Peer Review Report of the United States
National Organic Program
Section 2 - Introduction and Background
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2.1 Pre-Peer Review Activities
On June 17, 2009, the Government of Canada entered into an arrangement on the trade of organic products with the United States. This arrangement was the result of considerable review by both the United States and Canada. Both countries entered into an arrangement recognizing our national organic systems as equivalent but the arrangement is subject to the following conditions:
Imports from the United States into Canada
- 1. Agricultural products produced with the use of sodium nitrate shall not be sold or marketed as organic in Canada.
- 2. Agricultural products produced by hydroponic and aeroponic production methods shall not be sold or marketed as organic in Canada.
- 3. Agricultural products derived from animals must be produced according to livestock stocking rates as set out in CAN/CGSB-32.310-2006.
Exports to the United States from Canada
1. Agricultural products derived from animals treated with antibiotics shall not be marketed as organic in the United States.
Since the USDA and the Canadian Food Inspection Agency (CFIA) signed the US-Canada Organic Equivalence Arrangement, the National Organic Program (NOP) and the Canada Organic Office (COO) have worked to ensure a smooth implementation.
Under the Arrangement, the parties agreed to establish a high-level policy Steering Committee consisting of representatives from the Office of the United States Trade Representative, the USDA Foreign Agricultural Service, the Department of Foreign Affairs and International Trade (DFAIT), Agriculture and Agrifood Canada (AAFC), and the CFIA. Its purpose is to oversee implementation of the Arrangement and to guide the activities of the COO and the NOP.
As a result of the ongoing Working Group and Steering Committee meetings, the NOP notified certifying agents in November 2010 that for agricultural products certified under the US-Canada Organic Equivalence Arrangement, the statement "Certified in compliance with the terms of the US-Canada Organic Equivalence Arrangement" must accompany products that are produced under the terms of the arrangement. It must appear on documentation travelling with products shipped to Canada; it may also be included on the organic certificate, a transaction certificate, a statement on a bill of lading, purchase order, or any other affirmative attestation.
NOP also clarified that sodium nitrate is not allowed in raw or processed agricultural products and must be phased out completely for organic ingredients used in processed products shipped under the Arrangement.
2.2 Comparison of information/documentation: Results
During the establishment of the organic arrangement it was also agreed to conduct peer reviews of each respective organic program/regime in 2010. The countries agreed to utilize the following references in developing the review procedures:
- ISO 17040 - Conformity assessment general requirements for peer assessment of conformity assessment bodies and accreditation bodies, and
- ISO/IEC Guide 68:2002 - Arrangements for the recognition and acceptance of conformity assessment results.
2.3 Peer Review
Canada conducted a peer review of the United States NOP between November 29 and December 3, 2010. This report covers the results from Canada's assessment activities.
2.3.1 Objectives of the Peer Review
Canada's objective in conducting the review was to observe how the NOP implemented the US-Canada Organic Equivalence Arrangement.
By conducting the peer review, Canada expected to gain a better understanding of the structure and functions of the NOP program and to assess the rigour of controls associated with the overall program, specifically with regard to the controls associated with the (3) three critical variances on the US side. In addition, the review offered COO an opportunity to observe the overall effectiveness of the operations with regard to achieving the objectives of the organic program in the United States. Finally, through the review, COO has been able to glean information needed to inform the US-Canada Organic Equivalence Arrangement Technical Working Group and Steering Committee of future work needed between the two countries.
2.3.2 Peer Review Procedure
The peer review was performed in accordance with COO Peer Review Procedure and consisted of the following elements:
- opening meeting
- on-site verification
- closing meeting
This procedure requires that we plan and perform the assessment to obtain sufficient, appropriate evidence to provide a reasonable basis for our observations and conclusions based on our assessment objectives.
Prior to initiating the peer review process, the appointed Canadian peer review team was provided with a verbal proposal for the peer review process including: the proposed number of people conducting the review, their names and affiliation; expected duration; the proposed peer review plan which included visits to accredited certification agencies and certified operators.
The activities subject to the peer review process included: document review, record assessment, personnel interviews, visits to NOP's main office, visits to NOP accredited certification agency facilities, visits to processing operations and farming/producers of organic products.
Appendix 2 of US-Canada Organic Equivalence Arrangement Letter provides the authority for this peer review:
"Following advance notice from the CFIA, the USDA shall permit the CFIA to conduct on-site evaluations to verify that the USDA's certifying agents are carrying out the requirements of the United State's organic certification program, including through visits to agent facilities and to production facilities and farms that agents have certified. The USDA shall cooperate and assist the CFIA, to the extent permitted under domestic law, in carrying out such evaluations."
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