I have had an opportunity to discuss the situation with the BAP Integrity Team and their answer is below:
For New Farms in the BAP Program (1st Audit)
A. If required by volume of product 3 months of effluent would be required for record if the farm had been producing shrimp previously even if not under BAP requirements.
B. They must have at least one pond with shrimp in the pond but do not require a harvest be completed.
C. If Training Records and Management Documents are present during audit for Workers Health During Harvest, Health Management Plan, Transportation, Micro Testing for Ice on Shipments but no actual completed documents are available due to no harvest then the farm has met the intent of the Standard.
IOM Sponsors should be aware of the requirements and through the required self-assessment should make sure the farms are meeting the Standard however, an auditor cannot punish a farm for something that hasn’t occurred yet when a crop has not been harvested if they have all processes, procedures, training in place to show they can/will comply to the standards.
Auditors should indicate in those sections of the report when the facility has not yet harvested a crop a comment such as the following:
“The facility has not yet completed this task however, the facility has completed training for all required personal and has policies/procedures in place which show compliance to this clause”
This will provide the necessary information for CB and BAP to understand the situation.
If any questions arise during the course of the audit please don’t hesitate to reach out to the CB Team at your earliest convenience for clarification.