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1. The deadline for feedback on the principles and criteria of the legal, management, and traceability; production processes; and food safety smart modules (references supplied below), as well as on the rules related to the Global Food Safety Initiative (GFSI) requirements is 22 June for the Fruit and Vegetables and Aquaculture.
2. The deadline for the rest of the content in all the smart modules (for Fruit and Vegetables, Aquaculture, Flower and Ornamentals) as well as the GLOBALG.A.P. general regulations and GRASP is 6 July.

The reason for these two deadlines is an Advisory Board meeting scheduled for 28 and 29 June. At this meeting, it will be decided whether the Integrated Farm Assurance v6 Fruit and Vegetables and Aquaculture scopes are written as one standard that is acceptable and implementable by our stakeholders as well as for GFSI recognition or whether the GLOBALG.A.P. Secretariat will proceed with an alternative plan for those producers that need to show compliance with a GFSI-recognized standard.

As soon as we receive your detailed comments that are backed up by science or industry-related research, we can finalize the standard to be truly fit-for-purpose.

How to comment on GFSI-related points

All principles and criteria have been reworded to reflect simplification and harmonization while taking into account the feedback from the previous two public consultation periods. However, the documents provided for review  include content aligning the standard with requirements for GFSI benchmarking.

• For Fruit and Vegetables:

In the leftmost column of the document containing the smart modules legal, management, and traceability; food safety; and production processes, the identifiers of the principles required for GFSI benchmarking are set in green bold font.

The identifiers of principles originating from IFA v5.2/IFA v5.3-GFS are provided for reference in the leftmost column, appearing just below the newly numbered principle identifier.

In some cases, principles have been combined, separated, or reformatted for readability.

Stakeholders are encouraged to read all of the newly simplified principles and criteria, so as to best ensure the revisions are clear and pertinent to industry needs.

Principles required for GFSI benchmarking are as follows:

Legal, management, and traceability
LM 3.1, LM 4.1, LM 4.2, LM 4.2, LM 5.1, LM 7.1, LM 10.1, LM 11.1, LM 12.1, LM 13.1, LM 13.2, LM 13.3, LM 13.4, LM 14.1

Production processes
PP 1.1, PP 1.2, PP 1.3, PP 2.4, PP 2.5, PP 3.1, PP 3.3, PP 3.5.1, PP 4.1, PP 4.2, PP 4.3.1, PP 6.1, PP 7.1, PP 7.2, PP 9.1, PP 9.2, PP 9.3

Food safety
FS 1.1, FS 1.2, FS 2.1, FS 3.1, FS 3.2, FS 3.3, FS 4.1, FS 5.1, FS 6.1, FS 7.1, FS 7.2, FS 7.3, FS 7.4, FS 7.6, FS 7.7, FS 7.8, FS 8.1, FS 8.2, FS 8.3, FS 8.5, FS 9.1.1, FS 9.1.2, FS 9.2.1, FS 9.2.2, FS 9.2.3, FS 9.3.1, FS 9.3.2, FS 9.3.4, FS 9.3.5, FS 9.3.6, FS 10.1, FS 10.2, FS 11.1.1, FS 11.1.2, FS 11.1.3, FS 11.1.4, FS 11.1.5, FS 11.1.6, FS 11.2.1, FS 11.3.1, FS 11.3.2, FS 11.4.1, FS 11.4.2, FS 11.6.1

Principles associated with GFSI benchmarking do not appear in the worker well-being or environmental sustainability smart modules. The current GFSI benchmarking rules require that the principles noted above be scored Major Must.

• For Aquaculture:

Purple text in the document refers to GFSI requirements. After the consultation period, these will be harmonized as far as possible with the legal, management, and traceability; production processes; and food safety smart modules.

• For the general regulations

The updated general regulations also include content tailored to GFSI benchmarking requirements and are currently provided for public consultation. These include:

– Products identified as high-risk in the product list are not eligible for sampling when coming from production processes certified under Option 2 or Option 1 multisite with a QMS.

– The fully remote option (GLOBALG.A.P. Remote) is not available for audits with a GFSI benchmark.

– The current definition of unannounced audits by GFSI does not permit a 48-hour notification window; therefore, the producer or producer group will have no foreknowledge of an unannounced audit. Specific references are made to GFSI requirements in the rules for certification bodies.

– The more detailed the comments are in terms of scientific justification or other reasons as to why they are not suitable or how they can be modified, the better.

We appreciate your time and look forward to reviewing all comments and suggestions