For an operation involved in production:
The auditee is expected to ask his or her immediate buyer (e.g., packer, shipper, wholesaler, broker, etc.) if the product will be sold outside of Canada. The buyer should know if there are foreign customers, and can provide information to the auditee about agricultural chemical specifications. The auditee needs to know before spraying, if there are agricultural chemicals that shouldn’t be used or if the label directions are appropriate.
Asking the questions may prompt the buyer(s) to make some inquiries of their own, and get back to the operation with more information. If this information is not available, there is nothing more that the auditee can do. He has done his due diligence and tried to get as much information as possible before the application of the agricultural chemicals.
The CanadaGAP auditor will want to know if the auditee has had this conversation (verbally) with his/her buyer. The auditor should also ask to see if the auditee’s buyer has provided handouts or other sources of information on MRLs, or about which chemicals can or cannot be used, etc. There should be proof that this communication has taken place.
For an operation involved in packing, storage, repacking, wholesaling or brokerage:
The auditee will need to be aware of different MRLs for the countries that the product is being exported to. They need to know that the product that is being shipped to these countries has met any restrictions on agricultural chemical usage. The only way for the auditee to know destination market MRLs are being respected is to communicate with their suppliers who are actually doing the spraying.
There should be proof that this communication has taken place and that the auditee has considered the MRLs. Some acceptable forms of proof may include:
- Having copies of Form H1 from the operations who are supplying product (H1 will have information on what is sprayed, rate, etc.)
- A letter that was sent to all suppliers, clearly setting out expectations for suppliers to meet foreign country MRLs, and information about those MRLs (e.g., list of MRLs for specific destinations, website URLs or other sources of information, etc.)
- A list that was provided to all suppliers clearly outlining which agricultural chemicals can and cannot be used.
- Proof of residue testing that was carried out to ensure suppliers were following the MRLs.
For further information refer to Appendix Q: Documentation Requirements on Agricultural Chemicals for Exported Product.