Page 56 - Breeding and regulatory opportunities, Renaud

Chapter 2

for compliance to growers by stating that growers should justify to certiiers

their need to use non-organic seed through a description of their site-speciic

agronomic conditions and/or marketing considerations. Furthermore, growers

were required to provide written evidence to certiiers that they had contacted

at least three organic seed suppliers before requesting non-organic seed, and

to provide written description to certiiers of variety trials that had compared

organic with non-organic seed of the requested variety. For their part, certiiers

were required to annually evaluate the documentation from growers, enforce

the organic seed requirement on growers and on commercial operations that

purchased organic produce from growers, and ile a report listing the seed

varieties for which they had granted exceptions.

In 2007 and 2008, the NOSB released additional draft revisions of the guidance

document successively broadened the allocation of responsibilities among the

NOP, growers and the certiiers (ACAs) for enforcing compliance (NOSB, 2007;

2008ab). The drafts proposed that the relevant information could be more

efectively managed if certiiers were provided with a list of the non-organic

seed the growers used, with details of any issues relating to the equivalency of

organically grown and conventionally grown seed varieties, and information

concerning the growers’ need for speciic agronomic or market traits. The NOSB

proposed that the information be passed to an independent third party for

publication in a national database, and that certiiers maintain and submit upon

request to the NOP copies of growers’ lists of seed varieties for the crop varieties

permitted by each agency (NOSB, 2008ab). Failure to comply would place the

certiiers in violation of their responsibility, rendering them liable to loss of their

status as certiiers. In 2008, the NOSB approved the draft recommendations

but requested that the committee further ‘redistribute the burden’ of data

collection and reporting to a broader stakeholder group.

The inal NOSB recommendations submitted to the NOP in 2008 included

new language on the monitoring of an individual growers’ percentage use of

organic seed as a tool for assessing ‘good faith efort’. Documentation of the

levels of organic seed usage and evidence of improvement in the percentage

versus total seed usage by the ACA’s clientele should be audited as part of the

NOP accreditation review (NOSB, 2008c). The recommendations strengthened

NOP’s role in training certiiers on the seed rule and on the recommendations.

38