Pacific Agricultural Certification Society. Handbook For Organic Operators

Transcription

1 Pacific Agricultural Certification Society Handbook For Organic Operators Version 12, April 2015 Published by: Pacific Agricultural Certification Society nd Ave. Vernon, BC V1T 2N

2 Table of Contents 1.Definitions Introduction to PACS and the BC Certified Organic Program About This Book PACS Certification Principles of Organic Farming How the PACS Functions Certification Fees PACS Committees The BC Certified Organic Program The COABC The Canada Organic Regime The COABC Accreditation Board 8 3.Certification Standards BC Certified Organic Management Standards Categories of Certification Scopes of Certification PACS Certification Policies 11 4.Organic Certification Details Organic Inputs Types of Organic Operations Factors Affecting Certification Certification Process Making Changes on Your Farm or Facility 23 5.Equivalency of Certification Programs Recognition Agreements 25 6.Non-Conformity Follow-up, Reconsideration, Appeals, Public Complaints Non-Conformity Follow-Up Reconsideration Standards Interpretation Committee Rulings Appeals Public Complaints 28 7.Certificates and Labels Organic Certificates Organic Labelling Labelling and Signage Approval 32 8.Violations of the Standards Complaints Infractions by Operators 35 9.Confidentiality Enterprise Files Information for the Public Accreditor s Requirements PACS Constitution and Bylaws...37

3 1 1. Definitions Accreditation Initial and ongoing recognition of the Pacific Agricultural Certification Society by a recognized Conformity Verification Body under the COR. Applicant - A person or enterprise that has applied for organic certification under the BC Certified Organic Program provided by the PACS. Appeal - A procedure whereby a certified enterprise or a member of the public requests a review of a certification decision. The appeal may also be filed against the Pacific Agricultural Certification Society. BC Certified Organic Program The accreditation/certification program administered by the COABC under the Organic Regulations following the Agri-Food Choice and Quality Act (BC) and to the COR under agreement with the CFIA for ISO compliant accreditation. Canada Organic Regime (COR) - The documented framework of standardization and control measures necessary for the implementation of the Organic Products Regulation (Canada). In practice, the COR refers to all parts of the national standards for organic agriculture that is managed by the Canadian Food Inspection Agency. PACS is accredited by CFIA under COR (by recommendation of COABC and under their supervision see COABC below). Our Accreditation number is COR CB - Certification Body. May also be referred to as Certifying Body, Certifying Agency, Certification Agency, or Certification Agent. Certificate The document (issued by the PACS) that describes the organic status of an enterprise. May also be called the Certificate of Conformity. Certification The procedure by which a third party gives written assurance that a clearly identified process has been methodically assessed such that adequate confidence is provided that specific products conform to specific requirements. Certification Body The body that conducts certification. Certification Committee A group of persons delegated by the membership of the PACS the responsibility of assessing applications for certification. COABC The Certified Organic Associations of British Columbia. The administrator of the Organic Regulations pursuant to the Agri-Food Choice and Quality Act (BC) for regional certification. A competent body for accreditation to ISO compliant standards (Conformity Verification Body under the Canada Organic Regime). COABC Accreditation Board An independent body appointed by the COABC to carry out accreditation. Enterprise A production, processing or handling business or establishment. For the purposes of this document, an enterprise is also a member (or applicant for membership) of the PACS. International Organic Inspectors Association (IOIA) - The body (recognised by the COABC) responsible for training and upgrading of verification officers under the BC Certified Organic Program. Information regarding the IOIA is available at Inspection An on-site visit to premises for the verification of compliance with standards. Inspector A person appointed by the PACS Administrator to perform on-site visits. (Also see VO.)

4 2 ISO/IEC Guide Compliant Certification Program - Refers to the default organic certification program operated by the PACS. The PACS' Quality System meets the criteria established within ISO/IEC Guide General requirements for bodies certifying products, processes and services. Products certified by an agency accredited to this international standard qualify for export out of their home province or territory. Licensee An applicant who has attained organic certification and who has duly completed a PACS License Agreement which grants and limits the right to use the certification marks and phrases available under the PACS organic certification programs. Operator Any person, firm, or organisation that produces, handles or processes with a view to subsequent marketing thereof, products referred to as BC Certified Organic. For the purposes of this document, operator shall also mean a member of the PACS. In general, an operator describes a person; an enterprise describes an entity. Organic Production - A method of agricultural production, including any subsequent preparation, storage and transportation, conforming to the appropriate organic standards. Production Unit- A portion of an enterprise that produces an agricultural product under a specific management plan. Society The Pacific Agricultural Certification Society. Standards Organic production, processing and handling standards. Verification Officer - Inspector for evaluating certification criteria of individual operators and enterprises. VO Verification Officer.

5 3 2. Introduction to PACS and the BC Certified Organic Program 2.1. About This Book 1. The PACS Handbook for Organic Operators has been designed to assist applicants for organic certification to understand the process. New applicants will receive the Handbook in their initial certification packet. The most recent update is posted on the PACS website: The Handbook is meant to be used in conjunction with the Canadian Organic Standards, CAN/CGSB and CAN/CGSB , the Permitted Substances Lists. Details regarding the internal functions of the PACS may be found in the PACS Quality Manual, available from PACS PACS Certification 1. The Pacific Agricultural Certification Society is a non-profit society, incorporated in British Columbia (#S ) on August 03, Certification through PACS automatically provides free membership in the society which aims not only to keep certification costs low but also to provide opportunity for interested operators to participate in the framework of their certification. Certification fees therefore may be called PACS fees within this document. The purposes of the PACS, as described in its constitution are: a) To provide the administration of an organic certification program consistent with the criteria established and audited by the Certified Organic Associations of British Columbia. b) To represent the members of the Pacific Agricultural Certification Society in matters relating to the Agri-Food Choice and Quality Act of British Columbia as administered by the Certified Organic Associations of British Columbia. c) To represent the members of the Pacific Agricultural Certification Society in matters relating to the Canada Organic Regime as administered by their Conformity Verification Body. d) To provide public information activities with respect to organic agriculture. e) To provide certification services to organisations as requested by the membership of the Pacific Agricultural Certification Society. f) To be responsible for incidental matters related to the above-referenced activities. 2. The PACS was formed in order to provide an affordable and internationally recognised ISO/IEC Guide compliant organic certification program for organic enterprises in BC following the procedures of the BC Certified Organic ISO/IEC Guide Compliant Accreditation Program. 3. The PACS is a certification body whose major function is the certification of organic enterprises. The PACS may also provide certification services to other programs or jurisdictions as the membership decides. 4. The PACS operates from an office in Vernon, BC. The address for the PACS is: nd Ave. Vernon, BC V1T 2N1 Ph Fax admin@pacscertifiedorganic.ca

6 Principles of Organic Farming 1. Organic production is based on principles that support healthy practices. These principles aim to increase the quality and the durability of the environment through specific management and production methods. They also focus on ensuring the humane treatment of animals. 2. The general principles of organic production include the following: a) Protect the environment, minimize soil degradation and erosion, decrease pollution, optimize biological productivity and promote a sound state of health. b) Maintain long-term soil fertility by optimizing conditions for biological activity within the soil. c) Maintain biological diversity within the system. d) Recycle materials and resources to the greatest extent possible within the enterprise. e) Provide attentive care that promotes the health and meets the behavioural needs of livestock. f) Prepare organic products, emphasizing careful processing, and handling methods in order to maintain the organic integrity and vital qualities of the products at all stages of production. g) Rely on renewable resources in locally organized agricultural systems How the PACS Functions 1. A Board of Directors (elected at the AGM) manages the operations of the PACS. As a member of PACS (an enterprise must submit one person to represent their interests to the PACS) you have the right to attend the PACS Annual General Meeting and to participate in the election of the PACS Board of Directors. 2. The PACS Board of Directors appoints an executive and a Dispute Resolution Chairperson. The executive hires an Administrator who hires the Certification Committee. The Board elects the President who currently acts as the executive director of the Society. The Board may choose to hire an executive director if they see fit. 3. PACS Board members, managers and staff may not provide consultative services to PACS organic operators. However, the PACS Administrator may keep a list of consultants who are willing to provide such services and can provide these names to any applicant or operator who requires assistance Certification Fees 1. As a not-for-profit society, fee-for-service enterprise, the PACS determines its fees to cover the cost of the services it provides. The fees must be large enough to cover costs and allow room for contingencies - maintaining a fiscally responsible organisation is one of the requirements of ISO/IEC Guide The fees are determined by the membership at each Annual General Meeting. The fee structure is outlined below Initial Application Fee 1. (For new applicants only) $100.00, non-refundable. This fee is charged to cover the costs of opening/creating/processing a new file, including but not restricted to: new member support, registering a new certification number and opening a new account. This fee also includes providing books, documents and related resource materials, which are essential for the organic certification process. The Initial Application Fee is not

7 5 applied to operations that are already certified under the BC Organic Program (transferring from another CB) Annual Costs 1. Applicants costs are paid in two instalments. The first instalment consists of Fees which are paid at the time of initial or renewal registration form submission. The Fees have two components: PACS fees which contribute to the costs of running the PACS office and accreditation (COABC) Fees. The Fees do not cover inspection costs and expenses or Certification Committee review costs. These two comprise the second instalment which is billed following completion of the annual Certification Review Report. 2. The accreditor s (COABC) fees are determined by the accreditor annually. The PACS remits these monies directly to the accreditor as they are collected. The accreditor determines its own refund policies. 3. PACS fees are based upon an applicant s gross organic sales (in the case of handlers this is the gross organic receipts) of the previous fiscal year of the enterprise. For new applicants, the fees will be based upon anticipated gross organic sales and will be adjusted to the valuation of the actual gross organic sales after that value is verified during the annual inspection. Verification Officers will ask for proof of gross organic sales during their inspection, but will not report any confidential financial information to the PACS. 4. PACS fees are subject to change by determination of the members year by year. They are published in the Certification Registration forms available from the PACS office and on the PACS website Inspection Fees 1. Inspection fees are charged for inspection costs. Inspection costs will be charged to all enterprises in BC, Yukon or Alberta at the rate of $60/hr. for time billed to PACS by the Verification Officer (VO). (Clients from other Canadian locations should contact the PACS office for current hourly charges in their province or territory.) This includes time spent reviewing enterprise applications (or renewals), doing inspections and writing Verification Reports. Also included is time spent by VO (or PACS staff) tracking down missing documents or making follow-up visits or phone calls. The $60/hr charge includes the VO hourly wages plus a small administration cost related to handling and administering your inspection. 2. Expenses (including mileage, flights, travel time, accommodation) will be billed on a cost-recovery basis above the time-related inspection costs. Efforts will be made to arrange inspections requiring the least amount of travel and using the most efficient mode of transport. Organic farming organisations have traditionally arranged billeting for VOs at the enterprises they inspect in order to reduce travel expenses. This will be continued whenever possible. You will be billed for inspection fees after your inspection and Certification Review Report have been completed Certification Committee Costs 1. The PACS bills clients at the rate of $36/hr for office work performed during the normal procedures for certification. These include review of application documents, review of inspection reports, label reviews and review of submissions relating to non-conformities.

8 Administration Fees 1. The PACS bills clients an Administration fee that is stepped to correspond with ranges of fee categories. The fee may be $25, $50, $75 or $100. The fee recoups costs accrued for maintenance and support of ongoing updates of organic regulations and standards, included but not limited to website postings, inputs evaluations, newsletter distribution, mailing, etc Export Levy 1. The Export Levy is charged to enterprises which intend to export products into jurisdictions regulated by non-canadian organic standards (i.e. USA and overseas). The levy recovers part of the cost of maintaining ISO compliant accreditation and recognition agreements with international jurisdictions Documentation and Support Surcharge 1. The PACS bills transactional fees for documents or other requests that are beyond the normal procedures for certification. This includes transaction certificates, export declarations and responses by the Administrator to specific member enquiries Payment of Fees 1. PACS Clients are required to pay fees for services as described in the appropriate documents. Applicants must sign an agreement that obliges them, upon invoice from PACS, to punctually remit the fees required for services rendered. Non-payment of fees will result in initiation of certification suspension and cancellation. 2. Eight weeks will be allowed for return of annual renewal forms and fees. Renewals received after the deadline date for filing (indicated at the time the forms were forwarded to the member and on the previous year s organic certificate) will be assessed a $50 late filing fee for the first month and $25 for each following month or part thereof PACS Committees Certification Committee 1. The Certification Committee is responsible for determining the organic status of an enterprise according to criteria defined in the BC Certified Organic Program. The Certification Committee is appointed by the PACS Board on the recommendations of the PACS Administrator and is made up of persons having no interest in the enterprises being evaluated. The members of the Certification Committee have qualifications in quality control or in different areas of organic production. The Certification Committee operates independently from the PACS Board. The minimum number of members on the Certification Committee is three Dispute Resolution Committee 1. The Dispute Resolution Committee makes decisions according to criteria provided in the PACS Quality Manual regarding disputes, complaints and appeals that have been brought before the PACS Board of Directors. The PACS Board of Directors elects a Chair of the Dispute Resolution Committee; the Chair appoints members of the Committee as needed. PACS members who are appointed to the Dispute Resolution Committees are

9 7 obligated to attend to the duties required of them. Though the Board appoints a Chair, the Dispute Resolution Committee will not convene until its services are required PACS Technical Committee 1. The PACS Technical Committee is responsible to provide rulings on areas of concern in the application of the PACS Organic Certification Program. The Technical Committee cannot rule on an operation s certification status, but can provide interpretation of the program to the Certification Committee or individual operators. Operators should refer technical questions to the Administrator, who will request clarification from the Technical Committee. Such clarifications may become precedents for future enquiries The BC Certified Organic Program 1. The BC Certified Organic Program is a system of accreditation (of certification bodies) and certification (of organic enterprises) based on rules described in the Organic Agricultural Products Regulation of the Agri-Food Choice and Quality Act of BC. ISO/IEC Guide compliant accreditation and certification based on the Canada Organic Regime is provided under agreement with the Canadian Food Inspection Agency (CFIA) Purpose of Organic Certification 1. Organic certification ensures that generally accepted organic management systems are practiced not only by growers, but by all the people and enterprises that handle and process organic food on its journey to the final consumer. To facilitate this, the PACS provides a system that combines strict production standards, verifiable third party inspections and legally binding contracts protecting producers and buyers of organic products. 2. Organic certification verifies that operations have implemented organic production systems which conform to established standards. Organic certification is not a final product guarantee regarding the absence of residual environmental contaminants. 3. The PACS is specifically capable of providing certification services for: a) Commercial producers of organic crops and livestock, b) Organic apiaries, c) Processors of organic foods, d) Handlers of organic foods such as packers, wholesalers, distributors and other service providers, e) Restaurants and Retailers and f) Wild crop harvesters The COABC 1. The Certified Organic Associations of British Columbia is a society registered in British Columbia. The members of the COABC are also societies certification bodies operating in BC. The BC Ministry of Agriculture and Lands and the BC SPCA have non-voting (associate) memberships in the COABC. The BC Food Systems Network has a voting (consumer/environmental) membership in the COABC. 2. Each member organisation (Certification Bodies and associate members) sends representatives to the COABC. This group makes up the membership of the COABC.

10 PACS Relationship to the COABC 1. PACS is accredited by the COABC. This means that PACS must follow the certification program rules established by the COABC - the BC Certified Organic Program. Procedures and management standards for providing organic certification are defined within the BC Certified Organic Program. The PACS administers the program to individual licensees (PACS clients). The COABC monitors and surveils the PACS throughout this process. 2. As a member of the COABC, the PACS has the right to supply directors (1 director for every 50 PACS members) to the COABC Board of Directors. These persons represent the interests of PACS members regarding changes or amendments to the BC Certified Organic Program The Canada Organic Regime 1. The Canada Organic Regime (COR) is the mandatory program regulating organic claims by Canadian enterprises on qualified agricultural products that are traded across provincial or international boundaries. The Canada Organic Regime is administered by the CFIA in a separate department called the Canada Organic Office under the authority of the Organic Products Regulations (enacted under the Canada Agricultural Products Act). 2. The COABC is recognised by the Canada Organic Office (COO) as a Conformity Verification Body under the Canada Organic Regime. 3. Accreditation under the BC Certified Organic ISO/IEC Guide Compliant Program therefore entitles the PACS to supply its clients with certification under the Canada Organic Regime. Operators who are certified under the PACS Certification Program are authorised to label their interprovincially or internationally marketed products as Organic and to use the Canada Organic Biologique logo The COABC Accreditation Board 1. The Accreditation Board is an independent body appointed by the COABC. The job of the COABC Accreditation Board is to monitor and evaluate the programs operated by organic certification bodies according to criteria defined in the BC Certified Organic Program. Although the COABC appoints the Accreditation Board, the Board operates independently and makes the final determinations on the status of certification bodies such as the PACS. The PACS is regularly audited by the COABC Accreditation Board: records within the PACS files are examined and compared to corresponding records at the individual enterprises (clients of PACS which are examined by the Accreditation Board) in order to determine whether the records that PACS maintains at its office accurately reflect conditions at each of the organic enterprises. This verification audit process is integral through all levels of the BC Certified Organic Program. 3. Certification Standards 3.1. BC Certified Organic Management Standards 1. The PACS must apply the minimum standards provided by their accreditor. The PACS is accredited by the COABC whose BC Certified Organic Program standard is comprised of the following manuals: COABC Book 1 Operation Policies and Procedures (and its

11 9 Annexes) and COABC Book 2 Certified Organic Management Standards. These manuals are available on the COABC website: 2. The Certified Organic Management Standards describe the rules that an organic operator must follow in order to have their enterprise certified. There are many prohibitions in the standards (synthetic pesticides, synthetic fertilisers) but there are many active improvements in an organic system that must be undertaken as well (soil improvement programs, animal health programs). Organic production is not simply elimination of synthetic materials for non-synthetic ones - operators should study the standards to fully understand the commitment they have made to organic production methods. 3. COABC is recognized as a Conformity Verification Body by the Canada Organic Office of the Canadian Food Inspection Agency enabling PACS to provide certification to the Canada Organic Regime (COR) implemented by the federal government in Operators who are certified to the PACS ISO Compliant Program are therefore certified to COR and have the ability to export organic products outside of BC. 4. The Canada Organic Regime manuals are comprised two Organic Production System manuals: General Principles and Management Standards (informally known as the Canadian Organic Standards) CAN/CGSB and Permitted Substances Lists CAN/CGSB These manuals are available on the PACS website: or on the Public Works and Government Services Canada website Changing Standards 1. As with all organic certification systems around the world, the standards used by the PACS are living documents which are subject to change. The agency ultimately responsible for changes to the Certified Organic Management Standards is the Canadian General Standards Board (CGSB). Operators wishing to pursue changes to the organic management standards may put their proposals forward to Ottawa. Contact the PACS for appropriate forms and contact names. 2. If a PACS client or the PACS Certification Committee thinks that the standards are unclear or require interpretation, they can pursue the matter through the Accreditation Board. The Board will determine whether the enquiry is a matter that they can clarify or a matter that should be taken to the COO Standards Interpretation Committee. Contact the PACS for assistance. 3. The PACS shall notify its clients of any amendments to the COR regulations or the standards within two months of their publication. 4. Operators shall have up to 12 months after the publication date of an amendment to the standard or Permitted Substances Lists to come into compliance with any changes to their requirements Categories of Certification 1. Regional organic certification is conferred on specific plots of land (production units) or on specific enterprises such as organic processing businesses. The operator (or enterprise) is named in the certificate but organic certification does not refer to an actual person, but rather to a 'production unit' or system. A production unit is an organic enterprise or portion of an enterprise. 2. COR certification conversely is a system of certifying products which must fall within the scope of the federal Canada Agricultural Products Act (CAPA), including agricultural foods

12 10 for human or livestock consumption only. There are no standards for aquaculture or soil-less agricultural products (e.g. hydroponics, etc) at this time. 3. Although the BC Agri-Food Choice and Quality Act provides for organic certification of 'non-food' products (such as compost, or textiles), management standards for non-food products have not yet been developed Scopes of Certification Scope Definition 1. The Scope of certification refers to specific certification requirements (programs and standards) according to different marketing jurisdictions or different applications (e.g. PACS Risk Assessment Program) PACS BC Certified Organic ISO/IEC Guide Compliant Program 1. The BC Certified Organic Program (as described elsewhere in this manual) is the default certification program available to PACS clients. Operations that are issued a current BC Certified Organic Program certificate may label their products BC Certified Organic and use the BCCOP program symbol on their products. 2. As the BC Certified Organic ISO/IEC Guide Compliant Program is recognised to be compliant with the Canada Organic Regime, products which are certified to COR may be exported throughout Canada and to other countries according to the terms of organic equivalency arrangements implemented by the Canadian Government. (Export arrangements are negotiated and implemented by the federal government and change from time to time.) Labels of those products which are included in a certification program may display the Canada Organic Biologique symbol 1 once the PACS has confirmed that the products are organic and the products are listed on the operator s organic certificate Exports to the USA 1. Operators who wish to export to the US may do so if certified to COR. The terms of the US-Canada Organic Equivalency Arrangement allow the labels of COR certified products to display the USDA organic seal and those products may be exported into the USA. (NOTE: Livestock or animal product exports require specific evaluations.) Contact the PACS office for US-specific labelling approval if you are planning to ship organic products to the USA Exports to European Union Countries 1. COR certified products may qualify for export to EU destinations. (There are some restrictions.) The terms of the EU-Canada Organic Equivalency Arrangement allow Canadian grown organic product labels to bear the EU organic logo and those products may be exported into EU countries. (NOTE: Processed products made in Canada from imported ingredients are currently excluded under the terms of this agreement but negotiations may change that in the future.) Contact the PACS office for further information and for EU-specific labelling approval if you are planning to ship organic products to Europe. 1 Exception: Operations certified under the PACS Risk Assessment Program are not compliant with the Canadian Organic Regime, and may not export product out of their home province/territory.

13 Other International Destinations 1. If you intend to export organic products anywhere in the world, speak to PACS about your needs. The federal government is negotiating with other countries to increase organic trade opportunities Exports to Quebec 1. Organic operators who intend to ship organic products into Quebec must be aware that Quebec language laws affect all label content. Contact the PACS office for specific labelling instructions Out-of-Province Certification 1. Being accredited to the Canada Organic Regime allows PACS to provide certification services to enterprises that reside outside of BC. Such operations have the same opportunities for product claims and exporting as enterprises that reside within BC. 2. Out-of-province operations which are certified by PACS cannot use the BC Certified Organic Program symbol to market their products PACS Certification Policies 1. The PACS Board has created three specific policies for PACS clients: a) When an operator under active certification knowingly uses a prohibited substance (including new CCA treated posts) the operator s certification will be revoked and he/she will be ineligible for recertification for a period of 5 years. b) Any invoice or statement of account issued by a PACS operator must not only identify the status of organic products sold, it must display the statement: Certified by PACS in order to substantiate the organic status of the goods. c) When considering the use of conventional seeds to grow organic crops, a reasonable search for organic seeds consists of contacting at least 5 potential suppliers of organic seeds. 4. Organic Certification Details 4.1. Organic Inputs PACS Brand Name List 1. Operators must obtain and retain records and support documents (for example, purchase receipts, ingredients lists, labels, MSDS sheets, application logs, Non-Organic Ingredient Declarations or non-gmo statements) for all inputs used on or in organic products. Records must be made available for the Verification Officer to review during an inspection and must be retained in the enterprise s organic records for a minimum of 5 years. 2. All materials, ingredients and inputs used in organic products or production units must be scrutinized and approved by the client s Certification Body. PACS clients must contact the PACS office before using a new input to ensure that it is compliant with organic requirements.

14 12 3. The PACS previously maintained lists of branded products which the Certification Committee had reviewed and found acceptable for use under organic management practices. The PACS lists have now been turned over to the Organic Federation of Canada to be combined with those approved by other Canadian CBs. The amalgamated lists are available through the website: PACS clients who choose products from that list first must contact the PACS office to ensure that the products are acceptable to PACS. Identification on this list is not a guarantee of acceptance by PACS. 4. OMRI (Organic Materials Review Institute) is now evaluating inputs to COR requirements. Their website ( posts a list of materials approved in Canada. These materials are not currently available through their search engine. Organic operators must download the list and view the pdf version. This is the portion of the website where the link to the downloadable list is posted Types of Organic Operations 1. Certification can be attained for primary (farm) production, processing or handling or a combination of these. Farm production refers to the growing of agricultural products and includes everything from tree fruits through vegetables to mushrooms. Some specific types of primary production require specific application plans, like Greenhouse crops and Wild Crops and Maple Bush harvesting. Livestock production requires two application forms: one for the farm land and a second which covers animal husbandry information. Individual plans are available for poultry, livestock (beef, bison, pigs, etc.), rabbits and bees. Contact the PACS office for detailed descriptions of the requirements for certification for the specific organic products you wish to have certified Organic Farm Plan 1. A farming application (called an Organic Farm Plan) identifies a particular farm or farming business. Your application should be in the name of your farm, your family or your farm business. A specific farm name refers to all the sites of that farm that are operated as a single business, regardless of how many partners or sites are involved. If you are operating more than one type of farming business (an organic feed mill on one site and an organic mushroom farm on another, for instance) you must make a separate application for each business. 2. The PACS Organic Farm Plan (or Renewal Plan) pertains to the enterprise and land-based crops. If other types of production are involved (e.g. Greenhouse, livestock, apiculture, Maple Bush, Wild Crops, Mushrooms, etc.), additional application forms will be provided according to the products you wish to include in your certification. a) When applying for initial certification of land-based production units (including field crops, in-ground greenhouse crops, livestock and maple products) the application for

15 13 certification must be received by the certification body 15 months before the day on which the product is expected to be marketed. (OPR Schedule 1) b) A 'site' refers to a specific piece of property that is geographically separated from another. A 'field' refers to any separate plot within a site Food Preparation and Packaging 1. Any operation or portion of an operation that receives or otherwise acquires agricultural products for resale (including final retailers of agricultural products) who manufacture, process or transform, repack or re-label such products including, in respect of an agricultural product: a) Washing, grading, unpackaging, packing or re-packing, heating (baking, browning), storing, slaughtering, inspecting, packaging (or re-packaging) and labelling. 2. Any processor who manufactures a multi-ingredient agricultural product must submit: a) A detailed recipe describing the percentage (by weight) of each of the ingredients and the percentage (by weight) of the organic ingredients as part of the application process; b) Production and preparation details for the products to which the application applies. 3. It is necessary that handlers of organic product be included in the 'audit trail' from primary producer to final sale and that all handling operations undertaken on organic products be subject to verification. 4. Retail display of produce (in its original packaging) is not considered handling. 5. The on-farm washing and packing of produce by primary producers must follow the hygienic standards required of organic processors as well as the standards for handling produce required by the Canadian Food Inspection Agency. 6. Handlers who do not take ownership of organic products are not required to be certified. They are however an integral part of the audit trail and their handling of organic products must be inspected. If they offer their services to more than one organic operator, they have the option of applying for an Attestation of Compliance (to COR) which is recognized by all CFIA accredited CBs. Enterprises / operators who are seeking Attestation of Compliance verification through PACS must apply following the same procedures as handlers who own the products (see Section 4.4). The PACS office will supply the appropriate application forms and certification documents. 7. Handlers often have numerous facilities operated as one business. One application may suffice for the enterprise however, if individual facilities are separated by long distances or are operated as distinct management units, each facility will need to make independent applications for certification. Consult with the PACS Administrator to determine your situation On-Farm Preparation 1. On-farm preparation refers to activities that takes place before an organic product leaves the primary production unit. a) If you process only the organic products that you grow, you do not have to apply for certification as a processor but you must complete the On-Farm Processing section of the Organic Farm Plan. Your processing activities will be inspected along with your production units.

16 14 b) If you process someone else's organic products (on-farm), this activity is considered to be commercial processing. You must complete and submit a processing application form in addition to your farming application form Retail Certification 1. The PACS can provide COR organic certification to specific handling operations of retailers. Retailers whose handling operations are certified may use organic certification marks and phrases on those products which are subject to the verified handling. Retailers must ensure that the organic program symbols are associated only with products that are included in their organic certification program Grower Group Certification under COR 1. Multi-site grower group organisations can seek certification under COR. Detailed requirements are set out in the Canada Organic Office Operating Manual, Part F. Contact the PACS Office if you wish to have additional information Specifying the Type of Operation 1. Applicants for organic certification are asked to specify exactly which type(s) of certification (farming, processing or handling) they require as the documentation differs for each category. Some enterprises will have multiple aspects requiring the completion of multiple forms and the inspection of each facet of the operation Factors Affecting Certification Less than 70% organic products 1. Operations that (only) produce products containing less than 70% organic ingredients do not require certification, nor do their ingredients require evaluation by a verification officer Contracted Production 1. Contracted production facilities, though not requiring certification, shall be inspected. In these cases the contracted producer shall be included in the certification of the contracting party. The contracted production shall be inspected in the same manner and to the same degree as the licensee. The licensee shall be held fully responsible for the sub-contracted production and be subject to sanctions in the event on non-conformities by the subcontracted parties. 2. The PACS certified operator and the contracted operator shall jointly complete and submit the appropriate Third Party Service Provider form prior to the commencement of the contracted production. The form shall be reviewed and approved by the PACS Certification Committee in advance of the service Contracted Processing 1. Some organic processors prefer to contract an outside processing plant rather than develop their own facility. In this case the contracted facility and operator must:

17 15 a) Be certified by PACS or another CFIA accredited CB or b) Have a current Attestation of Compliance to COR issued by PACS or another CFIA accredited CB or c) In the case of a slaughter facility or abattoir, complete and submit the appropriate Third Party Service Provider form to the PACS Certification Committee, which will be reviewed and approved prior to the commencement of service, or d) Be willing to have a VO present every time an organic batch is processed. 2. The PACS licensee will maintain ownership throughout the process and shall maintain control of the raw materials, the manufacturing and the sales of the certified organic product. The licensee must have a contract in place with the contracted processor. This contract will specify the requirements that the contractor must meet for maintaining the organic integrity of the product. There must be clauses that specify an understanding of and compliance to the standards and an obligation to provide information and access to the PACS (you can request this information/form from the PACS Administrator). The subcontracted operator must be provided with a copy of the current Canadian Organic Standards. 3. Unless the contracted facility is certified or holds an Attestation of Compliance, it may not take ownership of the product nor may it market the certified organic product itself Contracted Storage 1. If you wish to contract storage of your organic product(s) to a non-certified facility, ask the PACS office for an Independent Storage Statement. This form must be completed and signed by the operators of each facility that is providing storage. The VO will ask to see this form during your inspections Transportation 1. The party owning the organic product at the point of transport is responsible for maintaining the organic integrity of the product. If you own an organic product while it is being transported, you are required to ensure that the organic goods do not become contaminated during transport. You may require transport operators to sign an attestation ( Transport Affidavit available from PACS office) or to fill out a form of your own making, or to become a certified handler on their own. Your VO will ask to see copies of procedures and documents in place to protect organic product in transit Transition to Organic 1. The transition period refers to the time from the initial application to the receipt of an organic certificate. The transition period varies according to the type of production and previous use of the production unit. For land based production, the maximum period of transition is 36 months from the last application of any prohibited input Reduced Transition Period 1. The minimum transition period for land based production is 12 months upon proof that there have been no prohibited inputs applied to the land in the previous 24 months. Such proof can be in the form of affidavits from the owner or manager during that period or affidavits from neighbours. The PACS will verify these statements.

18 Marketing Transitional Products 1. The PACS will allow the marketing of Transition to Organic products (1 st, 2 nd or 3 rd year transitional) and will issue a Transition to Organic Certificate for products that are only to be sold within BC. Transitional products may not be marketed as 'organic', 'certified organic' or BC Certified Organic. Transitional products may not be sold to a processor whose intent is to export a processed organic product Split Operations 1. Maintenance of non-organic operational units on an organic farm is allowed under the BC Certified Organic Program. Such operations are tolerated with specific limits and requirements because it is understood that certain crops are difficult or impossible to produce (at this time) in commercial quantities under an organic regime. Producers must document the particulars of the separate production units and submit the information to the PACS if they sustain a split operation on their holding. Adequate distinction must be maintained between the organic and non-organic portions of the farm. In addition the PACS requires and the VO will verify that: a) Non-organic (or transitional) crops, livestock and produce and organic crops, livestock and produce are of different varieties and are visually distinct. b) Prohibited materials are stored in separate locations from those where organic products are handled; c) Documentation regarding the production or processing and sales is well managed and makes clear distinctions between organic and non-organic products; d) The measures taken to safeguard against risk to organic integrity are understood and practiced at all levels of the operation Parallel Production 1. Parallel production is production of the same or visually similar crops on organic and non-organic portions of a farm or on two farms managed by the same operator. Parallel production is only allowed in the following cases: a) perennial crops (already planted); b) agricultural research facilities; c) production of seed and d) vegetative propagating materials and transplants. 2. Ensure that you advise the PACS Certification Committee if any of these circumstances apply to you. The PACS may ask for a written statement describing your intentions (to convert the parallel production units to organic certification) and your protocols which segregate and protect the organic integrity of the organic crops. 3. Specific requirements for parallel production include: a) clear demonstration that the identity of the crops so produced can be maintained during their production, harvesting, storage, processing, packaging and marketing; b) Keeping accurate and verifiable records of both non-organic and organic produce and product storage, transportation, processing and marketing. These will be checked during the inspection. c) The inspection will include the non-organic portions of the enterprise. d) The inspection will occur at critical times - normally at the time of harvest. e) The inspection will include an audit of all parallel production crops after harvest. f) Inspections may occur more frequently than once a year and may be unannounced.

19 PACS Risk Assessment Program 1. The PACS operates a Risk Assessment Program according to criteria defined within the BC Certified Organic Program. Unique in the world, the Risk Assessment Program rewards small, low-risk producers by allowing for reduced inspections (once in three years, with 5% of all Low Risk operations subject to unannounced inspections annually, the cost of which is shared by all members of the program), thus reducing costs for Low Risk operators. 2. Small farming operations will be automatically assessed against the requirements for the Risk Assessment Program. You will be notified if you qualify. 3. As risk assessment criteria are not recognised under the Canada Organic Regime, the PACS Risk Assessment Program is not applicable to operations that intend to ship organic products outside of their home province/territory or that intend to sell organic products to buyers who require COR certification. 4. Operators must have received an organic certificate throughout the previous 3 years and must have at least a 2 year history with the PACS. There can be no outstanding issues of non-compliance in effect Certification Process Registration 1. Every applicant for certification must complete a Certification Registration Form. Every person (or enterprise) that duly completes the organic certification process is granted free membership in the Pacific Agricultural Certification Society and has the rights and responsibilities associated with that membership. 2. The appropriate Certification Registration Form must be completed and the required fees must be paid before the certification process can begin or be annually renewed. 3. Applicants who have been granted organic certification in previous years must provide the name(s) of certification bodies to which applications had previously been submitted and details pertaining to processing the application and the resulting decision(s) Electronic Forms 1. Electronic forms have been developed and they are available to PACS clients via and on the PACS website ( A userid and password, which can be obtained by contacting the PACS office, are required to access the forms. Enrolling for postal delivery of documents from the PACS office is subject to cost recovery fees Certification Applications (Organic Plans) 1. Once the registration form and fees are received in the PACS office, operators are sent a certification packet containing electronic or paper copies of the following: a) Handbook for Organic Operators (this manual) b) the Canadian Organic Standards and Permitted Substances Lists c) Appropriate certification applications (Organic Plans) and associated forms. 2. There are separate forms for different categories of operations (production, processing and handling) and for different commodities (livestock, crops, apiculture, etc.). These