Sampling and testing organic products
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Date: August 2, 2017
Canadian Food Inspection Agency
Canada Organic Regime
1400 Merivale Road
Ottawa, Ontario, Canada, K1A 0Y9
1.0 Purpose and Scope
This directive specifies the responsibilities of Certification Bodies (CBs), accredited by the Canadian Food Inspection Agency (CFIA), regarding the sampling and testing of organic products.
- The Organic Products Regulations, 2009 (OPR)
- Canadian General Standards Board General Principles and Management Standards CAN/CGSB 32.310 (Canadian Organic Standards) and the Permitted Substances List CAN/CGSB 32.311 (PSL).
- The Canada Organic Regime (COR) Operating Manual
- Pest Control Products Act (S.C. 2002, c. 28)
Under the Organic Product Regulations (OPR), CFIA accredited Certification Bodies (CBs) must suspend a product's certification when the substances used in the production and processing of the product are other than those set out in the Permitted Substances Lists (PSL) or if the agricultural product comes in contact with substances other than those set out in the PSL (s.20).
Compliance in regards to prohibited substances must be verified through sampling and testing when there is a reason to suspect the presence of a prohibited substance as outlined in C.2.3.16, C.2.3.18 and C.2.3.19 of the COR Operating Manual.
The CFIA also samples and test organic products as part of its monitoring and surveillance programs for chemical residues. Through these programs the CFIA monitors the food supply for chemical residues and contaminants, and evaluates compliance with maximum residue limits (MRLs), tolerances and maximum levels established by Health Canada.
Health Canada's Pest Management Regulatory Agency (PMRA) is responsible for the registration and regulation of pesticides in Canada including the establishment of Maximum Residue Limits (MRLs) under the Pest Control Products Act (PCPA).
4.0 Requirements to be included in CB procedures for sampling and testing
Section C.7.15 of the Canada Organic Regime (COR) Operating Manual requires the CBs to document their sampling and testing requirements.
The following requirements should be incorporated by the CBs into their existing procedures to ensure consistency in the implementation of the Canada Organic Regime:
4.1 Criteria to determine which products or operations are subjected to sampling and testing
Based on a documented risk assessment, the following criteria may trigger sampling and testing:
- Type of product (e.g. susceptibility to disease or pests or usually high uses of pesticides in conventional systems);
- Local geography (e.g. lay of land, buffer areas, water supply, presence of neighbours and types of neighbouring land uses, nearby spray operations);
- Complaints or information previously received regarding the potential use of prohibited substances;
- Detection of chemical residues; or
- Signs of prohibited substances.
4.2 Description of the sampling techniques
The sampling techniques should be based on the specific commodity to be sampled including details on the sample selection, sample size, sampling equipment and sample submission. CBs should consider referring to Codex Alimentarius Commission (Codex) for information on recommended methods of sampling for the determination of chemical residues as guidance.
4.3 Sample submission information
The CBs samples should include the following information:
- Operator name and address
- Date of sampling
- Type and identity of product
- Specific location of sampling (e.g. a particular field, greenhouse, or part of a facility)
- Identifying numbers (e.g. lot number, greenhouse number, production line)
- Additional comments (e.g. reasons for suspicion of contamination)
4.4 Information on when, where and how samples should be submitted
All samples should be submitted to laboratories for testing as soon as possible but always according to related laboratory protocol. CBs are responsible for maintaining the chain of custody of samples prior to submission to the laboratories. Laboratories must hold current accreditation to ISO/IEC 17025: 2005, General Requirements for the Competence of Testing and Calibration of Laboratories and for which the scope of accreditation allows for the testing of the specific substance in food. Analytical methods used to detect the specific substance must have a limit of detection at or below 0.01 parts per million (ppm).
4.5 Documentation and record keeping
CFIA accredited CBs must maintain records to demonstrate that they conduct chemical residue sampling and testing of their operators products and follow up on chemical residue results that were forwarded to them for action.
4.6 Sampling equipment and training
The CBs are responsible to ensure that the Verification Officers (VOs) are trained on how to sample, label, and store products under proper chain of custody until samples are submitted for testing.
The CB shall ensure that the VOs are furnished with the proper sampling equipment at the time of the inspection as per specific sampling protocols provided by the laboratory.
5.0 CB Follow-up Actions on Chemical Residue Results
5.1 Follow-up on chemical residue results received from the CFIA
The CFIA forwards all chemical residue detection results from its monitoring and surveillance programs, with compounds identified that are not permitted by the PSL, to the CBs for follow-up through the Conformity Verification Bodies (CVB).
In addition to a follow-up by the CB, if residues are detected in excess of the MRL, CFIA inspection staff will follow-up on the violation.
Detections of chemical residues below the MRL are sent to the CB to follow up with the organic operator and to investigate the cause of the contamination. Based on the investigation, the CB will potentially apply enforcement actions (e.g. suspension, cancellation) as per clause 20 of the OPR.
5.2 Follow-up on chemical residue results from samples taken by the CBs
As per C.2.3.16; and C.2.3.18 and C.2.3.19 of the COR Operation Manual, when there is a reason to suspect that an agricultural input or product has come into contact with a prohibited substance, method or ingredient in the production and handling of organic products, the CB shall require pre-harvest or post-harvest testing of any agricultural input used or agricultural product to be sold, labelled or represented as being in compliance with the requirements of the Canadian organic standards.
CBs shall immediately inform the CFIA of any chemical residue result which exceeds the MRL and CFIA inspection staff will follow-up on the violation.
5.3 CB actions when chemical residues are detected below 0.01 ppm
- The CB shall inform the operator that chemical residues are present.
- At the next scheduled inspection, the CB will assess why chemical residues were present and may sample for chemical residues.
- Deliberate use of prohibited chemicals by an operator shall result in the CB initiating the cancellation process as per clause 20 of the OPR.
5.4 CB actions when chemical residues are detected at or above 0.01 ppm and at or below 5% of the MRL
- The CB shall inform the operator that chemical residues are present.
- As per clause C.2.3.18 of the COR Operating Manual, the CB will assess why chemical residues were present and shall sample for chemical residues at the operation no later than the next scheduled inspection.
- If the inspection and sampling indicate continued presence of prohibited chemicals which is not due to deliberate use, the CB shall issue a Non-conformity (NC) and request corrective action.
- Deliberate use of prohibited chemicals by an operator shall result in the CB initiating cancellation of the operation as per clause 20 of the OPR.
5.5 CB actions when chemical residues are detected above 5% of the MRL
- The CB shall immediately schedule an inspection and initiate an investigation to determine why chemical residues are present.
- As per clause C 2.3.18 of the COR Operating Manual, the CB shall conduct additional sampling as part of the investigation.
- If the inspection and sampling indicate continued presence of prohibited chemicals which is not due to deliberate use, the CB shall issue a Non-conformity (NC) and request corrective action. Products (lots) with chemical residues detected above 5% of the MRL shall lose their organic certification status.
Deliberate use of prohibited chemicals by an operator shall result in the CB initiating the cancellation process as per clause 20 of the OPR.
The CB shall report findings to the CFIA through their CVB by using the CFIA standardized reporting template.
The Operator is responsible for ensuring that their products meet The Organic Production Systems General Principles and Management Standards. A sample testing positive for one or more chemical residues may result in further testing or an inspection of the operator facilities/premises to determine their ability to be in compliance with The Organic Production Systems General Principles and Management Standards. In these cases, the Certification Body may recover from the applicant the fee payable for each inspection.
8.0 Conformity Verification Body (CVB) responsibilities
CVBs shall review the CB sampling and testing procedures and records during the on-site audit of the CBs.
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