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URGENT ACTION ITEM
Comments on Proposed Safe Food for Canadians Regulation (SFCR) to the CFIA

On January 21, 2017, the Canadian Government published proposed rule-making for the Safe Foods for Canadians Regulations (SFCR) in Canada Gazette I. These proposed regulations will combine and modernize 14 separate existing regulations including the Organic Products Regulations, 2009. The proposed regulations are designed to implement the Safe Foods for Canadians Act of 2012.

These proposed regulations impact all organic operators in Canada and may also impact those operators exporting into Canada. Pro-Cert Organic Systems Ltd. has been monitoring the development of these regulations and is participating with industry organizations to review the proposed regulations and provide feedback to the Federal Government.



The Deadline for Comments is:  April 21, 2017



The Address for Comment Submissions is:
    Richard Arsenault, Executive Director
    Domestic Food Safety Systems and Meat Hygiene Directorate
    Canadian Food Inspection Agency
    1400 Merivale Road, Tower 1
    Ottawa, Ontario K1A 0Y9
    Email:  This email address is being protected from spambots. You need JavaScript enabled to view it.



The SFCR can be found at:
http://www.gazette.gc.ca/rp-pr/p1/2017/2017-01-21/html/reg1-eng.php#reg



The SFCR Issues to Consider in your Comments Include:

  • The proposed move of the Organic Products Regulation (OPR) from Agriculture and Agri-Food Canada (AAFC) to Health Canada;
  • The loss of the Organic Products Regulation in exchange for Part 14 of the SFCR;
  • Specific errors and omissions in the SCR which include but are not limited to:
    • The lack of an acceptable appeal mechanism for organic operators and certifiers,
    • The lack of cancellation periods for fraudulent operators,
    • The proposed “expiring” certificate issue,
    • The problematic 15 and 12 month pre-application/pre-inspection rules.

Please also consider the Key Issues and Recommendations prepared by the Canada Organic Trade Association found at:
https://gallery.mailchimp.com/f64400aad0f09f97483d2c4d3/files/836ab5eb-ebee-4e7c-975f-67e0d0f29aab/SFCR.COTA.pdf



Additional Issues to Consider in your Comments Include:

  • The Loss of the Canada Organic Office (COO) and dedicated staff and titleswhich has already occurred,
  • The need for CFIA to create and publish a “positive” list of certified operators in addition to the existing “negative” list of cancelled operators.


The attached White Paper Version I
There are many other opportunities to improve the Canadian Organic Regime (program) or COR at this time of change. An ad hoc group of senior organic industry stakeholders has, over the last 12 months compiled a White Paper on COR enhancement opportunities. Version I was presented to the Minister of Agriculture on April 11th, 2017, and can be found at:
   
    PDF file: 
    http://pro-cert.org/images/documents/2017/White_Paper_Version_040717.pdf
   
You may wish to include some of the other issues and proposed corrective actions in your comment letter. The proposal to create the Canada Organic Products Act under AAFC instead of the proposed move to Health Canada needs your consideration and comment. This proposal is outlined in Section 2.0 of the White Paper.

 



Your Opinion is Important!
The CFIA is required by law to review and consider all the comments received in the 90-day gazette period. Do not miss this opportunity to improve the regulatory system which supports your organic business plan.

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.

The Canadian Organic Standards have been revised and updated and the new standards are being launched November 25, 2015. To ensure operators, producers, processors, certifying bodies, and verification officers are up to date on the revisions, COG is pleased to offer informative webinars - Changes to the Canadian Organic Standards - an Essential Update. The first round of the webinars have been successful and well attended.

 

The webinars are recommended for operators whose products are currently certified to the Canadian Organic Standard, independent organic inspectors, and the personnel of certification bodies and conformity verification bodies who require a knowledge of the Canadian Organic Standard to carry out their work. The cost of each webinar is $25 (tax included) but is FREE for ACORN members.

 

Dates and times (please note all times are listed in Eastern Time):

Friday, November 6 3:00PM Eastern - Crop Production presented by Maureen Bostock REGISTER HERE

Friday, November 13 11:00AM Eastern - Livestock Production presented by Anne Macey REGISTER HERE

Friday, November 20 11:00AM Eastern - Preparation Including Processing presented by Rochelle Eisen REGISTER HERE

 

Tuesday, February 2 - 8:00PM ASTCrop Production presented by Maureen Bostock REGISTER HERE

Thursday, February 4 - 8:00PM AST - Livestock Production presented by Anne Macey REGISTER HERE

Tuesday, February 9 - 8:00PM AST - Preparation Including Processing presented by Rochelle Eisen REGISTER HERE

 

DRAFT copy of Organic Production Systems General principles and management standards

DRAFT copy of Organic Production Systems Permitted Substances Lists

 

Part One: Crop Production

The first webinar in the series will examine the changes to the crop production components of the two standards.  We will also discuss changes to specialty crops: maple, greenhouse, sprouts, mushrooms and wild-crafting where applicable.  Changes to Tables 4.2 & 4.3 of the Permitted Substances List will be reviewed.  The webinar is primarily directed towards crop producers but would also be of interest to people involved in any level of the organic regulatory system.

 

Part Two: Livestock Production

The second webinar in the series will focus on the changes to the livestock production standards including changes to the Permitted Substances Lists for livestock feed and health care products.  The standards for beekeeping and honey production will also be reviewed.   The webinar will be of interest to livestock producers and people involved at any level of the organic regulatory system.

 

Part Three: Preparation Including Processing

The third webinar in the series will examine the changes to the preparation components of the two standards. Preparation includes, with respect to an organic product, the maintenance of organic integrity during post-harvest handling, manufacturing, processing, treatment, preservation, and slaughter. Changes to Sections 6 and 7 of the Permitted Substances Lists will be reviewed. The webinar is primarily directed towards anyone handling organic products as well as processors, but would also be of interest to people involved in any level of the organic regulatory system.

 

For more information or to register for the webinars please visit our website or contact us at  This email address is being protected from spambots. You need JavaScript enabled to view it.  or 1-888-375-7383.

More certified “Local Organic” food will be available at Farmer’s Markets and organic consumer’s doorstep in Ontario in 2015! Locally grown organic produce bearing the logo: 
Pro-Cert LOC Logo Ontario - Colour

means that it was produced on a small farm in Ontario in accordance with the Canadian Organic Standard and certified by Pro-Cert Organic Systems (Pro-Cert), an independent agency. A small farm, as defined by the provider of this unique service, is usually less than 10 ac in size, and is owned and operated by an Ontario family. J. Wallace Hamm, founder and General Manager of Pro-Cert stated: “The provision of a risk assessment based inspection and certification system designed for small Canadian farms is long overdue!” He continues “We’ve been working on this program since 2011 but were stymied by the rigid need for and cost of the annual inspection process explicit in the Canadian Organic Regime (COR). Annual inspection is only cost effective and appropriate for larger farming operations.”

“The Ontario program is a pilot project designed for provinces without provincial regulations or with regulations which will accommodate risk-based inspection and surveillance intensity” noted Dave Lockman, the Pro-Cert Certification Program manager for Eastern Canada.

The oversight and surveillance focus in LOC is on verifying the absence of unpermitted synthetic fertilizers, herbicides, insecticides, fungicides and other pesticides, and the non-use of GMO and other unpermitted technology during the annual food production cycle. Similarly, emphasis will be placed on ensuring the absence of unpermitted sanitation agents and preservatives during any on-farm processing, handling and transport to the market place.

Pro-Cert growers with dedicated land area greater than 10 ac are also able to use the Pro-Cert “Local Organic” logo on produce/product sold within the province but must be certified compliant with the Canadian Organic Regime (COR) and the annual inspection requirement.

The cost of this new service will be $300 per year based on a risk adjusted inspection schedule, plus inspection travel cost of $50 per event. The frequency of inspection will depend on the level of organic compliance as determined at the most recent inspection event or by other means of surveillance including but not limited to random sampling of produce and testing for unpermitted substances and technology. Small organic farms which require more than one inspection every two years will be required to pay for the extra inspection(s).

“Organic integrity is implicit in this risk based program” claims Hamm, who has worked as a forensic agrologist for some 45 years. “Producers who stray from the Canadian national standards will be identified and their problems will be corrected if they wish to use the Pro-Cert ‘Local Organic’ logo” continues Hamm.

“This is a ‘COR Ready’ program” says Lockman. “Local organic producers who out-grow the ‘small farm’ criterion or who wish to sell their surplus produce to COR certified buyers in or outside of Ontario, simply need to apply for and comply with the COR requirements including annual inspection and costs.”

The future of the LOC program in Ontario and in other provinces will depend on provincial organic regulations. If Ontario and the other provinces make provision for risk assessment based certification of small farms selling produce within their jurisdiction, then the Pro-Cert LOC program and similar programs will carry on into the future.

British Columbia is in the process of converting its voluntary risk assessment based provincial organic certification program to a mandatory one. “We are hopeful that Ontario and the other provinces will follow B.C.’s and Pro-Cert’s lead in addressing the special needs of small organic farmers with local markets,” continues Lockman.

Quebec, Manitoba and New Brunswick already have provincial regulations governing the use of organic labelling within their boundaries. All of these provinces have simply adapted the COR requirements without special provisions for small farms. “Given a successful ‘roll-out’ in Ontario, in 2015, we will extend the program to the remaining unregulated provinces in 2016 and beyond” states Hamm. “In the meantime, we will work to encourage the provinces already regulated to consider provisions for the certification of small organic farms with local markets.”

“’Local’ is a consumer/producer driven phenomenon that is not going away” mused Hamm. “Organic producers and consumers in Ontario and across Canada will benefit from the Pro-Cert small farm certification program and without a decrease in diligence, organic integrity or confidence” he concluded. Pro-Cert is Canada’s only Canadian, wholly family owned, certifying body. Its Head and Western Regional Offices are located on the Hamm family organic farm near Saskatoon, Saskatchewan. The Eastern Regional Office is located in the Village of Cambray, Ontario, and is responsible for the Ontario LOC program.

For more information contact: Pro-Cert Organic Systems (Pro-Cert) Head Office: J. Wallace Hamm Ph.: (306) 382-1299 Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

or Pro-Cert LOC Program contact for Ontario: Dave Lockman Ph.: (705) 374-5602 Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Click here to review the informative presentation by Wallace Hamm, PAg and Hugh Martin, CAA-ON outlining the economic advantages of transitioning to organic in Canada (Microsoft Powerpoint format).

Please take the time to read and forward. The article is found in AgAdvance, September, 2014 edition. You can also find a link to the online version here - http://agadvance.com/issues/sep-2014/organic-growth.aspx.

Draft editions of two National Standards of Canada for organic production systems are available for public review
Ottawa, July 23, 2014 ― The Canadian General Standards Board (CGSB) has released draft editions of the following Organic Agriculture Standards:
CAN/CGSB 32.310 Organic production systems ― General principles and management standards
CAN/CGSB 32.311 Organic production systems ― Permitted substances lists


These two standards can now be downloaded for public review.  Alternatively, you can contact CGSB at 
http://www.tpsgc-pwgsc.gc.ca/ongc-cgsb/cn-cu-eng.html
It is anticipated that there will be two public review periods. The first period of public review will be for a minimum of 60 days in accordance with the development of a National Standard of Canada and will be opened for comments until September 22, 2014.


Two versions of each draft are available, a copy showing the proposed changes since the last edition, and a copy not showing these proposed changes, to facilitate reading.  No changes have been balloted for approval by the committee to date. In addition, copies of the minutes of the two meetings for the development of these standards are available and detail the rationale for the changes and items rejected. Here is a list of the documents available in English and French:
To access the documents in French, please go to this site:
https://ssf.scc.ca/forums/cgsb-ongc/dispatch.cgi/_admin


Username  :  anonyme
Password :  ongc
Documents will be in the folder :
Public Review - examen public / Discussion/032/20 Organic Agriculture - Agriculture biologique
To access the documents in English, please go to
https://ssf.scc.ca/forums/cgsb-ongc/dispatch.cgi/f.discussion19/showFolder/100004/def/def/f79c

English documents:
Draft CAN/CGSB 32.310 English Changes not identified
Draft CAN/CGSB 32.310 English With changes identified
Draft CAN/CGSB 32.311 English Change s not identified
Draft CAN/CGSB 32.311 English With changes identified
Change form
Minutes of December 2013 Meeting
Draft Minutes of April 2014 Meeting

French documents:
Draft CAN/CGSB 32.310 French Changes not identified
Draft CAN/CGSB 32.310 French With changes identified
Draft CAN/CGSB 32.311 French Changes not identified
Draft CAN/CGSB 32.311 French With changes identified
Change form
Minutes of December 2013 Meeting
Draft Minutes of April 2014 Meeting
Members of the committee, organisations, institutions and the public are encouraged to submit comments, with supporting rationale, for any recommended changes.  Technical changes, translation issues and major editorial improvement s are welcome, but minor editorial changes are not recommended.  Only submissions sent via the Change Form with the appropriate supporting information will be accepted.    Please note that the standards do not include individual products or brand-names.
The Canadian General Standards Board will then compile, group and prioritize comments for the committee and disposition. The goal is to amend and re-issue the drafts, ballot by the committee and publish in Summer 2015.
If you want more information about the process or stay informed of the work of the committee, please contact
Mark Schuessler
This email address is being protected from spambots. You need JavaScript enabled to view it. < This email address is being protected from spambots. You need JavaScript enabled to view it. This email address is being protected from spambots. You need JavaScript enabled to view it. >
Canadian General Standards Board

The Review of the COS is underway, and it is exhaustive: all sections of the organic standards have to be revised. The review exercise will take

Pro-Cert’s much anticipated annual Newsletter is now available! This edition highlights 2014 Organic Prospects and includes a profile of the Canadian Organic Marketplace. Also included are Canada Organic Regime (COR) and USDA National Organic Program (NOP) Regulatory Updates as well as new information related to equivalency and international trade.

For this and more, download your copy now! A print edition is available through our offices if you are not already on our mailing list.