Sunset Review Update - As most of you already know, the deadline to send comments for the Sunset Materials Review has come and gone. You can review the comments at the following site: www.ams.usda.gov/nop/PublicComments/Sunset/PublicComments.html.

To re-cap on the issue, the Organic Foods Production Act of 1990 requires that the National Organic Standards Board (NOSB) reviews all materials that now appear on the National List of Allowed and Prohibited Materials every five years.

As a result, all materials listed as allowed and prohibited for crops, livestock, and handling must undergo a review by October 21, 2007, in order to continue to be allowed or prohibited for organic production and handling.

The USDA sought public comment to determine whether these substances should continue to be allowed or prohibited in organic production and handling.

Many companies, organizations, and individuals submitted their comments stating their case for the use or the prohibition of specific materials.

We are still awaiting the final outcome of the NOSB's review. As always, QAI will keep you abreast of any changes to the National List as a result of the Sunset Materials Review.

USDA Announces Cost Share Program for Producers - Funds to Defray Costs of Organic Certification

The USDA has announced that $1 million is available in federal funds to 15 states to reimburse producers for the cost of organic certification.

Eligible states include Connecticut, Delaware, Maine, Maryland, Massachusetts, Nevada, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Utah, Vermont, West Virginia and Wyoming. Producers may be reimbursed for up to 75 percent of their organic certification costs, not to exceed $500.

In order to be eligible for reimbursement, an organic production operation must be located within one of the designated states, meet the USDA national organic standards for organic production, and have received certification or renewal of certification by a USDA-accredited certifying agent during the period of October 1, 2005, through September 30, 2006.

Additional information may be found at the National Organic Program's web site: www.ams.usda.gov/news/148-05.htm

GMO Documentation - The NOP requires that “all products sold, labeled or represented as ‘100% Organic’, ‘Organic’, or ‘Made with Organic...’ must be produced and handled without the use of excluded methods (GMOs)” (205.105(e)), which implies that GMOs are not permitted in any phase of organic production, e.g., the growing, processing, or manufacturing of organic products.

In order to verify an organic claim, there are critical control points that must be in place to protect the integrity of the organic product from GMO contamination. These include, among others, verification of original seed source, avoidance of pollen drift, proper segregation and clean out of harvesting, transport and storage equipment and facilities.

Another critical control point for organic handlers is the verification that any non-organic ingredients or processing aids used in or on organic products are not produced or processed with GMOs. Currently, this verification is through written confirmation, in the form of a signed affidavit or declaration, from the suppliers of the non-organic ingredients and processing aids that their products are not produced and/or processed with GMOs. QAI requires such documentation for any non-organic ingredients, where relevant, prior to approving its use in a certified product.

The challenge for certified handlers is to get a declaration from their supplier that will address the requirements of the National Organic Program. There are a myriad of statements that are submitted to QAI for non-organic ingredients that do not adequately confirm that the non-GMO requirement has been met. As a result, QAI may require additional information to be submitted depending on the type of statement received.

In order to make life easier for the handler, the handler’s supplier of non-organic materials, and for QAI, we have developed a GMO Declaration (or affidavit) that covers the general spectrum of what is required in a GMO statement. This declaration first provides QAI’s policy regarding GMOs and how far back the supplier of a particular non-organic material needs to go in order to determine compliance. The declaration lists out several options that the supplier can choose from depending on the type of non-organic material they are producing. For each option, we also ask for the measures in place that justify the supplier’s claim, including Traceability/Identity Preservation Systems, PCR Testing, Production Techniques, etc. Often, suppliers needs to go back to THEIR suppliers to determine the GMO status of ingredients and processing aids used in their products.

Please have a look at QAI’s GMO Declaration and use it at your will. If you have any questions, please do not hesitate to contact your Account Coordinator.

Commercial Availability - On July 1, 2005, the USDA’s National Organic Program (NOP) issued a notice in the Federal Register regarding the final word on commercial availability and the interpretation of 7 CFR 205.606 in the USDA National Organic Program regulation.

This issue is one of the three counts of the Final Judgment and Order issued by the U.S. District Court for the District of Maine in the case of Harvey v. the Secretary of Agriculture; the other two being the issue of synthetics in organics and the issue of dairy feed provisions. For a copy of the final judgment and order, go to the newsroom section of the National Organic Program web site.

The outcome of the court’s declaratory judgment is that “7 CFR 205.606 shall be interpreted to permit the use of a non-organically produced agricultural product only when the product has been listed in section 205.606, … and when an accredited certifying agent has determined that the organic form of the agricultural product is not commercially available.”

Currently, the only agricultural materials listed on 205.606 are 1) native cornstarch, 2) water extracted gums, 3) kelp when used as a thickener and dietary supplement, 4) unbleached lecithin and 5) high methoxy pectin. All other non-organic agricultural ingredients would not be permitted in products making and “Organic” claim. Products making a “Made with Organic (specified ingredients or food groups)” claim are exempt from this requirement.

Up until now, many certifiers and certified handlers believed that any non-organic agricultural ingredient that was determined by the certifier and certified client not to be commercially available in organic form could be used in organic products. The court held that such an interpretation is inaccurate and is not substantiated by the Organic Foods Production Act (OFPA).

However, as the Federal Notice states, “because of the potential for confusion, and to enable and orderly transition to compliance with the regulation, the district court’s order regarding the meaning of 7 CFR 205.606 shall become effective and enforceable two years (June 9, 2007) from the date of its judgment and order.”

QAI will be including in its letters of non-compliance to certified clients a reminder regarding this issue. A copy of the Federal Notice can be found at: www.ams.usda.gov/nop/Newsroom/FedReg07_05HarveyCaseFinal.pdf

What can certified clients and prospective certified clients do to lessen the impact of the court’s final judgment?

Exercise your freedom of speech by petitioning the NOSB to include non-agricultural ingredients not currently available in organic form; see www.ams.usda.gov/nop/Petition/PetitionHome.html for instructions on how to file a petition.
Start searching out suppliers of organic minor ingredients now by visiting both the QAI web site www.qai-inc.com and the OTA web site www.ota.com.
Talk to your current suppliers of non-organic agricultural ingredients about becoming certified.

QAI Amends OCPs to Meet Changing EU Requirements - EU Requires Traders and Warehouses to be certified

EEC 2092/91, the EU Organic Products Regulation has been amended and now requires all operations that “store” or “market” products to be certified.

In order to help our clients meet the new EU requirements we have revised our current EU Organic Compliance Plans (OCPs) and added a plan specific to warehousing operations.

Operators who market but do not handle organic products can now utilize QAI’s streamlined EU Trader OCP for certification.

Off-site warehousing operations, not currently included as part of a QAI client’s certification can now utilize the QAI’s new EU Warehouse OCP for certification.

Current clients will be notified during their annual renewal process that all warehouses used to store their products will need to be certified by December 31, 2005 in order for them to maintain their compliance with the EEC 2092/91 regulation.

Click here to read the recent QAI Broadcast Fax regarding these changes.

Click here to read a statement by DEFRA clarifying the certification of warehouses.

Click here to read the EEC 392/2004 amendment requiring certification of Traders and Warehouses.

EU Proposes Extension of Import Procedure - QAI Continues to Provide Updates for Clients Exporting to EU

The EU has proposed legislation to extend the import procedure currently utilized by QAI clients to export organic products to the EU. The import procedure used by QAI clients as regulated by EEC 2092/91 Article 11 (6) is currently set to expire on 31 December 2005. The proposed legislation will extend the deadline to 31 December 2006 while the EU develops a new system for the importation of organic products.

Though QAI has received no official word on how the new procedure will be implemented, it is widely speculated that the EU will be developing a system to recognize accreditation bodies as having sufficient ability to audit certifiers to the EEC 2092/91 regulation.

This recognition will not be the same as equivalency since products will still need to be produced and processed in compliance with EEC 2092/91. However, the new import procedure may reduce the number of Technical Barriers to Trade (TBTs) such as organic import authorizations that current exporters to the EU face.

QAI is closely monitoring the proposed legislation and we will continue to keep our clients updated as more information becomes available.

Click here to read the COM 2005/0094 (CNS) proposed legislation.

Click here to read the European Commission’s Action Plan for organic agriculture.

Final EU Note

Due to increased demand and the amount of time involved in processing EU import authorizations, QAI will be charging a fee of between $50-$125 (based on complexity) for the processing of initial and renewal EU import authorizations.

Please e-mail Tom Chapman, QAI International Specialist, or contact him by phone at 858.792.3531 if you have any questions about these changes or other issues in regards to the EU organic regulation.

QAI Continues to Get you There! - QAI ISO 65 Accreditation Continued

QAI recently had a four day on-site visit from a USDA auditor to verify our compliance with ISO/IEC Guide 65: General requirements for bodies operating product certification systems. In addition to the review at the QAI Headquarters in San Diego, auditors spent two days observing our inspectors at work.

ISO Guide 65 specifies general requirements that a third-party operating a product or service certification system must meet in order to be recognized as competent and reliable. Adherence to the USDA ISO Guide 65 Program ensures that the certification agency operates a third-party certification system in a consistent and reliable manner. Compliance with ISO 65 or the EU equivalent EN 45011 is required for certifying to Québec, European, and Japanese standards.

ISO 65 accreditation is one of five accreditations QAI holds to guarantee the high quality and compliance of our organic certification programs. The auditors’ review covered our BIO Suisse, CAAQ, EU 2092/91, IFOAM, JAS and NOP programs. Our approved status will help QAI clients export products to foreign markets. To view our ISO 65 Certificate, click here.

September 15 - QAI goes to Capitol Hill — Join Us for Organic Day on the Hill!

September 15 - NSF International To Host Congressional Lunch
>Read More

September 16 - 18 - QAI at Natural Products Expo East — Washington, DC — BOOTH #1000

October 15 - 18 - QAI at Canadian Health Foods Association Conference and Trade Show East — Toronto, Ontario Canada — BOOTH #431

This issue we are up close and personal with Allison Wolff, QAI Account Coordinator

Back Story:
I hail from the great state of Wyoming. I was born and raised in Wheatland, which is set amid farms and ranches in the Southeast corner of the state. My mother is a first grade teacher, and my father works for Basin Electric Power Company. I have one older brother, Chris, who also resides in Wyoming. He and his wife just welcomed their first child on August 13th of this year.

I am a graduate of the University of Northern Colorado with a B.A. in Journalism, emphasis in advertising media and public relations. I played volleyball at the collegiate level, which taught me time management skills and helped me to develop work habits that will make me successful. Throughout my college career, I worked as a Public Affairs Assistant on the Arapahoe and Roosevelt National Forests and Pawnee National Grassland. Upon graduation I moved to Denver and worked for Coors Distributing Company. After one visit to San Diego I was sold, and now here I am.

Realtime:
I have worked at QAI for almost 2 years. One of the most personally rewarding aspects of working at QAI is meeting and establishing relationships with others who thrive on the excitement the organic industry inspires. I enjoy working in the professional, fast paced, structured and team-oriented environment that QAI provides me on a daily basis.

I spend my free time coaching high school volleyball, relaxing on the beach, traveling and cheering on #11 of the San Diego Padres. I enjoy shopping, attending various social events and spending time with my family.

Fun Facts:
Favorite Color: Green
Favorite Food: Steak
Favorite Movie: Back to the Future
Favorite Band: Collective Soul
Favorite Ice Cream: Vanilla
Favorite Sport: Golf
Heroes: : Mom, Dad & Chris
Hobbies: Biking, hiking, horseback riding, boating, fishing, camping, picnicking, golfing, pretty much anything outside.
Pets: Teacup Poodle named Belle. She weighs in at a hefty 2.6 lbs.

 

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™.