15 Jan

Updates from the ACA and OTA Fraud Prevention Task Forces

European and US organic programs develop and implement fraud prevention and detection strategies

 

In the following, we would like to provide updates on the many activities that have been employed in the last months to improve organic integrity:

  • a general overview over activities to improve organic integrity
  • an update from the ACA Traceability Working Group
  • an update from the OTA Global Organic Supply Chain Integrity Task Force
  • an update on activities of the USDA NOP 4031

Improving organic integrity - a lot has happened in the year 2017

When it comes to organic integrity, there's a discongruence between attitude and behavior: Everyone will agree that improving integrity is of utmost importance for the credibility of the organic claim. Yet, when it comes to implementing concrete action in their business, the greater part of companies tends to move responsibility over to the “Regulator” and certification bodies. The main driver for innovation and action are scandals. This could be experienced in Italy in the past, where Eastern European fraudulent imports shook up all actors and the market, it happened in other European countries with imports from Asia and Eastern Europe with competent authorities acting on weak information, and finally in the US with – again – imports from Eastern European countries through Turkey. TRACES and NOP 4013 were triggered by fraud. But what happened in trade? Yes, internal policies and procedures were certainly improved and tightened, but a more concise and concrete implementation of fraud prevention that knits certification data and transactions together is still lacking.

That being said, in 2017, there were a lot of activities aimed at improving integrity.

  • In 2017, the EU TRACES electronic Certificate of Import (eCoI) became mandatory mid of October,
  • the USDA NOP 4013 on the integrity of organic imports became effective in October as well,
  • and certifiers’ and trade organizations continued to further develop guidance documents for their members through working groups and task forces.

ACA Traceability Working Group (NOP Accredited Certifiers Association)

 “ACAs agree that the work of organic certification has become increasingly challenging as supply chains have become more complex and organic trade has expanded on local and global levels. The ACA convened a Working Group to identify some of the biggest challenges related to verifying traceability and to offer as many solutions as possible in the form of Best Practices.” Cited from the ACA document.

As reported, Frank Gerriets of Organic Services participated in the ACA Working Group. Frank is a recognized expert in software-based quality management withv a focus on integrity and risk-based audit management.
From the various detailed recommendations (find document here) the Working Group developed, we want to highlight the below as it underlines the necessity to go beyond transaction certificate and risk management down to the field level where the supply chain begins. Unfortunately, this simple and obvious fact has not yet seen wide acceptance.
"Certifiers should ALL submit data on organic acreage reports to NOP for inclusion in the Organic Integrity Database. This would enable a clearer picture of whether or not the organic land base supports production claims on small and large scales and allow for calculation of a mass balance across the supply chain.”
“Additionally, the organic industry could implement its own data driven solution, similar to the Check Organic program used in Italy.”
In past Integrity Insiders we have reported about the Federbio Integrity Platform based on Check Organic, the real-time certification and transaction data mass balance system.

OTA - Global Organic Supply Chain Integrity Task Force
The mandate for its Global Organic Supply Chain Integrity Task Force is to develop a best practices guide to use in managing and verifying global organic supply chain integrity to help brands and traders manage and mitigate the risk and occurrence of organic fraud. The best practices guide will include a vulnerability assessment, mitigation measures, and an alert and reporting system.
As reported, both Frank Gerriets and Gerald A. Herrmann of Organic Services are participating in OTA’s Task Force.
The Task Force holds regular meetings, sometimes in a weekly rhythm. At Expo East, the Task Force held a face to face meeting. During the meeting of the NOP Accredited Certifiers Association from February 6th to 8th, at which Frank Gerriets is participating, Gwendolyn Wyard, Vice President of Regulatory & Technical Affairs, OTA, will present the following draft document: ‘A Guide to Best Practices for Ensuring Global Organic Supply Chain Integrity’ for discussion.
The Task Force also compiled a list of technological solutions that have proven, e.g. Check Organic or are promising, e.g. Blockchain to enhance integrity in supply chains.

USDA NOP 4031
The ‘Interim Instruction Maintaining the Integrity of Organic Imports’ was developed as a reaction to the scandal (2016/2017) with considerable amounts of conventional corn and soy traded from Eastern Europe through Turkey, where the trader received valid certification based on perfectly falsified documentation. Among the instruction requiring certification bodies in a very detailed manner about how to apply inspections are the following:

  • Determine whether or not the operation maintains and implements adequate procedures for verifying the organic integrity of organic products.
  • Determine whether or not the operation maintains an appropriate recordkeeping system for product traceability.
  • Certifiers must verify that an operation’s records meet … and provide a complete audit trail allowing the certifier to trace products back to the last certified handler to verify organic integrity.

In its official comments to USDA AMS NOP the ACA writes: “To make this happen, certifiers need to be willing to share information with one another for the purpose of verifying compliance, as suggested in the 6/1/2017 NOP Webinar “Organic Supply Chain – Ensuring Organic Integrity through the Organic Control System.” We believe greater emphasis on this concept directly from NOP will facilitate a greater level of information sharing, which will significantly enhance certifiers’ abilities to conduct thorough and meaningful audits.”
While it seems so obvious that certifiers share information about inspection and certification results along the supply chain with each other, this is not what is today’s reality in organic certification. It is the certificate that is, respectively has to be taken as sufficient proof of previous certification as access to more detailed data is not made accessible or data management (paper trail) makes such exchange cumbersome. In Europe, as far as we understand, it is Italy only where the Accreditor ‘Accredia’ in cooperation with certifiers developed a guidance that oblige certifiers to make such information available. This guidance was the cornerstone that enabled the setting-up the FederBio Integrity Platform (based on Check Organic) knitting certification information together in real-time on which the integrity of product transactions is based. Such information has to include that on acreage as otherwise product integrity and mass balance cannot be established.
In this context it is of great importance that ACA has made clear in its position: “Certifiers should ALL submit data on organic acreage reports to NOP for inclusion in the Organic Integrity Database. This would enable a clearer picture of whether or not the organic land base supports production claims on small and large scales and allow for calculation of a mass balance across the supply chain.”

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