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Lesson learned: requirements are not always implemented correctly

Friday, April 28, 2023

Following the recent EWS notifications on Aflatoxin B1 in feed we found that unclear expectations and unfamiliarity with some requirements led to miscommunication resulting in maize being delivered to the customer that did not meet specifications. 

We have observed that there are two main areas of concern; 

  1. the application of the Country note QM-Milch and
  2. the application of the Aflatoxin B1 Protocol (TS 1.7 Monitoring, chapter 2). 

The root cause analysis demonstrated that the requirements of both scheme documents were not implemented correctly. The key observations on implementing the Aflatoxin B1 Protocol where: 

  • not applying the higher risk category when the origin of the maize is unknown;
  • the link between the analysed batch and the delivered batch is missing in the certificate of analysis. 

The key observation on implementing the QM-Milch County note is: 

  • the lack of clear communication about specifications between the GMP+ certified companies and QM-Milch farmers. As a result, feed was unintentionally supplied with higher levels of Aflatoxin B1 than allowed by the Country note QM-Milch causing presence of excessive Aflatoxin B1 levels in milk.​ 

To minimise the reoccurrence of similar incidents we want to emphasize to take the following into account: ​

  • Farmers must always verify whether the scope of GMP+ certification includes QM-Milch. Only GMP+ certified companies with the "QM-Milch" scope are allowed to supply feed to QM-Milch Farmers.
  • Suppliers must ask their customer if the feed will be used in the QM-Milch programme. ​If so, be aware that QM-Milch specific feed safety limits are applicable.
  • Always, inform your customer, your Certification Body and GMP+ International (via an EWS notification) when there is an exceedance in the QM-Milch specific feed safety limits. This is crucial to ensure prompt action is taken to prevent any harm to livestock and people.​
  • When purchasing maize, it is crucial to know the country of origin for the application of the Aflatoxin B1 Protocol, see classification overview. In case the country of origin is unknown, the risk category (High) must be applied.
  • There must always be a direct link between the certificate of analysis and the analysed batch. When the Monitoring Protocol of Aflatoxin B1 is applicable, and the country of origin is classified as high or medium risk, the certificate of analysis cannot be older than 3 months. 

Thank you for your cooperation. It helps to contribute to maintain and improve the feed safety. In this way, we continue to work together towards feed safety worldwide.