(UPDATED COVERAGE, March 29) Federal officials are considering how to implement unannounced inspections of certified organic operations and beef up criteria for inspectors, at the recommendation of the National Organic Standards Board.
In a March 21 memo to the NOSB, the deputy administrator of the National Organic Program, Miles McEvoy, responded to those and other recommendations the standards board made at its 2011 fourth-quarter meeting.
One member of the standards board sees the value of the recommendations from two sides of the issue. Standards board member John Foster is also senior manager for quality, food safety and organic integrity at Earthbound Farm, San Juan Batista, Calif. Before joining the Earthbound staff, Foster was a grower, researcher and organic inspector.
Foster said unannounced inspections are one method to improve the whole organic industry.
The Organic Trade Association is also on record as being in favor of the recommendations.
The standards board recommended mandatory unannounced inspections for at least 5% of certified operations each year. The scope could be limited, with the collection of samples depending on individual situations. According to the NOSB, an unannounced “full inspection” could serve as the annual on-site inspection for a certified operation.
“The vote of the NOSB demonstrates a strong will to ensure that all producers of organic food are in compliance every day,” Foster said. “In my many years as an organic inspector, I came to see that this kind of protocol improved not just compliance with the standards, but also provided real business value regardless of scale.”
In the memo, McEvoy said the NOP will “explore ways to implement inspection requirements to enhance organic integrity.”
As a former grower, Foster voiced support for tougher requirements for organic inspectors.
“I think the organic community and industry will be well served if we set standards for inspectors to calibrate expectations and accountability throughout the industry,” Foster said. “We owe it to certified producers and handlers, and to consumers, to ensure that the boots on the ground have sufficient experience, expertise and training.”
Recommendations for inspector qualifications include a baseline expertise level, continuing education requirements and accreditation criteria for certifying agents. McEvoy said in the memo the NOP has commissioned “additional work in this area” with the International Organic Inspectors Association.
The NOSB also recommended regulations for organizations that test and certify pesticides, fertilizers and other products used in organic production. The owner of a California company recently pleaded to falsifying paperwork on ingredients of supposedly organic fertilizer; tests proved he was using unapproved synthetic materials.
Currently NOP accredits third-party organic certifiers for crops, livestock, handling and wild harvest, but not for the review of fertilizers and other materials.
Foster said organizations that review those materials bear a unique burden and there must be controls in place to ensure they are qualified.
The Organic Trade Association has called for an accreditation process for material review entities, saying uniformity at the federal level would go a long way in guaranteeing the integrity of organic operations, according to a regulatory update written earlier this year by OTA’s associate director for organic standards and industry outreach Gwendolyn Wyard.
Members of the standards board recommend that accreditation of material review organizations include:
u A requirement that they use the NOP material classification guidance — which is still in development — to determine whether a material is synthetic or non-synthetic;
u Implementation of a quality management system with detailed review protocols and policies as required by ISO Guide 65 accreditation standards;
u Mandatory use of the NOP’s guidance for permitted generic substances, which is under development; and
u A requirement that part of their financing come from manufacturers of products seeking review.
The standards board also recommended that material review organizations be subject to compliance and enforcement actions of the NOP.
McEvoy’s memo did not indicate whether the NOP would develop an accreditation process for material review organizations. He merely said the NOP would report back to the NOSB “on how we plan to proceed with these recommendations.”