One of the most common sources of frustration for certified operations is being issued Notices of Noncompliance for minor paperwork issues, such as using an OMRI-listed material without first having written approval from CCOF. Our staff is committed to finding ways to work better with clients to prevent such problems and reduce the paper chase postinspection. A new idea that we are introducing is the CCOF Client Compliance Agreement. The CCOF Client Compliance Agreement can be quickly completed during your inspection and submitted directly to your inspector, who will include it in your inspection report to CCOF. If your CCOF inspector has identified one of the situations listed below as a potential cause for concern during your inspection, you can use the agreement to bring your operation into compliance quickly and painlessly. Situations where the CCOF Client Compliance Agreement may be applicable include:
- Use of an acceptable material not on the approved Organic System Plan Materials List
- Use of an organic product supplier not on the approved Organic System Plan, or failure to have a current organic certificate on hand
- Not having some minor records available at inspection
While these situations do not put the organic integrity of your product at risk, we may be forced to issue a Notice of Noncompliance (you will need respond in writing after your inspection) if they are not addressed during your inspection. Instead, CCOF wants you to be able to remedy the situation sooner and more effectively while our inspector is there in person. This agreement asks you to acknowledge that you understand the situation and will ensure compliance in the future. We want to improve the certification process, address issues in person, and provide simple and coherent mechanisms to communicate with you. However, please remember that CCOF inspectors do not make final certification decisions and additional areas of concern or noncompliance may be identified by CCOF after your inspection. While minor issues may be addressed by completing the CCOF Client Compliance Agreement at inspection, major or repeated issues will continue to result in Notices of Noncompliance and/or the need for an additional onsite inspection. CCOF staff continues to look for ways to make the certification process more cooperative and less confrontational. While we are bound to uphold the regulations set forth by the federal government, we believe that we can find ways to approach certification that continue to uphold the highest level of integrity for farmers, processors, and consumers by focusing on the practices of certified operations more than the paperwork generated to document those practices. We appreciate your feedback on how we are doing!