Compliant Product Labels - We all know that product labels making “100% Organic”, “Organic” and “Made with Organic (specified ingredients or food groups)” claims are subject to several requirements under the National Organic Program (NOP). One of QAI’s responsibilities is to ensure that all products we certify comply with the relevant provisions of the NOP Rule, including the labeling provisions. It is QAI’s policy to add products to clients’ certifications only after the labels or label designs have been submitted to QAI and are determined to be fully compliant.

Many clients do the right thing and submit their label designs to their Account Coordinators before they finalize and print the labels to ensure that they haven’t missed anything. Unfortunately, QAI has been dealing more and more with requests from clients to add new products to their organic certifications with non-compliant labels that have already been printed. This places QAI in a difficult situation of needing to enforce the NOP Rule and ensure full compliance prior to certification, while wishing not to impose unnecessary financial burdens on our clients who have outlaid the dollars to create and print product labels. This also places clients in the unfortunate and costly situation of having to change their labels and potentially having to dispose of an inventory of non-compliant labels.

QAI urges all clients to submit label designs or mock-up labels to their Account Coordinators prior to printing the final label. While this may seem time consuming, it will potentially save you time and money in the future if it is found that your labels are not compliant with the NOP requirements. To assist clients in designing labels that meet all the necessary requirements, QAI has developed an NOP Product and Label Worksheet. You can find this Worksheet by clicking on to the following link: Product and Label Worksheet

Current Documentation - The NOP requires that the records maintained by certified clients are sufficient to determine compliance with the Act and regulations of the NOP Rule. This general requirement would include such records as current verification of the certification status of ingredient or seed suppliers, pest and sanitation records, production and inputs records, and a whole plethora of other supporting documentation that, together, verifies organic compliance. While records need to be maintained by the certified client for a period of at least 5 years, the records that inspectors are most concerned with are those that are the most relevant to the products you are currently producing and that accurately reflect the current status of the ingredients, products, inputs, etc.

Clients generally are very vigilant about maintaining current verification documentation for their suppliers of organic ingredients. However, supporting documentation for the non-organic ingredients is not always regularly updated. Examples include: documentation from suppliers of non-synthetic flavors verifying that flavors have not been produced with synthetic solvents, preservatives and carrier systems; non-GMO documentation from suppliers of tocopherols, lecithin, non-organic agricultural materials, seed and cultures; verification of the lack of commercially available agricultural ingredients and seed in organic form; and the list goes on. These types of records need to be consistently updated, that is, at least every 12 – 18 months.

There have been instances where a supplier of a natural flavor issued a non-GMO affidavit to the organic client and then a year later changed their stance, allowing GMOs in the flavor. If the organic client would have relied on the initial affidavit received from their supplier to cover them for the flavor for longer than a year, they could have risked losing certification for their product.

Please ensure that you have a system for ensuring that existing supporting documentation verifies compliance with the NOP, is maintained on file, and is made available to the inspector or QAI upon request. This will not only ensure NOP compliance and fewer non-compliances but it will protect you, your products and your customers.

Attention Organic Producers: Do you use Rotenone or a Copper Fungicide in your Pest Control Program? - Ted Rogers, Sr. Analyst with the USDA Office of Pest Management Policy, is currently working on regulatory issues concerning the EPA re-registration of two pesticides with a history of use in organic systems. He would like organic producers to be involved in the discussion about re-registration of Rotenone and Copper Fungicides. Discussions on the Copper Fungicides will begin soon. Please contact him to become a member of his distribution list on the Coppers and later Rotenone:

Ted Rogers
Biologist, Senior Policy Analyst
USDA Office of Pest Management Policy
202-720-3846
trogers@ars.usda.gov

Further Information about the USDA Office of Pest Management Policy: The USDA Office of Pest Management Policy is responsible for facilitating dialogues on Pest Management policy to assure that US producers are aware of emerging issues that could impact their ability to effectively produce and store their crops. Dialogues often involve commodity groups, the Environmental Protection Agency, pesticide registrants, Extension and private specialist and researchers, individual producers, pest management professionals and other interested parties.

Over the past eight years the Office of Pest Management Policy has been involved in pesticide regulatory issues under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), and the Food Quality Protection Act of 1996 (FQPA). It has also addressed a number of issues of a more sweeping or holistic nature such as the use of Integrated Pest Management Systems in Stored Products, the threat of Soybean Rust and evaluation of tools and techniques to manage SBR in conventional and Organic systems.

The USDA Office of Pest Management Policy recently began to work with stored product specialists, pest management professionals and members of the Organic Industry to address emerging inputs and technologies to manage pest in organic stored products.

Additional information about the USDA's pest management programs may be found at their web site: http://www.ars.usda.gov/opmp/

Korea - Organic GMO Policy

The Korean Food and Drug Administration has revised the Korean labeling standards for food to state that “Genetically modified food or food additives shall not be used or detected” in products labeled as organic. This zero tolerance approach to GMO detection in organic products is stricter than the 3% GMO tolerance threshold for non-organic GMO labeling. The zero tolerance stance on GMO presence in organic foods increases the risk that products certified organic to the NOP would not be acceptable for sale as organic on the Korean market.

Mexico - Organic Legislation Passes the Camara Federal de Diputados

A federal law on organic products passed Mexico’s Camara de Senadores (equivalent to the US Senate) and more recently, on October 18th, the Camara Federal de Diputados (equivalent to the US House of Representatives). The legislation has been sent back to the Camara de Senadores for final approval. Upon approval by the Camara de Senadores, President Vicente Fox Quesada will have 30 days to publish the text of the regulation in the official gazette. QAI has been closely monitoring the development of the Mexican organic standard and will update our clients on the regulation when the official text is released to the public.

Canada – Organic Regulation Goes to Another Ballot

The Working Group of the Canadian Organic Standards Committee has requested another ballot on two working drafts of the Canadian organic standards after revisions to the previous draft were made. The two drafts up for vote are the Organic Production Systems — General Principles and Management Standards and the Organic Production Systems — Permitted Substances Lists. These drafts include full standards for organic production, handling and livestock as well as specific requirements for Apiculture, Maple Products, Mushroom Production, Sprout Production, Greenhouse Production and Wild Crops. The drafts will be submitted for ballot voting by November 7th and are seeking consensus approval by the Canadian Organic Standards Committee. If consensus approval is not reached, the standards will be sent back to the working group for further revision. Once they are approved, the standards will be sent to the Canadian General Standards Board for a second approval and then to the Standards Council of Canada for ratification. QAI has been closely monitoring the development of the Canadian organic regulation and will update our clients on the regulation with future developments.

Europe – EU Extension Approved, Materials Added

On September 28, 2005 the European Commission published in the Official Journal of the European Union an amendment to EEC 2092/91 to allow third country imports until December 31, 2006. This act officially approved previously proposed legislation.

If you have an import authorization approved through DEFRA for the export of organic products to the UK, please review this letter from DEFRA to see if you need to renew your current authorization:

http://www.defra.gov.uk/farm/organic/pdf/importsinto2006-letter.pdf

The European Commission revised the acceptable production materials lists in an amendment entitled EC 1318/2005. The changes are as follows: In Annex II Part A (QAI Table 1 Part A) under the title “Fertilizers and Soil Conditioners” the following was inserted:

Name: Industrial lime from vacuum salt production
Description, compositional requirements, conditions for use: By-product of
the vacuum salt production from brine found in mountains. Need
recognised by the inspection body or inspection authority (sic)

In Annex II Part B (QAI Table 1 Part B) under the title “Pesticides,” “Products for plant protection” under part IV "Other substances from traditional use in organic farming" the following was revised to state:

Name: (*) Ethylene
Description, compositional requirements, conditions for use: Degreening
of bananas, kiwis and kakis; Flower induction of pineapple. Need
recognised by the Inspection body or inspection authority (sic)

In Annex II Part B (QAI Table 1 Part B) under the title “Pesticides,” “Products for plant protection” the following was inserted under the new Part V:

Name: Calcium hydroxide
Description, compositional requirements, conditions for use: Fungicide.
Only in fruit trees, including nurseries, to control Nectria galligena.

Taiwan - Proposed Mandatory Organic Regulation in Legislative Yuan

The Council of Agriculture (COA) of the Taiwanese Government is currently in the process of consolidating regulations on organic labeling in Taiwan. The organic marketplace has been on the rise in Taiwan with 7-10% annual growth rates. The current voluntary organic standards are leading to confusion and consumer distrust. It is expected that in January 2006 the Legislative Yuan will pass the New Agricultural Food Safety Bill that includes provisions for a mandatory organic regulation under the control of the COA. Products being exported to Taiwan will need to be certified to the regional standard by certifiers registered with the COA. While the standard is expended to be enacted in January 2006 the USDA Foreign Agricultural Service also expects there to be an implementation period after this date. QAI has been following the developments of the Taiwanese Organic Standard closely and plans to take the necessary steps to register with the COA

Did you know? -

The Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents. It is updated daily by 6 a.m. and is published Monday through Friday, except Federal holidays, by the Office of the Federal Register, National Archives and Records Administration.

Recent publications of the Federal Register of interest to the Organic Community include:

Federal Register / Vol. 70, No. 174 / Friday, September 9, 2005 / Notices (National Organic Program notice to inform certified organic producers and handlers of AMS’ intention to release names and address of certified operation to the general public)

http://www.ams.usda.gov/nop/Newsroom/FedReg09_09_05NotToPublic.pdf

Federal Register / Vol. 70, No. 179 / Friday, September 16, 2005 / Proposed Rules (Proposed Amendments to the National List of Allowed and Prohibited Substances for Crops and Processing)

http://www.ams.usda.gov/nop/Newsroom/FedReg09_16_05NatList.pdf

Federal Register / Vol. 70, No. 203 / Friday, October 21, 2005 / Rules and Regulations (Final amendment to the national List of Allowed and Prohibited Substances extending the allowance for use of Methionine in organic poultry production until October 1, 2008)

http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.
gov/2005/pdf/05-21166.pdf

If you would like to see what has been published in the Federal Register the following link will take to “today’s” Contents for the Federal Register. Information of interest to the Organic Community appears under the Agricultural Marketing Service heading.

http://www.access.gpo.gov/su_docs/aces/fr-cont.html

Or you can search any date of the Federal Register at:

http://www.gpoaccess.gov/fr/

November 6 - 8 - QAI Presents and Exhibits at the The Healthy Living Foods Conference – Miami, FL

November 7 - 8 - QAI Presents at Flavor & Extract Manufacturers Association – East Brunswick, NJ

November 14 - 15 - QAI Exhibits at Private Label Manufacturers Conference Booth 1142 Chicago, IL — Rosemont Convention Center

November 15 - 16 - QAI Presents at Pest Prevention & Food Safety Seminar – Teaneck, NJ

November 16 - 18 - QAI Attends NOSB Meeting — Washington, D.C.

December 6 - 8 - QAI Presents at Middle East Natural & Organics Products Expo – Dubai, United Arab Emirates

A Day In The Life Of QAI Senior Account Coordinator Rebecca Kewley

Back Story:

I was born and raised in South Salem, NY in Westchester County with a population of about 13,000. I grew up on a lake surrounded by the cleanest air and water but still only an hour from the greatest hub of the world, NYC.

I grew up with an older brother, Josh, who currently has a very successful web design company in Phoenix, AZ. Mum has been working at a resource and referral agency for childcare for over 15 years and still resides in the same house I grew up in (how lucky am I!). My Dad has worked as a Manager in the music industry since before I was born. His connections always made for an exciting concert experience. Dad now resides in Nashville, TN with my Step mum, who is a successful singer/songwriter, and my very smart and witty eight-year-old Brother, Joe.

I attended the University of South Carolina for two years at which point I transferred to Northeastern University in Boston where I graduated with a Bachelor of Science degree in Communications. Northeastern allowed me the opportunity to co-op at Farm Aid which opened my eyes to America’s farmers and the benefits of organic agriculture. After spending several long, cold winters in Boston I decided the time had come to head west so I could fulfill my dream later in life of being able to say that I had lived in California. Unfortunately, my timing was off as my arrival in San Diego was the weekend before September 11, 2001. We are all fortunate, myself included, that the organic industry still continued to grow, as I was hired by QAI in December 2001 as a Client Service Representative.

Realtime:
My experiences at QAI these past 4 years, have been exceptionally rewarding. Working with clients and possessing those strong relationships has truly been the most enjoyable aspect. The environment at QAI is also extremely gratifying as it is one that supports working as a team and having fun together while also encouraging personal growth. During time away from the Q I spend a lot of time taking road trips, going to the movies or just taking in local San Diego attractions like Sea World!

Fun Facts:
Favorite Color: Blue
Favorite Food: Quorn products
Favorite Movie: Say Anything
Favorite Ice Cream: Chocolate in a waffle bowl
Latest Hobby: Knitting
Passions: Animals and conversations with elders
Pets: Two kitties – Berty and Cali

 

To contact QAI:

If you have questions, concerns, or need general information, go to the QAI web site to learn how to contact us or 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.

QAI, Inc is an NSF, International Company. Visit their web site to learn more about NSF International, The Public Health and Safety Company™.