GENERIC MANUAL ON QUALITY MANAGEMENT SYSTEM FOR SMALLHOLDER HORTICULTURAL FARMER GROUPS IN KENYA FOR CERTIFICATION TO EUREPGAP OPTION 2

Transcription

1 Page 1 of 127 GENERIC MANUAL ON QUALITY MANAGEMENT SYSTEM FOR SMALLHOLDER HORTICULTURAL FARMER GROUPS IN KENYA FOR CERTIFICATION TO EUREPGAP OPTION 2 Prepared by: Agribusiness & Allied Kenya Ltd (Nairobi Kenya) Standards & Solutions Consulting Ltd (Nairobi Kenya) The International Centre of Insect Physiology & Ecology (Nairobi Kenya) November 2006

2 Page 2 of 127 TABLE OF CONTENTS ACKNOWLEDGEMENT... 7 PREAMBLE... 7 PART 1: QUALITY MANAGEMENT SYSTEM... 8 Introduction Structure of Internal Quality Management and Control System (ICS) Organization brief Legality (Legal entity) Administrative structure Management structure Responsibilities and duties Group overall policy Group s goals Training and advice to farmers Quality Manual Document control Record control Complaints handling Internal audit/ inspection and management review Traceability and product segregation Sanctioning Withdrawal of certified products Use of EUREPGAP logo Subcontractors/service providers Sales and Distribution PART II: CONTROL POINTS AND COMPLIANCE CRITERIA Processes in KSHG Production Traceability Record keeping and internal self-inspection Choice of variety Site history and site management Risk assessment for new agricultural site Site management Crop rotation Soil management Fertilizer usage and storage KSHG fertilizer use policies Fertilizer application records Fertilizer application machinery Fertilizer stores Irrigation... 24

3 Page 3 of Predicting water requirements Irrigation method Quality of irrigation water Effective ways of irrigating Pesticide usage and storage KSHG pesticide policies Sprayer calibration and maintenance Disposal of empty pesticide containers, surplus pesticide, tank washings and obsolete pesticides Pesticides application records Pre-harvest interval Pesticides stores Personal protective equipment Harvesting Collection centres Waste and pollution management Pollution management plan Waste management Worker health, safety and welfare Environmental issues Bibliography Terms and definitions ANNEX 1: STANDARD OPERATING PROCEDURES PART 1 (QMS) A Procedure for Training A Document and Record Control Procedure A Complaints Handling Procedure A Internal Audit Procedure A Corrective Action Procedure A Traceability Procedure A Procedure for Sanctions and Appeals A Produce Recall Procedure A Use of EUREPGAP Logo, Trademark and Registration Number Procedure A Procedure for Sub-Contractors ANNEX 1 STANDARD OPERATING PROCEDURES PART II (CPCC) B Seeds Procurement Procedure B Site History and Site Management Procedure B Fertilizer Use Procedure B Water Management Procedure B Compliance With Pre-Harvest Intervals Procedure B Maintenance and Calibration of Equipment Procedure B MRL Sampling Procedure B Pesticide Preparation and Mixing Procedure B Harvesting Process Hygiene Procedure... 67

4 Page 4 of B Collection Centre Hygiene Procedure B Emergency Procedures B Personal Protective Equipment Cleaning Procedure ANNEXES 2 FORMS - PART 1 (Quality Management System) A Farmer Register A Training Attendance Record A Training Record A Internal Documents Master List A External Documents Master List A Record Master List A Documents/Records Issue Register A Complaints Logs A Audit Program Form A Audit Plan Form A Audit Summary Report A Corrective Action Report Form A Approved Suppliers/Subcontractor List A Inputs Checklist A Transport/Vehicle Checklist A Supplier Evaluation Checklist ANNEX 2 FORMS PART II (CPCCs) B Planting Calendar B Seed Variety List B Seed Treatment Record B Crop History Record B Crop Rotation Plan B Scouting Record B Calibration Record B Farmer MRL Testing Plan B Stock Inventory B Cleaning Schedule B Waste and Pollution Management ANNEX 3: CONTRACTS A Farmer vs. Farmer Group Contract (A guide to drawing a contract) B Farmer Group vs. Service Provider Contract (A guide to drawing a contract) C Farmer Group vs. Exporter Company(s) Contract (A guide to drawing a contract) ANNEX 4: JOB DESCRIPTION AND SPECIFICATION Production Manager Technical Manager Agronomist EUREPGAP Internal Auditor Technical Assistant Collection Center Head

5 Page 5 of Sprayer Operator ANNEX 5 RISK ASSESSMENT GUIDELINES ANNEX 6. ENVIRONMENT MANAGEMENT PROTOCOL

6 Page 6 of 127 LIST OF ABBREVIATIONS ADM - Administration BSMDP - Business Services Market Development Project CAR - Corrective Action Request CB - Certification Body CC - Collection Centre CCP - Critical Control Point CPCC - Control Points Compliance Criteria DFID - Department for International Development of the United Kingdom GMO - Genetically Modified Organism GTZ - Gesellschaft fur Technische Zusammenarbeit GmbH PSDA - Promotion of Private Sector Development in Agriculture HACCP - Hazard Analysis Critical Control Point ICIPE - International Centre of Insect Physiology and Ecology ICS - Internal Control System ID - Identification IPM - Integrated Pest Management KSHG - Kenya Smallholder Growers LPO - Local Purchase Order MD - Managing Director MN - Manual MRL - Maximum Pesticide Residue Level NGO - Non - Governmental Organization PCN - Produce Collection Note PHI - Pre-Harvest Interval PL - Plan PMO - Produce Marketing Organization PPE - Personal Protective Equipment PR - Procedures PRN - Produce Receipt Note QMR - Quality Management Representative. QMS - Quality Management System REC - Records REV - Revision SCH - Schedule TA - Technical Assistant WHO - World Health Organization

7 Page 7 of 127 ACKNOWLEDGEMENT Development of the Generic Manual on Quality Management System for Smallholder Horticultural Farmer Groups in Kenya for EUREPGAP Certification under Option 2 was financially supported by BSMDP (DFID funded Project) and GTZ Germany. Technical facilitation in the development of the manual was provided by GTZ Germany. The support of GTZ-PSDA (Ministry of Agriculture Kenya) in this initiative is highly appreciated. Equally appreciated is the enthusiastic participation of export smallholder horticultural farmer groups, especially through their animated discussions and experiences, which contributed more to the development of this manual than they would realize. Contribution of horticultural exporters in this endeavour is duly acknowledged. This manual is an output of the BSMDP / GTZ Generic QMS Manual Testing Project managed by the International Centre of Insect Physiology and Ecology (ICIPE) Technology Transfer Unit. It has been moderated and prepared by Agribusiness & Allied Kenya Ltd (Nairobi Kenya), Standards & Solutions Consulting Ltd (Nairobi Kenya) and ICIPE (Nairobi Kenya) PREAMBLE The Internal Quality management and Control System (ICS) is a key element in group certification under option 2 of the EUREPGAP Standard. The ICS is described in different documents that have been compiled in this "Quality Manual" for a smallholder farmer group. The manual defines an outline structure of the quality system and serves as a reference in the implementation and maintenance of the quality system. It contains policies and procedures that demonstrate that the group is able to control the principal requirements of the EUREPGAP Standard. In this document a fictional group referred to as Kenya Smallholder Growers (KSHG) has been considered. This doc)ment can /e )sed as a startin1 2oint to de3e4o2 a 1ro)2 5)a4it6 man)a47 ada2tin1 its contents accordin1 to the sit)ation o8 the 8armers and the s2eci8ic circ)mstances 9ithin the 1ro)2:s; /)t ens)rin1 that the re5)irements o8 EUREPGAP Standard are neither 4o9ered nor com2romised. The EUREPGAP normative documents (EUREPGAP General Regulations, EUREPGAP ;P;;, EUREPGAP <=S ;hec?list, and EUREPGAP ;P;; ;hec?list) are not attached to this manual but are freely accessible from EUREPGAP website :htt2cdd999ee)re2eor1; In this document it is assumed that smallholder farmer groups lack the technical capacity required for the running of the EUREPGAP quality management system. The farmer groups may therefore rely on the services from either private service providers (e.g. private consulting companies, produce marketing organizations) or exporters.

8 Page 8 of 127 PART 1: QUALITY MANAGEMENT SYSTEM Introduction This Quality Manual, documents the Internal Quality Management and Control System (ICS) of the Kenya Small Holder Growers (KSHG) as required by the EUREPGAP Standard. It contains the quality policy and quality goals of KSHG. Processes and procedures as well as responsibilities are described in detail. The manual is obligatory for all permanent and subcontracted staff of KSHG involved in the operation of the ICS. The ICS is based on the normative documents of EUREPGAP to which reference is made in the individual sections. The same applies to relevant national or European legislation. The contents of the manual are reviewed periodically to ensure that they continue meeting the requirements of the EUREPGAP Standard and those of KSHG 2.0 Structure of Internal Quality Management and Control System (ICS) 2.1 Organization brief The Kenya Small Holder Growers (KSHG) was established in... Currently the group has 72 registered members coming from three rural villages in the Mt. Kenya region. Members are dedicated to fresh fruits and vegetables production on a total of...hectares. Twenty-five out of the 72 members are currently EUREPGAP registered farmers cultivating an area of. hectares. KSHG runs a collection centre that is located at the local market. KSHG provides an environment, which fosters the growth of cooperative marketing through longterm contracts with reliable buyers. The group is seeking representative dialogue with authorities and is offering opportunities for education, networking and training to its members. Special emphasis is given to information of members concerning legislative changes in the area of food safety and quality. A general description of the work of KSHG, rights and obligations of their members, different types of membership etc. can be found in the constitution of the group. KSHG operates on the basis of funds that come from membership fees, deductions from produce payment, bank interest and fines imposed as per the group by-laws. Additional funding may be obtained from the government, industry and/or NGOs. Contact details: Group Chairman, Kenya Smallholder Growers, P.O. Box XXXX, Kenya. Tel: xxxx KSHG@xxxx

9 Page 9 of Legality (Legal entity) KSHG is a non-political, non-sectarian, non-profit organization that was formally registered on the.. day of.. under the "Ministry of Culture and Social Services". Registration Number: YYYYY. With regard to EUREPGAP, there are well-defined relations between farmers and KSHG, mainly through the ICS and contractual agreements. A Farmer Register will be maintained and regularly updated of all farms and produce collection sites according to the standard form (KSHG/REC/2.1.4A, Annex 2). A contract is drawn with the individual farmers (See Annex 3 for Guidelines). This contract details the respective obligations of KSHG and the farmer, especially his/her commitment to comply with the requirements of the EUREPGAP Standard and his/her agreement to comply with KSHG's documented procedures, policies and technical instructions. Procedure for Sanctions and Appeals (KSHG/PR/2.10A, Annex 1) of the ICS, which defines sanctions and appeals in the case of non-compliance, is an integral part of the contract Administrative structure Figure 1 illustrates the administrative structure of KSHG. It shows the extent to which farmers are involved in the decision making process related to horticultural growing and marketing Management structure As pointed out, KSHG lacks the technical capacity required for the running of the EUREPGAP quality management system. The farmer group therefore relies on the services from private competent service providers in order to ensure effective and efficient management of the KSHG QMS. KSHG has contracted private service provider firm to manage its system. KSHG has signed a technical contract (KSHG/PR/2.13A) (Annex 2 for Guidelines) with the service provider for the provision of various services in order to comply with the EUREPGAP Standard. The following are the key staff provided by the contracted service provider involved in the management of KSHG (Figure 2): Production Manager/EUREPGAP Management Representative. Technical Manager who also acts as the Quality Management Representative (QMR) Agronomist who is in charge of agriculture technical advice department and its staff EUREPGAP Internal Auditor Collection Centre Head However, in terms of function, a single individual can hold more than one position. For example, a Technical Assistant can carry out duties of Agronomist ; A Technical Manager can be in charge of Internal Audits (Figure 2).

10 Page 10 of 127 GENERAL ASSEMBLY GROUP MANAGEMENT COMMITTEE -EXECUTIVE MEMBERS (Chairperson, Secretary, Treasurer) -ORDINARY MEMBERS INDIVIDUAL MEMBER/FARMER KEY Reporting Channel Authority Channel Figure 1. Relationship between KSHG and registered farmers

11 Page 11 of 127 Technical manager /QMR EUREPGAP management representative/production manager Agronomist Internal auditor Collection Centre Head Technical Assistant Sprayer operators Individual farmer Private Service provider(s) / Extension personnel of exporter(s) or PMO(s) Provide technical services to individual farmers of the group KEY Reporting Channel Authority Channel Figure 2. Management structure

12 Page 12 of Responsibilities and duties The staff involved in the ICS has specific qualifications, competence and experience required to make technical judgments, carry out internal inspections and implement quality management policies. Qualifications, duties and responsibilities of key staff are defined in a job description (Annex 4). Every staff has to keep abreast of developments, legislative changes and other issues relevant in the certification process. Performance reviews are carried out routinely to find out training needs. Personnel training to update on recent developments of the standard, improve the quality of work and promote personnel development are carried out annually (Training Procedure KSHG/PR/2.3A, Annex 1). Contracts (KSHG/PR/2.13A) specify that work has to be done in accordance with the requirements of the EUREPGAP Standard and KSHG's quality policies and procedures. Who evaluates competence, is there a matrix? Group overall policy KSHG is committed to quality and safety of all fruits and vegetables produced by its members in a view of increasing their shares in international, especially European markets. KSHG is promoting socially, ecologically and economically sustainable farming practices in a pro-active way. Members are assisted in implementing integrated crop and pest management in their farms. KSHG is particularly committed to reducing the risk of pesticide use through adoption of the safest viable pest management practices, which can reduce residues, worker exposure, and ground water contamination. KSHG considers the implementation of good agricultural practices and particularly compliance with local and international pesticide legislations as important competitive advantages for maintaining and expanding access to export markets. Members are enabled to comply with the ever-increasing quality and safety requirements. Group certification is intended to reduce the overall cost of certification to the EUREPGAP Standard. KSHG is fully aware that successful work requires competent staff. For this reason, great importance is attached to training and equipment of its staff Group s goals The Group s goals and ongoing commitments vis-à-vis their members are to: Grow and market horticultural produce that meets quality, safety and legal requirements. Provide training and advice to its members on production and post-harvest handling, storage practices and technology Organize events and disseminate information to its members Provide up-to-date market and trade opportunities information to its members Achieve EUREPGAP group certification with all of their members through implementing systems of good agricultural practices and internal quality control that meet the requirements of the EUREPGAP Standard Collaborate with other organizations with similar interest in pushing legislative action to change and/or improve government policies and regulation affecting the industry

13 Page 13 of 127 Carry out any other activity that is considered to be of benefit to the members but within the legal framework of the group 2.3 Training and advice to farmers KSHG is convinced that technical assistance and training for their members are indispensable services in order to minimize risks that may arise from ignorance, misunderstandings etc and may result in having the group certificate suspended or cancelled. Practical advice on how to implement the EUREPGAP CPCC and information about any modification and/or revision of the EUREPGAP Standard is given by the service provider. This is compulsory for all contracted farmers. Further training is provided on special events (e.g. field days), by the service provider in close collaboration with Government extension agencies, NGOs, etc. KSHG commits itself through the service provider in the production of training materials (e.g. IPM manuals) that are not otherwise available, and to elaborate standardized forms / instructions for the recording system on the farms. KSHG through the service provider also publishes the KSHG newsletter annually where frequently asked questions and related answers are featured in the EUREPGAP section. The training is done as per the Training Procedure (KSHG/PR/2.3A, Annex 1). The trainings records are maintained (Training Attendance Record, KSHG/REC/2.3.1A; Training Record KSHG/REC/2.3.2, Annex 2) 2.4 Quality Manual KSHG has documented its ICS in this document that provides the Quality Management System of the group. The Farmer Group policies and procedures are provided in this manual. The contents of the manual are reviewed periodically to ensure that they continue meeting the requirements of the EUREPGAP Standard and those of KSHG. 2.5 Document control The documentation relevant for the operation of the ICS comprises the Quality Manual including operational procedures, work instructions (where applicable), recording forms and external standards. KSHG has created a system of documents and records keeping, which guarantees integrity and transparency of all the relevant operations of the ICS. Procedure for document/record control (KSHG/PR/2.5A, Annex 1) defines this. Internal and external document master list are maintained (KSHG/REC/2.5.1A, KSHG/REC/2.5.2A,Annex 2) 2.6 Record control KSHG recognizes the fact that Records form part of the documentation to provide evidence that the system is being implemented as planned. It is therefore a responsibility of each personnel to ensure that records generated are maintained as per the procedure for document/record control. The minimum retention period for records is 2 years. A record master list is maintained (KSHG/REC/2.5.3A, Annex 2). A document/record issue register (KSHG/REC/2.5.4A, Annex2) is used when issuing documents or records.

14 Page 14 of Complaints handling The ability to effectively manage customer complaints is considered essential to the success of KSHG. If a buyer has reason to complain, for example on the presence of a pesticide residue above set MRL, this may have serious consequences for individual farmers, such as the withdrawal (recall) of products, cancellation of individual registrations etc. Depending on the circumstances, such events may also result in a loss of credibility of the entire Farmer Group. For this reason complaints are handled by the Production Manager him/herself in order to find out whether the problem is a singular event or reveals a general lapse in the system. KSHG has a Complaints Handling Procedure (KSHG/PR/2.7A, Annex 1) & Corrective Action Procedure (KSHG/PR/2.8.4A, Annex 1) in place that guarantees that customer complaints are thoroughly recorded, investigated and followed up. Records associated with the complaints (KSHG/REC/2.7A, Annex 2 and corrective action (KSHG/REC/2.8.4A, Annex 2) are maintained. 2.8 Internal audit and management review KSHG has implemented a system for internal audits as required by EUREPGAP Standard. Each registered farmer shall be audited once per year against the EUREPGAP CPCC based on the current EUREPGAP Checklist. Procedures for internal audits (KSHG/PR/2.8A, Annex 1) describe in detail, how audits are to be undertaken and how results are documented. Based on the audit report that reveals the result of the evaluation including any non-compliance, the internal auditor will decide on the farmer's status: approved, suspended or cancelled (KSHG/PR/2.8.4A and KSHG/PR/2.10A). The adequacy and compliance of the quality management system with the EUREPGAP Standard will be assessed annually by an internal audit under the responsibility of the internal auditor. The evaluation follows an audit program (KSHG/REC/2.8.1A, Annex 2, audit plan (KSHG/REC/2.8.2A, Annex 2) and includes all elements of the ICS as per the audit checklist (EUREPGAP CPCC Checklist). It is ensured that the current EUREPGAP QMS Checklist for farmer group quality management system is being used.the main purpose of the audit is to find out, if the operating procedures have proven feasible and produce the expected results. In addition, an annual management review is carried out in order to verify the continued effectiveness and efficiency of the ICS. After the audit or inspection is done, a summary audit/inspection report is prepared (KSHG/REC/ A, Annex 2). 2.9 Traceability and product segregation KSHG operates a traceability system to ensure that all EUREPGAP registered products are traceable to the production site and tracked forward to the immediate customer. The system also ensures that the products are handled in a manner, which prevents mixing with non-eurepgap registered products. This traceability system forms a key element of the contractual agreements with farmers and farmers groups. The traceability and product segregation policy and procedure (KSHG/PR/2.9A, Annex 1) is binding to all individual member farmers.

15 Page 15 of 127 KSHG farmers place clear and unique visual identification on each and every block where the produce is grown. Produce is traced to the farmer level and also to the individual block where the crop is grown. Specific records concerning particular block production activities are also available at the collection centre office. These records are used to identify possible sources of problems at farmer level. The KSHG traceability and segregation procedure details how a KSHG EUREPGAP registered product can be traced back to the individual farmer and production block where the crop was grown and tracked forth to the immediate customer. Products meeting the requirements of the EUREPGAP Standard and marketed as such are traceable and handled in a manner that prevents mixing with non-eurepgap registered products. The traceability system is tested once per year to ensure that all of the relevant production, harvesting and packing information can be successfully retrieved Sanctioning The types of sanctions that will be applied to non-compliances of control points and to contractual issues are defined in accordance with EUREPGAP General Regulations and include the levels of warning, suspension and cancellation. The Sanctions Procedure and Appeal (KSHG/PR/2.10A, Annex 1) contains a catalogue of sanctions and is an integral part of the contracts with individual farmers. Suspensions or cancellations of registered farmers are immediately notified to the CB. Records are maintained of all sanctions including evidence of subsequent corrective actions and decision making processes Withdrawal of certified products KSHG has established a Product Recall Procedure (KSHG/PR/2.11A, Annex 1) containing the operating plan which will be executed in the event that a product problem is discovered which has the potential to affect the health of consumer, violates food safety regulations of the importing country, or could cause adverse public consequences for KSHG. The procedure will be tested annually in order to make sure that it can be effectively operated at any time should that be required 2.12 Use of EUREPGAP logo Use of the EUREPGAP logo, trademark and registration number is made in accordance with the EUREPGAP scheme requirements. KSHG has established a procedure (KSHG/PR/2.12A, Annex 1), which describes in detail the conditions of use and its control. Farmers have the contractual obligation to refrain from any unauthorized use of EUREPGAP trademark, logo and/or registration number.

16 Page 16 of Subcontractors/service providers KSHG contracts service providers through contract agreement that specify that the service providers must work in accordance with the Farmer Group Quality System and relevant procedures (Annex 3 for Guidelines). Service providers are evaluated before engagement as per supplier evaluation checklist (KSHG/REC/ A, Annex 2) and re-evaluated at least once in a year. An approved suppliers list (KSHG/REC/2.9.1A, Annex 2) is maintained. Inputs are verified as per the Inputs checklist (KSHG/REC/ A, Annex 2) are verified and when non-conformances are detected, the Corrective Action Procedure (KSHG/PR/2.8.4A, Annex 1) is applied. 3.0 Sales and Distribution KSHG sells their produce at the collection centre. Long-term links with a small number of exporters or produce marketing organization are preferred to a large number of different clients. The main advantage is seen in a reduced number of product specifications, which allow for concentration on the essential quality and safety aspects. Further benefits are better communication and higher commitment. This is particular important when problems have to be sorted out. Exporters/PMO are supposed to be an important source of information, e.g. on new market requirements or legislative changes in importing countries. Exporters may also be allies in the struggle for better infrastructure, legislation etc in our country. Close contacts to our customers are therefore a top priority. Vehicles transporting the produce are subject to quality checks as per transport/vehicle checklist (KSHG/REC/ A,Annex 2). PART II: CONTROL POINTS AND COMPLIANCE CRITERIA 4.0 Processes in KSHG 4.1 Production Traceability KSHG requires all its members to divide their plots into smaller production units called blocks. The size of the blocks must be measured accurately for the purposes of estimating the amount of inputs needed. Each block must be identified with a signboard indicating the name of the farm and block number. Any seed received and planted must have all details recorded including, the name of the supplier, date of purchase, lot number or batch, variety and name of particular seed treatment(s). Records of all inputs and outputs to a block including fertilizers and pesticides must be recorded as well as the personnel involved.

17 Page 17 of 127 Other traceability measures taken by the group include: Not mixing produce coming from different farms. Packing produce by batches depending on the origin of production. Establishing the list of the personnel used both for the harvest as well as in the plant and keep attendance sheets. Keeping technical sheets of the chemical products and detergents used for cleaning or controlling parasites or pests. The system of traceability used includes a minimum of documents indicating the origin of the product as well as a means of marking (e.g. crate label) which, ideally would enable to follow it throughout the whole commercialization process. Please refer to Farm Processes Flow chart (Figure. 3) for a summary of the traceability system. Risk assessments are carried out before each major process is implemented. A summary of guidelines on the various risk assessments appears in Annex Record keeping and internal audits A master list of all records (KSHG/REC/2.5.3A, Annex 2) as required by the quality system is kept and indicates the responsibility for records. KSHG requires that all records are up to date, legible, genuine and accurate. The Agronomist and QMR periodically check the integrity of all records as a basis for planning and follow-up. Every year a new set of records is started and old ones stored safely as described in Documents and Record Control Procedure (KSHG/PR/2.5A, Annex 1) for at least 2 years. Besides records, all growers are audited once a year as per EUREPGAP CPCC Checklist and a yearly farm audit record (KSHG/REC/2.2B, Annex 2) kept. Any non-conformances found are recorded on a corrective action report form (KSHG/REC/2.7A, Annex 2) and addressed as required Choice of variety KSHG farmers plant varieties that are recommended by KSHG Agronomist in liaison with market requirements. The variety choice is usually dependent on the prevalent pest and disease resistance, the climatic conditions of the geographical regions where KSHG farms are located (local farm ecology) and the quality specification of the client. The schedule of recommended varieties (KSHG/REC/3.1B, Annex 2) for all crops and planting schedule (KSHG/REC/3.0B) are made available. KSHG farmers plant only certified seeds. Seeds are the only propagation material used in KSHG farms. KSHG supplies the farmers with these seeds from the customers or when necessary from licensed seed vendors listed in the approved supplier list (KSHG/REC/2.9.1A, Annex 2). The supply of seeds is done according to the Seed Procurement Procedure (KSHG/PR/3.0B, Annex 1) and input procurement checklist (KSHG/REC/ A, Annex 2). Seeds certificates/delivery notes and

18 Page 18 of 127 seeds lot numbers records are maintained. The seed certificates/delivery notes and lot numbers are issued together with delivered seeds by the seed vendors. The individual farmers are regularly trained on the group quality management requirements to ensure among other things that they only source and plant certified seeds through the modalities laid down. KSHG may carry out additional seed dressings when necessary and this is done under the supervision of the KSHG Agronomist who is the technically responsible person. Seeds treatments and dressing s records (product name, target pests/diseases, date of treatment, concentrations used, special handling requirements, etc.) are kept and maintained for a minimum of two years in a record sheet (KSHG/REC/3.4B, Annex 2). Where visible signs of disease or substantial damage are found in delivered seeds, this must be brought to the attention of the KSHG Agronomist who is responsible for recording the nature of the problem, decision based on own observations and any action taken. KSHG does not grow any crop genetically modified (GMOs) Site history and site management Risk assessment for new agricultural site KSHG carries out a risk assessment (KSHG/PR/4.1B) on food safety, operator health and safety and environmental protection for new agricultural sites. The results of the assessment (KSHG/REC/4.1.1B, Annex 2) are used to determine whether or not the site is put into crop production. The risk assessment shows the potential impact of production on the adjacent crop and other areas. Within the risk assessment identified risks are quantified by likelihood of occurrence and degree of negative impact in the event of occurrence. This assessment is used to develop appropriate control measures and monitoring procedures. Where necessary, records are maintained to establish that effective control measures are in place. The risk analysis is well documented and covers the following:- a) Previous land use Previous crops and pesticides used on them Unacceptable wastes Natural vegetation and possibility of environmental degradation Animal production b) Type of soil Drainage patterns and liability to flooding and erosion c) Quality and level of ground water

19 Page 19 of 127 An appropriate laboratory capable of performing microbial analysis up to ISO level or national equivalent is used to determine water quality. d) Availability of sustainable water Authorization for use through a permit from the ministry of water or local authorities e) Impact of farming to adjacent areas. Spray drift At farm level risk assessment will consider: 1. Farm ownership status (in case of legal land issues) 2. Location of farm and area 3. Common history of land use (farm history in relation to crops outside vegetables which may have been grown e.g. cotton which is a heavy pesticide user) 4. Type of soil 5. Water source Figure 3: Farm production processes flow chart PROCESS ACTIVITY DOCUMENT CONTROL CPCC Section Planting Seed Issue and Dressing Planting Planting Schedule Planting Quantity vs. Acreage planted 1,2,3,4,5 Treatments Chemical/ Nutrient Chemical/Nutrient Issue Related Documents Spray nozzles, Frequency, Quantities 1,2,6,8,11,12, 13,14 Chemical/Nutrient Application Spray Application Details Spray application Programme Irrigation Irrigation Irrigation Application Details Irrigation Programme 1,2,7,11,12, 13,14 Farm Block Data Crop History record Farm Block Data Update

20 Page 20 of 127 Harvesting Collection at Shed Produce Receipt Note (PRN) Quality check and grading 1, 2, 9,10,11, 12,13,14 Crate Label Block Data Vs Crate Details Delivery to Pack house Produce collection Note(PCN) Block details PCN Details Site management A sign-post on the main access path to the plot identifies each plot or field. The sign incorporates the following information: - Farmer s code Block no Crop variety Area/quantity Planting date Expected harvesting date Every block is physically identifiable. KSHG holds key information about each farm under its control that details the layout of the farm and the subdivisions within the farm. The cropping history of each block is recorded (KSHG/REC/4.1.2B) and any incidents or accidents affecting any block are recorded with the actions taken to prevent adverse effects in subsequent crops [Traceability Procedure (KSHG/PR/2.9.2A, Annex 1)] Crop rotation Since different crops have different nutrients requirements KSHG recommends regular changing of the type of crops grown in a block. By this KSHG farmers reduce the risk of depleting the soil of specific nutrients and also reduce the incidence of pests and diseases. This rotation program helps add essential elements to the soil and builds and maintain up soil structure over the years. An annual cropping schedule (KSHG/ADM/KSHG/REC/4.2.3B, Annex 2, Crop Rotation Plan) has been developed by KSHG and farmers are recommended to adhere to it. Training of the farmers on this schedule is done by the Technical Assistants.

21 Page 21 of Soil management The type of soil on each farm is identified based on soil analysis and /or local cartographic soil-type maps. This information is used to determine the most suitable cultivation methods and use of land. Surface drainage is controlled to prevent erosion. Measures in place to prevent erosion include cross line planting on slopes, appropriate drainage channels and planting on borders of growing areas. Soil map information can be obtained from the Ministry of Agriculture for the farms to show the types and contents of the soil that exist in each farm. These are useful tools for planning planting crop rotations and planting programmes. KSHG Technical Assistants advise farmers on the suitable cultivation techniques. Cultivation techniques used are those considered suitable for particular area so as to improve or maintain soil structure and to avoid soil compaction. Hoeing is however indispensable for aerating the soil but it is not practiced in areas with loose loams to avoid damage of soil structure and thus erosion. Cross line techniques are recommended on slopes. These include terracing, planting along contours, planting grass/trees and bushes strips on borders of sites. Some of the specific practices are: Growing deep-rooted crops to bind soil particles Avoiding cultivation along river banks Growing trees in rows to act as wind breaks Contour ploughing (ploughing land across the slopes) Adding humus to soil by green manuring to bind soil particles together Making terraces on steep hillside to reduce the spread of water Growing cover crops to avoid movement of loose soil KSHG carries out no soil fumigation in all its farms to eliminate pests, diseases and weeds. Alternatives are recommended by the Technical Assistants to the farmers; these are:- Crop rotations Use of resistant and tolerant varieties Use of thermal/solar sterilizations where applicable. KSHG farmers do not use substrates in growing their produce. All crops are planted in the soil in situ Fertilizer usage and storage KSHG has established fertilizer stores near the produce collection centre and office. Farmers get fertilizers from the fertilizer store or buy from licensed fertilizer vendors. Fertilizer stock inventory (KSHG/REC/ 6.4.1B, Annex 2) are maintained. When buying from the latter, farmers obtain receipts and keep them in their farm files, which form part of the fertilizer usage and storage records. The receipts must have details of the type of fertilizer, quantity and date purchased. It is recommended

22 Page 22 of 127 that farmers buy only what they will apply. Should there be need to store fertilizer on the farm for later use the storage facility must meet the guidelines shown in Section Farmers are free to obtain fertilizers elsewhere as long as it is accompanied by proof of purchase (receipts) and a document to show content of the fertilizer. KSHG has ensured that the Agronomist and Technical Assistants responsible for determining the quantities and types of fertilizers to use are competent. Documentary evidence (KSHG/ADM/REC/6.1.1B, Annex 2) is available at the administration office that demonstrates training and competence of the technical assistants KSHG fertilizer use policies KSHG farmer(s) strictly adhere to the following policy. Failure to comply in any respect may render the produce from the farm unacceptable. The Group Agronomist or the Technical Assistants are the only authorized persons to give all fertilizer application advisory to the KSHG farmers. Fertilisers are only applied after a proper evaluation of the need for treatment and a justification recorded by the Group Agronomist or Technical Assistants. The justification for fertilizer (KSHG/PR/6.1B) is made after consulting the available soil fertility data and reference information of soil analysis for the blocks/farms in question, nutrient requirements of the growing crop and phase of growth. Soil analysis considers the ph, nitrogen, potassium, phosphorous and micronutrients levels in the soil prior to planting A decision to treat the crop shall be justified and specific instruction given to the farmers in their farm. The technically responsible person signs against it. This instruction includes; Name of the fertiliser Crop location to be treated Method of application Required equipment Dosage rate/equipment settings Name of the authorising person Instructions about any PPE required (as per label instructions) Fertilizers herein include inorganic fertilizers such as NPK and foliar liquid fertilizers, organic fertilizers such as farm yard manure, rock phosphates; composts and other related plant based decomposed/un-decomposed matter. A risk assessment shall be carried out for organic manure (for disease and weeds) used by the KSHG farmers and appropriate control measures taken and recorded to ensure that this manure does not carry a significant risk of transmitting diseases or weeds to crops being grown (KSHG/RAG/01). Organic fertilizer does not include treated or untreated domestic or industrial sewage. KSHG does not allow its growers of vegetables and fruits to use treated or untreated human sludge as fertilizer. Soil analysis of the farms shall be conducted according to the sampling procedure provided by the laboratory responsible. Updated soil maps are kept for reference. Where necessary, soil analysis is carried out at nationally recognized laboratories.

23 Page 23 of Fertilizer application records The actual fertilizer applied is recorded (KSHG/REC/4.1.2B, Annex 2). The production form contains the following information: Field identification number Application date Type of fertilizer Amount of fertilizer applied Method of application Name of the operator/person who applied the fertilizer Fertilizer application machinery All solid fertilizers are manually applied by hand using a cup of a known measure. Liquid fertilizers are applied using knapsack sprayers and these are hereby considered as the fertilizer s application machinery. There are documented records stating that technically qualified people or companies have carried out the repair and calibration of the equipments (KSHG/REC/8.5B, Annex 2, Calibration Report). For knapsacks calibration can be done as detailed in the Equipment Calibration Procedure (KSHG/PR/8.5.2B, Annex 1). Fertilizer machinery maintenance schedules/records are kept for all equipment; these include (where applicable): Date serviced/ repaired Next service date Spare parts bought and available Calibration records Other machinery here includes fertilizer weighing machines for which external verification is done annually by Weights and Measures Department of the Ministry of Trade; and records /receipts/invoices from contracted parties maintained Fertilizer stores KSHG ensures that fertilizer storage meets the following requirements:- Stores have an updated inorganic fertilizer inventory. This indicates the date bought or brought to the store, the date moved from the store and any balances (stock inventory KSHG/REC/8.8.15B, Annex 2). Inorganic fertilizers are stored separate from pesticides. The store is always clean, dry and covered from weather elements. Storage is in a manner that reduces risk of contamination of water courses. Liquid fertilizer stores are bunded. Organic and inorganic fertilizers are stored away from seeds and produce. The fertilizer store is a controlled area and entry restricted to authorized personnel only. The universal symbol of hazard is placed at the entrance.

24 Page 24 of 127 The risk of disease transmission from organic fertilizers is assessed. This assessment also considers weed seed content, method of composting, etc and is done before organic manure application. Fertilizers are stored in a manner that reduces risk to the environment. Purchased fertilizers are accompanied by documentary evidence of their pesticide content. This information is available for all the inorganic fertilizers used on EUREPGAP registered crops within the last 12 months Irrigation KSHG water use policy Water is a scarce resource, which needs to be managed efficiently. KSHG requires that all water for irrigation purposes is used within the restrictions of legal abstraction permits and licenses (KSHG/PR/7.2.2B). Weather information will be sourced through the media (e.g. radio). Irrigation application timings and rates will be determined following consideration of predicted rainfall, soil type, evaporation rates and crop needs. A water management plan will be developed by KSHG for all growers. Suitable practices might include: use of direct application rather than flood irrigation; application during cooler periods rather than in the heat of the day; the use of mulches and the addition of organic matter to the soil. These policies are contained in the KSHG water management plan Predicting water requirements KSHG farmers are recommended to predict the need for irrigation of their crops by conducting a soil hand test. This involves the farmer taking a handful of soil from several regions of his/her farm and feeling the soil for texture, moisture content and malleability. This helps the farmer to estimate the soil moisture content and thus make a decision on whether or not to irrigate. KSHG relies on the existing regional meteorological data, crop condition and hand test to predict when to irrigate. Farmers are therefore made to understand that plant water requirements depend on factors like a) Amount of rainfall received in the area b) Rate of evaporation and evapo-transpiration c) Depth of plant roots d) Type of plants and plants growth stage e) Soil properties like water-holding capacity Irrigation method KSHG recognizes that irrigation system also determines the water-use efficiency. For KSHG farmers, there are two methods used to irrigate and these are overhead and furrow Irrigation. These are the most cost effective method for the farmers currently. They are more effective than flood irrigation but not as efficient as drip irrigation.

25 Page 25 of 127 Where possible records are kept which indicate the date and volume used per irrigation unit. All legal extraction permits and licenses pertaining to the farm are maintained Quality of irrigation water Water quality is important, to both plant growth as well as a human health. Samples of water are collected and taken for analysis annually to determine its suitability for irrigation in terms of microbial, pesticide and physical contaminants where necessary. Surface water is open to contamination by sewage and/or pesticides. This is a potential human health risk, especially when the produce is eaten raw. Sources of contamination shall therefore be identified and controlled. KSHG farmers do not use sewage water. Risk assessment is done annually to determine potential microbial pesticide and physical contamination of all sources of irrigation water. A competent, locally recognized laboratory analyzes irrigation water. The risk assessment justifies the frequency necessary to analyze irrigation water and the results for the analysis maintained in KSHG/REC/7.3.2B, Annex 2. Microbial contaminants, pesticide pollutants, heavy metal pollutants are determined by a reputable laboratory. Any adverse effects are adequately acted upon according to the Complaints Procedure (KSHG/PR/2.7A, Annex 1) and Corrective Action Procedure (KSHG/PR/2.8.4A, Annex 1) and records of these kept. Water is always abstracted from sustainable water sources i.e. sources that can provide adequate water throughout the growing season and with the necessary approval Effective ways of irrigating Efficient ways of irrigation have been promoted. Farmers are recommended to: Irrigate during cooler periods of the day when humidity is low and thus evaporation rate low e.g. late evening and at night. Avoiding high weeds especially when using overhead sprinklers Proper maintenance of the sprinklers and piping network Pesticide usage and storage KSHG encourages usage of IPM (Integrated Pest Management) to minimize the use of pesticides. All pesticides application are justified and documented. When pesticides are applied anti resistance recommendations are followed as per product label instructions. KSHG receives IPM assistance from experts and also trains its own personnel.

26 Page 26 of KSHG pesticide policies Sprayer operators and all persons handling pesticides are trained on handling and safe use of pesticides. KSHG adheres to strict policies failure of which to comply in any respect renders the produce unacceptable. Its pesticide policies include: All sprayer operators and technical assistants adhere to the procedures for pesticides application, pesticide mixing, use and maintenance of personal protective equipment, disposal of excess tank mixes, and disposal of empty crop protection containers (KSHG/PR/8.8B). Minimal use of pesticides is employed to achieve an economic control of weeds, pests and diseases. This is achieved by using information obtained from crop scouting. This information is recorded in scouting records (KSHG/REC/8.1B) KSHG has current details of those pesticides whose use is banned in the European Union and other markets where produce from KSHG is destined or whose use is severely restricted as well as the approved crop protection product list. KSHG does not use pesticides contained in the banned list for any crop. Only those products in the updated approved pesticides list are stocked and recommended for use. Pesticides are only used for their intended crop and pest. Off label approvals are sought from the manufacturer of the product if the product label is not crop specific or does not have specific details. KSHG collaborates with its customers to ensure that pesticide residue analysis is carried out in order to monitor MRLs in the produce. KSHG has developed an annual MRL testing plan (KSHG/PL/8.7.3B, Annex 2) for all the registered produce and farms. This programme indicates the produce sample size [as per Sampling MRL Procedure (KSHG/PR/8.7.4B)] and the farms, which will be analyzed in a year. In case of excess MRLs the following remedial steps and actions are taken:!the affected persons are notified immediately by phone or Fax/ .!The batch is recalled for analysis and replacement (if possible).!an action report is generated and kept as a record of the incident.!the supplier is contacted to advice them of the problem.!produce from affected blocks is isolated until problem is corrected. Excess MRL problem is addressed and solved by checking the following:!phi observed!correct pesticide used!correct dose rates applied!proper application procedure followed!sprayer operator re-trained!right application machinery used and properly calibrated KSHG maintains a list showing the current acceptable MRLs levels for European Union or other markets. It is the responsibility of KSHG to maintain an accurate record of pesticides used on each crop. These include;!pesticide trade name and active ingredient.