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15 december 2016
With this letter GMP+ International would like to request you to, in the event of the gatekeeper protocol for transport of hay and straw laid down in GMP+ BA10, Annex 9, temporarily not to classify transport from the A-countries as a non-conformity, just as a remark and to motivate and document this remark.
According to GMP+ BA10, Annex 9 Gatekeeper protocol for road transport there is a possibility to use not certified transport for hay and straw if the origin of transport of hay and straw is located outside of the A-countries.
For transport of hay/straw specific types of loading compartments are obliged: flatbeds or curtain siders trucks. These types of loading compartments are widely used for transport of packaged products or pallet goods. Within GMP+ FC scheme, no certified transport is required for packaged products, since the risk of contamination is low. Therefore, flatbeds and curtain side trucks are usually not certified.
As a result of this, there are no countries that have sufficient certified loading compartments suitable for transport of hay and straw, including the A countries. This problem was discussed in the subcommittees Production, Trade & Collection and Transport. Based on the discussion a proposal was made to delete the list of A-countries for this specific type of transport.
GMP+ International is obliged to follow the formal procedure of the approval of the normative documents and to wait for approval by the Dutch Accreditation Council. The problem is however that GMP+ International, in contrast to the consultation by the Subcommittees and the IEC, cannot agree a deadline with the Dutch Accreditation Council. The Dutch Accreditation Council cannot guarantee that the approval of this amendment will be granted before 31-12-2016. As per 1-1-2017 also France, which is a significant supplier of hay and straw, will be listed as an A-country, this could cause a considerable shortage of hay and straw on the feed market.
Request to certification bodies
Taking the above into consideration, GMP+ International would request the certification bodies the following:
A nonconformity related to use of not certified transport is in generally to be classified as major or critical, depending on the risk for the feed safety.
In the event that the company applies the overall requirements of the gatekeeper protocol for transport of hay and straw from GMP+ BA10, Annex 9 properly, you are requested to temporarily not to classify transport from the A-countries as a non-conformity, just as a remark and to motivate and document this remark.
Thank you for your cooperation!
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