Managing high-risk subcontractor audits under IFA Aquaculture v6

Regulatory framework and risk classification for subcontractors

Managing outsourced activities is a critical compliance mandate for aquaculture producers and Quality Management System leads operating under Integrated Farm Assurance version 6. When a primary producer or producer group outsources postharvest handling, processing, stunning, or slaughtering tasks to an external facility, the certificate holder retains full regulatory accountability for product integrity. Section AQ 05 and Section AQ 28 establish the operational criteria governing subcontractor management.

Principle AQ 28.01.06 requires producers to maintain an up-to-date register of all subcontractors and classify them based on the risk of misidentification, substitution, or product dilution. Subcontractors engaging in processing, repacking, relabeling, stunning, slaughtering, or handling unpacked bulk products are classified as high-risk subcontractors. Conversely, entities limited to storing and transporting packed, sealed, and labeled goods with zero risk of identity modification are categorized as low-risk subcontractors.

This regulatory framework affects Option 1 individual producers, Option 2 producer groups, internal QMS auditors, and external certification bodies. The standard ensures that critical food safety, animal welfare, environmental protection, and traceability controls are maintained continuously across off-farm operations. Ignoring subcontractor classification or failing to verify external audit credentials risks major non-conformances and certificate suspension.

Audit options and letter of conformance requirements for high-risk sites

Principle AQ 28.01.07 defines two distinct pathways for demonstrating compliance at high-risk subcontracted postharvest units. High-risk subcontractors must either be audited annually by an approved certification body within the producer's certification scope or hold an independent valid GLOBALG.A.P. Chain of Custody or Integrated Farm Assurance certificate. This dual pathway provides flexibility while upholding strict auditing rigor.

When an external certification body audits a subcontractor directly on behalf of a producer under Principle AQ 05.01, the certification body must issue a formal letter of conformance. This letter serves as mandatory compliance evidence for subsequent audits and must contain five specific elements:

• Assessment date: The exact date on which the certification body conducted the physical assessment at the subcontractor facility.
• Certification body details: The official name and identification details of the approved certification body issuing the document.
• Auditor identity: The full name of the qualified auditor who conducted the site inspection.
• Subcontractor details: The legal company name, facility address, and operational scope of the subcontracted unit.
• Assessed principles and criteria: A detailed list specifying all principles and criteria evaluated during the audit.

Welfare and environmental controls at subcontracted slaughter units

Subcontracted slaughterhouses and primary processing units must comply with stringent technical requirements beyond general food safety. Principle AQ 25.01.01 and Principle AQ 26.01.03 mandate that all harvest and slaughter workers receive species-specific animal welfare training covering handling, stunning, and bleeding. Furthermore, Principle AQ 26.01.04 requires effective stunning to ensure animals immediately become unconscious prior to bleeding.

Environmental and biosecurity controls are equally critical during subcontracted slaughtering operations. Principle AQ 26.02.01 and Control Point CoC-SC 6.20 dictate that all blood waters generated during stunning and bleeding must be contained, treated, and disposed of safely to eliminate veterinary or environmental threats. In addition, Principle AQ 26.01.01 requires processing plants to maintain a structured feedback system communicating health indicators back to grow-out farms.

Comparison of subcontractor risk classes and verification methods

What to do now

• Maintain comprehensive subcontractor registers: Review all contracted processing and slaughter facilities to ensure complete records, risk classifications, and verification dates are documented.
• Verify independent certification credentials: Check the GLOBALG.A.P. IT platform annually to confirm that subcontractor Chain of Custody or Integrated Farm Assurance certificates remain active.
• Obtain formal letters of conformance: Ensure direct certification body audits of uncertified subcontractors yield complete letters of conformance containing all five mandatory data fields.
• Establish welfare feedback loops: Implement documented communication channels with subcontracted processing plants to receive harvest welfare indicators and post-slaughter health data.

Reference documents

• GLOBALG.A.P. Integrated Farm Assurance Smart/GFS – principles and criteria for aquaculture, v6.0_Mar23, Section AQ 05, Section AQ 25, Section AQ 26, Section AQ 28
• GLOBALG.A.P. Chain of Custody – control points and compliance criteria, v6.1_Nov22, Section CoC-SC 1.7, Section CoC-SC 6
• GLOBALG.A.P. general regulations – Rules for Quality Management System, v6.0_Sep22, Section 4.8 d