PAC Guidance on Application
of ISO/IEC 17065:2012 to
Organic Certification under the
EU Legislation on Organic
Farming
Proposed Draft Version 2015
May 2015
Introduction to PAC Guidance on Application of ISO/IEC 17065:2012 to Organic
Certification under the EU Legislation on Organic Farming
ISO/IEC 17065:2012 is an International standard which sets out criteria for
bodies operating certification of products and processes. One of the important
certifications in this area is certification of organic products. In many countries
organic farming and production is generally governed by the relevant regulations.
The compliance to the regulation is generally verified through conformity assessment
activities carried by the certification bodies accredited to ISO/IEC 17065:2012. Since
there is an increasing demand for organic products in many developed markets,
there is also a greater demand for certification of organic products by the accredited
certification bodies operating in the respective countries.
Access to the European Union market for organic products
The European Union is one such important market and access to this market is
regulated under regulation (EC) 834/2007 and various implementing rules. These
rules establish two mechanisms for access which require equivalence of the system
in the export country to that within the EU; country to country equivalence (for further
details the EU regulation may be referred) e and a list of recognized control bodies.
A list of equivalent control bodies or certification bodies(CBs) is already established
as Annex IV to Regulation EU-No. 1235 / 2008. Control bodies have to fulfill
requirements stated in the EU-No. 1235/2008which accreditation body’s shall
assess. Therefore special guidance is necessary for application by CBs and for
assessment by accreditation bodies.
Purpose of this document
If such CBs are to be accredited in a worldwide harmonized manner as complying
with ISO/IEC 17065: 2012, some Guidance to that document is necessary,
especially since there are many specific requirements pertaining to organic farming
and consequently requirements with respect to certification of such products and
processes. This document intends to provide such guidance and has three main
purposes:
 to enable accreditation bodies to harmonize their application of the standards
against which they are required to assess the certification bodies.
 To facilitate mutual recognition of accreditation process, especially to facilitate
the recognition of different organic certification schemes for mutual
acceptance.
 To assist certification bodies themselves and to those, whose decisions are
guided by their certificates.
For the convenience of usage this document has been structured on the same lines
as ISO/IEC 17065:2012 and the headings from that document are first printed in
bold; Guidance where it is offered is, for ease of reference, identified with the letter
“G”.
This Guidance forms the basis for assessment of organic certification bodies by the
accreditation bodies and will become essential for the consistent application of
ISO/IEC 17065:2012. This may also be used as the basis for assessment of AB’s
applying for ISO 17065:2012 MLA for organic products for import into the European
Union as all of this Guidance is expected to be adopted by certification bodies and
verified by accreditation bodies engaged in the accreditation of CB’s operating
organic certification.
This document was prepared through the contribution of the participants of the three
stage training &workshops for assessors of accreditation bodies on organic
agriculture (Annex 1). The training was organized by PAC and PTB. The program
was attended by the accreditation body personnel from different Asian economies.
Definitions
Since this document is intended specifically for accreditation of CBs for them to
provide access to the EU market, the definitions of regulations (EC)834/2007 and its
implementing regulations (see references below) should apply. To provide clarity of
understanding various terms used under these regulations are explained and linked
to the terms in ISO 17065 as follows:
The EU-Legislation on Organic Farming uses the term “control body” meanwhile the
ISO/IEC 17065:2012 uses the term “certification body”
The EU-Legislation on Organic Farming uses the term “control measures”
meanwhile the ISO/IEC 17065:2012 uses the term “certification requirements”
The EU-Legislation on Organic Farming uses the term “production rules” meanwhile
the ISO/IEC 17065:2012 uses the term “product requirements (clause 3.8).
Application for recognition
Regulation 1235/2008 sets out the need for control bodies to make an application to
the Directorate General for Agriculture and Rural Development (DG AGRI) of the
European Commission and, once recognized as equivalent, provide annual reports.
The application is performed through the DG AGRI web portal at
https://webgate.ec.europe.eu/agriportal/ofis-areq using the assessment reports
provided by the accreditation body. The procedure is described in Regulation
1235/2008 Article 11. To access this portal it is necessary to apply for a password
through the mail agri-organic-imports@ec.europa.euThere is an application deadline
of September 30 every year.
The scope of the production rules applied by the CB for the purpose of access to the
EU must conform to those described under regulation 1235 /2008 Annex IV.
References
COUNCIL REGULATION No (EC) 834/2007 of 28 June 2007 on organic production
and labelling and repealing Regulation (EEC) 2092/91
COMMISSION REGULATION (EC) No 889/2008 of 5 September 2008 laying down
detailed rules for the implementation of Council Regulation (EC) No 834/2007 on
organic production and labelling of organic products with regard to organic
production, labelling and control (as amended)
COMMISSION REGULATION (EC) No 1235/2008 of 8 December 2008 laying down
detailed rules for implementation of Council Regulation (EC) No 834/2007 as regards
the arrangements for imports of organic products from third countries (as amended)
Guidelines on imports of organic products into the European Union December 15,
2008
Useful addresses
European Commission
Directorate General for Agriculture and Rural Development
H3 Organic Farming
Rue de la Loi
1049 Brussels
BELGIUM
E: agri-organic-imports@ec.europa.eu
W: http://ec.europa.eu/agriculture/organic/splash_en
4 General Requirements
4.1 Legal and Contractual Matters
4.1.1 Legal Responsibility
4.1.2 Certification Agreement
G.4.1.2.1 The certification system shall be based on written agreements, with clear
responsibilities of all parties involved in the chain of operations for production of an
organic certified produce/product. The certified operators shall sign
contracts/agreements requiring them to:
a. Follow the production standards/regulations and other published requirements
for certification.
b. Not to use any prohibited items in its production of organic produce and
product.
c. Accept inspections.
d. Supply accurate information.
e. Notify the certification program of any changes.
f. Inform the certification body of complaints by the operator’s customers as well
as consumers of the product as received by the certified
operators/organizations.
G.4.1.2.2 The certification body shall ensure that its certification agreement requires
that its clients for organic certification comply with the following organic certification
specific requirements:
a) The certified operator shall provide access to the inspectors/evaluators of the
certification body, to all relevant facilities of organic production / farm unit,
including accounts and sales related records and other relevant
documentation to provide adequate audit trails and traceability of organic
certified produce and products.
b) The certified operator shall provide access to its record keeping system
adapted to the type of production that enables the certification body to
retrieve necessary information and to seek verification of the production,
storage, processing, purchase and sale.
c) The certified operator shall provide access to non-organic production units or
units associated by ownership or management to the applicant/certified
organic operator.
d) The certified operator shall provide the certification body, updated information
on the scheme of inspection and testing, which the certified operator
maintains or intends to maintain for ensuring organic integrity
4.1.3 Use of Licenses, Certificates and Marks of Conformity
G.4.1.3.1 Certification mark with indication referring to organic nature shall not be
used on non-organic products.
G.4.1.3.2 For the organic certification scheme requiring market surveillance,
conformity of the certified product shall be monitored in accordance with the
requirements stated in the certification scheme.
4.2 Management of Impartiality
G.4.2.1 The certification bodies that are administered by membership organizations
or are owned by the membership organization or organic producer organizations,
shall ensure clear separation of activities and all requirements with respect to
impartiality in decision making and other activities shall be ensured by the
certification body.
G.4.2.2 The certification body shall not offer any services that question its objectivity
and impartiality. Such services may include marketing and promotion activities for
organic products, consultancy services for clients and applicants.
4.3 Liability and Financing
Nil
4.4 Non-discriminatory Conditions
Nil
4.5 Confidentiality
G.4.5.1 Whilst maintaining confidentiality of information, the certification body shall
have provision for exchange of information as necessary. For example, when
laboratory tests showed that pesticides were found in organic products, the
certification body shall notify any other certification body concerned, say certifier for
manufacturer of organic products using as raw material the organic agricultural
products found to contain the pesticides. It shall also inform, where relevant, also the
competent authorities, any other relevant stake holders, etc.
4.6 Publicly Available Information
G.4.6.1The certification body operating the organic certification scheme shall have
processes for informing all concerned including the prospective and present certified
operators about the applicable standards for the different organic product categories
and the program changes including updates of procedures and standards.
G.4.6.2 The organic certification body shall identify clearly the standards and
requirements used for the different product categories. These shall be available to
the applicant and publicly accessible through its website.
G.4.6.3 The detailed information regarding organic production/farming related regulations
and standards against which the products will be certified and the certification processes,
as well as a fee table shall be made available through publications and electronic media,
and shall be available on the CB website from July 1, 2015.
5 Structural Requirements
5.1 Organizational Structure and Top Management
Nil
5.2 Mechanism for Safeguarding Impartiality
Nil
6 Resources Requirements
6.1 Certification Body Personnel
G.6.1.1 The certification body shall ensure that its personnel have sufficient
knowledge on organic agriculture and regulatory requirements relevant to organic
certification.
G.6.1.2 Qualification Criteria
G.6.1.2.1 The following criteria shall be applied for control and certification staff, in
organic certification, which shall include but is not limited to, as appropriate the
contract review personnel, inspection and evaluation personnel, technical reviewers
and decision makers. The staff shall have:
a. Sufficient background and knowledge in agriculture and/or food science, food
technology. The requirements may vary based on the functions undertaken by
the personnel. Knowledge may be gained typically through educational
qualification and/or experience, adequate to provide knowledge of organic
products and processes. Personnel shall be qualified on the basis of use of
appropriate evaluation methods.
Note: A number of evaluation methods like review of records; feedback;
interviews; observations/witness; examination can be used to evaluate
knowledge and skills.
b. Received appropriate training in respect to organic agriculture, food and feed
processing, trade, specific production areas (e.g. aquaculture) and organic
regulations and standards.
c. Gained experience for each scope by participation in a minimum of 10
certification audits or at least 6 days. The criteria stated above are specifically
applicable for personnel involved in inspection and evaluation activities.
G.6.1.2.2 Competence of decision maker – Decisions on certification shall be taken
by a competent person or group fulfilling the same criteria as stated in G.6.1.2.1.
G.6.1.3 The certification body shall actively identify training at entry level as well as
based on needs identified through systematic performance reviews and provide, as
necessary, training to its staff on the requirements of the standards, the certification
program and relevant methodologies. Adequacy of such training plans, training and
evaluation records, and the associate materials shall be maintained.
G.6.1.4 Depending upon the initial qualification and experience of individuals,
qualification process may include just an evaluation of knowledge and skills, an
induction period or a supervised working period with experienced auditors/inspectors
or a combination of these measures.
G.6.1.5 The performance monitoring for each evaluator/inspector should include
observation in on-site audit/inspection, normally not longer than every three years,
unless there is sufficient supporting evidence that the auditor is continuing to perform
competently.
6.2 Resources for Evaluation
6.2.1 Internal Resources – Covered in clauses G.6.1.1 to G.6.1.5 above.
6.2.2 External Resources
G.6.2.2.1 Subcontracting of testing – subcontracting of testing (of input materials
organic certified products, etc. for residue, genetically modified organism and others)
shall be carried out on a risk based assessment by the certification body.The
certification body shall ensure that the testing activities are subcontracted to
competent laboratories as demonstrated either by the sub-contracted laboratory
having accreditation to ISO/IEC 17025 for the relevant tests and providing endorsed
(Logo) reports or the certification body itself assessing the competence of the subcontracted laboratory to the requirements of ISO/IEC 17025. Where the assessment
of the sub-contractor is carried out by the certification body, it should be able to
demonstrate that the assessment team is technically competent and knowledgeable
in the application of ISO/IEC 17025 for the relevant fields of testing.
7 Process Requirements
7.1 General
G.7.1.1 The requirements and procedures set up by the CB shall take into account
the requirements with respect to organic farming as stated in the EU-Legislation on
Organic Farming. These also include any other supporting requirements as
prescribed by the importing countries. For example, for export to countries with in
EU, all applicable requirements prescribed in the EU-guidelines on Imports shall also
be covered.
G.7.1.2 Any organic certification program followed by the CB shall have defined
requirements for certification body’s functioning as well as certification process
requirements. CB requirements covering organic certification shall primarily be
based on ISO/IEC 17065:2012 and the certification process requirements shall
primarily be based on equivalent standards to the EU-legislation on Organic Farming
which appear in Titles II, III and IV of Regulation 889/2008.. In case these
requirements specific to organic certification have been documented by the Control
Body / Regulator / Accreditation Body / scheme owner then the certification body can
directly base its certification system on the prescribed requirements. However in
absence of these it becomes incumbent upon the CB to describe the certification
system related requirements (e.g. reduction of conversion period, exceptional
permission of conventional seeds etc.), covering CB requirements (based on
ISO/IEC 17065:2012) and certification process requirements (based on relevant
regulations). In such cases the accreditation body will need to evaluate the
equivalence of the certification process as part of its accreditation process.1
G.7.1.3 In respect of requirements based on EU Legislation on Organic Farming, if
the certification body uses an EU-equivalent certification program, the accreditation
body shall conduct an equivalence assessment between this certification program
and the EU-legislation on Organic Farming. The result of this assessment shall
include an explicit confirmation of the result of the equivalence assessment. The
result will be made available by the accreditation certificate to the public.
G.7.1.4 The certification program shall take into consideration explicitly the following
aspects as applicable: retroactive recognition of conversion period, separation and
inspection of conventional production units, parallel /split production, group
certification and wild collection.
G.7.1.5 The certification body shall have available and implemented policies for: risk
based inspections, management of deviations, non-conformities and corrective
actions, exchange of information with other control bodies and competent authorities
and a policy for the annual report for the EU-Commission.
G.7.1.6 The certification body shall have documented policies and procedures on
residue testing, testing of genetically modified organism, input materials and others
as relevant to establish organic integrity. These should generally include the
following:
a) System for identification of cases in which samples shall be taken for
analysis where, use of a substance prohibited by the standards, is
suspected.
b) A procedure on how to take samples and send them to the laboratory.
c) The number of samples taken per annum must represent 5% of the
operators under the scheme.
7.2 Application
G.7.2.1 The certification program shall not allow operators to switch in and out of the
certification system. While accepting an application for change of certification body
the certification body receiving such applications shall ensure availability of all the
background information in respect of the applicant organic farm / production unit, and
whether another certification body had denied certification to the applicant organic
operator. Certification body shall also have a documented system for corroborating
1
The production rules (product requirements) defined in regulation (EC) 889/2008 may not
be applied directly. Instead the CB must develop its own rules or use already established
rules. A line by line assessment must be provided by the CB as part of its application to the
Commission. This line by line analysis shall be verified by the AB.
the information received from the certification body who had previously certified the
operator.
G.7.2.2 Pre-requisite for application – The applicant shall comply with and confirm
at the time of application to the following. The certification body shall have
appropriate provisions in its system for application to ensure receipt of relevant
information from the applicant operator. :
a) The certification body and its auditors/inspectors shall have access to all
relevant facilities of organic production / farm unit, including accounts and
sales related records and other relevant documentation to provide adequate
audit trails and traceability of organic certified produce and products.
b) The certified operator shall have a record keeping system adapted to the type
of production that enables the certification body to retrieve necessary
information and to seek verification of the production, storage, processing,
purchase and sales.
c) The certification body shall have access to and inspect non-organic
production units or units associated by ownership or management to the
applicant/certified organic operator. Inspection stages should include review
of such units when there is sufficient reason for doing so, such as production
of the same kind of products, etc. The operator shall provide complete and
accurate information in respect of the above.
G.7.2.3 The applicant shall also inform in detail any scheme of inspection and
testing, which the applicant maintains or intends to maintain for ensuring organic
integrity.
7.3 Application review
Nil
7.4 Evaluation
G.7.4.1 Preparation for evaluation
G.7.4.1.1 While assigning evaluators/inspectors for the purpose of evaluation, the
certification body should generally ensure that the same inspector is not assigned to
one operator on a continuous basis. More than 3 years in a row (consequently) is not
considered desirable.
G.7.4.1.2The team nominated for the purpose of evaluation/inspection of the
applicant operator shall carry out an offsite review of the relevant information
received through application process as stated in clause 7.2 and ask for any
additional information if necessary. Based on this review, appropriate plan for
evaluation may be drawn up, this shall include visits to all facilities/farms and others
like suppliers of non-organic farm products in the neighborhood, etc, as applicable.
This planning should also include as appropriate sampling strategies and
requirements for testing based on review of risk analysis conducted by the operator.
G.7.4.2 Evaluation related
G.7.4.2.1 For smallholder group certification, the certification body shall evaluate the
proper functioning of the group’s internal control system, manual and documentation
as described in Guidelines on the imports of organic products to the EU.
G.7.4.2.2 Inspection procedures and methods used by the CB shall essentially
include, but not restricted to the following:
a) Visits of facilities, fields/farms, etc.
b) Review of records, accounts, sales figures, etc.
c) Sampling and analysis
d) Calculation and confirmation of input/output norms, production estimates, etc.
e) Interview not only with designated responsible persons on the
farm/production units, but also with other levels of employees like farm
workers, production staff, etc.
G.7.4.3 Evaluation reporting
G.7.4.3.1 The report shall follow a format appropriate to the type of organic
operations inspected/evaluated. Likewise, the report shall cover all relevant aspects
of the organic standards and certification process and adequately validate the
information provided by the operator, including:
a) Date and duration of the inspection, persons interviewed, details of
fields/farms and facilities visited.
b) Details of the on-site-visit.
c) Evaluator’s/Inspector’s observations and evaluation of compliance to organic
standards/regulations and the certification requirements.
d) Objective evidence for nonconformities detected.
G.7.4.3.2 Reports shall be designed to allow for elaboration and analysis by the
inspector on areas where compliance might be partial, standards might not be clear,
etc. for ensuring appropriate decision with respect to scope of organic certification.
7.5 Review
Nil
7.6 Certification Decision
Nil
7.7 Certification Documentation
G.7.7.1 In addition to the formal certification documentation the CB is required to
issue certificates of inspection for each shipment of products in the format provided
in Annex V of regulation (EC) 1235/2008. Before issue of such certificates the CB
shall verify whether the products listed and quantities included can have been
produced / prepared by the operator.
7.8 Directory of Certified Products
G.7.8.1 The certification body shall publish certified, suspended and decertified operators
on its webpage. The list shall be updated not later than 2 weeks after the decision has
been taken and not later than two days after a decision of decertification of an operator
has been taken.
7.9 Surveillance
G.7.9.1 The certification shall conduct on-site inspections of all operators at least
once per year.
G.7.9.2 In addition, the certification body shall have a system and documented
procedure for conducting operator based risk analysis, which shall determine the
frequency and type of surveillance activities to be conducted. The system for risk
analysis shall also be used for determining the number of announced and un–
announced inspections. The following aspects should be considered while
conducting the risk analysis:
a) The results of the previous control.
b) The complexity of the operator (Type and structure of operator).
c) Quantity of products concerned.
d) Risk of mixing of organic and non- organic product.
e) Previous track record both with respect to running the scheme as well as
rejects from the market, previous NCs, feedbacks, test result etc.
f) Complaints / Denunciations received.
G.7.9.3 The surveillance activities in respect of Organic production certification
scheme shall include the following:
a) Additional visits to the certified operator’s premises during the certification
period on the basis of a risk based system.
b) End product testing for residue and GMO.
G.7.9.4 The certification body shall ensure that in accordance with the EU regulation
requirements the number of additional inspections shall not be less than 10% of the
total operations certified.10% of the total inspections (annual plus additional) shall be
unannounced.
7.10 Changes Affecting Certification
G.7.10.1 The CB’s procedure should require the operator to inform them in cases of
any changes like, modification in organic product composition, manufacturing
process, farming practices, extension in farm acreage etc. The inspection and
certification agencies shall determine whether the announced changes require
further visits and confirmation. The certification body shall inform the operator of all
conditions under which the operator shall not release the organic certified material to
the market before getting confirmation from the certification body.
G.7.10.2 In case the Certification Body makes any changes in the certification
requirements, then it shall ensure, by any means that it chooses, that the information
is immediately transmitted to the operators and also inform about the transition
period for the operator to comply with the changed requirements. The transition
period shall be decided based on the changed requirements and should also take in
to account considerations such as the decision regarding the certified
produce/products already under production/produced before the changes are
intimated to the operator. In case changes are driven by the changes in organic
produce requirements as per EU regulation, then the transition period shall take in to
account the EU regulation requirements. The Certification Body shall also require the
operator to confirm the receipt of the information and his confirmation on following
the instructions transmitted.
7.11 Termination, Reduction, Suspension or Withdrawal of Certification
G.7.11.1 Certification bodies shall have documented procedures for dealing with
violation of the organic standards and certification procedures by the certified
operators. These should include requirements for minor deviations as well as major
deviations affecting the organic integrity of the certified products. In case of major
deviations affecting the organic integrity the certification body shall ensure that the
indication of certification is removed from the entire lot of the production run which is
affected by the major deviation. Where a violation is made by the operator, the
certification body shall withdraw certification from the operator. The certification body
shall have clearly documented procedures for withdrawal and cancellation of
certificates and certification marks, including aspects like product recall, etc.
7.12 Records
G.7.12.1 The CB shall maintain records to demonstrate the certification procedures
on organic farming/production have been effectively implemented. Such records
shall include but not limited to:
a) Full description of the farm/ production unit and/or collection areas, showing
the storage and production premises and land parcels and, where applicable,
premises where certain preparation and/or packaging operations take place.
b) It shall also maintain information about individual members of a grower group
as well as the organic certified unit’s sub – contractors, if any.
c) Every year an annual report shall be sent by each certification body to the
Commission of the EU by 28 February. The control body (certification body)
shall update the information of the technical dossier (reporting on changes
both to production rules and control measures) and shall describe all
necessary items as laid down in EU Regulation 1235/2008, Article 12 b.
7.13 Complaints and Appeals
G.7.13.1 The certification body shall have a procedure which describes how to deal
with complaints received from stakeholders like importers of the certified organic
products, competent authorities, regulators and other relevant sources. Response
times and responsibilities shall be clearly described.
G.7.13.2 The certification body shall have a system in place that guarantees that the
operators inform them of any complaints regarding the quality of an organic product.
8 Management System Requirements
8.1 Options
8.2 General Management System Documentation (Option A)
Nil
8.3 Control of Documents (Option A)
Nil
8.4 Control of Records (Option A)
Nil
8.5 Management Review (Option A)
Nil
8.6 Internal Audits (Option A)
Nil
G.8.6.1 The certification body shall ensure that during the internal audit the whole
organic certification program is reviewed at least once a year.
8.7 Corrective Actions (Option A)
Nil
8.8 Preventive Audits (Option A)
Nil
Annex 1
Useful addresses:
European Commission
Directorate General for Agriculture and Rural Development
H3 Organic Farming
Rue de la Loi
1049 Brussels
BELGIUM
E: agri-organic-imports@ec.europa.eu
W: http://ec.europa.eu/agriculture/organic/splash_en
Annex 2
List of participants (PAC-PTB Training Workshop for Assessors of
Accreditation Bodies on Organic Agriculture) who had contributed towards the
preparation of this document
No. Name of the organization
Names of the participants
1
Bureau Of Accreditation, Vietnam
Duc Giang Minh
2
Bureau Of Accreditation, Vietnam
Duong Hoang Thanh
3
Bureau of Agriculture
(BAFPS), Philippines
and
Fisheries
Product
Standards
4
Bureau of Agriculture
(BAFPS), Philippines
and
Fisheries
Product
Standards
5
Philippine Accreditation Office, Philippine
Nanita Fidelino
6
China National Accreditation Service (CNAS), China
Xiaotao Yang
7
China National Accreditation Service (CNAS), China
Jie Cao
8
Department of Standards Malaysia (Standards Malaysia)
Pui Wan Ng
9
Hong Kong Accreditation Service (HKAS), Hong Kong
Ching Hang Wong
10
Hong Kong Accreditation Service (HKAS), Hong Kong
Chi Chiu Leung
11
Mongolian Agency for Standardization and Metrology, Mongolia
Tsatsral Dagvadorj
12
Mongolian Agency for Standardization and Metrology, Mongolia
Dolgorsuren Tsetsegmaa
13
National Accreditation Body of Indonesia (KAN), Indonesia
Nugroho Febriyanto
14
National Accreditation Board for Certification Bodies, India
Shobha Hegde
15
National Accreditation Board for Certification Bodies, India
Dr. Hari Prakash
16
National Accreditation Board for Certification Bodies, India
Vani Bhambri Arora
17
National Standardization Council (NSC) Thailand
Patcharaporn Pojang
18
National Standardization Council (NSC) Thailand
Junnipa Srichaiwan
19
Pakistan National Accreditation Council (PNAC), Pakistan
Muhammad Sulaiman Qureshi
20
Pakistan National Accreditation Council (PNAC), Pakistan
Muhammad Azhar Naeem Kamboh
21
Sri Lanka Accreditation Board, Sri Lanka
Chanditha Indumala Ediriweera
22
GfRS Resource Protection Ltd, Germany (Trainer)
Dr. Jochen Neuendorff
23
GfRS Resource Protection Ltd, Germany (Trainer)
Jutta Krawinkel
Joeve Calleja
Lara Vivas