In the last six months CCOF has been in an ongoing dialogue with the National Organic Program (NOP) and USDA about issues we see in the certification and accreditation process that are overly reliant on paperwork and unnecessarily drive up costs. We are concerned that small operators may be leaving the NOP due to both the difficult paperwork and costs of organic certification. CCOF has implemented a number of innovative solutions to these issues and has been working collaboratively with the NOP, other certifiers, representatives of the National Organic Standards Board, and the Organic Trade Association to explore opportunities for improvement.
CCOF Leads the Discussion
In November 2012, CCOF Certification Services wrote the NOP about Practices, Not Paperwork, discussing our mutual concerns and providing 10 opportunities where we believe the NOP could help CCOF and other certifiers reduce paperwork while improving certification implementation. They were:
- Support Practices, Not Paperwork in instructions to certifiers
- Support operations responding to onsite situations
- Support use of tools other than noncompliances
- Support updates to OSP during inspection
- Support certifier assistance in completing and modifying OSP
- Support and encourage electronic documentation systems
- Support simplified continuation of certification processes
- Support collaboration between certified operations and certifiers
- Discourage reliance on “Described in the OSP”
- Support increased inspector quality
Read the full document and the USDA's response. CCOF does not believe that certification should be easy or there should be no recordkeeping, effort, or cost involved. But, over the last 10 years we have observed the evolution of the accreditation system: concepts that were written into the NOP standards have driven some certifiers towards paper-heavy practices that may act as barriers to success for operations. We are concerned that this could cause small farms and others to leave the organic program. For example, there are instances where CCOF is compelled to issue noncompliance notices for practices not described in the OSP but also not a violation of organic standards. We are working to identify these and clarify what practices and changes at the farm or processor level require the operation to notify CCOF. See the Certification News article on Organic System Plan Updates, for more discussion.
We are extremely gratified to report that the NOP has responded positively to our suggestions and is implementing an initiative called Sound and Sensible. CCOF even received a letter from USDA Deputy Secretary Kathleen Merrigan underscoring their commitment to addressing these issues.
Under the Sound and Sensible initiative, the NOP is working to help certifiers and operations focus on what is most important in certification. During the Accredited Certifiers Association training in January, the NOP discussed these concepts with certifiers and gave direction in areas where certifiers may be focusing too heavily on paperwork. In several of these areas CCOF has been leading the way, such as our brief annual update form, client compliance agreements, electronic inputs management, and approaches to OSP updates. In other areas we are working to implement the NOP’s direction.
With the NOP’s support and collaboration, many of CCOF’s helpful approaches and new ideas can be implemented nationwide to benefit all organic operations. In addition, best practices from other certifiers can be adopted by CCOF over time. Records are important and unavoidable in the certification system. There is also no way to avoid some costs of certification in terms of fees and costs to the operation to maintain and demonstrate compliance. We’re working to minimize these expenses wherever possible so we can concentrate as a community on organic practices.