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	<title><![CDATA[Grist - Comment Feed for Implications of the last organic latte]]></title>
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            <title>Comment #1 by Chris Schults</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Thu, 12 Apr 2007 04:25:12 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/1</guid>
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				<p><strong>Great research<p>Thanks Stephanie!

<p>Look out! It's a <a href="http://grist.org/cgi-bin/search.pl?query=&amp;gristtitle=%22media+shower%22&amp;gristcat=Gristmill" rel="nofollow">media shower!</a></p></p></strong></p>
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				<p><strong>Great research<p>Thanks Stephanie!

<p>Look out! It's a <a href="http://grist.org/cgi-bin/search.pl?query=&amp;gristtitle=%22media+shower%22&amp;gristcat=Gristmill" rel="nofollow">media shower!</a></p></p></strong></p>
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            <title>Comment #2 by Samuel Fromartz</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Thu, 12 Apr 2007 07:21:11 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/2</guid>
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				<p><strong>Great Reporting<p>Stephanie, thanks for looking further into this issue. The key part of internal certification was that the USDA viewed these inspectors as employees of the grower groups, rather than as independent agents accredited by the USDA. Technically, that's true (and under the organic regs, all inspectors must be accredited). <p>
But the question is whether the system worked, and I heard - as you did - that it did work and was designed for these special cases.

<p>Samuel Fromartz
Author
<a href="http://www.fromartz.com/" rel="nofollow">Organic Inc.</a></p></p></p></strong></p>
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				<p><strong>Great Reporting<p>Stephanie, thanks for looking further into this issue. The key part of internal certification was that the USDA viewed these inspectors as employees of the grower groups, rather than as independent agents accredited by the USDA. Technically, that's true (and under the organic regs, all inspectors must be accredited). <p>
But the question is whether the system worked, and I heard - as you did - that it did work and was designed for these special cases.

<p>Samuel Fromartz
Author
<a href="http://www.fromartz.com/" rel="nofollow">Organic Inc.</a></p></p></p></strong></p>
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            <title>Comment #3 by Emily Brown Rosen</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Thu, 12 Apr 2007 12:32:45 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/3</guid>
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				<p><strong>java justice</strong></p><p>Not correct, Sam. Organic inspectors are not "accredited" by USDA. &nbsp;Inspectors are contractors or emplolyees of USDA-accredited certifiers. Certifiers must demonstrate to USDA that they hire competent inpsectors with sufficient expertise, that they receive regular training and evaluation, and that they are free from conflict of interest. &nbsp;Otherwise, the certifiers could lose their accreditation. As the ruling stated "The internal inspection procedures, &nbsp;whereby each production unit is inspected, was overseen by members of the grower group who were not required to have sufficient expertise, be subject to an annual performance review or to disclose conflicts of interest." Conflict of interest will be the difficult issue to solve for any inspector hired directly by a grower group and not by the third party certification agency. </p>
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				<p><strong>java justice</strong></p><p>Not correct, Sam. Organic inspectors are not "accredited" by USDA. &nbsp;Inspectors are contractors or emplolyees of USDA-accredited certifiers. Certifiers must demonstrate to USDA that they hire competent inpsectors with sufficient expertise, that they receive regular training and evaluation, and that they are free from conflict of interest. &nbsp;Otherwise, the certifiers could lose their accreditation. As the ruling stated "The internal inspection procedures, &nbsp;whereby each production unit is inspected, was overseen by members of the grower group who were not required to have sufficient expertise, be subject to an annual performance review or to disclose conflicts of interest." Conflict of interest will be the difficult issue to solve for any inspector hired directly by a grower group and not by the third party certification agency. </p>
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            <title>Comment #4 by tad mutersbaugh</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Fri, 13 Apr 2007 00:18:20 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/4</guid>
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				<p><strong>So, to whom does this ruling apply?</strong></p><p>With respect to Emily's point, will those Mexican certifiers who DO provide full training and accreditation, and who provide the NOP/USDA with evidence that village-level inspectors have successfully completed their training, be allowed to continue certifying? </p><p>
I have read the summary, and it appears contradictory on this point. I do know that at least one Mexican certifier has told associated grower groups to keep following their (arduous and expensive) accreditation procedures. In my view, they certainly should be permitted to continue. I sat through a village inspector training course and had to work to pass the exam. And then inspectors have to prove their mettle during field evaluations. This training, at least in the case with which I am most familiar, is quite rigorous. (and not a fluke, I've seen these done since 2000). Also, this group does have inspectors sign 'conflict of interest' forms, and I know that inspectors are evaluated on an annual basis, although I have not investigated the content of those evaluations.<br>
So, I'm unsure of how far this ruling reaches (also having seen only the summary). Does it apply only to certifiers who do not meet these norms, or is it to be generally applied to all Mexican certifiers?<br>


<p>tad</p></br></br></p>
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				<p><strong>So, to whom does this ruling apply?</strong></p><p>With respect to Emily's point, will those Mexican certifiers who DO provide full training and accreditation, and who provide the NOP/USDA with evidence that village-level inspectors have successfully completed their training, be allowed to continue certifying? </p><p>
I have read the summary, and it appears contradictory on this point. I do know that at least one Mexican certifier has told associated grower groups to keep following their (arduous and expensive) accreditation procedures. In my view, they certainly should be permitted to continue. I sat through a village inspector training course and had to work to pass the exam. And then inspectors have to prove their mettle during field evaluations. This training, at least in the case with which I am most familiar, is quite rigorous. (and not a fluke, I've seen these done since 2000). Also, this group does have inspectors sign 'conflict of interest' forms, and I know that inspectors are evaluated on an annual basis, although I have not investigated the content of those evaluations.<br>
So, I'm unsure of how far this ruling reaches (also having seen only the summary). Does it apply only to certifiers who do not meet these norms, or is it to be generally applied to all Mexican certifiers?<br>


<p>tad</p></br></br></p>
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            <title>Comment #5 by Samuel Fromartz</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Fri, 13 Apr 2007 00:47:19 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/5</guid>
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				<p><strong>Noted<p>Emily, thanks for posting that correction - and for participating. (Emily works for Pennsylvania Certified Organic and has been involved with organic regs for a long time.)<p>
For those who don't know the background, the regs instituted a wall that prevented certifiers from working directly for the companies they certify. That created distance that gave integrity to certification.<p>
The question, though, as Ted points out, is whether internal inspection can be overseen in a way that has integrity.

<p>Samuel Fromartz
Author
<a href="http://www.fromartz.com/" rel="nofollow">Organic Inc.</a></p></p></p></p></strong></p>
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				<p><strong>Noted<p>Emily, thanks for posting that correction - and for participating. (Emily works for Pennsylvania Certified Organic and has been involved with organic regs for a long time.)<p>
For those who don't know the background, the regs instituted a wall that prevented certifiers from working directly for the companies they certify. That created distance that gave integrity to certification.<p>
The question, though, as Ted points out, is whether internal inspection can be overseen in a way that has integrity.

<p>Samuel Fromartz
Author
<a href="http://www.fromartz.com/" rel="nofollow">Organic Inc.</a></p></p></p></p></strong></p>
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            <title>Comment #6 by Stephanie Ogburn</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Fri, 13 Apr 2007 01:05:30 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/6</guid>
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				<p><strong>To add to that<p>Yes, thanks Emily. &nbsp;The question is also whether external inspection is intrinsically better, as Ted notes in giving the example of the external certifier who was essentially willing to be paid to deliver certification. &nbsp;In developing nations (where corruption is often high) it might be be better to have internal, true believers.<br> &nbsp;<br>
An added note: certifiers in the US also sometimes think the USDA's tendency to force this separation (that is, the tendency to say you can't be a certifier if you're also a farmer in the grower group) is overkill and highly inconvenient. One farmer I interviewed who also spun off his own certification business had a heck of a time getting his business accredited because he was a grower in the area where he'd be certifying. After jumping through a lot of hoops, he did it--but perhaps separation of interests (which is the traditional approach to addressing corruption) is not the best way to deal with potential corruption. One fix does not all problems solve.

<p>Stephanie

<a href="http://www.stephaniepaigeogburn.com" rel="nofollow">http://www.stephaniepaigeogburn.com</a></p></br></br></p></strong></p>
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				<p><strong>To add to that<p>Yes, thanks Emily. &nbsp;The question is also whether external inspection is intrinsically better, as Ted notes in giving the example of the external certifier who was essentially willing to be paid to deliver certification. &nbsp;In developing nations (where corruption is often high) it might be be better to have internal, true believers.<br> &nbsp;<br>
An added note: certifiers in the US also sometimes think the USDA's tendency to force this separation (that is, the tendency to say you can't be a certifier if you're also a farmer in the grower group) is overkill and highly inconvenient. One farmer I interviewed who also spun off his own certification business had a heck of a time getting his business accredited because he was a grower in the area where he'd be certifying. After jumping through a lot of hoops, he did it--but perhaps separation of interests (which is the traditional approach to addressing corruption) is not the best way to deal with potential corruption. One fix does not all problems solve.

<p>Stephanie

<a href="http://www.stephaniepaigeogburn.com" rel="nofollow">http://www.stephaniepaigeogburn.com</a></p></br></br></p></strong></p>
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            <title>Comment #7 by Stephanie Ogburn</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Fri, 13 Apr 2007 01:33:37 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/7</guid>
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				<p><strong>Typo<p>Sorry Tad! &nbsp;

<p>Stephanie

<a href="http://www.stephaniepaigeogburn.com" rel="nofollow">http://www.stephaniepaigeogburn.com</a></p></p></strong></p>
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				<p><strong>Typo<p>Sorry Tad! &nbsp;

<p>Stephanie

<a href="http://www.stephaniepaigeogburn.com" rel="nofollow">http://www.stephaniepaigeogburn.com</a></p></p></strong></p>
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            <title>Comment #8 by Ron Steenblik</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Fri, 13 Apr 2007 03:15:15 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/8</guid>
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				<p><strong>Good paper on barriers to developing countries<p>A couple of years ago, when I was working for the OECD, we commissioned a very good paper on barriers to developing-country organic certifiers. The paper, "Certified Organic: Reducing Barriers to Developing-Country Exports of Conformity Assessment Services", written by the then president of the International Federation of Organic Agriculture Movements (IFOAM), Gunnar Rundgren, can be found starting at page 124 <a href="http://www.oecd.org/dataoecd/19/27/36223999.pdf" rel="nofollow">here.</a></p></strong></p>
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				<p><strong>Good paper on barriers to developing countries<p>A couple of years ago, when I was working for the OECD, we commissioned a very good paper on barriers to developing-country organic certifiers. The paper, "Certified Organic: Reducing Barriers to Developing-Country Exports of Conformity Assessment Services", written by the then president of the International Federation of Organic Agriculture Movements (IFOAM), Gunnar Rundgren, can be found starting at page 124 <a href="http://www.oecd.org/dataoecd/19/27/36223999.pdf" rel="nofollow">here.</a></p></strong></p>
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            <title>Comment #9 by Emily Brown Rosen</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Fri, 13 Apr 2007 05:41:57 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/9</guid>
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				<p><strong>to whom does it apply?<p>Tad,<br>
The USDA ruling applies to all certification agencies that are accredited by USDA. (we reserve the term "accreditation" to mean the approval process of the certification agencies, in this case by USDA. IFOAM is an international accreditor) If the Mexican certifier is USDA accredited, then they are responsible for hiring, supervising and evaluating all inspectors they use. The practice has been that the certifier will inspect 20% of the grower group farms a year, and that the grower group must provide sufficient oversight of all members to make sure this is a good sampling. I'm not sure who is hiring the 'village level' inspectors you describe, but if it is not the accredited certifier, then it may not be permited, unless we can work out a better understanding with USDA of how to structure this. &nbsp;I don't think this recent announcement is really a done deal, it has not been consistently provided to all USDA certifiers yet, and may be applied in a case by case basis as certifiers are renewed. There also is a lot of interest in finding a solution that is not so draconian. <p>
There is a list of all USDA accredited agencies at <a href="http://www.ams.usda.gov/nop/CertifyingAgents/Accredited.html" rel="nofollow">http://www.ams.usda.gov/nop/CertifyingAgents/Accredited.h ...<br>
So it is easy to check if the agency is in good standing. &nbsp;Granted, there are problems with the current system of accreditation of the USDA approved agencies, but at least there is a system for oversight. <p>
Emily</p></br></a></p></br></p></strong></p>
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				<p><strong>to whom does it apply?<p>Tad,<br>
The USDA ruling applies to all certification agencies that are accredited by USDA. (we reserve the term "accreditation" to mean the approval process of the certification agencies, in this case by USDA. IFOAM is an international accreditor) If the Mexican certifier is USDA accredited, then they are responsible for hiring, supervising and evaluating all inspectors they use. The practice has been that the certifier will inspect 20% of the grower group farms a year, and that the grower group must provide sufficient oversight of all members to make sure this is a good sampling. I'm not sure who is hiring the 'village level' inspectors you describe, but if it is not the accredited certifier, then it may not be permited, unless we can work out a better understanding with USDA of how to structure this. &nbsp;I don't think this recent announcement is really a done deal, it has not been consistently provided to all USDA certifiers yet, and may be applied in a case by case basis as certifiers are renewed. There also is a lot of interest in finding a solution that is not so draconian. <p>
There is a list of all USDA accredited agencies at <a href="http://www.ams.usda.gov/nop/CertifyingAgents/Accredited.html" rel="nofollow">http://www.ams.usda.gov/nop/CertifyingAgents/Accredited.h ...<br>
So it is easy to check if the agency is in good standing. &nbsp;Granted, there are problems with the current system of accreditation of the USDA approved agencies, but at least there is a system for oversight. <p>
Emily</p></br></a></p></br></p></strong></p>
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            <title>Comment #10 by TheSSG</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Sun, 15 Apr 2007 08:51:10 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/10</guid>
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				<p><strong>This seems strange...</strong></p><p>Ok, as much as I see how this is bad, ECONOMICALLY, I would agree that moving things to EXTERNAL certifiers is a good thing.</p><p>
I'm not all about the free market, and letting companies regulate themselves. &nbsp;While any way you go, there will be corruption, I think that Government/External sources are easier to monitor and less prone to corruption.</p><p>
This is like if we let GM do all the EPA policing...<br>
Not a good idea...</p><p>
I know it sucks for the farmers, but I stil think it's a move in the right direction.</br></p>
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				<p><strong>This seems strange...</strong></p><p>Ok, as much as I see how this is bad, ECONOMICALLY, I would agree that moving things to EXTERNAL certifiers is a good thing.</p><p>
I'm not all about the free market, and letting companies regulate themselves. &nbsp;While any way you go, there will be corruption, I think that Government/External sources are easier to monitor and less prone to corruption.</p><p>
This is like if we let GM do all the EPA policing...<br>
Not a good idea...</p><p>
I know it sucks for the farmers, but I stil think it's a move in the right direction.</br></p>
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            <title>Comment #11 by tad mutersbaugh</title>
			<link>http://www.grist.org/article/java-justice/</link>
			<pubDate>Mon, 16 Apr 2007 06:55:32 -0700</pubDate>
			<guid isPermaLink="false">http://www.grist.org/article/java-justice/11</guid>
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				<p><strong>Economics, Integrity and Fairness<p>Responding to a few of the points above, I'd first like to address Emily's note about village-inspector `credentialing' (to distinguish it from the USDA usage [thanks Emily]). It is true that peasant inspectors are paid by the producer group umbrella organization, although the method of payment conforms to normative organic certification practices. Inspectors certify compliance in other villages (not their own), and the inspected group pays inspectors regardless of how the internal inspection comes out.<p>
That said, perhaps there is room for certifiers to become more directly involved in credentialing and evaluations? Emily's idea - I hope I'm not misrepresenting it -- merits serious consideration. In practice there are very few villagers who have the skills set necessary to work as inspectors (accounting, speak Spanish, speak local indigenous language, are sufficiently mobile but not likely to migrate to the US, and can pass exams to become registered with certifying agencies). Over time this group has tended to become more and more professionalized, yet their village lifeways allow them to live and work for less than urban-based professionals. Perhaps this group can be accommodated within the USDA framework.<p>
In a broader context, and as the study cited by Ron Steenblik points out (also supported by many research studies), the contemporary certification template reflects an ongoing evolutionary process and will likely develop in new directions in years ahead. Why, as Stephanie asks, should the USDA insist on idealized forms of service-provider/client separation that may not be effective at achieving organic outcomes under Mexican conditions? Even the ISO Guide 65 on certification states that certification systems may not place limits on who can be certified (section 4.1). In practice, insistence upon a costly system does this by setting a minimum farm-size such that only farms over, say, 25 hectares can afford to certify. <p>
It is my sincere hope that some middle ground may be found that can accommodate USDA concerns without placing organic certification beyond the reach of those who need it the most.<br>
Despite the strange attractiveness of ideal separation to TheSSG, the real-life effect of disqualifying Internal or Group-based certification would be to exclude tens of thousands of impoverished Mexican farmers from organic farming*. <p>
*for my economic arguments, see papers at<br>
<a href="http://www.uky.edu/~tmute2/mutersbaugh/" rel="nofollow">http://www.uky.edu/~tmute2/mutersbaugh/<p>
tad

<p>tad</p></p></a></br></p></br></p></p></p></p></strong></p>
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				<p><strong>Economics, Integrity and Fairness<p>Responding to a few of the points above, I'd first like to address Emily's note about village-inspector `credentialing' (to distinguish it from the USDA usage [thanks Emily]). It is true that peasant inspectors are paid by the producer group umbrella organization, although the method of payment conforms to normative organic certification practices. Inspectors certify compliance in other villages (not their own), and the inspected group pays inspectors regardless of how the internal inspection comes out.<p>
That said, perhaps there is room for certifiers to become more directly involved in credentialing and evaluations? Emily's idea - I hope I'm not misrepresenting it -- merits serious consideration. In practice there are very few villagers who have the skills set necessary to work as inspectors (accounting, speak Spanish, speak local indigenous language, are sufficiently mobile but not likely to migrate to the US, and can pass exams to become registered with certifying agencies). Over time this group has tended to become more and more professionalized, yet their village lifeways allow them to live and work for less than urban-based professionals. Perhaps this group can be accommodated within the USDA framework.<p>
In a broader context, and as the study cited by Ron Steenblik points out (also supported by many research studies), the contemporary certification template reflects an ongoing evolutionary process and will likely develop in new directions in years ahead. Why, as Stephanie asks, should the USDA insist on idealized forms of service-provider/client separation that may not be effective at achieving organic outcomes under Mexican conditions? Even the ISO Guide 65 on certification states that certification systems may not place limits on who can be certified (section 4.1). In practice, insistence upon a costly system does this by setting a minimum farm-size such that only farms over, say, 25 hectares can afford to certify. <p>
It is my sincere hope that some middle ground may be found that can accommodate USDA concerns without placing organic certification beyond the reach of those who need it the most.<br>
Despite the strange attractiveness of ideal separation to TheSSG, the real-life effect of disqualifying Internal or Group-based certification would be to exclude tens of thousands of impoverished Mexican farmers from organic farming*. <p>
*for my economic arguments, see papers at<br>
<a href="http://www.uky.edu/~tmute2/mutersbaugh/" rel="nofollow">http://www.uky.edu/~tmute2/mutersbaugh/<p>
tad

<p>tad</p></p></a></br></p></br></p></p></p></p></strong></p>
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