Aims :

Establish clear rules for pesticide testing of organic food and crops, to safeguard equal treatment of all operators and increase consumer trust in organic products.

Background :

Frequent pesticide testing by certification bodies is, on the one hand, expected by handlers, retailers, and consumers. On the other hand, it may be a disadvantage for the respective certifier, because it causes considerable costs.

Normative framework :

NPOP:

Chapter 4 B 8.5 Analysis and Residue Testing

Testing is a major instrument for organic certification, provided it is done by competent institutions accredited as per ISO 17025 having appropriate facilities for quality testing…

NOP:

§ 205.403 (c) The on-site inspection of an operation must verify:

(3) That prohibited substances have not been and are not being applied to the operation through means which, at the discretion of the certifying agent, may in-clude the collection and testing of soil; water; waste; seeds; plant tissue; and plant, animal, and processed products samples.

§ 205.504 A private or State entity seeking accreditation as a certifying agent must submit …

(6) A copy of the procedures to be used for sampling and residue testing pursuant to § 205.670.

Terms, clarifications, abbreviations :

Pesticides: all plant protection products not listed in NPOP and the National List (NOP).

Policy :

General determination:

Contrary to some media or consumers, we do not consider pesticide testing the most important tool for controlling organic operations. Nevertheless, in order to establish a high quality level, we will do sampling for pesticide testing with a relatively high frequency. Increased residue testing at the producer level will reduce the need for testing at the importer or processor level, and thus increase the producer’s competitivity on the organic market.

Normal situation:

In all cases except those mentioned in 5.3, samples for pesticide testing will be taken only in case of suspicion.

Sampling frequency for special crops, according to risk:

The following figures stand for percentages of growers (in case of smallholder groups) or fields (in case of individual farms) in a country or region, where samples should been taken within one growing season.

Adaptations:

The sampling frequency shall be higher in case of big operations with a large quantity of products, in case of high-value products and of very significant price differences between the organic and the conventional market. In general, sampling shall be more frequent during the first years of certification. If considerable residues are found with high frequency, the above-mentioned percent-ages shall be increased. If no or only very low residues are found, percentages can be decreased, at least during a certain period.

Sampling by the operator:

In case of operators with a good and reliable quality management, where the operator takes a suffi-cient number of samples, using reliable procedures, ADITI needs not do any sampling on its own. The operator must give ADITI access to sampling protocols and testing results. ADITI will accept these results only in case of testing by an accredited or otherwise reliable laboratory.

Payment:

Under NPOP, the operator has to pay for sampling and testing. To avoid inadequately high costs for particular operators, ADITI will take care that at similar operations with similar risks, the same number of samples is taken throughout the years.

Under NOP, ADITI will carry the cost for sampling and testing. To cover these costs, the overall flat fee for NOP certification has to be somewhat higher than for NPOP certification.

Release of the test results:

The test results are evaluated by the responsible technical staff who will take appropriate action in case of necessity.

A copy of the test results is always forwarded to the operator. If the operator was NOP certified a copy of the test result is also forwarded to the USDA-NOP.

The test results are filed in a separate section of the operator’s folder at the ADITI office.