Information Sheet on CanadaGAP Certification with Costco Addendums – Update for 2013 Contents 1. Summary of Changes and Updates to the Costco Addendums for 2013 ......................................... 1 2. Passing Grade .................................................................................................................................... 3 3. Corrective Actions ............................................................................................................................. 4 4. Reaudits ............................................................................................................................................ 4 5. Audit Types ....................................................................................................................................... 4 6. Autofails and Other Key Requirements ........................................................................................... 5 1. Summary of Changes and Updates to the Costco Addendums for 2013 Costco has release new versions of their Addendums for 2013. Below is a list of changes in the new versions of the Costco Produce Audit Addendums effective January 1, 2013. The question numbers refer to the new versions. Changes to sentence structure that do not change the meaning of the requirement (e.g. word “documented” replaced with “written”) have not been included in the list of changes. Once again GFTC has provided an excel version for all of our auditors. Note: There are also five new requirements in the addendums. These are significant and have been highlighted in yellow and bold in the chart below. Growing Area: Question number General Description of Change 10 questions have been removed in the new version – specifically 1, 3, 4, 5, 6, 7, 9, 10, 11, 12 General N/A now allowed for all questions except the auto-fail items 2 Removed the wording in explanation re: “supervised by trained person” 5 Added wording at the beginning of the question and explanation “if the grower ships their product to more than one packer shipper”. A sentence removed from explanation: Copies of the raw material supplier supporting documents are available for review and filed in an easy to retrieve manner. 6 Additional guidance provided: Letters of guarantee will be accepted for packaging. And in explanation: In the event the grower is not responsible for supplier monitoring they must retain records for auditor review 7 Part of the explanation changed: If testing indicates a poor result, corrective actions are required. This must include a re-test. Testing frequencies are to be based on risk and must have occurred at minimum within the last 12 months. Harvest Crew: Question number 2 Description of Change 3 The old Question 3 has been removed 3 Reminder added to explanation: Hand sanitizer must not take the place of washing with soap and water. 6 Question 6 is completely new and requires that hand wash stations (in the field) are located outside the restroom so the supervisor can observe hand washing NOT an Auto-fail 14 Clarification provided that gloves are supplied by the grower/harvest company; pickers do not supply own gloves 17 Same requirement but split into 2 questions (Q 17 & 18 ins 2013 version). N/A is now allowed for this question. 19 New requirement for pest control in harvest equipment storage areas NOT an Auto-fail 20 New requirement that harvest equipment storage areas are free from evidence of Explanation expanded. Entity is not to be penalized for lacking previous audits in first year of certification. Group audits may be allowed if requested in writing in advance pests (rodents, mammals, birds). Auto-fail 18 The old Q 18 regarding storage of packaging has been removed from new version 25 (23 in old version) the notes on effective dates have changed 27 & 28 Same as old question #25 but the requirement is now split into 2 questions Packinghouse, Cooler, Cold Storage and Processing Facility: Question number 6 Description of Change 10 Reworded. Beard covers AND moustache covers are required. But this requirement only applies to those facilities that handle exposed product. 11 Clarification provided that cotton gloves may be worn under non-latex gloves for RTE product 13 New wording/clarification added on letter of guarantee 14 & 15 This is the same requirement but split into two questions (Q 13 in old version) 18A Clarification that the on-site traceability exercise (during audit) be conducted on a Costco item 22&23 This is the same requirement but split into two questions (q 21 in old version) 26-28 The notes on “Effective dates ...” have been changed 29 Now applies only in the U.S. New requirement to provide hand sinks in the restrooms AND at the facility entrance and that hands are washed after using the restroom and again upon entering the facility – NOT an Auto-fail 2. Passing Grade Costco has a passing grade of 85% for all the addendums AND the CanadaGAP audit. In addition, all the auto-fail criteria must be met (i.e. no auto-fails). The Auto-fails are all identified in the addendums in Bold and are summarized below. 3. Corrective Actions All suppliers who score below 98% (even if they pass) on their CanadaGAP audit or any of the Costco Addendums must submit a Corrective Action Plan to Costco within 14 days of their audit being posted to Azzule. Costco has not provided a form for this. Some producers use the CGAP CAR form, some make up their own. This is just a plan on how they will correct their non-compliances/non-conformances. Producers can send their CAR to us for posting (CGAPReports@gftc.ca) or post it themselves. Instructions are on the front page of the Addendums. Score Action Required 98 - 100% No corrective actions needed 85 - 97% Corrective action plan required < 85% Corrective action plan and re-audit required 4. Re-audits Re-audits for growing area and harvest crew audits must be conducted within 30 calendar days of the original audit date. Re-audits for packinghouse, cooler, cold storage and processing audits must be conducted within 60 calendar days of the original audit date. If the growing season is finished, the audit must take place within the first 30 calendar days of the next growing season. A product recall or other serious incident will initiate a requirement for a new food safety audit. Note - Re-audits are full re-audits of everything regardless of whether they have passed the other checklists. For example, if they pass CGAP and Growing Area but fail Harvest Crew, they need a full reaudit of all three. 5. Audit Types Operation/Addendum Producer Producer/Packer Packer Growing Area Harvest Crew * * * * Packinghouse with HACCP * * Growing Area The growing area audit is performed a minimum of one time each year or during the growing season. It covers fields, pesticide usage, water usage, harvest practices a "ranch" is defined as a parcel of ground (not necessarily a "lot" for production purposes) with the following characteristics: common management, common water supply and contiguous grounds. For the purpose of farm or ranch audits, manual development or self‐audits, a ranch or farm is defined as contiguous ground that is under common management. Field ‐ Harvest Crew The harvest crew audit is performed at a minimum of once per year for Costco and may be done periodically during the harvest season. The harvest crew audit must be conducted during harvest of the crop supplied to Costco. The harvest crew audit is divided into sections that correspond to areas of potential contamination risk in the harvesting operation. These areas include employee safety & hygiene, harvest practices and food security. A "harvest crew" is defined as a crew of harvest personnel under common management. Facility ‐ Packinghouse with HACCP The packinghouse audit is performed at a minimum of once per year. Questions are used to assess the facility’s food safety program. The audit is comprised of three main sections; a Good Manufacturing Practices section, a Food Safety File Requirements section and a HACCP section. The audit encompasses the areas of pest control, equipment, sanitation, employee hygiene practices, and all other operational practices and documentation as they relate to food safety. Food security is also addressed. A "packinghouse" is where whole commodities are prepared and packed for commercial distribution after being subjected to processes such as sorting, washing, weighing, etc. 6. Auto-fails and Other Key Requirements Auto-fails - Growing Area, Harvest Crew and Packinghouse No functioning hand-wash stations (or incomplete hand washing). Note: Costco does not accept hand wipes and hand sanitizers as a hand washing station. Hand washing stations must include soap, water and paper towel. Product contamination/adulteration is observed. Failure to have a written pest control program. Evidence of insects, rodents, birds, reptiles or mammals in any product, ingredient or primary packaging supplies. Water test results fail to meet set standards and no corrective action has been taken to include a re-test. Note: Costco requires water tests for irrigation/chemical application water. Water tests should be taken from irrigation equipment (e.g. drip lines, pivot nozzles) or where the sprayer is filled from for accuracy Evidence of systemic fecal contamination by wild animals and/or a single account of human or domestic animal fecal matter, in the growing area, close to the growing area or in any storage areas. Employees with obvious sores, infected wounds or other infectious illnesses are allowed to have direct contact with exposed food products, production, equipment or storage areas. Products not properly coded for traceability throughout the process . Additional Auto-fails for Packinghouses ONLY Processing facilities, Packinghouses, Coolers and Cold Storage facilities supplying product to the U.S. and not meeting registration requirements of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (the Bioterrorism Act) or companies located in the U.S. supplying product to Costco locations in other countries. http://www.registrarcorp.com/fda-food/registration/ Failure to take corrective actions, when critical limits are not met in a HACCP program. A documented Food Safety Plan/Manual (for facility auditees) has not been established. Food allergens are present and an allergen control program has not been developed. Evidence of serious pest infestations (rodents, insects, birds, etc., including decomposed pests) inside the facility, including in pest control devices. Other key requirements – not auto-fails Pest Control: Pest control programs must be developed and monitored by licensed, certified pest control personnel. In the case of a country without this requirement, pest control personnel must be trained and have written protocol to demonstrate their understanding of pest control as it applies to food safety. Pest control program now required in harvest equipment storage buildings too Glove Policy Costco prohibits the use of Latex AND powder‐free Latex gloves. Hairnets: Costco requires the use of Hairnets, Beard nets and Moustache covers where applicable for packing house employees handling open product Trace Back / Mock Recall Exercise – Packinghouses Costco requires all packinghouses, coolers, cold storage and processing facilities to do a trace back AND Trace forward exercise at least twice a year (once for operations who are in production 6 months of the year or less). Documentation must indicate the date and time the exercise was initiated, product chosen, amount produced, affected lot codes, percent located, time exercise was completed. 100% of product should be located within two hours. Raw Material Sources – Packinghouses and Growers Costco entities/suppliers must have a program in place to approve and monitor their suppliers (all raw materials, ingredients and primary packaging). Their suppliers must provide them with a current (within 1 calendar year) third‐party food safety audit and a product specification sheet which includes product attributes, labeling and code dates. Additionally, facilities supplying raw materials and ingredients must be operating under a HACCP program Primary packing facilities must have an ongoing, documented monitoring program to evaluate primary packaging compliance to specifications, including a method to identify specific lot numbers. Food Contact Surfaces With the exception of commodities where using wooden bins is the industry standard, produce must not come in contact with surfaces which are not accessible and/or cannot be cleaned, including but not limited to the following: foam rubber, any type of carpet, non food grade plastic, etc. Miscellaneous o In all operations, hand washing must take place with soap and water. There is no approved substitute for hand washing, including hand wipes, sanitizer, etc. \ o Costco does not allow false nails or nail polish. o No drinking water (or any other beverage), in any container, is to be allowed on the packing line or processing floor. o Although countries outside the US may have different requirements, Costco does not allow any beverages on the packing line or processing floor. Employers must provide employees adequate fresh water supplies located in areas which do not create food safety hygiene issues. o Picking bags, gloves, knives and aprons must be covered under equipment storage and control procedures and be on a documented cleaning schedule. The grower is responsible to maintain cleanliness and good repair. o Toilet and hand washing facilities must be within a 5 minute walking distance for all employees. Even harvest employees o Finished product sell unit (for example, clam shell, bag, package, and carton) must be marked with a use‐by, sell‐by or packed‐on code that can be used for traceability/recall purposes. Julian dates are not acceptable. Suppliers should refer to item specifications, provided by Costco buyers. o Harvesting equipment must be on a documented cleaning and sanitizing program. A monitoring program to verify that successful cleaning and sanitizing of all product contact surfaces must be in place.