In the Summer 2017 Organic Report, we featured an article entitled “Organic fraud prompts action on import verification” describing the various avenues the Organic Trade Association was pursing to address organic fraud after the discovery of fraudulent soybean imports from Turkey. In addition to the trade association’s 2018 Farm Bill priorities that include a call for increased trade oversight, we reported on the Global Organic Supply Chain Integrity Task Force that had convened.
Making up the task force are over 30 member companies representing farmers, handlers, traders, consultants, attorneys, certifiers and retailers. Task force co-chairs include Kim Dietz (Senior Manager of Organic Policy at The J.M. Smucker and President of the OTA Board), Monique Marez (the trade association’s Director of International Trade), and Nate Lewis (the trade association’s Farm Policy Director). The task force has been meeting in subgroups over the past six months to develop a Best Practices Guide to Preventing Organic Fraud to help brands and traders manage and mitigate the risk and occurrence of organic fraud. The work is being shared and coordinated with an Accredited Certifiers Association (ACAs) Working Group that is developing an ACA Best Practices Guide for Verifying Traceability in the Supply Chain.
The purpose of the Best Practices Guide is to provide businesses engaged in organic trade with a risk-based approach for developing and implementing a written organic fraud prevention plan to assure the authenticity of organic products by minimizing vulnerability to organic fraud and mitigating the consequences of occurrence.
By outlining systematic approaches to the organic certification process and verification procedures carried out by ACAs and certified operations, the Guide’s recommended practices are intended to establish an industry standard for businesses to create continuously improving internal programs and processes for achieving organic integrity throughout their associated supply chains. The Guide will become the industry standard reference for achieving integrity across complex organic supply chains.
Structure and content
The booklet will present a systematic approach to developing a written organic fraud prevention plan summarized by a four-step process:
1. Conduct a vulnerability assessment, including:
✓ Know your products (history, economic and geographical factors)
✓ Know your suppliers (manufacturer, broker, certified/uncertified, history)
✓ Know your supply chain (length, complexity, traceability, supply and demand)
✓ Know your existing verification measures and identify the gaps
2. Design and implement internal mitigation measures including a supplier approval program that involves second-party supplier audits
3. Ensure practices are effective through monitoring and verification tools such as internal audits and control testing
4. Integrate practices into the organic certification system via the Organic System Plan as well as other quality management systems such as GFSI ISO 22000.
The task force also is working to include a section on what to do when you suspect or detect fraud. The Guide will include detailed instructions and a sample template for submitting a complete and effective complaint to the National Organic Program’s enforcement division. Moreover, the task force is developing a section on industry-wide recommendations for further actions needed and another providing additional resources and helpful tools and technologies for identifying and deterring fraud.
In summary, the Guide:
✓ Provides businesses engaged in organic trade with a risk-based approach for developing best practices for improving the resilience and overall integrity of global organic supply chains
✓ Is intended for individual businesses engaged in selling, buying, producing, processing or packaging certified organic products
✓ Provides background on the participant’s responsibilities and organic requirements for a simple and complex organic supply chain
✓ Aims to set a standard industry practice that compliments and reinforces the organic certification process and verification procedures carried out by ACAs and Material Review Organizations (MROs) as authorized by USDA’s National Organic Program.
✓ Provides guidance on developing and implementing a written organic fraud prevention plan to assure the authenticity of organic products by minimizing vulnerability to organic fraud and mitigating the consequences of occurrence
✓ Presents a process for carrying out a vulnerability assessment to design and implement appropriate mitigation practices
✓ Recommends monitoring procedures and verification tools that will ensure the practices and procedures are effectively implemented
✓ Includes detailed information on what to do when you suspect or detect fraud and the process for filing a complete and effective complaint to USDA’s National Organic Program
✓ Identifies other industry-wide needs and recommendations for next steps and further actions
✓ Provides additional resources and helpful tools for identifying and or deterring fraud.
It is critical that distributors, traders and holders of organic brands have systems and measures in place that adequately support the promise of providing organic food that people can trust. The task force expects to complete the Best Practice Guide for Preventing Organic Fraud in 2018 during which time it will also be exploring the best avenues for industry-wide adoption and implementation. If you are interested or would like to participate, please contact the author. //
Gwendolyn Wyard is the Organic Trade Association’s Vice President of Regulatory and Technical Affairs and Chair of the task force (firstname.lastname@example.org).