The Trouble with Organic Inputs
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2019 AGM Breakout Session
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The Trouble with Organic Inputs
- 1. The Trouble with Inputs Jennifer Scott, CSI Kate Loghrin, Bio-Ag Terry Good, TEK-MAC Simon Jacques, Ecocert Moderator: Amy Hamblin Smith, OCO
- 2. ● Soil Amendments & fertilizers ● Pest control ● Feed ● Livestock healthcare products ● Processing materials ● Preparation Materials ● Cleaners, disinfectants ● Facility storage Inputs:
- 3. ● Canada Organic Regime (COR) Permitted Substances List ● Conformity verification bodies (CVBs) ● Certification bodies (CBs) ● Inputs approved as part of Organic Systems Plans (private list) ● Inputs approved for suppliers (public list) Canada
- 4. ● Inconsistent approvals ● Redundancy of reviews ● Lack of info for transitioners ● Burden on operators and CBs ● Competition, confidentiality and liability The Trouble with Inputs
- 5. ● Other Jurisdictions ● Liability concerns ● Privacy concerns ● Options for Input Approval Our Agenda:
- 6. ● National Organic Program (NOP) who acts as CVB ● Material Review Organizations (MROs): ○ Washington State Department of Agriculture (WSDA), ○ OMRI ○ California’s Organic Input Materials Program (OIM) USA
- 7. ● Provides 40% of the organic food sold in the US ● Governed by State Organic Program & NOP ● Organic Input Material (OIM) Program ○ Public registry of organic fertilizers ○ ISO 17065 accredited ○ Accepted by CBs across the US ○ Result of a liquid fertilizer scandal California
- 8. ● BioSuisse ● FiBL (Research Institute of Organic Agriculture) the sole verifier ○ Non-profit with government and private funding ○ Reduces issues re: dispute resolution, privacy and shared methodology Switzerland
- 9. ● CFIA: Liability rests with CBs ● Good faith + diligence = not liable ● COR and ISO ensure CBs & CVBs have: ● legal agreements ● provisions to cover liability ● OMRI also has provisions Liability
- 10. COR and ISO permit: ● Sharing info to “verify validity of information on an operator.” (COR) ● Sharing of info when required by law (ISO) ● Contracts to govern info sharing between actors (ISO) OMRI-CB contract permits sharing for: ● Legal proceedings ● Audits ● Compliance Disputes ● Requests from Regulatory Bodies Privacy
- 11. Solutions Review LONG TERM: 1) Status Quo: Let the market figure it out 2) Create one central database of inputs ● voluntary sharing by CBs ● CFIA mandated sharing ● CFIA requires suppliers to get reviewed ● CB’s public lists linked to one another ● Inputs as part of an organic integrity database 3) Single Service Provider SHORT TERM: 1) Create a shared Methodology 2) Create a stronger dispute resolution process
- 12. ● Inconsistent/missing CVB oversight? ● Lack of clarity, depth in regulations USA: ● “Recalibration Training” ● ACA developing best practices ● Strong culture of collaboration Shared Methodology
- 13. ● CVBs ● Standards Interpretation Committee (SIC) USA: ● NOSB Subcommittee on Materials/GMO ● NOP 3012: Lays out process for dispute resolution Dispute Resolution
- 14. Next Steps: ● Further interviews ● Focus Groups + Surveys ○ Suppliers ○ Producers E-mail amy@organiccouncil.ca to share your thoughts!
- 15. The Trouble with Inputs Thank You! Questions?
Notas do Editor
- What is the Organic Value Chain Round Table (OVCRT) Inputs Task Force
- Soil amendments are substances applied to the soil to improve fertility and tilth and to correct soil problems. Fertilizers, plant foods and soil amendments are primarily used for their plant nutrient content and may be applied to the soil or to plant foliage. Crop production aids and materials (plastic mulch, pest traps, pest management substances, plant disease substances) Feed, feed additives, and feed supplements Livestock healthcare products and production aids (to maintain the health of the animal - remedies, medications, bedding ) Processing Materials (ingredients, food additives like wax or yeast, processing aids) Cleaners, disinfectants and sanitizers Facility management substances (pest control, post-harvest storage)
- Canada Organic Regime (COR) Permitted Substances List Conformity verification bodies (CVBs) Certification bodies (CBs) Inputs approved as part of Organic Systems Plans (private list) Inputs approved by suppliers (public list)
- Why are we looking at inputs: Differing methodologies inconsistent approvals for operators Suppliers need to expend resources for multiple reviews Lack of information for transitioners Burden of cost of operators and CBs In addition to difference in methodology, other factors that keep CBs from wanting to work together: Competition for fees Confidentiality concerns Liability
- Ask some Qs about how we might adapt what’s going on in other jurisdictions Liability concerns for CBs in sharing approved input lists Privacy concerns that hinder sharing of input information in the sector Solutions Developing a Shared Methodology for CBs doing input verification Dispute Resolution when CBs come to different conclusions about inputs Options to improve input approval
- National Organic Program No CVBS - the NOP Accreditation and International Activities (AIA) Division is responsible for accrediting CBs MROs that comply with ISO 17065 deemed acceptable sources of input approval MROs named by NOP 3012 Policy Memo on Material Review: Washington State Department of Agriculture (WSDA) OMRI California Dept. of Food and Agriculture (CDFA) Organic Input Materials Program (OIM)
- California: Provides 40% of the organic food sold in the US Governed by State Organic Program & NOP - duplication Inputs are handled is a similar manner to Canada suppliers may pay for review by OMRI or CBs offering review services, or inputs approved as part of the CB’s review of producer’s Organic Systems Plans Organic Input Material (OIM) Program Public registry of organic fertilizers ISO 17065 accredited Accepted by CBs across the US Liquid Fertilizer Used as an example of liability or lack of shared methodology Really a case of fraud - using synthetic nitrogen and lying about it No one held liable, except for supplier for fraud Industry protected (many producers would have lost certification) Led to greater requirements for inspection for liquid fertlizers No one wanted to do it, so OMRI was used and eventually OIM
- Majority of Swiss organic operators work under BioSuisse, an umbrella organization for organic farmers associations BioSuisse has it’s own regulations, including a requirement to use FiBL Non-profit with government and private funding Reduces issues re: dispute resolution, privacy and shared methodology Because FiBL’s list is public and has been part of the system as it developed, certifiers have had no interest in taking on their own verification programs. FiBL says this is because they saves them time “and risk”
- Concerns over liability: We’ve heard that they prevent CBs from accepting the decisions of other CBs and MROs Creates duplication in material review efforts Two things I’m hearing from Industry + CFIA: Liability ultimately rests with CBs That CBs who demonstrate that they have developed, adhered to and correctly applied procedures are not liable: SFCA (59): “No person who exercises powers or performs duties or functions under this Act is liable in respect of anything done or omitted to be done in good faith in the exercise of those powers or the performance of those duties or functions.” COR Operating Manual + ISO 17065: CBs maintain responsibility if they outsource CBs must have a legal agreement with producers CBs must have provisions to cover liability CVBs also must have provisions to cover liability OMRI Certifier Subscription Service Agreement OMRI agrees not to hold the CB liable if OMRI makes a mistake The CB agrees not to hold OMRI liable if CB makes a mistake OMRI maintains “current errors and omissions insurance policy at all times of no less than $1,000,000.” When has liability been tested? Biodegradable Mulch Disagreement between CBs Possible misrepresentation from supplier re: petroleum content SIC reviewed and deemed it approved Industry petitioned to have it delisted Producers and suppliers were protected with lengthy time frame for discontinuation of use No actual legal proceedings Any other cases? Consensus on CB liability, but how does good faith come into play? Do we need to make actual legislation clearer? Every part of the system (CB, CVB, MRO) has liability provisions, - is this necessary? How could contracts between entities affect liability? Do we need a legal or insurance expert to review? Costa Rica: Both state and CBs can approve inputs Liability undefined Switzerland: FiBL says it would take liability and it saves CBs from risk Never tested USA: Consensus: Liability rests with CBs MROs, not CBs, ISO accredited
- Confidentiality concerns prevent CBs from sharing private lists and accepting decisions of other CBs and MROs COR permits consultation between CBs and mutual acceptance of approval decisions CB may share any confidential information with CFIA or other CBs to “verify validity of information on an operator”, and all parties must treat this information as confidential. ISO 17065: All info from client except for what is publicly available is to be treated as confidential CBs may share information if required by law or contractually agreed upon and the client is informed Confidentiality with third parties are governed by contract Do MRO’s Confidentiality Agreements conflict with CFIA oversight? OMRI contract: Confidential information will be released in the context of legal proceedings, third party audits, product compliance dispute, and requests from regulatory bodies CFIA Compliance and Enforcement can compel MROs to provide documents in the case of an investigation What’s in their contracts with suppliers? We don’t know. Could privacy be governed by contracts between CBs, producers and MROs? Legal expert needed? Other jurisdictions (not a lot to say): USA: Similar situation: CBs can consult and accept decisions Organic Food Production Act (1990) requires CB confidentiality No ISO so no opportunity for private contracts WSDA and OMRI accept each other’s decisions Not sure if they share info
- How can we get suppliers to share input approval costs without negatively affecting the supply of inputs? Possible solutions: Long-term -status quo/let the market figure it out -create one central database of inputs -voluntary sharing by CBs -CFIA mandated sharing -CB’s public lists linked to one another -Inputs as part of an organic integrity database (a list of certified organic operators and products in Canada currently in development by COTA, based on the USDA’s organic integrity database) -one input reviewer (maybe OMRI?) -Possible solutions: Short-term -create a shared methodology -would accreditation for input review help? -create strong conflict resolution process -would having a single CVB help?
- Contrasting approval between CBs Inconsistent accreditation and auditing for CBs due to multiple CVBs Lack of CVB audits for material review programs ISO 17065 and COR Operating Manual offer some structure, but do not go far enough: ISO 17065 details rules around subcontracting, impartiality, confidentiality etc. CGSB and COR do not address procedures or the level of depth USA: NOP 3012: little better than ISO 17065 or COR Operating Manual “Recalibration Training” for NOP auditors Accredited Certifiers Association: White Paper on Material Review: 2010: Is developing a shared methodology worth our time? 2019: Working group about to release a best practices guide Costa rica: CBs all have their own processes, but the still accept each other’s decisions Gov brings CBs together to discuss issues every two months (we have conferences but is it at the same level?)
- COR: Complaints against CBs are the responsibility of the CVB CB’s have a requirement under COR (c.2.2.8) to report another CB that has approved an ineligible input. “The CVBs shall come to collective decision on the status of the input in timely manner.” CFIA is the final arbiter (but what is their process?) Standards Interpretation Committee (SIC) provides interpretation of the CGSB 32.310, 32.311 and 32.312 Overseen by OFC, who support the SIC with their resources Convenes periodically to review questions, public given time to comment, answers posted on OFC site USA: NOSB Subcommittee on Materials/GMO Similar role to SIC Drafts clarifications, guidance and standards for the National List Chair appointed by NOSB, members appointed by Chair NOP 3012: Lays out process for dispute resolution - more direct communication with certifiers NOP notified of need for final determination Reviews to see if regulations have been properly applied If non compliant, the certifier will be informed and instructed to rescind approval. All certifiers informed, provided with a timeline for cessation Certifier decisions valid until are all informed of NOP decision NOP dispute resolution not used often. CBs will settle between themselves Switzerland: FiBL manages virtually all input verification No disputes, no need for dispute resolution - though complaints go to BioSuisse Costa Rica Similar to Canada: Complaints against CBs and handled by the government Accreditation and Registration Unit in Organic Agriculture (ARAO) ARAO forwards complaints to the CBs who must conduct an internal investigation and reports the results back to ARAO
- Now that we have a better idea of the parameters we’re working with in terms of liability and privacy, and the scope of problems like dispute resolution, we can better investigate the feasibility and logistics for the various options we talked about in January How does input verification interact with other government run registries and verification programs? Pest Management Regulatory Agency CFIA Fertilizer program How can we control input approval without negatively affecting the supply of inputs? Can we address the problem of CVBs not auditing material review? What sort of benchmark metrics do we need to measure progress on input verification issus?