracts, the quality of the goods supplied under this Code of Practice must be established by a Gafta Approved Analyst and evidence made available. [R]

23.6 Any owned, managed or contracted testing facilities used to establish the quality of goods supplied under this Code of Practice for any other purpose must be GTAS Assured or must be an assured testing facility under an Assurance Scheme that has been approved by Gafta. [R]

23.7 Where goods are traded on Gafta contracts, any third party inspection company employed to control the weight and quality of goods supplied under this Code of Practice must be a Gafta Approved Superintendent and evidence made available. [R]

23.8 Any third party inspection company employed to control the weight and quality of goods for other purposes must be from the list of Gafta Approved Superintendents or from the list of GTAS Certified Superintendents or have accreditation for the services provided and the evidence made available. [R]

23.9 Any contractor employed to undertake fumigation, pest control and/or denaturing operations must be GTAS Assured or must be assured under an Assurance Scheme approved by Gafta. [R]

24.0 Complaints Procedure

24.1 A record of complaints against the business must be maintained. [R] This procedure must include systems for:

• The prompt documentation and investigation of complaints. • Deciding on internal actions required to prevent re-occurrence.

25.0 Personnel and Training

25.1 All personnel must have a written job description outlining responsibilities, line management and reporting procedures. [R]

25.2 All personnel must be made aware of the Quality Manual relating to the business. [R]

25.3 All personnel must be aware of the Company policy document relating to Health and Safety. [R]

25.4 All personnel must be made aware of the GTAS Code of Practice for Trading and Merchanting and any other applicable scheme manuals. 25.5 Where training or instruction is provided this must be evidenced by records signed by the trainer and trainee.

26.0 Recall and Withdrawal Although every effort is made to minimise the risk of the production, or placing on the market, of unsafe goods there are occasions when an accident or mistake occurs, or unforeseen circumstances that might compromise the integrity of goods being supplied under this scheme. For this reason there might be a requirement to withdraw or recall goods in the market where the risk to the consumer is considered to be high. Under EU General Food Law, food and feed business operators that consider (or have reason to believe) that a food/feed which it has imported, produced, processed, manufactured or distributed does not comply with food/feed safety requirements must immediately initiate procedures to withdraw the goods in question and must inform the competent authority.

Therefore a product withdrawal or recall system is a fundamental component of a company’s safety management system.

26.1 A company must have a written system for product recall/withdrawal that can be invoked both within and outside of business hours, and is understood by all employees. The system must include a requirement to keep records of the incident, the assessment of the incident and the resulting remedial action. The procedure for recall/withdrawal should be tested annually for effectiveness including the ability to trace goods back to their source. Where applicable, modification of the operating system should be made to prevent a further occurrence of the problem. [R]

26.2 A company must have a written recall/withdrawal policy. [R]


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26.3 The company must appoint a suitably qualified person(s) to be in charge of co-ordinating the process.

26.4 Where goods are returned or the movement of goods halted as the result of instigating the recall/withdrawal procedure, those goods must be subject to a further quality control/risk assessment before either being disposed of or being returned to the market.

27.0 Gafta Dispute Resolution Rules Where the parties to the contract have agreed to refer any disputes to arbitration under Gafta rules, the Gafta Dispute Resolution Rules are the key documents that the parties must follow. There are four separate dispute resolution rules provided under the Gafta contract terms. These are: -

25.1 Gafta Arbitration Rules, No.125. These rules provide for both first tier, and second tier (Appeals) arbitration.

25.2 Gafta Simple Dispute Arbitration Rules, No. 126. These rules provide first tier only arbitration, with no provision made for Appeals.

25.3 Gafta Arbitration Rules for Use with Charter Parties or Other Forms of Maritime Transport, No.127.

25.4 Gafta Mediation Rules No. 128. Note: see also the Gafta Arbitration Code of Practice.


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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.

A P P E N D I X 2

Introduction to HACCP -Hazard Analysis And Critical Control Point System

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

• PRINCIPLE 1 Conduct a hazard analysis.

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

• PRINCIPLE 3 Establish critical limit(s).

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

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

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

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



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

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

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

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

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

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

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

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

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

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

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

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

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



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

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

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

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

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

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

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

Frequency = Volume x Chance x Seriousness 100

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

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



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

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

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

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

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

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

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

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

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

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

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 8.0

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

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

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

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

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

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

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

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

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

Additional cleaning options:

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

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

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



The 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



A Introduction This Code of Practice is for Brokers and their clients engaged in the trading of combinable crops and animal feed materials. It sets out the procedures that must be followed. Failure to comply with the Code does not in itself invalidate a contract or agreement between two contracting parties.

B Scope This Code of Practice is for the use of Brokers who have negotiated the confirmation terms of a contract between sellers and buyers using as a basis and incorporating the appropriate standard contract terms.

Where there is one Broker to a transaction he is deemed to be acting on behalf of both sellers and buyers; referred to hereas the 'Principals'. Where there are two Brokers to a transaction, they are each deemed to be acting for and on behalf of the principal to the contract by whom they were engaged.

1.0 Code of Practice for Brokers

1.1 Confirmation Of Contract Following the unconditional acceptance of an offer a contract exists between the Buyer and the Seller (Principals).

The Broker may confirm by a method of rapid communication such as telex, or letter if delivered by hand on the date of writing, or telefax, or email or other electronic means (not later than the next business day unless otherwise agreed), confirmation of acceptance of this contract.

1.2 In any event the Broker should provide a full and accurate written contract confirmation of the business so agreed between the Principals.

1.3 Any special conditions which are not covered by an agreed standard contract form, such as the Gafta Standard Contract forms, should be specifically negotiated and confirmed in writing at this time.

1.4 In the case of a sole Broker; when a contract confirmation is drafted by him it should be sent to both Principals for signature.

1.5 In the case of two Brokers; unless otherwise agreed it shall be the duty of the Sellers' Broker to raise the contract confirmation and to send it to the other Broker. The Brokers should exchange the terms between them, and drafts should continue to be exchanged between them, until such time as they are identical and agreed, before they are sent to their Principals for signature. Both Brokers should be named on the contract.

1.6 Failure by a party to sign a contract confirmation does not necessarily invalidate it but their signatures provide certainty, particularly at a later stage if there is a dispute.

2.0 Notices

2.1 All notices required to be served on the contracting parties should be communicated rapidly in legible form.

Where Gafta contracts apply, the acceptable methods of rapid communication are defined in the Gafta Notices clause as either telex, or letter if delivered by hand on the date of writing, or telefax, or email or other electronic means, always subject to the proviso that if receipt of any notice is contested by the addressee the burden of proof of transmission shall be on the sender who shall, in the case of dispute, establish, to the satisfaction of the arbitrators or board of appeal that the notice was actually transmitted to the addressee.

2.2 Notices for the appropriation clauses of Gafta Contracts provide for the despatch of a notice either direct to a principal, or to a Broker/agent, which is then deemed to have been received.

2.3 A notice to a Broker or agent under the parties' contracts terms is deemed to be a 'Notice' under the contract.

2.4 When a notice is received by a Broker he has a duty to pass it on as quickly as possible in accordance with the contract terms. Failure to do so could result in a breach of contract by one of the Principals.

3.0 Brokerage Commission

3.1 Rates of commission are negotiated between Brokers and their Principals direct, and are not subject to a scale or agreement by any organisation or association.

A P P E N D I X 5

Code of Practice for Brokers



3.2 The Brokerage Clause in Gafta Contracts is the agreement between the Principals with regard to the payment by them of the brokerage agreed. A Broker is not a party to that agreement.

3.3 A Broker is not a party to his Principals' contract and does not fall under any of their terms with particular regard but not limited to, the fulfillment or default of a contract, nor its domicile or jurisdiction clause.

3.4 A Broker and/or his Principal may wish to enter into an agreement for brokerage and may use the specimen form attached.

4.0 General Standards

4.1 Brokers are advised to take out Professional Indemnity Insurance.

4.2 Brokers must comply with all statutes, statutory instruments and regulations applicable in the country in which they operate and, where applicable, are authorised to operate as Brokers.

4.3 A Broker must not act as a principal, professionally or privately in the physical commodity or related paper market in which they are broking.

4.4 A Broker must not act as an agent for any company and must remain free from any commercial ties that could prejudiceany advice given to a client.

4.5 Brokers must not at any time exchange monies with an employee of any company acting as a Principal in a contract in which the Broker has an involvement.

4.6 Brokers should at all times give best and impartial advice and should not knowingly mislead a client.

5.0 Arbitration In the event of a dispute between a Broker and his Principal, the use of the attached specimen agreement will provide for settlement by arbitration in accordance with Gafta Simple Dispute Arbitration Rules No 126, in force at the date of the agreement.



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 6

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 7

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

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