By Michelle Menken, Organic Services Manager
The USDA National Organic Program (NOP) conducted its semi-annual audit of MCIA in July. Two auditors from the NOP were here in the office for a week, reviewing files and procedures. One focus of this audit was how we are implementing the new rule changes, Strengthening Organic Enforcement (SOE) and the Organic Livestock and Poultry Standard (OLPS).
They noted several findings that were easy fixes, and we have updated some of our forms already. Many of the remaining findings have to do with developing written policies for various aspects of how the accreditation staff do their work, such as staff training policies and when to issue Noncompliances vs Certification Letter notes and reminders.
The NOP clearly believes that we should be issuing more Noncompliances. Notices of Noncompliance are issued when an operation is not following the requirements of the regulations, such as not documenting an organic seed search, or having incomplete or not auditable records.
If you receive a Noncompliance, you must answer by the date in the letter. The response should say how you are going to correct the problem listed in the letter. If you do not understand the Noncompliance, please contact MCIA. Not responding can lead to a Proposed Suspension.
For handlers and processors, we have added some new forms due to SOE. One is the Supplier’s List. Handlers must ensure that their suppliers are certified organic. You can check suppliers’ certificates on the Organic Integrity Database (OID). You may still need to contact the supplier for product addenda if the ingredients you want to source are not listed on the certificate, or if we need to know the product category (100% Organic or Organic). Importers must be certified, and each imported shipment of organic products must be accompanied by an Import Certificate. Review NOP205.273 for information on imports.
Avian living conditions and transport and slaughter requirements were added under the OLPS changes. These give specific requirements for poultry housing and stocking densities. This includes the specific required indoor and outdoor square footage, amount of perch space, and exit areas for pullets, layers, and broilers, turkeys, and ducks. All poultry operations must test weekly for ammonia levels in their barns. Review NOP205.241 for information on new poultry requirements.