As the organic community dives deeper into the Strengthening Organic Enforcement USDA (SOE) Rule and we approach the March 19, 2024, deadline, certified operations will need to take a closer look at portions of their organic system plans. One key component that will need attention is your fraud prevention plan.
SOE will require all certified operations to have a fraud prevention plan. Organic fraud prevention plans must include a description of the monitoring practices and procedures to be performed and maintained to verify that the plan is effectively implemented, including the frequency with which they will be performed. Your organic fraud prevention plan must describe the monitoring practices and procedures to prevent fraud and verify suppliers in the supply chain and the organic status of products received, as appropriate to the certified operation’s activities, scope, and complexity.
CCOF will soon be requesting that our clients create or review and update their fraud prevention plans as required by the Strengthening Organic Enforcement USDA Rule. Your current Organic System Plan already covers some of the elements of an organic fraud prevention plan. Some operations may already have a food safety program that can be easily adapted to cover organic fraud prevention. Other operations may already have an organic fraud prevention plan through the Organic Trade Association (OTA) Fraud Prevention Solutions Program. If you do not have an established organic fraud prevention plan yet, start brainstorming this topic now and keep a close eye out for further communication from CCOF.
The NOP has several free online courses in their Organic Integrity Learning Center (OILC) that provide more information about fraud in the organic industry and how to close the gaps that provide opportunities for fraud. While aimed at certifiers, the following courses may be helpful if you are just learning about organic fraud prevention plans: Organic Fraud and the Criminal Mind and Preventing the Organic Fraud Opportunity. There are other courses available in the NOP’s OILC that may cover topics relevant to your fraud prevention plan. Instructions for accessing the NOP’s OILC and how to register for and take courses in the OILC can be found on the USDA website.