Sixty-day Comment Period Announced for NOP National List - The USDA AMS is seeking public comment to determine whether materials currently on the National List should continue to be allowed or prohibited in organic production and handling.

As required by the Organic Food Production Act of 1990, a sunset provision requires that all 165 synthetic and non-synthetic substances in organic production and handling be reviewed every five years. The current list is set to expire Oct 21, 2007. As a result, the USDA AMS seeks public comment. It is imperative that the organic industry makes comments about all materials listed on the present National List. According to the USDA AMS, if “No Comments” are received on a material, it will automatically be removed from the list. Deadline for comments is Aug. 16, 2005. Your public comment should include relevant documentation that supports your position.

Submit written comments (identified with Docket Number TM-0407) by mail (send to Arthur Neal, Director, Program Administration, National Organic Program, USDA-AMS-TMP-NOP, 1400 Independence Ave., SW, Room 4008-So. Ag Stop 0268, Washington, DC 20250), e-mail (National.List@usda.gov), or fax (202-205-7808). The Federal Register notice is posted under the Agricultural Marketing Service at http://www.access.gpo.gov/su_docs/fedreg/a050617c.html

QAI Launches Two New Programs - QAI has developed two new programs for the certification of pet food and personal care products. For both programs, the National Organic Program (NOP) Rule is used as the foundation, with additional requirements outlined in a separate addendum. Until such a time as there is an industry approved national organic personal care standard and pet food standard, QAI will certify personal care products and pet foods to the minimum requirements summarized below.

Since the NOP has been clear that the NOP Rule does not cover the certification of pet foods and personal care products, these products certified under QAI’s programs are advised that they may not display the USDA seal. Furthermore, clients certified to these programs will be issued a “QAI applicable standard” certificate rather than an NOP certificate.

Pet Food - There are two categories of certification under QAI’s pet food program: 1) Pet Treats and Snacks and 2) Pet Food. Certification under the first category requires that organic pet food marketed as “Pet Treats” or “Pet Snacks”, which also does not make a “complete and balanced” (or similar wording) claim on product labels, must comply with the relevant sections of the NOP Rule in order to be certified as “100% Organic”, “Organic”, or “Made with Organic (specified ingredients or food group(s))” by QAI. Certification under the second category requires that organic pet food that is marketed as “complete and balanced” (or similar statement) must meet all relevant sections of the NOP Rule, with the exception of added essential nutrients¹, and must also meet the nutritional standards set by the Association of American Feed Control Officials (AAFCO) in order to be certified as “100% Organic”, “Organic”, or “Made with Organic (specified ingredients or food groups)” by QAI. (Click on above image to view actual QAI’s Pet Food Addendum.)

Personal Care - Under QAI’s Personal Care Organic Certification Program, QAI also accepts the use of organic ingredients that are certified to the European Organic Regulation, EEC 2092/91. In addition, QAI accepts the use of non-organic, non-agricultural materials that are listed on Table 2, Annex VI, of the EEC 2092/91². For all organic ingredients used, participants in this program will need to maintain organic certification documentation to verify that all organic ingredients are certified to the NOP and/or the EEC 2092/91. For all non-organic, non-agricultural ingredients or processing aids used, participants in this program will need to maintain documentation that verifies that the materials comply with relevant annotations and are not produced and processed with the use of excluded methods (Genetically Modified Organisms) and ionizing radiation, as described in Food and Drug Administration regulation, 21 CFR 179.26. The use of non-organic, agricultural ingredients is subject to all applicable requirements under the National Organic Program (7 CFR 205). (Click on above image to view actual QAI’s Personal Care Addendum.)

1. The FDA defines “Essential Nutrients” as external sources of vitamins, essential minerals, essential amino acids and essential fatty acids that are found in the tissues of healthy target animals and are not produced in sufficient quantities to support an animal’s growth, development, function, or reproduction.

2. QAI is aware that some European certifiers have developed their own private organic standard for personal care products. At this time, QAI has not reviewed individual personal care standards. While QAI is currently only allowing participants in this program to use suppliers and ingredients that comply with the NOP or the EEC Regulation 2092/91, we may consider reviewing and accepting personal care standards if they are deemed compatible.

JAS Law Being Revised - The current Japanese Agricultural Standard (JAS) organic law, enacted in June 2000 to regulate the term ‘organic’ on plant-based food products, is undergoing a major revision. This revision includes the introduction of new organic livestock regulations, changes to the current production and handling requirements, and an overhaul of the current procedures to accredit certification bodies.

The new JAS regulation will be established to manage the production of organic livestock and livestock products. Under the new regulation operators exporting organic dairy and other livestock products to Japan will need to be certified to the JAS livestock standards. The proposed JAS livestock standards are significantly different from the NOP in many areas. Some notable differences are more perceptive stocking and feeding rates, different transitional requirements, less restrictive organic feed requirements, and more lenient standards for the use of drugs for livestock healthcare. The current export arrangement between the US and Japan would need to be amended to include livestock products as it currently only covers plant-based food products.

JAS - Organic Agricultural Feeds
JAS - Organic Livestock Products
JAS - Organic Processed Feeds
JAS - Organic Processed Products

Changes to the two current JAS regulations covering production and processing of plant-based organic products will have mixed effects on organic operators. These changes include allowing and disallowing different agricultural chemicals, food additives and non-agricultural ingredients. Pest control substances were amended for processing operations that should make it easier for JAS certified processors to control pests. The revised allowable list of food additives is more restrictive, only allowing additives that have been explicitly listed in the regulation.

Japan Organic Products - Changes to Japanese Organic Standards

JAS accreditation of certification operations is also expected to change. In a move to reduce the central government’s role in the administration of the JAS law, many roles of MAFF (Ministry of Agriculture, Forestry & Fisheries) are being shifted to certification organizations. The JAS law is being restructured along the lines of ISO Guide 65 requirements and will require all current Registered Certification Organizations to become reaccredited under the new system. The new accreditation will include an onsite inspection of the certification organization, which could be cost prohibitive for some current Registered Certification Organizations. Foreign Registered Certification Organizations will be required to pay the travel costs of two auditors in addition to the current translation and interpretation costs. All applications will need to be made in Japanese and English language support will not be offered.

Japan Food and Agricultural Import Regulations and Standards
JAS Law System to be Revised in 2005

These changes are expected to be officially adopted in September 2005. Between September and March 1st 2006 all certifiers will need to be reaccredited under the new accreditation system. Certification bodies that are not reaccredited by March 1st 2006 will not be allowed to certify new JAS organic operations after that date. Additionally, all operators will have to change to productions and processing systems complaint with the new JAS law by March 1st 2006 in order to continue JAS certification.

QAI will continue to closely monitor these changes in the JAS law and will notify our clients of all the pertinent changes once they have been made official. QAI, through our Japan office, Ecocert-QAI Japan Ltd., is already preparing for the new JAS certification and accreditation requirements, and will continue to provide JAS certification to the new requirements. QAI’s expertise and quick response to regulatory updates such as these enable us to continue servicing our clients without international trade disruptions. QAI can get you there!

QAI Answers Your Call - Some of our valued clients have been asking similar questions regarding QAI’s operational policies. As a result, and for your convenience, we have compiled and published QAI Policies pertaining to Organic System Plan Certification. Electronic versions are now being sent out to applicants and renewing clients with their annual invoice.

QAI Policies apply to the organization’s management system being certified against a selected standard within the scope of QAI’s certification program. Among the areas covered in QAI Policies are: extending the scope of certification; annual monitoring; confidentiality; complaints; corrective action; and enforcement. These policies should be considered in their entirety, and applied within the context of the selected Standard and the Service Agreement that has been made between the organization and QAI.

Changes to these polices will be reviewed by the Stakeholder Advisory Panel. The Panel is composed of members representing stakeholder concerns. It includes representatives from The Organic Trade Association, The Organic Material Review Institute and the following constituency groups: Manufacturer, Producer, and Retailer/Consumer. Members meet annually at a designated trade show and communicate by phone or email at other times during the year. Public comment is welcome at these meetings. For further information about the next meeting time or to express your interest in becoming a member of the panel, please contact our Senior Vice President, Joe Smillie.

July 4th - Ecocert - QAI Japan is offering a seminar for currently certified clients, new applicants and people who are interested in the JAS Organic program.>Read More

July 17 - 19th - QAI Exhibits at IFT Conference in New Orleans.
>Read More

QAI Spotlight on Ann Hourigan, Client Service Representative

Back Story:
I am a military brat….My parents met at an Officer’s club in Philadelphia. My mother was an Ensign in the Navy from a town outside Boston. My father was a Marine Captain from York, Nebraska. Soon after they were married they received orders to transfer to Camp Pendleton, California, where they had their first child, me. The military dictated much of our family life. When I was 6, we were sent to Japan for 4 years. When I was 10, we moved to Nebraska. Two years later, we returned to Southern California.

After spending the first two years of my college experience at UC Santa Cruz, I graduated from UC San Diego with a B.A. in Psychology, in 2004. By the time I graduated from college, I had been with QAI for a little more than a year, initially fulfilling the role of Client Service Representative Assistant. In that time, I picked up a good amount of knowledge pertaining to organics. Upon graduation, I became a full time Client Service Representative at QAI, Inc.

Realtime:
Working at QAI has been one of the few constants I have experience in a sea of changes for me over these past two years. I truly enjoy working at QAI. I really appreciate the fact that I work with so many interesting people from so many walks of life. I feel very fortunate to have received the opportunities that I have had from working at QAI. I have grown with the company, as an employee and as a person.

Fun Facts:
Favorite Movie: Gone with the Wind (classic) / Virgin Suicides (modern)
Books: I love classic American literature, but my favorite would be anything by J.D. Salinger. I am currently reading Gabriel García Márquez’s, Love in the Time of Cholera.
Heroes: She-Ra, Princess of Power
Hobbies: I love to workout. I run, hike, walk, swim, ride my bike, etc. I also enjoy knitting, reading, and spending time with my friends.

QAI Contact List for Clients - Please note that in our continuing efforts to stay accessible, we have provided our RightFax numbers. Clients can fax directly to our individual desktops through this service, making us just a click away! View our Contact List.

 

To contact QAI:
If you would like to contact QAI with questions, concerns, or for general information, please go to http://www.qai-inc.com to send us an email. For questions pertaining to QAI’s Quality News contact Ellen P. Holton, QAI Director of Marketing and Business Development directly at 858.792.3531 ext 115.