USDA Organic Regulation 205.201 (a)(3) has been updated to indicate the Organic System Plan must include “…description of the monitoring practices and procedures to verify suppliers in the supply chain and organic status of agricultural products received, and to prevent organic fraud, as appropriate to the certified operation’s activities, scope, and complexity;”
In the future, OCIA will be asking operations to provide their organic fraud prevention plan as part of their Organic System Plan. Such plans take time to develop and require multiple departments in your organization to work together, and all operations must be compliant with this change in the regulation by March 19, 2024.
The preamble to the Strengthening Organic Enforcement (SOE) regulation indicates:
As a best practice, a robust plan for supply chain oversight and organic fraud prevention may include:
- A map or inventory of the operation’s supply chain that identifies suppliers;
- Identification of CCPs in the supply chain where ORG fraud or loss of ORG status are most likely to occur;
- A process to verify suppliers and minimize supplier risk to organic integrity;
- Practices for verifying the organic status of any product they acquire and/or use;
- A vulnerability assessment to identify weaknesses in the operation’s practices and supply chain;
- Mitigation measures to correct vulnerabilities and minimize risks;
- Monitoring practices and verification tools to assess the effectiveness of mitigation measures; and
- A process for reporting suspected organic fraud to certifying agents and the NOP.
Vulnerability Assessment and Control Plans are required under GFSI, FSMA, BRC, SQF, and FSSC 22000, so your operation may have similar plans in place that can be a model for an organic assessment.
There are some good resources available for operators:
- Free online course: Developing an Organic Fraud Prevention Plan MOOC online course: https://foodfraudpreventionthinktank.com/courses/developing-an-organic-fraud-prevention-plan-mooc-ota0/
- OTA’s Organic Fraud Prevention Program, which includes some templates and a guidebook: https://ota.com/OrganicFraudPrevention
The Strengthening Organic Enforcement rule can be found online here: https://www.ams.usda.gov/rules-regulations/strengthening-organic-enforcement