October/November/December 2007 We hope you enjoy this issue of QAI’s Quality News! And as always, please let us know if there are any topics you would like us to cover in upcoming issues.

Attention Organic Handlers and Organic Livestock Operators: 3 Materials Removed from the National List

3 materials no longer permitted for use:
Effective October 21, 2007, the U.S. Department of Agriculture (USDA) published a final rule that amends the USDA's National List by removing, and therefore prohibiting the use of, the following substances in organic agricultural livestock production and organic handling:

Materials removed from Section 205.603: Synthetic Substances Allowed for Use in Organic Livestock Production

1. Milk replacers without antibiotics: as emergency use only, no nonmilk products or products from bovine somatotropins (BST) treated animals.

Materials removed from Section 205.605: Nonagricultural (Nonorganic) Substances Allowed as Ingredients in or on Processed Products Labeled as “Organic”' or “Made with Organic (Specified Ingredients or Food Group(s)”

1. Colors¹: nonsynthetic sources only
2. Potassium tartrate: made from tartaric acid

Background

The Organic Foods Production Act (OFPA) requires the establishment of a National List of allowed and prohibited substances. This list identifies synthetic substances (synthetics) that are allowed and nonsynthetic substances (nonsynthetics) that are prohibited in organic crop and livestock production. The National List also identifies nonsynthetics and synthetics that are allowed for use in organic handling.

The exemptions and prohibitions granted under the OFPA are required to be reviewed every five years by the National Organic Standards Board (NOSB). The Secretary of Agriculture has authority under the OFPA to renew such exemptions and prohibitions. If they are not reviewed by the NOSB within 5 years of their inclusion on the National List and renewed by the Secretary, their authorized use or prohibition expires. Consistent with the recommendations from the NOSB, this final rule renews 165 allowances and prohibitions on the National List (along with any restrictive annotations) and removes three exemptions from the National List.

For a complete discussion on the issue, visit:
http://www.ams.usda.gov/NOP/Newsroom/FedRegSunsetReview10-16-07.pdf.

¹ Several colors have been added to the NOP’s interim final rule, Section 205.606. Additionally, those colors that are considered “agricultural” ingredients may still be used in products making a “made with organic…” claim.

The Canadian Organic Logo

QAI International Account Coordinator and Board Member of the Conseil des Appellations Agroalimentaires du Québec (CAAQ), Kasey Moctezuma recently returned from a trip to Montréal, Québec where she had the opportunity to verify the information below regarding the use of the Canadian logo. The logo was recently presented at the Barrie Farmer’s Market, as part of a Canadian Organic promotional campaign, to heighten consumer awareness of the new federal requirement, which will go into effect in December 2008.

Use of the Canadian Organic Logo on Products
Section 16 (1) of the Organic Products Regulations goes into effect two years after the date the regulations were registered -- December 14, 2008.  The section regarding the use of the Canadian logo, however, went into effect on the day that the regulations were registered, which was December 14, 2006.

The Canadian Federal Inspection Agency (CFIA), which will be governing the Canadian Organic Regime, has clarified that the use of the logo will be under a licensing scheme prior to December 14, 2008.  This type of license will be granted to operators who have their products certified by a Certification Body that has been accredited by an Accreditation Body, approved by the CFIA.

To date, no certification body has been accredited. QAI is prepared to become one of the first approved agencies to administer the Canadian logo, but first the CFIA must approve the list of Accreditation Bodies who will oversee the certification agencies.

Once certified by an approved agency, the operator may apply to the Canadian Organic Office of the CFIA for a license. The Canadian Organic Office will maintain a list of all operators approved to use the Canadian Organic legend.

Use of the Canadian Organic Logo in Advertising
According to the QMS Manual (draft 2), which serves as the guideline for the Canadian Organic Products Regulations, stakeholders may request to use the Canadian Organic logo.  The logo is defined as an “agricultural product legend” on their advertising materials, including brochures, posters, hand-outs, in newspapers and other publications, on television, etc.

For more information on Canadian logo licenses:
Contact the Canadian Federal Inspection Agency Organic Office.

Michel Saumur
Canadian Organic Office
Canadian Food Inspection Agency
Tel: 613 221 7165
Fax: 613 221 7296
msaumur@inspection.gc.ca

For more information on the Canadian organic regime:
Contact your account coordinator or Kasey Moctezuma, QAI Canadian specialist.

Kasey Moctezuma
kasey@qai-inc.com
858 792 3531

Attention Egg Producers and Egg Washing Facilities

Egg Washes and Other Additives must be Compliant with the NOP

QAI requires that any materials used directly on organic eggs must be compliant with the National List of Allowed Substances, 205.605.  This includes egg washes, defoaming materials, and egg coatings. All ingredients within these products must either be certified organic or listed on the National List, 205.605.

While this may not be a surprise to many of you, QAI realizes that in the past some materials may have been reviewed and approved based on incomplete ingredient information. Material Safety Data Sheets (MSDS) and specification information generally only list the hazardous ingredients, so other ingredients, including defoaming materials and stabilizers, have not been assessed for compliance for some products. Going forward, QAI will require full disclosure MSDS or compositional analysis documentation in order to assess the compliance of an egg wash, defoamer, or egg coating.

Compliant Materials for Sanitizing and Washing Eggs

The following egg wash ingredients are allowed for use in organic egg production:

• chlorine materials - allowed under §205.605(b) for disinfecting and sanitizing food contact surfaces, except residual chlorine levels in the water shall not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act – calcium hypochlorite, chlorine dioxide and sodium hypochlorite
• potassium hydroxide - allowed under §205.605(b)
• sodium hydroxide – allowed under §205.605(b)
• hydrogen peroxide – allowed under §205.605(b)
• sodium carbonate – allowed under §205.605(a)
• Peracetic acid (peroxyacetic acid) – allowed under §205.605(b)
• Defoaming agents – all ingredients must be organic or on the National List, such as silicon dioxide, lecithin, organic vegetable oil, silicon dioxide replacements such as the Nu-Flow product listed below.
• Egg coatings – organic oils

There is a host of compliant egg wash products available on the market, and QAI has specifically reviewed these products to ensure compliance with the NOP.  Please go to the following link for the specific products reviewed and approved to date: http://www.qai-inc.com/pdfs/Compliant_Materials_Organic_Eggs.pdf. QAI will continue to update the approved products list on the website as more product suppliers submit information to QAI.

Prior to using any egg wash or other additive, contact your account coordinator to begin the formal review process and to update your organic compliance plan.  And as always, please ensure that egg washing and sanitizing procedures meet USDA requirements.

Going Forward

QAI trusts that this clarification does not come as a shock to most egg producers; however, we will be contacting all egg clients individually to discuss the issue in greater detail.

Please note that the use of any non-compliant materials for cleaning, sanitizing, and/or coating eggs, which have been purchased after the date of this notification, will be cited as a major non-compliance. Invoices, or other purchase documentation, must be kept on file and made available to the QAI inspector to demonstrate the date of purchase. Suspension of certification may result from the use of egg washes and other additives containing ingredients that are not organic or listed on the National List of Allowed Substances, 205.605.

Please contact your account coordinator if you have any questions.

Evaluation of Pesticide Materials for Organic Crop and Livestock Production

The National Organic Program (NOP) has recently released the following information and policy on inert ingredients used in pesticide² materials for use by organic crop and livestock operations³:

I. Background from the NOP Website

The NOP regulations currently allow use of inert ingredients, which appear on the Environmental Protection Agency (EPA) List 4A – Minimal Risk Inert Ingredients and List 4B – Other ingredients for which EPA has sufficient information to reasonably conclude that the current use pattern in pesticide products will not adversely affect the public health or the environment – in a variety of applications, primarily as pesticides in organic production operations.  These lists are maintained and managed by the EPA.  

The EPA has been reassessing the materials on List 4, which has resulted in the revocation of several List 4 inert ingredients. The following revoked ingredients are now prohibited under NOP:

• Acetylated lanolin alcohol (CAS Reg. No. 91994-94-4)
• Acrylic acid methyl ester, polymer with acrylonitrile and 1,3-butadiene (CAS Reg. No. 27012-62-0); the tolerance exemption is called “Nitrile rubber modified acrylonitrile methylacrylate conforming to 21 CFR 177.1480.
• Coumarone – indene resin (CAS Reg. No. 63393-89-5)
• Manganous oxide (CAS Reg. No. 1344-43-0)
• Pentaerythritol monostearate (CAS Reg. No. 78–23–9)
• Pentaerythritol tetrastearate (CAS Reg. No. 115–83–3)
• Polyglyceryl phthalate ester of coconut oil fatty acid (CAS Reg. No. 66070-87-9)
• Sodium fluoride (CAS Reg. No. 7681-49-4)

The EPA has also reclassified a number of List 3 inert ingredients (inerts of unknown toxicity) as List 4 inert ingredients.  However, these materials have not been reviewed and approved for use in materials used in organic operations. NOP also advises that the “Inerts List” system and the EPA’s review and labeling program, which determines the compatibility of pesticides with the NOP Regulation, may no longer be compatible with the NOP Regulation. Going forward, the NOP will need to collaborate with the EPA and the National Organic Standards Board (NOSB) to determine the most effective and efficient way to amend the NOP regulations accordingly.

II. QAI’s Policy on the Assessment of Pesticide Input Materials

In light of this, QAI and all parties reviewing pesticide product ingredients for compliance with the NOP are required to use EPA’s August 2004 lists of approved List 4 inert ingredients, minus the revoked inert ingredients.  Links to the aforementioned lists are as follows:

• List 4A - http://www.epa.gov/opprd001/inerts/inerts_list4Aname.pdf
• List 4B - http://www.epa.gov/opprd001/inerts/inerts_list4Bname.pdf

QAI will no longer be able to accept affidavits that state that inerts are compliant with EPA List 4. QAI will be requesting detailed information on all pesticide inputs, including the complete information on the Inert Ingredients. Input manufacturers may communicate with QAI directly to protect proprietary information. Alternatively, input manufacturers may choose to have their inputs certified through an NOP-accredited organization or similar organization, and QAI will work with these organizations to verify compliance.

This policy will remain in effect until superseded by regulatory changes or new guidance from the NOP is announced.

² “Pesticides” include all materials used for pest, weed and disease control on certified organic and transitional fields.

³ For the complete article, visit: www.ams.usda.gov/nop/NoticesPolicies/NOP5008ReassessedInertIngredients09-06-07.pdf

Nov 11 - 13th PLMA's 2007 Private Label Trade Show, Chicago, IL

QAI is a proud sponsor of the Organic Trade Association

In this issue, we turn the spotlight on Miki Takada, Account Coordinator and Japanese Agricultural Standard (JAS) Program Specialist.

Miki Takada, Account Coordinator and JAS Program Specialist

Background:

In high school, I wanted to become a film producer, and went to U.C. Santa Cruz, where I studied film and politics. Living in Santa Cruz made me reconsider my career path, and I decided that I wanted to do more to help protect our planet. Instead of working in Hollywood, I went back to San Diego, where I grew up, and obtained a master’s degree in pacific and international affairs with an emphasis on international environmental policy at U.C. San Diego. I started working at QAI upon completion of my graduate program. I have worked at QAI for little over a year now. 

Real Time:

How did I end up in the organic industry? Simple: I love food, and I care about the environment. Having great co-workers and clients, and being able to utilize my Japanese on a regular basis is definitely a plus. I love working in this industry where people are concerned about protecting the earth.  I find myself learning something new every day.

Fun Facts:

Hobbies: Watching WWE and movies, traveling, sports
Travel Wish List: Spain, Germany, Italy, Brazil, Costa Rica
Favorite TV Show: CSI, Law & Order: SVU
Favorite Food: Mexican food, Italian food, Japanese food (but no meat)
Favorite Baseball Team: the Padres, of course!

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 Joshua Rollins, Sales Coordinator.

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