Canadian Food Inspection Agency peer review report on Switzerland's organic system – 2017
Annex A: Summary of the FOAG's action plans/comments to the CFIA's recommendations from the Canadian Food Inspection Agency peer review report on Switzerland's organic system - 2017
|No||CFIA recommendation||FOAG's action plans|
|1.0||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.||In case of a damage resulting from an error in the FiBL input list, general liability law provisions would apply. However, at the occasion of the next annual office audits, FOAG shall instruct the two domestic CBs, which do inspection of farms, to develop requirements for a contractual agreement between the FiBL and them.|
|2.0||Consider working with the domestic CBs to defining the NC issued to the operators and the timelines to address them.||In Switzerland a comprehensive and harmonized sanction catalogue defining NC and enforcement measures for organic primary product producers (farms) exists. The sanction catalogues of the CBs for processors, retailers, importers and exporters, however, are not yet harmonized. Therefore, the FOAG has initiated a process of comparison and discussion between the domestic CBs with the objective to develop a harmonized sanction catalogue also for these categories of operators at Swiss level. If no harmonization can be reached, the FOAG is entitled to issue instructions (OFO, RS 910.18, Art. 32(5)).|
|3.0||Review the current NC definition and how these are handled by the SAS.||In cases where the FOAG finds a NC during its supervisory tasks at a CB, it issues a "recommendation" (German: Auflage). This means the FOAG requires the CB to take a corrective action. In cases where the FOAG observes a process, a document or a behavior, which is not a NC towards the organic ordinances, but still could be improved, the FOAG has the possibility to advise the CB to take a corrective action. In this case, the FOAG makes an "observation" (German: Empfehlung). This system has proved to be a very effective instrument for supervising CBs. It should not be changed.|
|4.0||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.||
A discussion around the missing legal authority of the FOAG to suspend or cancel the authorization of the CBs has led in December 2016 to a proposal to amend the OFO (RS 910.18) accordingly. By now, the proposal has passed two inter-service consultations and a public consultation.
The amendment shall enter into force as from 01 January 2018. With the new provisions, the legal relations between FOAG and the domestic CBs will be formalized. There will be a formal approval, and the possibility of suspension/withdrawal of the CBs authorization to carry out activities under the OFO.
|5.0||Consider formalizing the legal relations between the FOAG and the domestic CBs||See FOAG's comment to CFIA Recommendation No 4.0.|
|6.0||Consider developing a standardized timelines for the domestic CBs to address the observations made by the FOAG as part of their surveillance activities.||FOAG will add a section in the "guideline for audits" with criteria to define the timelines for domestic CBs to address the observations made by the FOAG.|
|7.0||Consider developing means to supervise the work of the international CBs including evaluation of the CBs' annual reports.||In the framework of Annex 9 of the Agricultural Agreement between the EU and Switzerland, a closer cooperation with the Commission of the European Union, especially with regard to imports and to the work of international CBs, shall be examined. In future, joint supervisory work may be possible.|
|8.0||Evaluate the needs to involve the domestic CBs in the investigation of chemical residues currently led by the CAs||In November 2015, the FOAG and the FSVO jointly issued instructions on residues in the organic sector. The instructions define the roles of the different parties involved in general and in particular outline the responsibilities of the CBs and the CAs during the investigations of residue cases.|
|9.0||Consider training the CAs and the CBs in the light of the new Food Law as relates to follow up on chemical residues||First positive experiences with the enforcement of the instructions on residues have been made over the last one and half year. Moreover, during the last OEWG, FOAG together with all participants identified the need to establish an experience and knowledge group for residues to handle complex cases. This group will meet for the first time in November 2017.|
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