Q&A: GMP+ inland and coastal transport

Friday, February 25, 2022

Together with the GMP+ Community, we do our best to articulate the requirements we have drawn up as clearly as possible in the scheme documents.  Nevertheless, there are matters that require further explanation, for example about practical execution and implementation. For this reason, we provide answers to three questions we have received in relation to GMP+ inland waterway transport and short sea shipping here.

What do I need to pay attention to when painting/coating loading compartments?

On the one hand, painting/coating protects the loading compartments against rust, wear and aggressive components/substances in cargoes. On the other hand, it makes the surface smooth, which makes the loading compartment easier to clean and means it will dry more quickly.

The paint/coating must not represent a risk to the safety of feed.

  • If you see loose pieces or flaking paint/coating, remove them as quickly as possible. Otherwise, there is a risk that they will end up in the feed, causing it to become contaminated.
  • The paint/coating must be food grade. This means that it is suitable for using on surfaces which come into contact with foods and/or feed. Check this carefully. If this information is not shown in the instructions for use, read the technical data sheet (for example, MSDS – material safety data sheet) or contact the supplier of the paint/coating. Store this information carefully in case you receive questions about it during the GMP+ audit/inspection.
  • Check carefully how long the paint/coating needs to dry before it is completely usable (in other words not just touch dry/tack-free or overpaintable). Please note: paint/coating is only food grade if you strictly adhere to the drying times specified by the manufacturer.

Due to differences in ambient temperature and humidity, it can sometimes take longer before the paint/coating is completely usable. Keep this in mind when planning maintenance/transport.

I have transported a forbidden/non-classified product in my dry cargo vessel. Do I need to initiate a release procedure immediately after unloading?

An immediate release procedure is only compulsory if you want to transport feed immediately afterwards. In this case, you should first initiate the release procedure, as described in Work Plan 9c.

It does not matter how many non-feed cargoes you have already transported after transporting the forbidden/non-classified product.

If no feed is transported after transporting a forbidden/non-classified product, but instead, for example, sand, coal, scrap metal, etc., you can delay the release procedure.

But please note: if you delay the release procedure, there is a risk that you may forget it completely. This can happen if you do not often transport feed. Such an omission may go unnoticed during a Loading Compartments Inspection, because details will only be requested about the previous three cargoes. During the GMP+ audit, the auditor/inspector looks back much further at the products transported. A missing release procedure before loading with feed will be regarded as a serious shortcoming that can result in the loss of your GMP+ certificate.

If you nevertheless decide to delay the release procedure, it is important that you devise a system for yourself so that you do not forget to initiate it at a later date.

I have transported a prohibited/non-classified product in my tanker vessel. Can I also apply the release procedure described in Work Plan 9c?

No, this is not permitted – the procedure in Work Plan 9c is only for dry cargo vessels. The GMP+ FC scheme does not have a release procedure for tanker vessels. This means that only dedicated GMP+ feed tanker vessels may transport GMP+ feed. No products other than products for the food and/or feed industry may be transported.

The GMP+ FC scheme strictly adheres to the Inland Waterways Hygiene Code. If you have loaded products in your tanker vessel other than products for the food and/or feed industry, drastic measures are required to make the tanker vessel suitable for feed transport. These include replacing all piping, coil and pumps that may have come into contact with the cargo. In addition, the loading compartments, boiler and slob tanks may also need to be replaced. For a detailed description, see Work Plan 9a. Store the proof of the measures taken carefully because you may be asked for it during the GMP+ audit/inspection.

It is therefore also important when purchasing a second-hand tanker vessel that you establish whether the vessel has exclusively been used to transport products for the food and/or feed industry. Store the proof to this effect as documented information in case you receive questions about it during the GMP+ audit/inspection.

If you have any other questions relating to the GMP+ requirements for inland waterway transport and short sea shipping, we would like to hear them. Our helpdesk will deal with your question. We will publish questions that may also be of interest to other firms in a subsequent edition of the inland waterway transport and short sea shipping newsletter.