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Canadian Food Inspection Agency peer review report on Switzerland's organic system – 2017
11. Observations and recommendations

The FOAG was invited to comment on the recommendations listed in the table below and to provide details on their intention to implement them in the table included in Annex A:

The CFIA's observations and recommendations on the peer review of Switzerland's organic program
No CFIA observation CFIA recommendation
1. The CFIA team observed that the CBs rely and trust independent organizations to generate a list of approved inputs which lists various trade names however there is no contractual agreement between these parties. Consider developing requirements for contractual agreement between the domestic CBs and the parties involved in the input assessment to protect liability in the event of an issue such as the presence of a prohibited substance which was not properly assessed by these independent organizations.
2. The CFIA team observed that the categorization of and timelines to address the NCs vary between the two CBs as well as between farmers and processors. The sanction catalogue used by the CBs for the farmers differs from the catalogue used for the operators because the farm system is linked to the Swiss subsidy program. Consider working with the domestic CBs to defining the NC issued to the operators and the timelines to address them.
3. The FOAG classifies the findings of surveillance activities as recommendations and non-compliances while the SAS issues non conformities (major and minor). The CFIA team noted that the timeframe in which CBs must address these findings is not standardized Review the current NC definition and how these are handled by the SAS.
4. Currently, the FOAG does not issue any formal letter of recognition to the CBs, nor do they have the authority to suspend or cancel the accreditation of a CB. Review the FOAG oversight process for approving the CBs to ensure that the FOAG has the legal authority to suspend or cancel the authorization of the CBs.
5. Currently, the FOAG does not issue any formal letter of recognition to the CBs. Consider formalizing the legal relations between the FOAG and the domestic CBs.
6. The FOAG classifies the findings of surveillance activities as recommendations and non-compliances while the SAS issues non conformities (major and minor). The CFIA team noted that the timeframe in which CBs must address these findings is not standardized. Consider developing a standardized timelines for the domestic CBs to address the observations made by the FOAG as part of their surveillance activities.
7. Once recognised, the international CBs are required to provide annual reports to the FOAG. The CFIA team observed that the FOAG does not evaluate these reports. They are just verified for completeness. Consider developing means to supervise the work of the international CBs including evaluation of the CBs' annual reports.
8. The CFIA team noted that the CB involvement in an investigation when chemical residues are detected in organic products at retail level is very limited although they are the expert in certification Evaluate the needs to involve the domestic CBs in the investigation of chemical residues currently led by the CAs
9. The CFIA team noted that the CB involvement in an investigation when chemical residues are detected in organic products at retail level is very limited although they are the expert in certification Consider training the CAs and the CBs in the light of the new Food Law as relates to follow up on chemical residues
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