 |
Last update: 23rd October 2008
New! IFOAM’s position and appeal for public comments on the CACC recommendation to the NOSB - Recommendation on Certifying Operations with Multiple Production Units, Sites and Facilities under the National Organic Program.
As communicated in recent announcements, IFOAM has been working on preparing a response to the August-September recommendation of the Certification, Accreditation and Compliance Committee (CACC) of the US National Organic Standards Board (NOSB) regarding the certification of operations with multiple production units, sites and facilities. This recommendation is intended to lead to a guidance document or regulation that would replace or complement the 2002 NOSB recommendation on group certification.
Based on several rounds of consultation among its membership and other stakeholders during the spring and summer, IFOAM prepared a draft position on the latest CACC recommendation published in September 2008. The draft position has been sent out for a final round of comment in the past couple of weeks, and received broad support and valuable inputs from nearly 20 organizations. Based on these inputs, we developed the final IFOAM position which you can download by clicking here.
IFOAM will submit and defend this position prior to and at the mid-November NOSB meeting in Washington DC. However, numbers matter, which is why we encourage each of you to submit a similar comment, or letter of support for the IFOAM position, to the NOSB before the deadline, which is November, 3rd 2008.
Here you also find the “How to file your comment” document which explains how to submit your comment to the NOSB, either by Internet (which we recommend) or by post, and how to view comments that have already been posted.
This is a strategic opportunity for the organic movement to shape its own future by ensuring the continued acceptance of group certification for all those smallholders whose livelihood has already been significantly improved through access to international organic markets. With coordinated efforts and a massive participation, we have a chance to influence the outcome of the NOSB discussions, as well as the resulting rule by the US National Organic Program. I count on your active participation to make this action an influential one. I also encourage you to circulate this announcement within your own network. Please, be reminded that the deadline for comments is the 3rd of November.
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.
At its upcoming meeting on the 17th-19th November, the NOSB will
discuss a final recommendation provided by its Certification,
Accreditation, and Compliance Committee (CACC).
|
|
