Organic Broadcaster

Protecting organic integrity: Too little, too late?

By Harriet Behar, MOSES

Recently, there have been numerous negative articles questioning the integrity of organically labeled products in the U.S. marketplace. The Washington Post did in-depth investigative reporting on three topics: imported livestock non-organic feed grains that were sold as organic; a dairy producing a significant amount of organic milk that was not providing pasture as required by the organic regulation and their certification agency, which was not doing its due diligence in oversight; and, algal oil DHA that is still allowed in organic milk products even though 7 years ago the National Organic Program stated its use may not meet organic regulations. No further information has been provided since then by the NOP and this algal oil is still present in organic milk.

Those of us in the organic world never want to see these types of articles. The vast majority of organic producers using the USDA organic seal are following the rules, and should be proud to own an organic certificate. We are rotating crops, providing healthy pastures, providing pollinator and beneficial insect habitat, protecting soil and water quality, keeping up with the paperwork and working diligently to continually improve our operations to leave them in better condition for the next generation.

It should not surprise us, since the non-organic food system suffers from poor supply management and faltering growth leading to lower prices, that some may be see the organic label as “easy pickins” for committing fraud.

For many years, MOSES and other organizations have been pushing the National Organic Program to both tighten up its enforcement capabilities and its accreditation program. This accreditation covers both the organic certifiers as well as the oversight of the National Organic Program itself.

It is true that the NOP has greatly improved review time of the ever increasing number of complaints that come into its office. However, it has not improved its overall system, especially in detecting fraud without a specific complaint.

It is time to recognize organics is a big enough player in the food system that we are an attractive target for fraud because our systems are not tight enough to prevent it.

In Europe, there has been an Anti-Fraud Initiative since 2007 ( Its members include all sectors of the organic supply chain, from farmers to processors, manufacturers and distributors, as well as certification bodies. The members have met around the European Union for 10 years to create awareness within the trade of how traceability of products and transparency of certification activities and audits improve organic integrity. This group stresses that the entire supply chain holds responsibility for protecting the organic marketplace from fraudulent sales of organic products. The development of various controls, management and oversight across numerous countries and languages has been a challenge, but the discussion and education on this topic has increased verification and accountability.

The U.S. trade and the NOP have known about this initiative for many years, and even though we are one of the largest organic markets in the world, we did nothing to address the issue of fraudulent organic products in our country.

The Organic Trade Association announced recently, after the Washington Post’s articles, that it will be convening an anti-fraud task force to develop a best-practices guide for importers to use when verifying international imports of organic goods. While it’s good to address this weak link in our organic food supply chain, perhaps at some point this group will also look at the domestic supply chain and develop strategies for verifying organic integrity there as well.

There are many instances where buyers and sellers of organic produce, grains, meats, dairy and more could have more transparent and trackable documentation. Systems that provide trust that the documentation is legitimate also need to be implemented. Hopefully, this OTA task force will look to the work of the European group, and learn from its decade-long discussion on this topic, especially since we seem to be coming late to the show.

While it is a good thing that the trade is taking some responsibility for this, the task force membership and discussions unfortunately are not open to the entire organic community, nor is it clear how it will develop recommendations. OTA can do a better job by following the transparent nature of the EU organic integrity network. The NOP should work with the National Organic Standards Board on this issue, which would bring public input and transparency to the process.

The NOP is considering electronic certificates to provide real-time verification. This type of organic import certificate has been required for many years by the EU and other countries. The U.S. customs agents at our port of entries have little to no understanding of organic standards.

When there are unusual trends, such as large shipments of imported organic corn and soybeans taking over the U.S. organic marketplace within a year, no one at the NOP seems to notice—even when it is brought to their attention! A large organic dairy appears not to be meeting the organic pasture regulation, and its certifier provides little to no oversight even after the operation was cited for not meeting the NOP rules.

It is time for the organic community and the National Organic Program to reassess current oversight of fraud, and rebuild the system of accountability to reflect the fact that organic is a ripe target for those who want to make an extra buck without doing the work to deserve it.

There are numerous activities the NOP could implement now, and others that will take some time. The electronic certificate system for organic verification should be as tight as technology will allow. If the accreditation of an organic certifier is revoked by another accreditation body, such as the EU, the NOP must immediately review this action and follow suit if warranted. This has not occurred in the past and is something that the NOP could implement on its own. When there is a surge of imports, or any other marketplace anomaly, it should trigger an automatic investigation. Again, this is something the NOP can do now without approval by congress.

There are other partners within the U.S. government that could be leveraged to help the NOP ensure organic integrity. The Global Agricultural Trade System, operated by the USDA’s Foreign Agricultural Service, must be updated to track imports of all organic products, instead of the few it does now.

Without current data, trends and anomalies cannot be tracked. At our borders and ports of entry, there are automated tracking systems that provide information to personnel on each type of import. These need to be updated to include organic-specific information and questions that must be answered before imported products are sold as organic in the U.S.

Domestically, oversight of certifiers and the NOP’s accreditation program, as well as its own operations needs to be tightened up as well. True oversight mandated in the Organic Food Production Act and the NOP regulations through a Peer Review Panel should be implemented. This should include continuous oversight from year to year, and accountability that deficiencies are transparent to the public and the corrective actions are taken.

Accountability like this is required of all certified organic operations, and must be implemented by everyone from the bottom to the top of the organic supply chain. This oversight should be embraced by the NOP now—we no longer have the luxury to procrastinate. Certifiers must be held accountable to consistent implementation of all aspects of the regulation, and the NOP cannot let items languish while the marketplace questions the legitimacy of ingredients or activities on organic operations.

Those of us who have been certified organic for many years on our own operations have seen both the standards and the accountability required by our organic certifier become tougher and more comprehensive each year. We should expect no less of the National Organic Program.

Continuous improvement must be incorporated into all the NOP and USDA do. The status quo is failing the organic sector and must be changed. Consumer trust in the organic label is one of our most important assets. All sectors must do everything they can to overcome this bad press by moving ahead with comprehensive solutions.

Harriet Behar is the senior organic specialist at MOSES, runs a certified organic vegetable and herb farm, and serves on the National Organic Standards Board.

From the July | August 2017 Issue

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