2. Remediation: What is it? Can everything be remediated?
Remediation is the process of fixing practices that did not meet GAPC Certification Standards. There are six different types of remediation a grower could be asked to go through depending on the practice that was found not be in compliance. All remediation must be done within four weeks of receiving the results of the Certification Audit. Growers will receive a detail report of their results and instructions on how to remediate any found non-compliance that can be fixed. Growers will have to schedule and coordinate with individual audit firms to get the remediation completed in the four week time frame.
Types of Remediation
1) Documentation Review (DR): If documentation review is required for remediation, the grower must collect all missing records and organize the information using the GAPC record templates or the grower’s own record keeping method. Once all missing records have been prepared and organized, the grower can send them to the auditor who visited their farm. Successful remediation is at the auditor’s discretion.
2) Documentation Review with Corrective Action Plan (CAP): In addition to the Documentation Review, a Corrective Action Plan may also be required. This indicates that the grower must submit, in addition to the appropriate documentation, a report/document that indicates why the grower did not follow the GAPC standard and how the issue will be corrected in the future.
3) Documentation Review with Picture (DR): If documentation review with picture is required for remediation, the grower must take a picture of the remediated item or items. Once all pictures have been prepared and organized, the grower can send them to the auditor who visited their farm. Successful remediation is at the auditor’s discretion.
4) Not Remediable (NR): There will be some issues on the farm that are simply not remediable, such as rotating crops, or planting disease resistant varieties. Non-Remediable issues are opportunities for improvement the following year. Critical NR practices will result in the grower not being Certified.
5) Visual Inspection (VI): If a Visual Inspection is required, the goal should be to find a long-term solution to the issue as opposed to a temporary fix. The grower should make all necessary changes or fixes that require an auditor to revisit their farm. Then the grower can contact the auditor who visited their farm to schedule a follow-up visit. In some cases, the Visual Inspection for remediation may include Worker Interviews
6) Visual Inspection with CAP (VI CAP): In addition to the Visual Inspection, a Corrective Action Plan may also be required. This indicates that the grower must submit, in addition to the follow-up visit, a report that indicates why the grower did not follow the GAPC standard, a timeline of how the issue was fixed, and what the solution was. Worker Interviews may also be included if necessary.
Not everything can be remediated....
As you read above there are some things that are not remediable. These items unfortunately cannot be fixed this year and depending on your score and whether or not it is a critical item may prevent you from becoming GAPC Certified.
For example, both of the following questions are not remediable but one is a critical standard and the other is an additional standard.
- Do you only use labeled pesticides on your farm for tobacco production? This is a critical standard and if you answer "no" then you will not be able to be certified.
- Does your current crop rotation prevents tobacco from being grown in the same field for three or more consecutive years? This is an additional standard. If you answer "no" to this question it will depend on your score whether or not this prevents you from being certified as you need to only achieve 75% of the additional standards.
To find out which standards and questions are remediable and how they will have to be remediated review the GAPC Certification Standards and Remediation Details which were mailed to you in your initial approval packet and found
here.
Not Certified (NC): Grower is Not Certified as they are not in compliance with a “Critical” standard. Grower may try to get certified again anytime in the future.
Not Certified Depending on Score (NC*): Grower is Not Certified if compliance with this additional standard is needed to reach minimum certification score. Grower may try to get certified again anytime in the future.
Immediate Suspension (IS): Grower is not certified and cannot try again to be certified until one (1) year from date of original audit.
Immediate Suspension and Potential Report (ISR): Grower is not certified and cannot try again to be certified until one (1) year from date of original audit. GAPC also reasonably believes this Non-Remediated practice constitutes a serious violation of the law, or a severe infraction that could cause the industry and/or supply chain and may be reported to authorities.
