On this page
- What the requirement is, and why it exists
- Self-assessment structure and documentation rules
- Step-by-step procedure for completing internal self-assessments
- Example
- Before your audit
- Questions people ask
- How often must a producer complete an internal self-assessment under Non-GM?
- Is a written comment required for non-applicable points in the self-assessment?
- Who can perform the internal self-assessment on an Option 1 single farm?
- How long must completed Non-GM self-assessment checklists be retained?
- Reference documents
The short version
- Producers must perform an annual documented internal self-assessment covering all Module 2 control points before external audits.
- Every non-applicable control point in the self-assessment checklist must include a clear written justification.
- The self-assessment must evaluate facility descriptions, feed risk analyses, conversion tracking, and five-year document archives.
- Identified non-conformances must be corrected with documented corrective actions prior to the certification body inspection.
What the requirement is, and why it exists
Under the GLOBALG.A.P. Non-GM Add-on Standard Module 2 Farm/Producer Version 1.1, producers must perform an annual internal self-assessment against the complete Non-GM checklist. Control Point NON-GM FARM 2.5 establishes that this self-assessment must be documented, completed in full, and maintained on file prior to the certification body inspection. This mandatory requirement applies to Option 1 individual producers and Option 2 producer group members producing livestock or farmed aquatic species.
The primary objective of the internal self-assessment is ensuring continuous operational verification between external certification audits. Rather than relying solely on annual third-party inspections, producers must systematically review their own facility descriptions, feed purchasing logs, storage segregation, and conversion tracking. Self-evaluations enable farm managers to identify potential contamination risks, operational gaps, or recordkeeping errors before they result in audit non-conformances.
Compliance leads and internal auditors must recognize that Control Point NON-GM FARM 2.5 is classified as a Major Must. Completing the self-assessment partially or omitting required justification comments for non-applicable criteria constitutes a direct Major Must non-conformance. Demonstrating a fully completed self-assessment proves active management commitment and establishes a verifiable baseline for non-GM supply chain integrity.
Self-assessment structure and documentation rules
Executing a compliant self-assessment requires evaluating all principles and criteria contained in Module 2. The evaluation must cover administrative governance, facility risk assessments, species conversion periods, document retention, and feed handling protocols. Producers must utilize the official GLOBALG.A.P. Non-GM add-on checklist to ensure every control point is systematically audited.
A critical requirement of Control Point NON-GM FARM 2.5 is the mandatory recording of comments for every non-applicable control point. If a control point does not apply to the specific farm operation, the auditor or producer cannot simply leave the field blank or mark non-applicable without explanation. Management must record a clear, site-specific justification explaining why the criterion does not apply to the physical scope.
Important: Option 2 producer group members must complete internal self-assessments, while the central Quality Management System conducts annual internal inspections of all registered group members under Control Point NON-GM FARM 3.1.
| Requirement | What the auditor checks | Evidence to have ready |
|---|---|---|
| Control Point NON-GM FARM 1.1 | Verification that the documented facility description matches current physical feed flows | Updated facility sketch, feed storage layout, and written process description |
| Control Point NON-GM FARM 2.1 | Review of the on-farm risk assessment evaluating potential GM feed contamination points | Documented risk analysis covering feed intake, equipment, and species commingling |
| Control Point NON-GM FARM 2.3 | Verification that species-specific feed conversion periods in ANNEX 1 are fully met | Feeding logs, livestock movement records, and previous owner Non-GM statements |
| Control Point NON-GM FARM 2.5 | Review of the documented annual self-assessment completed prior to the CB audit | Fully completed Module 2 self-assessment checklist with non-applicable comments |
| Control Point NON-GM FARM 4.1 | Examination of the five-year document archive preserving Non-GM compliance records | Archived feed delivery bills, invoices, analytical tests, and self-assessments |
| Control Point NON-GM FARM 5.5 | Audit of feed mixing and grinding equipment flushing logs to prevent carryover | Equipment flushing records and annual ISO 17025 GMO test analysis reports |
Step-by-step procedure for completing internal self-assessments
Performing an effective self-assessment requires a structured review process across farm management, feed procurement, and operational storage. Internal auditors must examine physical facilities and verify supporting records against actual working practices. To ensure full compliance, producers must follow a standardized five-step self-assessment procedure:
- Download the current GLOBALG.A.P. Non-GM add-on Module 2 checklist and assemble all feed delivery notes, supplier declarations, and feeding logs.
- Conduct a thorough physical walk-through of feed storage areas, mixing equipment, and livestock or aquaculture housing units.
- Complete every checklist item, marking compliance status and writing detailed comments for every non-applicable control point.
- Document corrective action plans for any identified non-conformances, specifying responsible personnel and closure deadlines.
- Sign, date, and archive the completed self-assessment checklist, ensuring availability for external certification body review.
Common finding: External auditors frequently issue Major Must non-conformances when producers leave non-applicable control point comments blank on the self-assessment checklist.
Note: Under Control Point NON-GM FARM 4.1, all completed self-assessment checklists and supporting corrective action files must be retained for at least five years.
Example
During an annual audit of a trout farm certified under IFA Aquaculture and the Non-GM Add-on, the certification body auditor reviewed the farm's internal audit records. The farm manager presented a completed Module 2 checklist signed two weeks prior to the audit. However, Control Point NON-GM FARM 5.5 regarding feed mixing equipment was marked non-applicable without any written explanation. The auditor raised two Major Must non-conformances under Control Point NON-GM FARM 2.5 and Control Point NON-GM FARM 5.5 for incomplete self-assessment documentation and missing flushing records.
To resolve the non-conformances, the farm manager updated the checklist to include a written comment explaining that the farm purchases hundred percent commercially manufactured compound feed and does not operate on-farm feed mixing or grinding equipment. The manager re-submitted the documented checklist to the certification body, closing the non-conformance.
Before your audit
- Verify that the annual Non-GM self-assessment is fully completed and dated before the external certification body audit.
- Ensure that every control point marked non-applicable contains a clear, written justification comment.
- Check that facility descriptions under Control Point NON-GM FARM 1.1 reflect all physical feed storage and intake locations.
- Confirm that species conversion tracking records demonstrate compliance with minimum feeding durations in ANNEX 1.
- Review incoming feed invoices and delivery notes to verify explicit Non-GM status statements under Control Point NON-GM FARM 5.2.
- Inspect mobile and stationary feed mixing equipment flushing logs if home-mixing operations are conducted on-site.
- Ensure that all self-assessment checklists, corrective action reports, and feed records are archived for five years under Control Point NON-GM FARM 4.1.
- Verify that any non-conformances identified during the self-assessment have documented corrective actions and closure evidence.
Questions people ask
How often must a producer complete an internal self-assessment under Non-GM?
Control Point NON-GM FARM 2.5 mandates that producers must complete an internal self-assessment at least once every twelve months. The self-assessment must be fully documented and finalized prior to the annual external certification body audit.
Is a written comment required for non-applicable points in the self-assessment?
Yes. Control Point NON-GM FARM 2.5 explicitly requires documented comments for every control point deemed non-applicable. Leaving non-applicable fields blank results in a Major Must non-conformance during the external audit.
Who can perform the internal self-assessment on an Option 1 single farm?
The producer, farm manager, or designated internal auditor may complete the self-assessment. The designated person must understand the Non-GM Module 2 requirements and have access to all facility records and operational areas.
How long must completed Non-GM self-assessment checklists be retained?
Control Point NON-GM FARM 4.1 requires producers to archive all completed self-assessment checklists, feed delivery notes, and compliance records for at least five years. These historical records must be accessible during certification body inspections.
Reference documents
- GLOBALG.A.P. Non-GM Add-on Standard Module 2: Farm/Producer, v1.1_Jan20, Section NON-GM FARM 1, Section NON-GM FARM 2, Section NON-GM FARM 3, Section NON-GM FARM 4, Section NON-GM FARM 5
- GLOBALG.A.P. General Regulations Rules for Individual Producers, v6.0_Sep22, Section 5.1
- GLOBALG.A.P. General Regulations Rules for QMS, v6.0_Sep22, Section 4.2
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