Group Certification under the US NOP: Send your comments to IFOAM
Note: Relevant documents are available here.

Name of your organization:  *
Your name (contact name):  *
Your Email:  *
Country:  *
IFOAM member
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Explain briefly your interest / involvement in the discussion on group certification:
 
Please comment on one or several of the following issues identified by IFOAM and click on "submit" when you are done.
 
Q1: IFOAM supported the criteria proposed by the CACC for the clustering of 'members' or 'sub-units" (understood as farms / operators) into Production Units (a group can be comprised of one or many production units), including the guidance that an upper limit on the number of subunits included in a given production unit should be based on the feasibility of effective oversight by management personnel and factors such as size and accessibility of the subunits. The OTA, on the other hand, has proposed an upper limit of 200, with the added requirement that production unit that includes more than 200 operators subunits must be fully justified based on the aforementioned guidance.
Do you think that this is too prescriptive?
 
 
Q2: IFOAM has taken the position that a distinction should not be made between initial and renewal inspections. In both cases, the Internal Control System (ICS) is audited every year, the production unit is inspected every year through a combination of risk assessment and random sampling of the members (subunits) and within the production unit, the ICS personnel visit and review each member's farm/plot at least once a year.
Do you agree that the methodology be the same for initial and renewal inspections?
 
 
 
Q3: IFOAM supported the CACC recommendations on the description of the ICS personnel and how to address potential conflicts of interest: in order to mitigate the potential for noncompliances to go unreported, the Internal Control System personnel must receive contractual (in-writing) assurances that under no circumstances are they to be admonished in any way because they have detected and reported a noncompliance. In essence, this written assurance from the organization (group) creates a firewall of protection for Internal Control System personal to implement the operation's Organic System Plan. Additionally, these personnel must also be required to disclose, in writing, any potential conflicts in advance of surveillance and review.
Do you agree?
 
 
Q4: The Appendix document imposes annual training of the members of a group by external specialists. IFOAM has taken the position that it is an unreasonable burden and instead recommended that all ICS personnel and group members receive training from an external specialist every 3-5 years, or more often if necessary or required by the accredited certifying agent as part of a sanction imposed or as a corrective action.
Can you share information on what types of training are commonly being done? How far are the groups from meeting the proposed CACC requirement and how far are they from meeting the alternative requirement proposed by IFOAM? Do you support IFOAM's alternative requirement?
 
 
Q5: The OTA has proposed that each subunit be externally inspected not less than every 5 years, meaning that the yearly rate of external inspection is 20%. This is much more demanding than the ISO 62 square root approach of the current IFOAM Accreditation Criteria and current EU guidance document.
Should IFOAM fight for its current IAC approach or be prepared to compromise and which outcome would be acceptable?
 
 
Q6: The OTA proposed the following methodology for the external inspection of subunits: "The process begins with use of risk assessment to identify subunits of greatest concern to select. The second step is to select a random sample of lower risk subunits to inspect, with the size of the sample based on risk factors for the group as a whole. Every subunit operator or member would thus know there was always a possibility of being inspected by the certifier, even if they are in the low risk group and have been inspected more recently than five years. Various risk assessment methods are used to identify the lower risk subunits and to determine the size of the random sample of these to be inspected. Higher levels of overall risk for a group would dictate a higher proportion of lower risk subunits to include in the random sample."
What is your reaction to this approach?
 
 
Q7: Do you have any other comment regarding the CACC documents, the IFOAM position or the OTA position?
 
 
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