Organic Integrity in the Supply Chain: Overview for Certified Organic Handlers

Hello, I’m Miles McEvoy, Deputy Administrator of the National Organic Program within USDA’s Agricultural Marketing Service. Today, I’ll be covering organic handlers’ and organic certifiers’ responsibilities to ensure compliance of all organic imported products with the USDA organic regulations. We will review the responsibilities of organic handlers in verifying that imports comply with U.S. standards and we’ll review the role of certifiers in overseeing imports and enforcing the standards. This is especially important for organic imported products that involve long and complex supply chains. The National Organic Program’s mission is to protect the integrity of USDA organic products throughout the world, so consumers can trust the organic label. We do this by enforcing the Organic Foods Production Act and the USDA organic regulations. We have implemented an organic control system that includes organic standards; inspections and auditing of organic farmers, processors, handlers and distributors; accreditation of the certifiers that verify organic production and handling; and an enforcement process that includes civil penalties and other sanctions. The size and complexity of organic trade has grown over time, and many U.S. businesses rely on imports to create the organic products that consumers want. As the organic market grows, many growers, processors, and handlers are working within multi-business supply chains, often across borders. Organic handlers play a vital role in ensuring the integrity of organic products from farm to market. The global organic control system includes strict standards; accreditation of certifiers (also known as control bodies); certification of farmers, processors and handlers; and enforcement. There are three critical components of the certification process. First, organic system plans that describe all aspects of the farming or handling system and how those operations comply with the organic standards. Second, comprehensive inspections/audits of the production and handling operations, and third, audit trail and traceback systems that ensure organic products can be traced from farm to market, or market to farm. Organic certification is a key component of the global organic control system. Handlers that sell, label, or represent products as organic must be certified with limited exceptions. We’re focusing on organic handlers in this presentation, so let’s be clear on what handling involves. Wholesalers, traders, importers, exporters, brokers, distributors and commissioned merchants are handlers, as they are involved in selling organic agricultural products and must be certified, unless they are only handling organic products that remain in the same packaging or container. Let’s summarize the requirements for certified organic handlers. Handlers must have complete organic systems plans, recordkeeping systems, compliant organic handling practices, and are subject to inspections and audits at least annually. Organic System Plans describe in detail the practices it follows to ensure organic integrity. For example, organic system plans must list each input used and its source – this includes all organic products received – from all sources – whether they are from local farms or are imported products. The handler must have procedures to verify that all organic products received comply with the USDA organic regulations and they verify that they originate from a certified organic producer or handler. Handling operations must have recordkeeping system that fully discloses all activities and transactions in sufficient detail to be readily understood and audited. Some examples of the records that many handlers maintain, and that certifiers regularly check during inspections and audits include records verifying incoming product, certificates for all incoming products, invoices, purchase orders, bills of lading, scale tickets, clean truck affidavits, contracts, certificates of analysis, inventory records, weigh tickets, receipts, and more. These records must be sufficiently detailed so that an inspector can easily understand and audit them. They must be sufficient to verify that the all imported organic products comply with the USDA organic regulations. If the documentation does not provide a clear audit trail back to a certified organic operation, then the product cannot be sold, labeled or represented as organic. Now, let’s look at critical practices that certified handlers are required to implement. The regulations require organic handling operations to prevent the commingling of organic and nonorganic products; and protect organic products from contact with prohibited substances. For example, fumigation with a prohibited substance results in a product being no longer organic. Handlers must also make sure that any container used for organic products is clean of non-organic products or prohibited substances. They also implement proper clean-out and transportation procedures to prevent organic product from coming into contact with non-organic product. So, if you are moving grain, for example, from a truck to a large storage container or cargo hold on a ship, you must make sure that adequate clean-out procedures of the container have been completed, so there is no risk of contact with any prohibited substance. Certified handlers must be available during normal business hours for inspections, sampling, and audits of records by certifiers or National Organic Program personnel. These audits include reconciliation audits, that evaluate the amount of organic product received, compared to the amount of organic product sold. The inspections also include trace-back audits to ensure a complete audit trail back to the last certified organic operation. Some handlers may be excluded from certification, if the handler only receives organic products that are already packaged or in a container, and remain in the same package or container. This means there are uncertified handlers that are involved in the supply chain between the farm and the market. Because of this, it is critical that certified operations have sufficient records to maintain the audit trail, especially if they are sourcing ingredients from uncertified handlers. Certified operations may not accept organic products without verifying the source and certification of the product. Now, let’s review the role of certifiers, the organizations that oversee certified operations. USDA-accredited certifiers operate around the world, and conduct inspections at every certified organic operation. Certifiers also collect samples and test for prohibited substances – this residue testing is a critical element of the USDA organic regulations. Certifiers audit the certified operation to ensure they are maintaining appropriate records for imported and exported products. Certifiers also confirm that the operation maintained the organic integrity of imported product; this includes no fumigation, irradiation, and commingling. Finally, certifiers issue operations certificates, transaction and import certificates when they verify compliance with the organic standards. Certifiers are also critical in conducting investigations and enforcing the standards for the operations they certify. Certifiers have skilled inspectors all over the world that investigate complaints and conduct unannounced inspections. Certifiers also issue adverse actions and conduct mediation sessions that bring operators into compliance and protect organic integrity. Organic inspectors and certifiers work globally to protect the integrity of the USDA organic seal. USDA-accredited certifiers are required to follow detailed accreditation requirements, outlined in the USDA organic regulations and the NOP program handbook, which is available online. NOP conducts on-site evaluations of certifiers every 2.5 years, at the midpoint and at the renewal point of the five-year accreditation term. Additional audits are conducted based on identified risks or compliance concerns. Here’s summary of what YOU can do. If you are a certified organic handler, reconfirm that you are following the requirements we discussed today. Make sure you have solid documentation that organic imports are certified organic, and request import or transaction certificates issued by accredited certifiers when you are importing products. If you do not have solid documentation that verifies that imported organic products comply with the USDA organic regulations or if you do not have solid documentation that verifies the certified organic source of the organic product then you must not sell, label or represent that product as organic. If you have evidence that a product being sold as organic does not meet the requirements, we encourage you to provide specific information to [email protected] The Agricultural Marketing Service and the National Organic Program are commited to protecting organic integrity across the supply chain. The goal of this presentation was to summarize requirements for certified handlers – for more information about the organic standards, visit us at Thanks for listening.

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