Laura Batcha, executive director, Organic Trade Association & Melissa Hughes, board president, OTA

Organic Trade Association weighs in with USDA on top enforcement priorities

The trade group identifies the most critical areas to increase the integrity of the global organic control system.

The Organic Trade Association on Wednesday submitted comments to the U.S. Department of Agriculture (USDA) on its top ten priorities to boost the integrity of the global organic market.

The comments were filed to help shape a set of proposed rules that the National Organic Program (NOP) will publish in spring 2019 to strengthen the oversight and enforcement of organic regulations. NOP is calling the rules its Strengthening Organic Enforcement rulemaking, and it is one of the largest pieces of single rulemaking in the history of NOP. The proposed rule will cover at least 10 major topic areas related to oversight and enforcement.

The trade group's identified priorities reflect the input from an Organic Trade Association members task force formed earlier this year to engage early with the NOP, to answer a set of enforcement related questions that NOP distributed to the organic industry, and to help craft a fair and effective final rule that will protect organic trade and the USDA Organic label.

"The USDA, organic certifiers, and organic businesses all have a shared role in protecting the integrity of the Organic seal, and our members have stepped up to be a part of the solution," said Laura Batcha, CEO and Executive Director of the Organic Trade Association. "Today's organic market is a global market, and fraud anywhere in the global chain impacts all of us. The integrity of organic is the lifeblood of the organic industry, and we are committed to preserving and strengthening the trust in organic held by consumers all over the world."

The Organic Trade Association urged the NOP to take "timely action" on all of the key areas identified, saying that each priority cited is "extremely important" to increase organic integrity.

The top ten list of the trade group's enforcement priorities were the following:

Excluded Operations: Require certification of each producer, handler and handling operation in the organic supply chain with very limited exceptions.

Organic Integrity Database: Require at least annual reporting to the Organic Integrity Database from accredited organic certifiers on aggregate organic production area by crop and location.

Complaint & Alert System: Upgrade the process to prioritize complaints, improve the National Organic Program complaint system, and develop a public alert system.  

Organic Identification: Boost organic identification requirements to include in documentation with certified products and with all non-retail containers and packaging containing organic.  

Testing: Update the National Organic Program's Guidance on Residue Testing and increase required use of testing for imports and other high-risk products and/or regions.

Grower Groups: Formally respond to the National Organic Standards Board Recommendations and conduct rulemaking to ensure consistent oversight and enforcement of group operations.

Inspector and Certifier Oversight (including Satellite Offices): Develop more robust auditing of Accredited Certifying Agencies including annual audits of satellite offices domestically as well as in foreign countries.

Equivalency and Recognition Arrangements: Prioritize oversight and data transparency in arrangements, improve communications with the trade partner, and do appropriate follow-up.

Inspectors (Qualifications, Training and Field Evaluations): Improve qualifications and training of inspectors to detect fraud, and set minimum requirements for qualifications/training.

Import Certificates: Put in place a system that collects more data, including tracing the original product to its origin, and improve online access to electronic import certificate system.

Source: The Organic Trade Association

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