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Important Changes Made to the Canadian Office's Operation Manual! Now Introducing a new OCIA service: Attestations of Compliance

In late June of 2012, the Canadian Organic Office (COO) introduced important changes to Section C11 of the Operation Manual for Accredited Certifying Bodies that could potentially affect your operation. These changes include the need for certifying agencies to verify the compliance of operations that provide contractual work for operations with certified products, where the service is not eligible for certification under Section 14 or 19 of the Organic Product Regulations (2009).

Services exempt from certification include: the slaughter of organic livestock, or the transportation and storage of organic livestock or an organic product, or other custom services performed on bulk products, where the ownership of the product remains with the original producer. Such services might include off farm seed cleaning, and grain grinding, roasting, or extrusion.

As of January 1, 2013, operations that perform these services for certified organic entities must now complete the process to receive an "Attestation of Compliance" by an accredited certifying agency. An Attestation of Compliance is a written document issued by a certification body confirming that the processing activities and services noted above fully comply with the Canadian Organic Regime standards and the Organic Product Regulations.

The process for being granted an Attestation of Compliance by a certifying body exactly mirrors the process of certification. Operations that wish to receive an Attestation of Compliance letter from OCIA must do the following:
a.) complete the appropriate Organic System Plan & Organic System Plan Annual Update
b.) supply OCIA with all the relevant documents outlined in the Organic System Plan & Annual Update
c.) successfully complete a pre-inspection document review
d.) be inspected during a time when organic products are being handled or processed
e.) successfully comply with any noncompliance follow up issues noted during a final review, and
f.) reapply for the attestation yearly if they wish to continue providing contractual services to organic operations.

Following a successful inspection and compliance review, the operation will receive an Attestation of Compliance certificate that notes the date the attestation became valid and its date of expiration, along with the types of services for which the operation has been verified compliant to provide to organic operations. Having an Attestation of Compliance certificate means that a service provider will not have to go through multiple inspections for each entity for whom it provides services, as in the past. An Attestation of Compliance certificate from OCIA will be recognized as valid by all other certifying bodies who verify compliance to the Canadian Organic Standards.

It should be noted that some operations may require both an organic certificate and an Attestation of Compliance, depending upon the scope of products and services an operation provides. For example, a slaughter operation that also provides cutting and wrapping of organic meat products will require certification for the processes of packaging and labeling, and an Attestation of Compliance for the process of slaughtering organic livestock. Another example of an operation that might require both an organic certificate and an Attestation of Compliance would be a seed cleaner who also bags and labels organic product. Organic certification is required for the packaging and labeling portion of the operation, while the seed cleaning portion of the operation would require an Attestation of Compliance. Just one inspection and review will cover the granting of both certification and attestation.

Operations will be able to request "Attestation of Compliance" as an additional program on the 2013 Organic System Plan Annual Updates provided by OCIA. The cost for an Attestation of Compliance will closely mirror certification costs, in that inspection and review fees will still be charged, but quarterly sales fees will not be applicable for operations that provide services versus those operations selling organic product.

To Summarize:

Who needs an Attestation of Compliance?
Any operation that provides contractual services to certified operators.

What kinds of services need to be covered under an Attestation of Compliance?
The slaughtering of organic livestock, seed cleaning, grain roasting, and the provision of organic product storage are all services that require attestation.

How does my operation get an Attestation of Compliance certificate?
Apply with OCIA (as you would for certification).  The process for receiving your Attestation of Compliance will exactly mirror the process for receiving an organic certificate.

For how long is my Attestation of Compliance certificate valid?
12 months.  Attestation of Compliance certificates must be reapplied for annually.

How do I know if I need an organic certificate, an Attestation of Compliance, or both?
If your operation produces & sells organic products, you need to be certified organic. If your operation provides a service, where the product continues to be owned by the original producer, it is likely that you need an Attestation of Compliance. If your operation performs packaging and labeling of any organic product, however, you will likely need both an organic certificate AND an Attestation of Compliance. If you have questions, contact OCIA International or your Regional Office for clarification.

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