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A collection of certification news items, standards changes and updates for certified organic operators.
General
Improvements for you: New operation update, sales types, and company statement during inspections
CCOF recently radically improved its systems for tracking client information and gathering updates during inspections. Since April 24, 2007, CCOF inspectors have been asking CCOF operations to review their operation information, phone numbers, contact numbers, and email addresses during all inspections. We've ensured that all contacts, phone numbers, and emails associated with your operation are listed and you are given the opportunity to make corrections. In addition to address and phone number changes, this is an opportunity to add new approved contacts to your operation and remove any who are no longer at the operation. Simply make any changes, sign the Client Inspection Update, and CCOF will make these changes as updates to your OSP.
Please review your information during each inspection and make any changes so we can communicate with you as effectively as possible and list your accurate information in our annual directory.
How Can We Improve Further?
CCOF Certification Services is constantly trying to improve our systems and the certification process. In the coming months and years, we'll concentrate our efforts more effectively on soil management, natural resources and substantive certification issues at the processing level. Our goal is to focus certification away from increasing paper records to substantive organic management issues at the farm and processing level. We're open to your ideas and comments. Please let us know where our focus should be directed, records that could be eliminated or areas we should focus on more effectively by emailing ccof@ccof.org. We will take these into consideration as we explore ways to improve the certification experience while ensuring that the highest level of organic integrity is maintained with CCOF organic certification.
Thank you for your input.
November 2007, NOSB Meeting Information
CCOF’s Certification Services Director, Jake Lewin, attended the November, 2007 NOSB meeting to represent CCOF and the needs of CCOF certified operations. Aquaculture was the subject of a day-long symposium and considerable public comment. In addition to several petitions and sunset items, the NOSB also addressed (1) inspection and certification of grower groups and other multi-site operations, (2) guidelines for the commercial availability of organic ingredients and seeds, and (3) definitions of materials on the National List.
Read the OMRI NOSB Meeting Report or the report of the Accredited Certifiers Association for more information.
CA State Organic Program Proposed Mediation and Appeals Procedure (7/21/07)
As a State Organic Program (SOP), the California Department of Food and Agriculture (CDFA) is the California state appeals body for certification denials, suspensions, and revocations. Unfortunately, as CCOF has discovered in the last year, the SOP has been unable to process appeals requests due to a lack of internal procedures to govern the process. CCOF Certification Services is pleased to see that CDFA has now published proposed appeals and mediation procedures. We expect the process to be in place in the near future and to have appeals of adverse certification actions processed more efficiently through the SOP.
In order to protect the integrity of organics, CCOF is sometimes required to initiate serious non-compliance, revocation, or suspension action against operators found to be in violation of the National Organic Program. However, due process rights, mediation opportunities, and the appeal process are important components of ensuring all parties are treated fairly. If CCOF issues non-compliance or other adverse action, you will be provided with your options for appeals and these new procedures should ensure the ability of the CDFA to participate fully in the process. For more information, visit the California State Organic Program or call (916) 445-2180.
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Expedited Certification Program Released (1/19/07)
Download Expedited Certification Enrollment Form
CCOF has unveiled an expedited organic certification program in response to the booming demand for organic certification. Clients seeking organic certification can now go through the same rigorous inspection and review criteria as the regular certification process in a fraction of the time.
The CCOF Expedited Certification Program was designed to meet the needs of operations capable of compliance that do not have sufficient time to undergo the certification process because of impending harvests, market releases or product launch deadlines. Fast-track applications receive top priority processing and are immediately assigned an inspector who is required to submit reports to CCOF within 48 hours of final inspection. CCOF's internal review and processing is guaranteed to be completed within 72 hours. In some cases the expedited certification process can be completed in as quickly as a week compared to the recommended 12 weeks prior to organic harvest using the regular certification method. Organic certification is not guaranteed since it depends upon inspector findings, compliance on site, and the quality of the application. Under no circumstances are USDA standards compromised.
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2007 Fee Changes (1/10/07)
CCOF continues to provide the most competitive and cost effective organic certification program possible. From time to time we are forced to raise fees in order to ensure continued service. Notably, in 2007 there will be no increase in small grower certification fees. However, due to the complexity and accreditation challenges associated with processors, livestock operations, and international standards there are small fee increases in these areas. An explanation of changes effective January 1, 2007 appears below. CCOF's current fee schedule.
We at CCOF raise certification costs only when necessary to ensure your access to qualified staff, timely service, and the high integrity certification you’ve come to expect. We thank you for your understanding.
Processors: CCOF’s two lowest processor certification fee categories will increase slightly to $550 (previously $475) and $600 (previously $550). This leaves CCOF processor fees highly competitive with other certifiers while ensuring adequate staff to address your needs.
Livestock Operations: The minimum annual certification fee for livestock operations with more than 10 animals will be $475 in 2007. CCOF takes livestock certification seriously and is constantly working to stay informed and participate in organic livestock issues at a state and national level. Because of the inherent complexity and work involved in all livestock certifications, CCOF is forced to implement this fee increase.
Global Market Access program: Enrollment in CCOF’s Global Market Access program will now be $150 to allow CCOF to address rapidly increasing accreditation costs. This will provide CCOF the resources to improve our program and continually seek improved international access to our members. As import regulations in the European Union, Canada and elsewhere evolve, CCOF is continually working to ensure our Global Market Access program ensures your success. As our accreditation and others costs have increased substantially, we are forced to raise the cost of this important service.
CCOF is working hard to improve access to European and other markets. For instance, CCOF is actively fighting for the ability of CCOF operators to utilize Potassium Bicarbonate in the production of crops destined for the EU. This could have a critical benefit for wine, raisin, berry and other producers. Similarly, European organic imports regulations are in transition. As European standards are updated, import recognitions may improve significantly. CCOF is working hard to stay abreast of developments and modify our Global Market Access program to ensure you benefit.
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Earlier Renewals in 2007 (1/10/07)
CCOF clients may receive their next renewal at least one month earlier than in past years. Over the last several years CCOF has found that when renewals are sent the day they are due, we are unable to effectively renew the bulk of CCOF’s clients and begin the inspection process. This has lead to a series of problems. So that CCOF can ensure annual inspections and timely reviews, we are attempting to begin each renewal cycle with as many clients renewed as possible.
Therefore, to give you and CCOF more time for the renewal and certification process, CCOF has begun sending renewal notices a full month prior to the month they are due. This began in December for the January 1, 2007 renewals and has proven to be a great success. CCOF now has more time to work the renewal process without cutting into the year available to complete the inspection and review. This will ensure lower costs and better service to you.
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California Cost Share Funds Sold Out
Funding applications for the State of California program to help defray the cost of organic certification overwhelmed the California Department of Food and Agriculture (CDFA) offices last week, and the following announcement was sent shortly after new applications were distributed.
We apologize for any confusion and hope some our certified clients got their forms filled out in time.
Tuesday, September 19, 2006
Greetings Organic Industry:
We are sorry to announce that the Certification Cost Share Program has already received more than enough applications to commit the funds we had remaining. If your application is not already in the mail please do not send it.
Hopefully, within the next three weeks you will receive a letter from the program that says your application has been received and approved or a notice that we were not able to approve it.
It will still take several months for us to request the funds from USDA and then have the State Controller issue checks.
Thanks to all for your participation. This will make a total of over one million dollars that we were able to distribute to the organic industry.
Ray Green,
Organic Program Manager
California Department of Food and Agriculture
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GMO Rice Reporting Information
Due to a discovery that GMO rice had been found in non-organic rice supplies in Arkansas and Missouri, CCOF and CCOF growers were required to report all 2006 organic rice varieties and suppliers. As of September 2006, there is no evidence of GMO contamination of organic or California grown rice. More information: View the USDA statement, request to certifiers and CCOF request for information.
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Quebec Organic Produce Labeling Update (July, 2006) (Download a copy of this announcement)
CCOF Certified clients directly or indirectly shipping organic product to Quebec are advised that they must label products according to CAAQ organic labeling standards. Notably, CCOF and the name of the certified operation must be identified as the certifier on all products including fresh bunched or loose produce. Standard PLU stickers or twist ties must be modified to meet these requirements.
Please be aware that the CAAQ may levy fines and take compliance action against companies and products found in Quebec without compliant labeling. CAAQ organic produce labeling flyer and exemption request.
Specific examples include:
- Cucumbers, each cucumber must be labeled with the information required in 9.4.3 below.
- Bundles of leeks, parsley, broccoli, grapes, etc… must be labeled per 9.4.3 below.
- Product in clam shells or in bags must be labeled per 9.4.3.
- Bunches should be individually labeled where each fruit cannot be labeled.
CCOF certified products may be shipped to Quebec by a broker or third party without the knowledge of CCOF producers. In such cases CCOF recognizes that the third party is responsible for informing the CCOF producer of their intent to ship the product to Quebec and provide for the required labeling.
If the CCOF producer is shipping the product directly to Quebec, be advised that you are responsible to meet the labeling requirements of Quebec. CCOF strongly recommends enrollment in the CCOF Global Market Access program for all clients who directly or indirectly export organic products to foreign markets.
Please indicate during your inspection and annual updates of any known or potential future sales into Quebec so CCOF can help you by ensuring your compliance with CAAQ requirements.
CAAQ standards can be viewed at www.caaq.org, or http://www.caaq.org/en/home.asp. In Chapter 9, Section 9.4 addresses Labeling of fruit and vegetables by operator that requires individual labeling of each “individual” fruit or vegetable.
9.4 Labeling of Fruit and Vegetables by Operators
9.4.1 Perishable foods, such as certified fruit and vegetables, shipped and intended for sale, shall be individually labeled (using stickers or others methods) by the operator holding an organic compliance certificate for these products.
9.4.2 When, due to their specific nature, products cannot be labeled individually (e.g. grapes), then it is the unit of sale (grape or broccoli bunch, parsley bundle, etc.) that shall be affixed with a label.
9.4.3 The operator that holds the certificate shall print its name (or identification codes allotted by the certification body) along with the name of the certifier on all labels attached directly to fruit, vegetables and other food products in this format.
9.4.4 In exceptional cases, when no labels can be affixed to each fruit or vegetable, their packaging must be done under the responsibility of the certificate holder and in a container upon which the label will be affixed. This label must include all information required by Article 9.2.1.
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CCOF Global Market Access Program released
In an effort to provide additional benefits and ensure continued international market access for CCOF clients, CCOF has revised its international program. The new "Global Market Access" program provides certification to both the European EEC 2092/91 standard and IFOAM requirements in addition to verifying other international standards as required by CCOF clients. The new program and standards became effective
February
10, 2006. CCOF has revised Manual III: CCOF Global Market Access and strongly encourages current and prospective CCOF International clients to review it. Visit www.ccof.org/international.php to learn more and view a copy of the revised program.
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EU Regulatory Change Requires Inspection of All Storage Facilities
In an important move for CCOF exporters, a recent change in the EU organic regulations by the European Commission has added the requirement that all handling and storage facilities associated with products destined for the EU must be inspected. This change will affect a number of CCOF certified clients who seek CCOF Certification under CCOF’s International program. Under this ruling all warehouses and distribution points must be inspected under this requirement while under the NOP many of these facilities are exempt from certification. CCOF will be working with clients to meet this requirement as efficiently and effectively as possible. Towards this goal, CCOF will utilize current storage facility affidavits as demonstrations of compliance and will include inspections of these facilities at the lowest possible cost. Defra's announcement on the subject can be viewed by clicking here. Click here to view the amendment to the European Union Organic Regulation 2092/91.
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Quebec Clarifies Organic Labeling Issues
CCOF recently received an announcement from the organic regulatory authorities in Quebec (the CAAQ). These include specific requirements labeling organic products with <70% organic content and wine labeling standards that go into effect on Jan 1, 2006. Notably, products with less than 70% organic content must be accompanied by a certificate of verification attesting to the organic ingredient content. Additionally, the product must include the name of the certifier providing the verification with the statement “verified by…”. While CCOF does not expect CCOF clients to be affected by this requirement, companies in need of ingredient verification for the Quebec market are encouraged to contact us. The wine labeling announcement reiterates the requirement that wines with added sulfites may only carry a “Made With Organic Grapes” label. This is similar to the National Organic Program. Also, the CAAQ has clarified that organic production techniques that are prohibited in Quebec may not be utilized for products sold in Quebec. Namely, organic Hydroponic and Aeroponic production may not be sold as organic in the province. Click here to view the CAAQ Organic Labeling and Certification Announcement.
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Add CCOF Logo to your website easily
CCOF has made it easy for both certified clients and supporting members to include the appropriate logo on their website by following the steps in this document. Please note the CCOF logo may only be used by certified clients or on links pages that do not imply certification or approval by CCOF. The brand new CCOF supporting member logo may be used by any supporting members in good standing. Please contact CCOF Marketing at marketing@ccof.org or 831-423-2263, ext. 31, with any questions or for assistance.
 
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New Streamlined Organic System Plan (OSP) Released
CCOF is pleased to announce the development of new streamlined Organic System Plan (OSP) documents. Both new clients and clients updating their OSP will be pleased to find the forms almost 50% shorter and considerably more efficient. Highlights include a reduction in the overall number of pages, clarification of questions, a reduction in jargon, and the combination of many sections resulting in a more intuitive process. Download the new OSP... Download new add acreage and add product forms...
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Important Materials Update Organic Biolink 14-0-0 Prohibited (12/21/07)
Organic Biolink 14-0-0, marketed by Westbridge Agricultural Products was recently identified as incompatible with organic production and removed from the WSDA Brand Name Materials List of inputs compliant with organic standards. Therefore, CCOF growers must immediately cease and desist use of Organic Biolink 14-0- 0. Existing supplies may not be used. At this time, the other Westbridge WSDA-listed brand name materials included on approved OSPs will continue to be recognized as compliant.
This is not the first high nitrogen fertilizer to leave the organic market and may not be the last. As identified in the Spring 2007 issue of CCOF's Certified Organic magazine, CCOF has significant concerns regarding high nitrogen liquid fertilizers. CCOF will keep you informed of changes or developments as they arise by posting them in the "Certification Updates and Resources" section of our website. For a current list of materials recognized by CCOF as compatible with organic production, please visit the OMRI website.
Please note that to ensure compliance with NOP standards, all materials should be included on your OSP and approved by CCOF prior to use. Additional OSP forms are available at www.ccof.org/osp.php and www.ccof.org/forms.php.
Thank you for your support of organic farming and CCOF.
Livestock News: Medicinal Substances Regulation Changes - December, 2007
Over the last few months, National Organic Program (NOP) livestock regulations that cover medicinal products have changed significantly.
Additionally, CCOF has re-evaluated our interpretation regarding the allowance of certain livestock products.
Please see below for important updates that may affect your operation.
CCOF livestock operators will be recieving a mailing regarding these changes in the near future.
Or, download a pdf copy of the announcement.
Key subjects include:
- Medicinal Products Added to the National List
- News about Banamine
- Products Not Added to the National List
- Health Care Products Reevaluated by CCOF: Immunoboost, Calf 180, and Calcium Borogluconate
- Guidance on Medicines vs. Feed Supplements
- Issues Regarding Excipients
- Removal of Milk Replacers From the National List
- Upcoming Changes
Please note that to ensure compliance with NOP standards, all materials must be approved by CCOF and included on your OSP and prior to use. Additional OSP forms are available at www.ccof.org/osp.php and www.ccof.org/forms.php.
Uncertified Animal Brokers And Hay Fraud (7/21/07)
The recent months have been extremely busy for CCOF livestock certification. As we all await further clarifications from the NOP on pasture requirements, CCOF has received clarifications from the California State Organic Program (SOP) regarding animal and hay brokers.
Animal Brokers Must Be Certified
As of this past spring, it has become clear that brokers who take possession of organic animals must be certified for the animals to retain their organic status. While there are exemptions in the NOP regulations for brokers of packaged products, this does not apply to live animals.
Considerable risks are involved when non-certified parties are involved in the trade of live organic animals or hay, including an inability to verify the sources of animals and management practices performed while under the possession of non-certified parties. Therefore, operations that take possession of organic animals for any amount of time must be covered under an approved organic system plan and certified by a USDA accredited certifier. This will protect CCOF livestock producers by ensuring the management practices of the broker are reviewed and full records are maintained to verify the legitimacy of all transfers.
CCOF is aware of animal brokers involved in the transfer and sale of organic animals. In some cases transfers from non-certified brokers or with missing documentation have caused the loss of organic status for the animals and delays in organic production. All sales and transfers of organic animals as of April 1, 2007, must include a full chain of custody that inincludes only certified organic parties. CCOF reserves the right to not recognize the organic status of transfers that have not previously been disclosed. If you have a specific issue, please contact us immediately. If you are approached by non-certified parties with organic animals for sale, trade, barter etc., please contact CCOF at ccof@ccof.org and/or the California SOP at rgreen@cdfa.ca.gov .
Per the SOP, the only exemption to the certification requirement is the trucking company itself. Operations that simply pick up and transport animals a short distance without taking management control, feeding, or caring for the animals beyond transport are not required to be certified. However, the operation that maintains title for the animals during transport is responsible for ensuring that transport practices meet National Organic Standards, especially if rest stops or feed is provided en route.
Hay Brokers and Fraudulent Product
CCOF has recently become aware of two uncertified operations fraudulently representing themselves as organic operations. Both Orient Farms and Stewart Hay are not currently certified organic and appear to have been marketing organic hay up to and as recently as June, 2007. An investigation is ongoing at both the State and National Organic Program levels. If you have purchased organic hay from these operations, please contact CCOF so we can take appropriate action. In the interim, it is critical that you protect yourself by ensuring that all suppliers have current certificates prior to accepting deliveries of organic products and that your list of suppliers is current in your approved OSP. Purchases from suppliers not listed in your OSP that turn out to be fraudulent could negatively affect your certification status.
Important Animal Purchases/Transfers Records
Operations accepting organic livestock into their operation should maintain the following types of records. Operations that do not have appropriate documentation demonstrating legitimate animal transfers or sales may not have their animals recognized as organic.
· Incoming documentation clearly identifying the type and organic status of the animals.
· Lists of animal ID numbers and/or brand identifications.
· A State Brand Inspection Certificate.
· Current valid organic certificates for all involved parties.
CCOF is committed to serving your needs. If you have any questions, please contact us and speak to any of CCOF's grower/livestock certification staff.
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Propane for Rodent Control (Spring 2007)
Please be aware that propane combustion has been identified as a rodent control material incompatible with organic production. Commonly, this is marketed as an injection and combustion system under the Rodenator brand. While CCOF previously approved this use, recent clarifications from the National Organic Program during the certifier training in Asilomar (Jan, 2007) have made it clear that organic growers may not use this or other similar products for rodent control in organic fields. Please note that CCOF expects the manufacturer to petition for inclusion of this use on the National List and CCOF may support the petition if requested by its clients. In the interim, CCOF will be requiring that certified growers immediately cease and desist use of all propane combustion based rodent control devices.
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Important Materials Update- Biolizer XN Prohibited (01/10/07)
Biolizer XN, produced by California Liquid Fertilizer (a subsidiary of United Organic Products) was recently identified as incompatible with organic production and removed from the OMRI Product List of allowed materials. Therefore, CCOF growers must immediately cease and desist use of Biolizer XN. Existing supplies may not be used. At this time, the other Biolizer OMRI-listed brand name materials included on approved OSPs will continue to be recognized as compliant.
For a current list of materials recognized by CCOF, please visit the OMRI website at www.omri.org. Please note that to ensure compliance with NOP standards all materials should be included on your OSP and approved by CCOF prior to use. Additional OSP forms are available at www.ccof.org/osp.php and www.ccof.org/forms.php.
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Materials Announcement & Review Form Released
It is your responsibility to verify all input materials are allowed before you use them. Read CCOF's announcement about use of approved materials.
Materials that have been approved for use can be found on the Products List published by the Organic Materials Review Institute (OMRI), www.omri.org, or Washington State Dept. of Ag. (WSDA), www.agr.wa.gov/FoodAnimal/Organic/MaterialsLists.htm. For materials not on either of these lists, CCOF will review the material for CCOF clients on a case by case basis to determine compliance with National Organic Program and international standards. To have your product reviewed please download and complete the Material Review Request Form.
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Updated Policy on Feed Harvested Prior to Inspection ("Hay in the Barn")
Date: 09/07/06
CCOF Hay in the Barn Exception Policy
On a day to day basis CCOF's policy as written will remain in effect (see livestock policy update mailer below). That is, as a general rule CCOF will recognize hay and other products fed to organic dairy animals only when harvest occurs after inspection.
However, we are willing to consider a very limited number of exceptions on a case by case basis. To grant an exception, we will be looking at a few limited criteria including:
- Prior notice. If harvest will occur prior to inspection, it is the responsibility of the operator to notify CCOF in advance of harvest that there is a conflict between impending harvest and inspection dates. Lack of prior notice will be a serious factor in each case.
- Compliant recordkeeping. Any operation seeking an exception must have complete readily available records for harvest and other aspects of compliance. Operations that indicate the maintenance of harvest records but who do not have them at inspection cannot be considered. It is critical that the operation be able to demonstrate compliance at the time of the inspection.
- Timeline. Operations seeking an exception will be subject to limited timelines between harvest and inspection dates. It is highly unlikely that a month between events would be acceptable. Whereas, a week is more likely to be recognized. It is important that the inspector can view as much evidence of the harvest as possible including waste in the field, freshness of product, newly baled hay etc.
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IMPORTANT ANTIBIOTIC POLICY CHANGE ANNOUNCMENT (Download copy of this memo )
To: All CCOF Organic Dairy producers
From: CCOF Certification Services
Dated: July 7, 2006 Effective Immediately.
Re: Change in CCOF policy regarding use of antibiotics on organic livestock.
CCOF Certification Services has been directed by Ray Green, Manager of the California Department of Food and Agriculture State Organic Program, to amend our policy regarding to the use of antibiotics in organic dairy production. Based on direction from Mr. Green, the following is CCOF’s policy on antibiotics, effective immediately:
- Any animal, including calves, treated with antibiotics will lose its organic status and can never return to organic production.
- You may not withhold treatment from a sick animal in order to preserve its organic status, per NOP section 205.238(c)(7).
- You must ensure that animals treated with prohibited materials, including antibiotics, are clearly identified as separate from the organic animals. All meat, milk or milk products from treated animals must be segregated from organic products and there must be clear documentation of the separation.
CCOF CS will no longer allow an animal treated with antibiotics to return to the milking herd, even if the animal is managed organically and remains on the organic farm. CCOF CS producers must cease and desist the transition of any animal treated with an antibiotic immediately.
CCOF’s change in policy on this issue is based on recent changes in the NOP standards that are posted on the USDA website, under “Today’s News” dated June 5 th and June 16 th, 2006.
We appreciate your efforts and thank you for using CCOF for your certification needs. Please contact us at 831-423-2263 if you have any questions regarding this change in policy.
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Livestock Policy Mailer (July, 2006)
In an effort to serve our clients and keep them informed regarding recent policy and certification changes, CCOF mailed an update to all livestock clients. The mailer included an update on CCOF herd conversion and antibiotic use policies. Additionally, an organic livestock certification Frequently Asked Questions document and "To Feed or Not to Feed", an explanation of feed additive and supplement rules, were included. Interested parties can view and print the CCOF Livestock Certification Update Mailer here.
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Nu-Film P has been re-instated as allowed for use in organic production.
Thanks to re-classification of particular inert materials by the EPA, the popular adjuvant has regained its status as an allowed material.
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Certification Assistance Resources
The Western Region Organic Farming Compliance Handbook provides a wealth of resources to new and currently certified organic farms and agricultural professionals. This important resource contains sample forms, certification readiness checklists and helpful explanations of a variety of issues relating to organic standards and the certification process.
The ATTRA organization provides a wealth of resources to help farmers, processors, and others learn about and prepare for organic production and certification. Their organic production website includes organic inspection readiness documents, sample forms, and information on organic marketing, farm practices and more! Check it out at http://www.attra.org/organic.html. Especially helpful are articles on Preparing for An Organic Inspection and the National Organic Program Compliance Checklist for Producers. Additionally the ATTRA Organic Production Website has numerous articles on organic pest control and other issues.
CCOF also prints a quarterly magazine and periodic updates that provide detailed information on certification issues and includes helpful articles on various issues regarding organic standards and compliance. These resources are provided free of charge to all CCOF clients and supporting members. Operations considering certification in the future are encouraged to join CCOF as a supporting member to begin receiving materials and becoming informed about organic standards and certification issues. Past magazines and articles are available in our magazine archive.
Finally, ATTRA provides a variety of certification assistance resources at www.attra.org.
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Processor/Handler/Retailer/Private Label Specific
NOP Intirim Rule for Non-Organic Agricultural Ingredients
Addition of 38 Non-Organic Ingredients to National List Strengthens Organic Standards -The USDA has published an Interim Final Rule in the Federal Register to allow 38 non-organic ingredients for use in organic processed foods. They have been added to the National List of Approved Substances on an interim basis while the comment period is extended for 60 days.
Under current standards all non-organic agricultural ingredients used in products labeled "organic" must be included in the national list 205.606 and commercially unavailable in organic form. These ingredients must constitute less than 5% of the product.
Although media coverage might claim this move is a weakening of organic standards, it is actually quite the opposite. These changes are a tightening of the regulations because it reduces the number of ingredients that may be used overall. These ingredients are permitted only when the organic equivalent is unavailable commercially. Prior to June 9, 2007, organic processors could use ANY non-organic agricultural ingredient they needed, as long as it was less than 5% of an organic product, and as long as they could document that it was not available commercially in an organic form.
These new rules greatly restrict the use of other non-organic ingredients in processed organic food. Adding 38 items to the National List is nothing compared to the thousands of possible ingredients that were previously considered acceptable. The significant limitation of potential non-organic ingredients helps support the market for organic minor ingredients and could be seen as an important step forward for organic standards.
CCOF will continue to require all companies utilizing a non-organic ingredient included on the final 205.606 list in the 5% of a product labeled "organic" to undergo thorough searches.
While this significantly limits the universe of potentially allowed non-organic agricultural ingredients in organic products, there has been some concern about the inclusion of specific items, such as hops, that may, in fact, be available in an organic form. If you support or oppose the inclusion of these materials, now is your opportunity to comment during this 60 day interim allowance.
If you are positively or negatively affected by the potential allowance of any of these materials in the non-organic 5% of products labeled "organic", now is your time to comment to the NOP. Deadline: August 27th!
Instructions for submitting public comment to the NOP...
View the Interim National List Additions...
Read an open letter from the Accredited Certifiers Association (ACA) regarding these changes...
Read the USDA Press Release...
Read the OTA Fact Sheet...
Read the OTA Q&A Sheet...
Who is affected by AFSII De-Accreditation?
Please be aware that the National Organic Program recently revoked the accreditation of American Food Safety Institute International (AFSII). While representing a hardship for a number of AFSII certified operations, this clearly demonstrates the intention of the National Organic Program to maintain a strong organic and accreditation program.
Under the revocation AFSII certified companies and products must transfer their certification prior to August 26, 2006. Read the National Organic Program announcement.
To assist our members, CCOF is providing the following guidance for dealing with AFSII certified companies and products:
- Only products produced under AFSII certification prior to August 26, 2006 can be recognized as organic by CCOF certified companies.
- CCOF clients utilizing AFSII certified ingredients or co-packers must receive new certification documentation from their suppliers or co-packers prior to August 26, 2006. Unless new certificates are provided by businesses formerly certified by AFSII, incoming ingredients must not be recognized as organic. Co-packers formerly certified by AFSII must not be utilized after August 26, 2006, for ingredients or products which will bear the CCOF name and/or seal.
- Products produced after August 26, 2006 cannot display the AFSII certification logo or name or be produced under AFSII certification
Read the USDA document: Enforcement & Integrity of the National Organic Program: Q&A's for Consumers
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Commercial Availability Rule Change Update Notice 8/1/05
Wine Label Update Notice 8/5/05
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