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Thursday, 12 May 2016 18:16

Producers – Plan Ahead for Compliance

With the onset of the 2016 planting season in most regions, the time for decision making has arrived, and sometimes these decisions are made at the last minute. Many of the non-compliance issues that arise at inspection stem from these decisions and delay successful completion of the certification process. Some areas to consider in your spring planning include:


Seed Sourcing
The standards around seed sourcing in Canada and the US are essentially the same. Organic seed must be used unless not commercially available. Seed includes seed, bulbs, tubers, cuttings, annual seedlings, transplants and other propagules. If organic seed is not commercially available, you must be able to show your basis for this claim by documenting your search for the same. Pro-Cert’s Organic Seed Search Summary or equivalent record can be used. Non-organic seed used on the farm must be non-gmo. If you are planting a GMO potential crop (eg. Soy, corn, alfalfa, etc.) you need to collect a non-gmo statement from your supplier or consider a seed analysis prior to planting.


Permitted Substances
Any substances used that are not included on your Application & Contract Input Substance Summary, should be reported to Pro-Cert. These may include soil amendments, seed treatments, inoculants, crop amendments and more. To facilitate a timely review of the substance please collect from the distributor or manufacturer a list of ingredients. Please note – we do not need product formulation (the recipe) – only composition (the ingredients). Non-GMO statements for inoculants should also be collected and on file.

We strongly recommend approving substance use through our offices prior to application as: (1) substances can be reformulated from one year to the next and previously approved substances may no longer be compliant; (2) Canadian applicants are working with a revised Permitted Substance List in 2015; and (3) unpermitted substance use cannot be undone. Once applied, a non-permitted/non-compliant substance will result in the loss of organic status on the treated parcels.


Parallel Production
Parallel production is defined as the simultaneous production of organic and non-organic crop varieties, including transitional crops of the same or similar, visually indistinguishable varieties. Under the Canada Organic Regime (COR) parallel crop production of annual crops is strictly prohibited. Under the USDA National Organic Program (NOP), while parallel production is not specifically prohibited, operators are required to maintain physical barriers and management practices to prevent commingling of organic and non-organic products. Further, the record keeping system must be able to disclose all activities and transactions to be readily understood and audited.

Parallel production or annual crops under the COR, automatically results in the loss of organic status for the affected crop. Therefore we strongly encourage Canadian operators to consider your cropping plans closely to ensure there is no parallel production between your organic and transitional and non-organic parcels.

Parallel production under the NOP, is not prohibited but where possible we encourage American operators to avoid the practice. Records of handling of both the organic and non-organic produce must be available for inspection and audit. Additional post-harvest inspections may be required to verify segregation and appropriate record keeping.

By considering compliance in your plans at all times you can avoid potential issues, before they arise and potentially delay or derail your organic certification and marketing plans.

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