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NOSB recommendation on Group Certification |
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Last update: 2nd January 2009.
New: final released formal NOSB Recommendation to the NOP on Certifying Operations with Multiple Production Units, Sites and Facilities under the National Organic Program, November 2008. Click here to view it.
On November 19th, the National Organic Standards Board (NOSB), an advisory group to the USDA National Organic Program (NOP), discussed the recommendation presented by their Certification, Accreditation and Compliance Committee (CACC) on “Certifying Operations with Multiple Production Units, Sites and Facilities under the National Organic Program”. The CACC recommendation passed, with two substantive amendments:
- All new entrants to a group must be externally inspected in their first year with the group. New entrants are in addition to the determination of the sample size of high risk and random.
- Under risk factors to consider in determining high risk, the following was added: Gross earnings of U.S. $5,000 or more per year.
This last amendment is however to be understood as the $5,000 USD gross income being only a risk factor, not a mandatory requirement for inspection. Although IFOAM did not originally support these two amendments, they appear to be the best compromises reached, as other suggestions were far more restrictive to the continuation of grower groups. The vote by the NOSB was 12 yes, 2 no and 1 member was absent.
This final recommendation is the result of a year and a half of work by the CACC, with intensive input from IFOAM, the Organic Trade Association (OTA), and other certification agents and civil society organizations who responded to the various public comment opportunities provided by the NOSB. In this last round of comment, ending Nov 3rd, the NOSB received 21 written comments (14 from IFOAM members), among which 20 supported the concept of the CACC recommendation and the continuation of group certification. 7 supported the recommendation unconditionally, while 13 supported it with some reservations or requested changes. Only one organization (US-based certifier) indicated an opposition to the certification of grower groups altogether. 11 comments support the IFOAM position and comment, half of them unconditionally.
A consistent theme among those making oral comments was the need for training of the members of the group, the internal control system staff, and certification agents who take on group certification. A suggestion that IFOAM had brought forward last year, to include a new category of NOP accreditation for multi-site certification, was reiterated several times at the meeting. The NOP has noted that this would require a rule change.
The final amended language of the recommendation was released by the NOSB Executive Director in December 2008. This new recommendation provides additional guidance and does not contradict or cancel the previous recommendation provided by the NOSB in 2002, which is also valid. The NOP will now decide how to deal with the recommendation and whether additions to the NOP Rule will be proposed or if a guidance document for certification agents is sufficient to enforce the current NOP Rule.
Background:
The US NOSB (National Organic Standards Board) submitted a recommendation to the USDA (United States Department of Agriculture) in 2002 regarding the certification of community grower groups. Currently the 2002 NOSB recommendation on grower group certification is still allowed as a guidance document for accredited certifying agents (ACA) but the Certification, Accreditation and Compliance Committee (CACC) was mandated to update and/or clarify the 2002 NOSB recommendation in order to address the issues related to oversight and inspection of grower groups that resulted from the noncompliance decision of a grower group certification in 2007.
The CACC completed their recommendation which was posted in the US Federal Register for an open public comment period in fall 2007. Comments were considered at the November 2007 NOSB meeting and the recommendation was continued as a discussion paper with a decision to defer any vote on the recommendation until further work was completed by the CACC. The October 2007 CACC recommendation can be viewed here.
The US being the largest market for organic products in the world, and group certification being a main model through which developing country organic producers are certified, it was essential for IFOAM to influence the outcome of the NOSB recommendation drafting process. Beginning in August 2007, IFOAM liaised with those who had drafted the CACC recommendations and with the US National Organic Program (NOP) to educate on and advocate for the group certification concept based on IFOAM criteria and guidelines. Despite these efforts, IFOAM was not satisfied with the final November 2007 CACC recommendations. Fulfilling its role of leading the organic movement worldwide, IFOAM worked on a response to the recommendation, and then organized a member call to action as needed to influence the outcome of the NOSB vote. A special IFOAM Task Force prepared a position on the CAC recommendations, which was released the week prior to the deadline for comments and submitted to the NOSB during the November 2007 meeting.
In the download column of this page you find the IFOAM November 2007 position which explains why the group certification procedure, when properly managed and inspected, is compliant with the requirements of the US National Organic Program (NOP) Regulations. You will also find the IFOAM November 2007 comment letter to the NOSB, as well as the sample letter that was developed by IFOAM during that period and the 10 points highlighted in the document entitled “10 points for comments”.
To read our Questions and Answers on the revision of the NOSB 2002 recommendation on “Criteria for Certification of Grower Groups”, click here.
To read the final report of the IFOAM actions until November 2007, click here.
Between November 2007 and May 2008, the CACC worked on developing a new guidance document to be appended to their November 2007 recommendation. The appendix document was posted for public comments shortly before the 20th- 22nd May meeting, during which the NOSB received comments from the stakeholders on that document.
The IFOAM group certification task force put together a comment to the Appendix document, which was read by the World Board member Katherine DiMatteo at the NOSB meeting. Other organizations such as the Organic Trade Association (OTA) of the US also commented on the document. A number of issues have been raised, such as the number of external re-inspections needed, the possible distinction between initial and renewal inspections, the frequency of external training of the group, etc.
Unfortunately, there was not sufficient time for IFOAM to collect comments from its members prior to the May 2008 NOSB meeting. The CACC put out their paper late and the time to respond was very short. However, the appendix document was not presented for a vote this time, which left space for another round of comments before the November 2008 NOSB meeting.
Shortly after the May 2008 NOSB meeting, IFOAM identified key questions and requested comments from its membership and other stakeholders to help prepare its position during the summer of 2008, in anticipation of the new CACC recommendation that was going to be made public in September 2008. Comments were collected and taken into account in the drafting of the position on this September CACC recommendation.
Based on several rounds
of consultation among its membership and other stakeholders during the
spring and summer, IFOAM prepared a draft position on the CACC
recommendation published in September 2008. The draft position has been
sent out for a final round of comment after the publication of the September recommendation, and
received broad support and valuable inputs from nearly 20
organizations. Based on these inputs, IFOAM developed the final IFOAM position which you can download by clicking here.
IFOAM
submited and defended its position prior to and at the mid-November
NOSB meeting in Washington DC and encouraged its members to submit a similar comment, or letter of support
for the IFOAM position.
At its 17th-19th November meeting , the NOSB discussed the final recommendation provided by its Certification,
Accreditation, and Compliance Committee (CACC), alongside the inputs from public comments.
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