By Chris Grigsby, Director, MOFGA Certification Services LLC
The unprecedented nature of the COVID-19 global pandemic has caused tremendous disruption to so many aspects of our daily lives, including our food system. MOFGA Certification Services (MCS) has also had to shift the organic certification process due to the regulatory requirements. The USDA National Organic Program (NOP) rule requires, as part of the annual application and renewal process, an onsite inspection to verify compliance. The spring shutdowns of most states, including travel restrictions and stay-at-home orders, have required adjustments to the normal course of work for MCS and how we conduct inspections.
The NOP has been clear with accredited certifiers such as MCS that there can be no shortcuts to verifying compliance of producers; inspections and oversight must go on. To that end, we have been working to adapt our regulatory activities to the demands of the pandemic for continuing to verify the organic integrity of MOFGA-certified farms, facilities and products while keeping everyone involved safe. Rest assured, we are working extremely hard to ensure the integrity of the MOFGA-certified products you depend on!
MCS has developed temporary contingency plans for inspections for the 2020 cycle that include the use of technology when appropriate to reduce the amount of onsite inspection time needed. We have instituted a hybrid inspection approach, which includes a remote desk audit of records, a virtual tour and interview, and the potential (with permission of the operation) for un-hosted onsite field and facility tours where applicable. In addition, MCS has developed guidance for certified operations and applicants, as well as extensive training, support, tools and personal protective equipment (PPE) for inspectors. We are well underway, and our goal is to complete the roughly 450 farm-based inspections by the end of the year.
If navigating organic certification during the pandemic wasn’t enough, the NOP has also signaled that it will be releasing a new proposed rule to amend the regulations, Strengthening Organic Enforcement, which will be published in the Federal Register and will be accompanied by a 60-day public comment period. The proposed rule aims to close longstanding loophole exemptions regarding who needs to be certified that have caused integrity and fraud issues in the global supply chain, codify best practices and other guidance into the regulation, and create additional requirements for onsite inspections. While the issuance of the proposed rule is welcomed by MOFGA and those in the organic and consumer communities, the timing isn’t the best. MOFGA and MCS will be considering comments, as well as working with our coalition partners to put forth comments that keep in mind the organic producers and communities we serve.
Additionally, USDA-NOP missed the congressionally mandated deadline to finalize and publish the Origin of Livestock final rule, which will finally remove loopholes that created a continuous transition scenario of non-organic animals (organically managed since the last third of gestation) onto organic dairy operations. We are pushing and urging the NOP to act immediately, and we encourage all stakeholders to pressure the USDA to publish the rule without any further delay.