CCOF has recently released a new version of Manual One: A Guide to CCOF Certification. This improved version includes several updates and clarifications regarding CCOF processes and procedures. The updated manual also includes key legal protections for CCOF and requires that CCOF clients involved in Adverse Action appeals and other legal proceedings, such as subpoena requests, pay CCOF legal and staff time costs. These changes are intended to protect CCOF and CCOF clients by ensuring that CCOF has the necessary resources to provide excellent service to all clients. Key sections that have been updated include:
- Definitions: Clarifications and standardization of terms between CCOF and the National Organic Program.
- 1.2.4 Private Label Entities: Clarification and updates to this section, removal of redundant section.
- 1.3 Overview of CCOF Certification Manuals: Clarification of availability of CCOF Manuals. Notification that CCOF reserves the right to modify these manuals at its discretion. Applicants and clients are required to meet the requirements in the most current Manuals.
- 1.3.1 Additional Resources: Clarification regarding OMRI Generic and Product Lists availability as additional resources, but not formal CCOF manuals.
- 2.2 Application Review and Cost Estimate: Updates reflecting current practices regarding Regional Service Representative (RSR) assignment and inspection process.
- 2.5.1 Continuation of Certification Procedure: Updates reflecting current renewal processes and post-inspection review outcomes.
- 2.5.2 Withdrawal of Certification: Clarification to allow formal, verbal certification withdrawal process.
- 2.7.1 & 220.127.116.11 Noncompliance and Correction of Noncompliance Procedures: Clarification of noncompliance process and reasons for issuing noncompliances, updated to reflect NOP requirements.
- 18.104.22.168 False Labeling and Misrepresentation of Organic Status: Title modified to include misrepresentation of organic status in addition to labels so that web and other representations are covered. Civil penalty notification updated to reflect current $11,000 fee level.
- 2.11 Indemnification: Requirement to indemnify CCOF against legal claims.
- 4.8.6 Fees for Other Services: Updates reflecting current billing rates for technical services such as subpoenas, documentation research, and other requests.
- 4.9 Complaint, Investigation and Adverse Action Fees: Requirement that CCOF clients are responsible for reimbursing CCOF for all costs incurred by CCOF as a result of adverse actions, investigations, and legal issues involving the applicant or client. Ensures that costs associated with appeals and meditations in which CCOF prevails are the responsibility of the operator. These measures will ensure that CCOF clients in good standing are not forced to pay for the significant time and expense associated with appeals and subsequent formal administrative proceedings at the State or Federal level.
A copy of the new manual can be found by visiting our Standards & Program Manuals page or by contacting CCOF and asking to have a copy sent to you free of charge. If you have questions or comments, please contact Jake Lewin, Chief Certification Officer, at firstname.lastname@example.org.