Ever tell a friend that you are a producer or handler of certified organic products and get the question, “Does that mean you do residue tests to verify that your products are organic?” The answer can be lengthy and chances are your audience will soon get the “deer in the headlights” look. Just make sure you know what’s involved: QAI is required to sample and test a minimum of 5 percent of all operations certified. This means there is a pretty good chance that an inspector will show up at your farm or facility, with instructions to pull a sample for residue testing.
Sampling may be required for several reasons, including as a result of a complaint or an investigation, if you are producing or handling a high-risk commodity, or from random selection. Specific instructions will be included in the inspection work order and the inspector is required to have all the necessary equipment, packaging and the chain of custody document necessary to track the sample all the way to the laboratory. You are allowed to help the inspector collect the sample but the inspector has to be present throughout the process and must keep the sample in her/his possession until it is shipped to the laboratory.
The NOP regulations allow the sale of products as organic as long as they are produced according to the regulations and contain less than 5 percent of the U.S. EPA limit for registered pesticides or comply with other international limits. While testing of soil and crop tissues at the farm is mentioned, it is more likely that the inspector will collect the portion of the crop intended to be marketed. At the handling facility, inspectors will typically be asked to sample ingredients.
Just like with making records available, certified companies are required to allow the collection of samples. It is common to be concerned that samples will come back positive, with an above the threshold residue for organic sale. A safe approach is to hold products until the results are received, but this is not required. QAI recently updated its internal procedures to immediately release testing results upon receipt and review. This means that the hold time will generally be less than two weeks. Please be sure to contact QAI with any questions on this or any other topic.
For additional information of the requirements, please reference NOP Instruction 2610 which provides the sampling instructions to certification agencies as well as many useful references to the standards.