Calculating Minor Must threshold and 28-day corrective action rules

What the requirement is, and why it exists

Under the GLOBALG.A.P. General Regulations Rules for Individual Producers version 6.0, Option 1 individual producers must satisfy strict compliance thresholds to obtain and maintain certification. The certification framework divides principles and criteria into three distinct levels: Major Musts, Minor Musts, and Recommendations. Section 7.1.1 mandates that producers achieve 100 percent compliance with all applicable Major Musts, at least 95 percent compliance with all applicable Minor Musts, and full contractual compliance with the certification body agreement.

The primary objective of the 95 percent Minor Must threshold is establishing a measurable, standardized threshold for farm compliance while accommodating minor operational variations. Minor Musts address secondary risk controls, preventive maintenance, and detailed recordkeeping. While a single Minor Must omission does not automatically trigger audit failure, allowing unmonitored non-compliances would undermine supply chain integrity and food safety assurances.

When an audit reveals non-conformances, Section 7.4.3 defines the corrective action process. For subsequent audits, producers must close all identified non-conformances within a maximum period of 28 calendar days. Enforcing strict corrective action windows prevents unresolved operational gaps from persisting across production cycles and ensures swift risk remediation.

Mathematical calculation formula and rounding rules

Section 7.1.2 establishes the precise mathematical formula used by internal auditors and certification bodies to determine maximum allowable Minor Must non-compliances. The calculation subtracts non-applicable Minor Must criteria from the total number of Minor Must criteria, then multiplies the result by 5 percent: (Total Minor Musts - Not Applicable Minor Musts) x 0.05 = Total Allowable Minor Must Non-compliances. Internal auditors must apply this equation across all operational areas to establish the exact compliance threshold prior to the third-party inspection.

To maintain compliance integrity, Section 7.1.2 mandates a strict rounding rule. The calculated figure for allowable non-compliances must always be rounded down to the nearest whole integer. For example, if a checklist contains 67 total Minor Musts and 17 criteria are verified as not applicable, the applicable total is 50. Multiplying 50 by 0.05 yields 2.5 allowable non-compliances, which rounds down to 2.

Scores are calculated strictly without upward rounding. A final score of 94.8 percent cannot be rounded up to 95 percent. The producer fails the compliance threshold until sufficient Minor Must items are corrected.

Initial audit deadlines versus subsequent audit warning windows

The operational timeline for resolving non-conformances depends on whether the inspection is an initial certification audit or a subsequent annual audit. Quality managers must differentiate between these two audit scenarios to avoid unexpected certificate suspensions or re-audit penalties.

Under Section 7.4.3.1, an initial CB audit grants the producer a maximum window of three months from the audit date to achieve 100 percent Major Must and 95 percent Minor Must compliance. If the producer fails to close all non-conformances within three months, a complete re-audit must be conducted before certification can be granted.

For subsequent CB audits, Section 7.4.3.1 dictates that the certification body issues a written warning at the closing meeting detailing all non-conformances. The producer must close all non-conformances within a maximum of 28 calendar days. Quality leads managing complex farm operations may also use handling self-declared suspensions if operational difficulties prevent timely resolution without losing original anniversary dates. To successfully navigate the 28-day corrective action window, compliance managers must execute a structured four-step remediation workflow:

1. Review the provisional audit report issued at the closing meeting to categorize all identified Major Must and Minor Must non-conformances.
2. Conduct a root cause analysis for each non-conformance and assign corrective actions to responsible operational staff with strict internal 14-day completion targets.
3. Gather documentary and visual evidence, such as updated logs, photos, and calibration certificates, proving physical implementation of corrective measures.
4. Submit the complete corrective action package to the certification body well before the 28-day deadline to allow auditor review and verification.

Example

During a subsequent annual audit of an Option 1 table grape producer, the certification body auditor identified one Major Must non-conformance regarding pesticide storage labeling and three Minor Must non-compliances out of 40 applicable Minor Must items. The allowable Minor Must limit was 2 items (40 x 0.05 = 2.0), meaning the producer failed both the Major Must and Minor Must thresholds. The auditor issued a written warning with a 28-day closure deadline.

The compliance manager immediately installed correct chemical hazard labels and updated safety registers within 10 days. The manager submitted photo evidence and updated chemical logs to the certification body on day 12. The auditor verified the evidence and lifted the warning on day 18, enabling the certification body to issue the certificate within the mandated 28-day decision window under Section 7.1.3.

Before your audit

• Verify that all applicable Major Must criteria have verified evidence of full compliance during internal self-assessments.
• Calculate your exact Minor Must threshold using the rounding down formula to determine your maximum allowable non-compliances.
• Ensure that every non-applicable Minor Must item in the self-assessment checklist includes a clear written site-specific justification.
• Review parallel production records if applicable, ensuring compliance with parallel ownership rules for certified and non-certified lines.
• Establish an internal corrective action team capable of responding to provisional audit warnings within 14 calendar days.
• Confirm that emergency contacts and calibration certificates are updated and immediately available for auditor inspection.

Questions people ask

How is the allowable number of Minor Must non-compliances calculated?

Section 7.1.2 calculates the limit by subtracting non-applicable Minor Musts from total Minor Musts, multiplying by 5 percent, and rounding down to the nearest whole integer. For example, 45 applicable Minor Musts multiplied by 0.05 equals 2.25, which rounds down to 2 allowable non-compliances.

Can a Minor Must score of 94.7 percent be rounded up to pass?

No. Section 7.1.2 explicitly prohibits rounding up percentage scores. A score of 94.7 percent or 94.8 percent is below the mandatory 95 percent threshold and results in a non-conformance.

What happens if a producer fails to close non-conformances within 28 days during a subsequent audit?

Under Section 7.4.3.2, if non-conformances are not resolved within the defined period of up to 28 calendar days, the certification body must impose a certificate suspension within 24 hours. The suspension remains in effect until verified corrective evidence is accepted or certificate cancellation occurs.

What is the deadline for a certification body to make a certification decision?

Under Section 7.1.3, the certification body must make the final certification decision within a maximum of 28 calendar days after closure of all outstanding non-conformances, or within 28 days of the closing meeting if no non-conformances were found.

Reference documents

• GLOBALG.A.P. General Regulations Rules for Individual Producers, v6.0_Sep22, Section 6.2, Section 7.1, Section 7.4
• GLOBALG.A.P. General Regulations Rules for Certification Bodies, v6.0_Sep22, Section 8.1, Section 11.3