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Interpreting the Organic Standards

Organic Agriculture Centre of Canada

The Canadian Organic Standards (COS) were voluntary until 2009. They became mandatory when the Organic Products Regulations (OPR) were implemented in June 2009. Many meetings of the CGSB Committee on Organic Agriculture (TC) were held to revise the standards and make them fully applicable. But, transitioning from theory to practice is always challenging. Though revised by talented people, standards can hardly cover all possible scenarios experienced in the real farming world.  So, when the Canada Organic Office (COO), the CFIA agency responsible for the monitoring of the OPR, started receiving specific questions about how to apply the standards in given contexts, a decision was made to consult with a committee that would provide clarification on particular issues: the Canadian Standards Interpretation Committee (SIC) held its first meeting in December 2009.  Composed of seven members from the TC elected by the Organic Federation of Canada, the SIC analyzes, comments and tries to come to a consensus on the meaning of the standard in a given background.

Farmers need to be practical; they adhere to organic principles, but then need to apply or adapt the principles to their practices. And no one wants to lose certification for not having done the right thing. 

More than 50% of the questions received by the SIC are about permitted substances. Some annotations defining the use of substances give “grounds for interpretation”. It is clear when the substance is prescribed “only” for a specific use or should be derived only from a specific process. But, sometimes the annotation is stated as a general comment that does not seem to exclude some other use. Furthermore, some substances are repeated in the same table or in two different tables with different annotations. Which annotation should be followed when using this substance? Operators will surely choose the prescription that best fits their needs. But what is the real intent of the standard?

The Canadian PSL is a list of permitted substances. But what if a substance is not included? Many questions were issued about “absent” substances. There are general directives about the use of substances not registered on the PSL; they should comply with the general principles of 1.4.1. But operators want to be reassured about their practices. There is also ambiguity with processes from which allowable substances are derived; and though the availability on the market of some substances can be a burden, the restrictions on acceptable processes of production must be restated.  Specific production requirements are also questioned; some operators want to be confirmed that the general principles of the COS also apply to specific crops, which are perceived as being “aside” the main cropping systems.

Some questions are simple: the answer is Yes or No. But other questions are more complex, some others cannot be clearly interpreted; they reveal a gap or a lack of clarity. The SIC has no authority to revise the COS, and has to be very careful to avoid rewriting the standards; interpreting is reading what is stated and clarifying the original intent of the authors, not going beyond what was written. If faced with a question that highlights an instance of ambiguity or apparent contradiction in the wording of the Standard, the SIC may propose a revision which would involve the CGSB Technical Committee.  This is the group legally responsible for the maintenance of the Standard. Moreover, the PSL proposals being currently subject to ballot or figuring on the work list of PSL working groups cannot be considered: they are not applicable to the work of SIC until they are inserted in published standards amendments. 

The SIC interprets questions and issues answers that are posted on the COO website to undergo a 60 day comment period. This comment period is a clear indication that the standards are really managed by the whole sector. Should a comment challenge a proposed interpretation, the SIC will bring the question back for further discussion, to consider the comment and whether or not to revise the answer.  The main purpose of the SIC is to assure uniform application of the rules to all operators and CBs. The Questions and Answers are posted on the COO website. Questions should be sent to the COO.

This article was written by Nicole Boudreau, Organic Federation of Canada, on behalf of the OACC with funding provided by Canada’s Organic Science Cluster (a part of the Canadian Agri-Science Clusters Initiative of Agriculture and Agri-Food Canada's Growing Forward Policy Framework).  The Organic Science Cluster is a collaborative effort led jointly by the OACC, the Organic Federation of Canada and industry partners
. For more information: oacc@dal.ca or 902-893-7256.

Posted July 2011