organic integrity

Cross-Check Audits to Detect and Deter Fraud

To ensure continued consumer trust in the integrity of the organic label, CCOF constantly looks for ways to address fraud. One method we began in 2018 is cross-check auditing of CCOF-certified operations. A cross-check is a review of audit trail records across multiple producers or handlers to compare what was reported as grown and sold as organic to what was purchased, received, or processed as organic by another operation. Cross-checks are similar to in/out mass balance.

Letter from CCOF Chair and CEO on Hydroponics and Livestock Certification

Dear CCOF Member,

Transparency. Respect. The democratic process. We read these values out loud at every CCOF governance meeting, staff meeting, chapter meeting, and annual meeting. We remind ourselves of these values throughout the year because it takes diverse perspectives and collaboration to create a world where organic is the norm.

CCOF Launches Innovative Pasture Compliance and Feed Audit Inspection Program

To support organic integrity and ensure compliance with the National Organic Standards pasture rule for ruminant animals, CCOF is introducing a new Pasture Compliance and Feed Audit inspection program (PCFA). 
On May 15, 2017, CCOF published a Certification News article titled “Dairy Grazing Season Clarification.” This notice reiterated expectations for certified operations, in addition to identifying areas where we planned to add additional focus on in the next year.

Updates for Importers in the United States

CCOF-certified importers should be prepared to provide detailed information during inspections to ensure that they meet the expectations of NOP Interim Instruction 4013. An importer is anyone who directly imports (importer of record), as well as operations who are the first certified organic business located in the United States taking title, receiving, or selling imported products.

Be Prepared for Additional Review of Uncertified Handlers

Without the additional oversight provided by the certification process, uncertified handlers are a source of potential fraud in the organic supply chain. Beginning in late 2017, CCOF increased oversight of uncertified handlers by verifying additional audit trail records during inspections and with an Uncertified Handler Affidavit (UHA). The UHA helps us determine if an uncertified handler is legitimately excluded from certification. This change is in line with National Organic Program expectations and other certifiers’ reviews of supply chains.

Reviewing Websites Now a Bigger Part of Inspections and Certification

As organic operations and the internet have matured, we are now faced with many businesses that have a website or whose entire sales and marketing are based on an online presence. We are adopting a new approach toward the websites of certified operations to ensure a level playing field and avoid consumer confusion.

Service Providers' Role in Organic Integrity

Service providers such as nut hullers and coolers are a critical part of the organic supply chain, ensuring that organic producers have certified locations to handle their crops or products. CCOF has a flexible approach to certification of certain types of service providers. This approach relies on the service provider’s system for verifying certification status of incoming crops or products.

Investigation and Complaint Cost Recovery

CCOF spends many hours investigating complaints and following up on residue results from third parties, such as the USDA, the California Department of Food and Agriculture, the Department of Pesticide Regulation, or others. In most cases, the origin of the issue is a misunderstanding or a minor mistake, or the issue cannot be validated. In other cases, the violations of standards, failure to follow an operation’s OSP, or other practices are found.

Strengthening Oversight of Uncertified Handlers in the Supply Chain - Uncertified Handler Affidavit

This is advance notification of an update that will print in our next magazine. Additionally, an action item will appear for all potentially affected CCOF-certified operations. If you source from uncertified brokers, traders, wholesalers, or distributers, submit an Uncertified Handler Affdavit (UHA)  for each uncertified supplier at or before your next inspection and be prepared for additional audit trail verification during inspection.