Courtney Pineau, associate director, Non-GMO Project, explained that manufacturers that want their products to carry the Non-GMO Project Verified mark must undergo evaluation with one of the independent technical administrators contracted by the organization. There are four such contractors that are trained to perform evaluations, which include analyzing ingredient statements from suppliers, material handling protocols, and potentially ingredient testing and facility inspection if there are high-risk ingredients. Once the technical administrator determines that a product is compliant with the Non-GMO Project Standard, certificate is issued and the product becomes eligible for display on the Non-GMO Project website and shopping app.
Sarah Krol, global managing director, food safety, NSF International, Michigan, explained the process whereby consumables are certified as non-GMO. NSF International is one of the few organizations authorized to provide Non-GMO Project verification for producers, manufacturers, retailers and restaurants. The key principles of the Non-GMO Project include analytical testing of high-risk raw material at critical points in the supply chain. The Project states the “goal of the Standard is to assist farmers, processors and manufacturers in avoiding GMO (genetically modified organism) contamination by providing consistency of definitions and methodology for investigating source materials, testing high-risk ingredients, and building identity preservation practices into the supply chain.”
Similarly, NSF International’s own certification, NSF Non-GMO True North, provides an exacting direction for producers, including ranchers, farmers, processors and manufacturers, to guide their practices when seeking non-GMO certification. These are the protocol’s requirements:
• Finished products with less than 0.9 percent GE content (5 percent for feed)
• Lifecycle feed requirements—upon weaning or first feed following birth
• Dairy: Milk cows fed non-GMO feed a minimum 30 days prior to first certified milking and thereafter
• Risk-based testing requirements (validated testing methods like PCR, ELISA, etc.)
• Annual audit (risk-based—desk versus onsite)
• No cloned animals
• Compliance management system with risk assessment
The process for either program includes several steps: scope and application, initial review, desk audit or inspection, technical review, resolution and finally, certification or verification, specifically as follows:
1. Application: Includes basic information about the product(s), ingredient(s) and, number of facilities as well as a risk assessment. Upon review of these documents a decision about an initial on-site audit will be made as well as sample testing.
2. Evaluation plan, documentation request and quote: NSF prepares an evaluation plan, document request and contract with a quote. It is important to note that the True North certification inspection can be combined with USDA (U.S. Department of Agriculture) Organic, NSF Gluten Free, SQF, BRC, GLOBAL G.A.P., PrimusGFS and CanadaGAP inspections.
3. Document submission: Details are submitted about the processes and product(s) for review including standard operating procedures, production facility information and test results.
4. Document review: NSF technical evaluator reviews the documents and clarifications may come after this review.
5. On-site inspection: An on-site inspection is scheduled. Records and procedures will be inspected and samples may be collected for testing.
6. Corrective action review and certification decision: Any required corrective action responses are reviewed for compliance and a certification decision is made.
7. Certification and ongoing compliance: Product(s) are approved for certification and eligible to use the either the Non-GMO project verification mark or the NSF Non-GMO True North mark depending on which certification protocol the client is seeking.