Canada Organic Regime Operating Manual
Part F Requirements for Grower Group Certification of Organic Product Under the COR

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F.1 Objective

This section outlines the requirements for obtaining group certification under the Canada Organic Regime (COR) to allow grower groups to participate in the COR.

F.2 Requirements for Grower Group Certification Under COR

F.2.1 Requirements for Multi-site Organization

  • F.2.1.1 The multi-site operation composed of production units, sites, or facilities, shall be organized as a "person" according to Section 12 (1) of OPR. Pursuant to the section 2 of the Canada Agricultural Products Act, a person is defined as meaning "an individual, a corporation, an association or an organization."
  • F.2.1.2 The grower group may be organized on itself i.e. as a co-operative, or as a structured group of producers affiliated to a processor.
  • F.2.1.3 All members of the grower group shall apply similar production systems and should be in geographical proximity.
  • F.2.1.4 The grower group shall be established formally, based on written agreements with its members. It shall have central management, established decision procedures and be a legal entity.
  • F.2.1.5 The grower group shall have in place an effective and documented internal control system.
  • F.2.1.6 The management of the grower group shall sign a written contract with the CB specifying the responsibilities of the grower group and of the internal control system. The management shall obtain signed obligations from all grower group members to comply with the Canada Organic standard and to permit inspection by the CB, the CVB or the CFIA.
  • F.2.1.7 The grower group shall only seek certification with aCB accredited by CFIA under the COR that is qualified to perform certification of operations with multiple production units, sites, and facilities and. A CB shall be considered qualified if they have policies and procedures to verify compliance of the group and the individual group members. The CVB shall assess the ability of the CB to perform the group certification.
  • F.2.1.8 The practices of the grower group operation shall be uniform and reflect a consistent process or methodology, using the same inputs and processes.
  • F.2.1.9 Participation in the grower group shall be limited to those members who market their organic production only through the grower group, unless the member is individually certified.

F.2.2 Requirements for Internal Control System

  • F.2.2.1 The grower group shall document and implement an Internal Control System (ICS), with supervision and documentation of production practices and inputs used at each sub-unit, and collected at each production unit, site, or facility to insure compliance with the Canada Organic Regime.
  • F.2.2.2 The internal control system shall include a contractual arrangement with each member of the grower group.
  • F.2.2.3 The internal control system shall be implemented by competent personnel and internal inspectors designated by the grower group shall carry out internal controls.
  • F.2.2.4 The internal inspectors shall be suitable trained and ensure that potential conflicts of interest are limited.
  • F.2.2.5 The internal inspectors shall carry out at least one annual inspection visit to each individual operator including visits to field and facilities.
  • F.2.2.6 The internal control system shall contain appropriate records including:
    • F.2.2.6.1 production description, production and/or preparation specifications for products to which the application applies;
    • F.2.2.6.2 maps, description of the farms and the facilities of all members;
    • F.2.2.6.3 list of inputs (ingredients and agricultural substances);
    • F.2.2.6.4 a copy of organic production and/or preparation plans;
    • F.2.2.6.5 remedial actions required by the CB during the previous certification cycle, as well as any corrective measures implemented by members concerning these requests;
    • F.2.2.6.6 a complete list of group members.
  • F.2.2.7 The internal control system shall have a mechanism to remove non- compliant group members from the list.
  • F.2.2.8 The internal control system shall record all non-compliances as well as the corrective actions imposed with agreed time for completion.

F.3 Certification Process

F.3.1 Initial Certification

  • F.3.1.1 The CB shall evaluate the effectiveness of the internal control system to assess compliance of all members with the requirements set out in CAN/CGSB 32.310 and CAN/CGSB 32.311.
  • F.3.1.2 The certification inspection of the grower group by the CB shall include an assessment of the risks to organic integrity within the grower group and the environment in which it functions. A sample of all sites under the grower group's responsibility shall be subject to inspection visits by the CB.
  • F.3.1.3 The percentage of group members subject to the initial and the annual certification inspection shall be based on the results of a risk assessment. For normal risk situation, it shall not be lower than the square root of the total number of units under the responsibility of the group. If the risk is higher than normal, the resulting number of the preceding formula shall be multiplied by 1.2, whereas with a high risk, it shall be multiplied by 1.4. Factors to define the risk shall include:
    • F.3.1.3.1 factors related to the magnitude of the grower group
      • Organisation size and sites' size
      • Value of the products
      • Numbers of years the grower group has functioned
      • Number of new members registered yearly
      • Staff turnover
      • The management structure of the internal control system
    • F.3.1.3.2 factors related to the characteristics of the grower group
      • Variations in the product systems
      • Risks for intermingling and/or contamination
      • Geographical dispersion of the sites
      • Degree of uniformity among the production units, sites or facilities
    • F.3.1.4 The CB shall assign VOs who have appropriate training on inspection of internal control systems.
    • F.3.1.5 During the certification inspection the VO shall determine whether:
      • F.3.1.5.1 all internal control documentation is in place;
      • F.3.1.5.2 internal inspections of all group members have been carried out annually;
      • F.3.1.5.3 new group members are only included after successful resolution of any non-compliances found during the internal inspection, according to the procedures agreed with the CB;
      • F.3.1.5.4 all non- compliances have been dealt with appropriately by the internal control system;
      • F.3.1.5.5 inspection records have been maintained by the internal control system.
    • F.3.1.6 The VO shall carry out a witness audit to determine whether the inspections of the internal control system are conducted as written.

F.3.2 Maintenance of Certification

  • F.3.2.1 Each year the CB shall define and justify a risk-based sample of members subject to annual inspection.
  • F.3.2.2 The members visited by the CB shall be predominantly different from one year to another. Some of the selection criteria of the sites being subject to visits may include:
    • Results from internal control system inspection;
    • Complaint files;
    • Significant variations of the sites' size;
    • Modifications since the last certification.
  • F.3.2.3 The CB shall increase the number of the annually inspected members to at least three times the square root of the number of the members in the grower group in cases of high risk situations (e.g. ICS has issued lot of internal sanctions , a lot of new grower members).
  • F.3.2.4 The CB shall ensure that the grower group maintains an updated list of all members and informs the CB in timely manner any time when changes to the status of the members occurs.
  • F.3.2.5 The CB shall ensure that the grower group has established procedures for adding new members to the grower group.

F.4 Records

  • F.4.1 The CB shall ensure that the grower group has record-keeping protocols for the individual production units, sites, or facilities within a grower group.
  • F.4.2 The CB shall maintain records of sample inspection to ensure that over time the inspections are representative of the grower groupas a whole and take into account any previously identified risk.

F.5 Certification Documents

  • F.5.1 The CB shall provide certification documents to the grower group as a whole. Members within a grower group that has had its operations or product certified cannot not possess individual certificates unless that member has obtained its own certification independent from the grower group.

F.6 Suspension and Cancellation

  • F.6.1 The CB shall hold the grower group as a whole responsible for compliance of all members.
  • F.6.2 The CB shall have a documented suspension policy in the event of non-compliance by the grower group or a member.
  • F.6.3 The CB shall suspend or cancel the certification granted to the grower group as a whole, in accordance with Section 21 from the Regulations, in cases where the grower group's internal control system fails to act on these non-compliances.
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