Recently, the NOP issued final rules and instructions to certifiers that provide important improvements to certification and require certifiers to raise the bar for both unannounced inspections and testing. These efforts help ensure that organic certification is rigorous and meaningful in the marketplace while guaranteeing that all NOP certified operations and certifiers are required to meet similar requirements. CCOF has performed both unannounced inspections and residue testing for some time and is therefore pleased to see these requirements effectively instituted by NOP. We salute the National Organic Program’s (NOP) commitment to improving the implementation of organic certification.
On January 1, 2013, the National Organic Program’s (NOP) Final Rule regarding Pesticide Residue Testing went into effect. This final standard mandates that certifiers perform residue testing of a minimum of 5% of their certified operations. CCOF has been preparing for this requirement by performing residue testing for several years, providing feedback to NOP and working with other groups to ensure the final rule did not pose an undue burden on CCOF operations or farms exclusively.
The NOP implemented the vast majority of CCOF and partner organization comments on the proposed rule. We are extremely pleased that the NOP has provided certifiers with significant discretion regarding the type of testing, reasons, and materials tested within the rule.
The new rule allows certifiers to test for a wide variety of residues including:
Tests may be based on random selection, complaints, investigations or risk analysis and all tests performed count towards the 5% minimum. In addition, the rule allows tests of plant parts, soil, water, and finished products instead of only farm gate products as was initially proposed. This establishes the rule as an effective compliance monitoring tool. CCOF worked hard to ensure this degree of flexibility, which will help ensure the efficacy of residue testing while ensuring that the entire organic community is subject to similar requirements. Certifiers may not charge operations for testing. The improved final rule will benefit CCOF operations and consumers by increasing consumer confidence.
After recommendations from the National Organic Standards Board (NOSB) the NOP has released NOP Handbook Instruction Policy 2609 regarding Unannounced Inspections (NOP 2609: Unannounced Inspections). This policy is intended to provide consistent application of NOP standards by recommending certifiers perform unannounced inspections of at least 5% of their operation annually. CCOF has actively lobbied for this clarification which requires all certifiers to meet the same percentage of unannounced inspections CCOF already performs annually.
The NOP instruction document describes certifier best practices and reflects many CCOF comments to the NOSB and NOP. CCOF is well positioned to meet the requirements and does not foresee an additional burden for CCOF clients. CCOF operations are generally not charged for unannounced inspections unless they are mandated as a part of ongoing monitoring of their operation.