Is there an assessment aid for evaluating the analysability of raw materials?
The following assessment aid provides an overview of the feed and raw materials that can and cannot be tested. The analysability of feed and raw materials also occurs in consultation with the responsible analysis laboratory.
May a certificate be awarded if there are positive GMO analysis results in a business and it has been found that the feed or raw materials in question had already been delivered before the analysis results were available?
First it must be taken into consideration which measures the business has introduced following the positive analysis results (Were there direct and long-term measures? Evaluation of the analysis results and process analysis?). If no concrete and effective measures were taken, that would be a reason not to issue a certificate. Corrective measures must be taken and their suitability must be proven through analyses. A follow-up audit is to be carried out by the certification body if it is necessary to evaluate the corrective measures.
Farmers must take and save a reference sample for each risk-prone feed. Does the farmer also have to take and save reference samples for VLOG-certified products or products recognised pursuant to a standard recognised as equivalent by VLOG?
Farmers receiving risk-prone feed material exclusively in VLOG-certified quality or in accordance with a VLOG-recognised equivalent standard, and/or have feed mixed only by VLOG-certified mobile grinding and mixing facilities are exempt from the requirement of drawing reference samples.
Does a sample of feed that is not at risk have to be taken and analysed in an agricultural operation?
No, only risk-prone feed must be sampled and analysed.
May the feed business provide the reference samples for risk-prone feed directly together with the supplied feed (e.g. in the event that the farmer is not present on the premises)?
A requirement in the VLOG Standard is that on delivery, the supplier and the client must take a sample of the feed together. VLOG generally holds that deviating from this procedure is not expedient because, in this case, the integrity of the transport is not guaranteed.
May feed analyses from affiliated feed producers be taken into account?
The results analysed by VLOG-recognised system participants or those certified according to an equivalent VLOG-recognised standard may be taken into account in agricultural operations on condition that they concern the batch of the delivered feed that is actually used.
How are positive GMO feed analysis results to be handled?
Positive GMO analysis results of feed are to be handled in the following manner within the scope of the VLOG Standard.
For how long does a farmer need to keep reference samples?
The farmer must always keep the last three samples, but at least the samples from the last two months.
Are dairy operators that are group organisers responsible for the sampling and analysis of feed?
There is a difference between sampling and analysis, although, according to the VLOG Standard, both are necessary only for feed that is risk-prone according to the VLOG Standard, feed that is not VLOG-certified or certified according to a standard recognised as equivalent.
Within the scope of the self-monitoring system and the analysis plan that is part of it, the group organiser must prove that when using non-VLOG-certified risk-prone feed, the farmers take reference samples and keep them accordingly. There must be at least one analysis result per audit interval per agricultural supplier.
It is acceptable if the certification body takes care of sampling and analyses. However, in the event of deviations/positive results, further analyses must be carried out (on behalf of the dairy operator) within the scope of the corrective measures if needed.
What does the number of analyses required per audit year (2-12 analyses) relate to in the Food Stage?
The number of samples (between 2 and 12) per audit year relates to the raw materials used (goods receiving) from the entire “Ohne Gentechnik” product range.
A processing facility that produces “Ohne Gentechnik” cheese, for example, is put into risk category 2 (12 analyses per audit year necessary). Assuming that the business, pursuant to its analysis plan created on the basis of the risk analysis, must analyse only the paprika extract used in the “Ohne Gentechnik” cheese, does the paprika extract have to be analysed 12 times if no other raw materials relevant for the analysis are used?
The business must spread the 12 samples over all the ingredients that need to be analysed in a risk-targeted manner. If this concerns only the paprika extract, then only this is to be analysed.
The number of samples can be reduced only if the number of batches received in the audit period is smaller than the minimum number of samples of 12 (e.g. 5 batches).