Certified organic operations manage a complex system of requirements to maintain compliance. QAI wants to make sure the certification process is completed in a timely and efficient manner so you can get on with what you do best, making great certified organic products.
When an operation is given a notice of non-compliance, a corrective action response (CAR) is required by a given due date. QAI has noticed an increase in the frequency of operations failing to respond, which leads to proposed suspension letters being issued to certified operations. Frequently, certified operations then attempt to submit a corrective action to make the proposed suspension go away.
The National Organic Program has instructed all certification bodies that corrective action responses cannot be accepted after the operation has received an adverse action letter (proposed suspension, proposed revocation or certification denial notice). Once an adverse action letter is issued, the only paths for resolution are for the certified operation to request mediation with the certification body, to submit an appeal to the NOP or to accept the adverse action (final suspension, revocation or denial of certification).
QAI’s policies for due date extension requests and mediation requests are changing to manage these requirements. We anticipate these policies will improve responsiveness and reduce the time it takes to complete the certification process.
QAI will send a reminder notice of a due date pending, along with a warning notice that corrective action responses cannot be submitted after the operation has been sent an adverse action notice. In order to avoid the adverse action notice, the client must, by the due date, either submit the corrective action response or submit a written request for an extension up to 14 days. If the extension request is approved, there will be an administrative fee applied to offset additional administrative costs related to delays in the certification process.
If an adverse action notice is issued to the operation and mediation is requested, QAI will charge a formal mediation fee when formal mediation is requested or required. Formal mediation involves a third-party dispute resolution mediator. Alternatively, informal mediation may be conducted where the operation and QAI agree to terms of resolution between themselves, without a third party. No fees apply for informal mediation.
These fees will not affect you provided complete corrective action responses are received by QAI on time. Please contact QAI for any questions related to these policy changes.