Crop Production - Questions and Answers Regarding National Standard on Organic Production Systems

The Canadian Food Inspection Agency, in partnership with the Organic Federation of Canada, has developed the Organic Standards Interpretation Committee (SIC). The objective of the Committee is to provide, to the Canada Organic Office, interpretive guidance on issues related to the National Standards for Organic Agriculture (CAN/CGSB 32.310 and CAN/CGSB 32.311).

These are the final answers to questions raised by organic stakeholders, regarding the National Standards for Organic Agriculture. Any further clarifications related to these questions and answers can be sent to the Canada Organic Office. The numbers found in brackets at the end of each question are reference numbers used by CFIA staff for tracking purposes. Please quote the reference number when sending in your query.

Can parallel production be allowed if management to avoid co-mingling is documented? (1)

No. The intent behind the present standard (Section 5.1.2) is a prohibition on parallel production of non distinguishable crops on the same enterprise. Post harvest operations are not subject to this prohibition (Reference: 5.1.2).

Can seeds be considered an input as opposed to a crop, for the purpose of allowing seed companies to practice parallel production? (2)

No, because in the current Standards, seeds are not listed in the definition of inputs (Reference: 5.1.2).

Are there any exceptions to the rule against alternating between organic and non-organic production outlined in Section 5.1.6? (6)

The intent to section 5.1.6 is to prevent deliberate abuse. There are cases where an operator may cease organic production and then transition again to organic which are clearly not deliberate. Cases such as these are not clear violations of section 5.1.6.

Does the requirement, in 5.1.1, that land be in compliance with the Standard for 12 months prior to harvest apply to new fields added to an existing application? (8)

The specific requirement of 5.1.1 for a production unit to have a full 12 months of supervision by a Certifying Body before a harvested crop, is intended for new operations. Existing operators adding fields to their management must demonstrate compliance with all other aspects of transition, including withdrawal periods for prohibited substances. (Reference: 5.1.1)

Is the buffer zone around treated posts permanent or transitional? (12)

The standard does not prescribe any buffer zone surrounding treated fence posts. This must be determined on a case by case basis.

Are seeds produced on buffer strips able to be planted in organic fields? (17.1)

Seeds grown on buffer strips under the Standards are the same as those grown on conventional farms (see 5.1.5). Exceptions to the use of organic seeds are specified in section 5.3.2.1 (Reference, 5.3).

Can non-organic common seed be used if organic common seed is not available? (17.2)

For the purposes of 5.3.2.1, common could be considered a varietal distinction subject to the exceptions to the use of organic seeds. See also section 3 Definition of commercial availability.

Can a farmer irrigate land from an irrigation system that uses Magnicide? (19)

Active substances included in Magnicide are not allowed for application to organic production units. If equipment that has been in contact with prohibited substances is thoroughly cleaned and can be shown to be free from such substances, it may be used to irrigate organic farms. Although irrigation equipment is not specifically mentioned in the standard, the principle outlined in 5.6.3 should apply.

Does the use of a "peat moss/compost etc. mix" satisfy the requirements of 7.5.1 for "a container system with soil"? (25)

Section 7.5.1 allows for container grown production with soil and prohibits hydroponics and aeroponics. In hydroponic production the soil is replaced by an inert substance. A compost and peat moss mixture does not constitute an inert substrate thus satisfies the requirements of a container system with soil.

Is parallel production allowed in greenhouse production? (57)

No. Under the standard, parallel production is prohibited in greenhouse production. All of the crops dealt with in section 7 are subject to the prohibition on parallel production contained in 5.1.2.

What are the effects regarding certification, of an unintentional spill of plastic pellets onto and organic field? (67)

The standard requires 36 months transition after the application of a prohibited substance by the operator (5.1.1 - 32.310). Unintended contact is covered under 5.1.4. Depending on the nature and extent of contamination, buffer strips around the contaminated zone and/or a transition period may be reasonable ways of maintaining the organic integrity. A prescriptive solution that applies universally to all cases of potential contamination is not possible, but in every case the degree of risk must be assessed and every attempt must be made to mitigate the negative impact on the final product. (see organic principles III- organic practices paragraph 5)

Is it parallel production if the same seedling type production is separated by time? (57)

The growing of visually indistinguishable crops (organic and non-organic) non simultaneously does not constitute parallel production. This rule applies equally to all field crops and greenhouse production, including seedlings.

Is the prohibition on hydroponics applicable only to greenhouses, or to all types of crop production? (74.2)

The prohibition of hydroponics is universal and not limited to greenhouses. See section 5.4 - 32.310.