Comments of the Organic Trade Association on NOSBís Recommendation on Grower Groups
September 20, 2002
OTA notes that the NOSB Accreditation Committee has received comments from OTAís Quality Assurance Committee Accreditation Subcommittee. While these comments were not authorized by OTA at the time they were submitted, OTA nonetheless agrees with the substance of those comments and offers the following in addition.
Comment 1. Requirements for grower group participation.
OTA supports the conditions recommended by the NOSB for participation in a Grower Group and propose that it be explicitly included in the conditions that the certification is of the Grower Group. Therefore, individuals certified with the Grower Group would not posses certificates for their individual operations and would only sell organic products through the Grower Group.
Comment 2. Criteria for establishing numerically valid site sampling protocols.
Historically, certifiers have required varying percentages of growers in a Grower Group be inspected each year. As the language in the Final Rule stands, it is clear that an inspection of the operation (Grower Group) is required. The inspection of the Grower Group operation would include the Internal Control System (ICS) and a percentage of the individual growers in the Grower Group. We suggest that the certifying agent have policy and procedure as to how many growers will be inspected annually.
OTA supports the following language:
ďThe certification agent shall have policy and procedure for determining how many growers must receive an annual inspection by the certification body. For each of the Grower Groups it certifies, a certification agent must document its method for determining the number of growers to be inspected. This determination must include consideration of:
- The number of operations participating in the Grower Group;
- The size of the average operation in the Grower Group;
- The degree of uniformity between the groupís operations;
- The complexity of the groupís production system(s); and
- The management structure of the groupís Internal Control SystemĒ
Comment 3. Position on Addendum I
OTA supports the guidance offered for inspection of Grower Groups; use of the Internal Control System, Organic Control Points, and Inspection Report Guide; and having this information included into the NOP accreditation requirements for certifiers, as well as in the NOPís Accreditation Procedures Manual.