National Organic Program Apparently Cracking Down on" Commercial Availability" Issue

From Organic Business News Feb. 2006
http://hotlineprinting.com/obn/archives/2006/2006-02/NOPCrackingDown.html

NOP Cracking Down On Commercial Availability Issue

Certifiers are being told in National Organic Program training sessions to
get tougher on enforcing commercial availability regulations.

"We are putting everyone on notice that we are holding certifiers' feet to
the fire," said Mark Bradley, associate policy director for the NOP. "We are
seeing a deficiency here."

Organic producers are required under the law to make a good faith effort to
source organic ingredients for the 5% non-organic portion of certified
organic products.

Bradley said there have been instances reported to the NOP where processors
did not do a good enough job of sourcing organic ingredients, and certifiers
vary in their enforcement. While the regulations are still general, Bradley
said that if a processor, for example, is looking for a type of organic
lecithin and it was not available, certifiers are required to verify that
which was specified was not available. "We are giving them real examples of
what is not enough" effort to find organic ingredients, he added.
Certifiers should be comparing the specifications of productions found to be
unavailable with non-certified inputs used, Bradley said.

"There is a perception in the industry that if an ingredient was not
commercially available, conventional could be sourced for minor
ingredients," Bradley said. While that is true, certifiers have to make sure
that their clients are following the same specifications that were on their
farm plan.

The NOP said that cost is not a factor when processors are looking for
ingredients. Certifiers should be checking suppliers for availability.
Bradley said inconsistency among certifiers over enforcing commercial
availability ranked high in the "NOP's top 30 hit list".

In a series of training sessions, in California during Jan. 2006, at BioFach
in Germany, and at the Independent Organic Inspectors Assn. annual meeting,
the NOP emphasized problem issues that need to be corrected. Another issue
is conflicts of interest, where a consultant who has ties to a certifier
cannot recommend a client for that company.

Bradley said the "biggest train wreck" is producers that are making changes
on inputs before the certifiers have signed off on a farm plan. There are
several cases where prohibited substances or the wrong sprays were used on
crops.

Some farmers are not checking label ingredients and are using items that are
on the National List, Bradley said. "This becomes a huge problem that is
completely preventable," he said.

At least 75% percent of between 30 and 40 cases of suspension of
certification involved improper uses of input that did not have the approval
of the certifier and were not in compliance with national regulations,
Bradley said.