Small-Scale Solutions: Growing the Organic “Tent”

On September 5th, OCO held a webinar on ‘Small Scale Solutions’ for Organic certification in Ontario. This was the second in the #YourStandardsYourSay series, following the first on the Canadian Organic Standards review process.

Organic sales in Ontario are currently estimated at $1.6 billion, but many more producers are pursuing organic practices without officially certifying. Many smaller operations are not certifying due to lack of resources to handle paperwork and costs. Could it be possible to create more accessible regional certification options, that ensure organic integrity while growing the sector?

Experts from across the country weigh in on solutions

Executive Director Carolyn Young welcomed 5 panelists: Rochelle Eisen, BC Small-scale certification consultant and COG President, Tony McQuail of Meeting Place Organic Farm and Organic Federation of Canada Small-Scale Working Group Lead, Cameron Dale who manages the Evergreen Brickworks Farmers’ Market in Toronto, and Dave Lockman, Pro-Cert Certification Program Manager.
Hot topics included how to designate a farm as ‘small scale’ (income? acreage?…); whether to hold all producers to the same standards, or to reduce requirements and/or fees; who should set certification standards; and who is best fit to inspect. All speakers agreed on one thing: their interest in expanding the Organic ‘tent poles’ so that more operations can join. And each had their own take on how to do it.

British Columbia’s small scale solution

Starting on the West Coast, Rochelle Eisen explained BC’s ‘Low Risk’ category for businesses selling only within the province. BC has had voluntary regulation from even before the national standards existed. This meant that farmers and businesses could choose to certify using the provincial regulations (BC Certified Organic Program). This program allowed provincial certification bodies (certifying organic products traded only within the province of BC) to become accredited under Organic BC. This program did not require the same oversight and paperwork now used for certification under that Canadian Organic Regime because provincial certification bodies do not need to be ISO accredited. Because of this, BC was able to create a “low-risk program”.

In 2012, Organic BC commissioned a report to investigate solutions that would lower the burden of certification for small-scale producers in the province of British Columbia (there is also a summarized presentation of the results). Rochelle highlighted that during the consultation process many farmers made it clear that they wanted the same Organic standard for all operations, and many did not want subsidies for some groups to certify and not others. In the end it was determined that the ‘Low Risk’ certification is considered financially accessible for a robust service.

One certifier lists their criteria for the ‘Low Risk’ certification as: operations who do not export products out of their home province, whose production systems do not include both organic and non-organic crop production or organic and non-organic livestock production, have no outstanding conditions on their certification, and have had an organic certificate for the past three years. Depending on the certifier the low-cost program has a reduced cost of $400-$500, as farms will only be inspected once every three years, and 5-10% percent of these farms will receive unannounced inspections during non-inspection years. All are still expected to submit renewal applications each year which are subjected to a desk review. If there are any changes in practices, size, etc., the farm is moved back into the regular certification pool. With this option certifiers are recovering the cost of the desk review renewal process but not the cost of inspections; however, it has reduced the overall inspection costs which include time and costs of driving to properties all over the province.

BC’s new organic regulation act has existed since 2015, but was rolled out gradually until it came into full force in September 2018. Now, uncertified producers of any size in the province marketing their food or beverage products as “organic” will face the possibility of penalties, including a $350 fine.

Why is ISO certification an issue?

International Organization for Standards (ISO) is a non-governmental organization that develops international standards with its member organizations. ISO 17065:Conformity Assessment covers international requirements for bodies certifying Organic products, processes and services. it is important for certifying bodies must conform to these international standards for equivalency agreements between countries. This includes procedure, training, and administrative work allowing products to be compared. It does not make certification more difficult for the producer, but does add layers of administrative rigour – and the accompanying work and cost – for the certifier.

Ontario Small-Scale Working Group’s survey-based solutions

In 2014, the Organic Federation of Canada (OFC) conducted a cross-Canada survey of both certified and non-certified small scale producers. The OFC’s Working Group on Small Scale Organic Certification received over 250 survey responses. They found that a “one size fits all” organic certification was not feasible for small scale farmers due to the time needed for paperwork for diverse crops, small staff teams, and cost; however, respondents also said that the decision of small farmers not to certify was hindering the growth of the organic movement.

The Working Group then drafted two alternate certification models based on survey feedback, for farms that mainly sell directly to individual customers through markets, CSAs, farm gate, etc. The top two recommendation proposed were a peer-reviewed certification or pledge option to conserve resources.

“Certified Local Organic” – The Peer Certification Model:

  • Annual on-farm inspections conducted by peers.
  • Compliance with the Canada Organic Standard is verified online by a third-party certification body
  • Records and verification reports are accessible and available online
  • Annual certification costs based on gross sales of organic product.
  • Acknowledge that inspections in remote areas may be difficult to execute

“Organic Affidavit (OA)” – The Self-Declaration model:

  • Producers publicly pledge to understand and follow the Canada Organic Standard
  • Applications and pledges can be viewed online
  • Low annual certification costs
  • Acknowledge that this model may not be accepted by the wider organic producer community

Below is a breakdown of responses to the survey question asking why non-certified smaller farms were not certified:

Reason # of responses Percentage
Cost 28 23.9%
Direct Marketer/Don’t need certification for marketing 22 18.8%
Effort/Paperwork/Redtape/Time 18 15.4%
Inflexibility of Regulations 11 9.4%
Perception of restriction related to land tenure (rented and/or multiple locations) 7 6.0%
Lack of supply or cost of inputs 6 5.1%
Organic brand/regs not strong enough for benefit (or have bad reputation) 6 5.1%
Just Starting Business, not ready yet 3 2.6%
Follow organic principles/beyond organic 3 2.6%
Disillusionment with certification system 3 2.6%
Lack of organic infrastructure (grain elevator, abattoir, feedlot) 3 2.6%
Lack of information/education on regs 2 1.7%
Market Won’t Bear True Organic Cost 2 1.7%
Geography increases Cost 2 1.7%
Upcoming Retirement 1 0.9%

Innovating solutions with Farmers’ Market Customers

Cameron Dale spoke next about his project to meet customer interest in transparency at the Evergreen Farmers’ Market, while also addressing concerns of vendors about the paperwork and cost of certification. He launched a consumer survey to try to find market-scale solutions for product labelling and verification. As a result of the survey, he is overseeing a pilot project making 5 categories available for producers, which they must display signage.

Cameron thinks that “organic” is still the strongest label, but is supporting experimentation with the benefits of other options for their market.  They are currently monitoring and debriefing with farmers on how this is going.

A Certification Body’s accommodating category

Since 2015 Pro-Cert Organic certifiers have been piloting a ‘Local Organic’ certification for produce in Ontario, for farms with under 10 acres of dedicated land. Dave Lockman explained that this certification costs $300 per year, plus $50 for an inspection every second year.  This option is limited to producers growing crops, who only sell within the province they are growing in, who sell directly to the end user, and who are located in a province without organic regulation. To reduce administrative costs and lower the certification price, Pro-Cert has opted to not have this meet ISO 17065 level requirements, as well as eliminating:  the 15 month wait for certification, reporting to CFIA or creditors, following up on complaints. Dave noted that although the program has been pared down, the fees for producers still don’t cover the costs of running the program.

This unique program started in 2015 with 4 businesses, increasing to 17 in 2016, then 18 in 2017, and then down to 9 this season.  Dave thinks that numbers this season were lower due to a few producers switching to the full Canadian Organic Regime program, and others leaving due to paperwork and record-keeping requirements and costs still being a challenge.

Where’s the best place to start for an Ontario small-scale solution?  

At the federal level, Rochelle asserted that the only way to incorporate change is to update the CFIA operating manual with a new ‘low-risk’ category and assessment tools; this would give certifiers meeting ISO standards the tools they need.  She also suggested surveying certification bodies to see what they think, and what services they could sustain profitably.

This could help to glean wisdom from the experience of Pro-Cert, who have found that smaller operators selling direct are a unique category with complex operations and are one of the most labour intensive clients.  Dave suggested that what is needed is a system that would allow certifiers to be able to decide what is important to certify for this type of operator.

Tony advocated for working with certifiers and the current federal system, or ensuring that if regulation at that level was changed it would reduce – or at least not further burden – producers with workload and costs.  

An audience member also highlighted that in 2020 the European Union will allow a new low-risk category for Organic certification which requires bi-annual inspection, and wondered if their regulation could be used as a starting point.

Tune in for the next webinar in the #YourStandardsYourSay series on November 7th at 12pm: Something Fishy About Aquaponics?

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