Canadian Food Inspection Agency peer review report on Switzerland's organic system – 2017
6. Implementation of the Swiss Organic Program

6.1 Accreditation and supervision of CBs

6.1.1 General

The FOAG office is the competent authority responsible for the oversight of the organic system in Switzerland. This system covers the activities performed by operators at all stages of the production, preparation and distribution chain from farm to fork.

In 2015, Switzerland revised its control and supervisory system to clarify the difference between the accreditation and supervision tasks.

While the accreditation of the CBs is granted by the SAS, the supervision of the CB is conducted by both the SAS and the FOAG. The SAS and the FOAG carried out separate surveillance activities on CBs by using their own tools to record their observations. All records are well maintained and easily retrievable.

6.1.2 Domestic CBs

Switzerland's four CBs are accredited by the SAS to ISO 17065.

While two CBs are accredited to certify primary production activities, the other two CBs are accredited to certify processing activities.

Assessment activities required under the OFO accreditation process are led by the SAS.

Accreditation is granted for a period of 5 years during which time the CBs are subject to various supervision activities by both the SAS and the FOAG. These are conducted through on-site office and witness audits. No documents are issued to the CB to reaffirm their ongoing accreditation during the 5 year cycle.

While the SAS's annual surveillance activities focus on compliance to ISO 17065, the FOAG's annual surveillance examine the implementation of the OFO, that is risk assessment, risk-based planning of inspections, effective management of complaints, and implementation of sanction measures consistent with the sanctions catalogue. The FOAG takes into account results of the SAS's surveillance reports when planning their on-site activities.

In addition, both the SAS and the FOAG conduct witness audits. The SAS conducts at least one annual witness audit per type of production, for example livestock, farm, processing, importing, trading, etc. according to their 5 year accreditation cycle.

Article 33 of the OFO requires the FOAG to conduct annual supervisory activities of the CBs.

In 2015, the FOAG started to conduct supervisory activities, and to develop their program including specific criteria for assessing the effectiveness of the CBs, and a regular schedule. The FOAG has developed procedures and tools to conduct and document their supervision activities.

The FOAG has conducted the following activities independently from the SAS:

• in 2015: 4 office audits
• in 2016: 4 office audits and 2 witness audits
• in 2017: at the time of the CFIA peer review the FOAG had conducted 1 office audit and 1 witness audit

CBs are required to submit annual reports to the FOAG. These are used to prepare the FOAG's surveillance visits and, to assess the overall performance of the CBs.

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.

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. Instead, the CBs and inspection authorities are listed in Annex 4a of the EAR Ordinance on Organic Farming - PDF (474 kb).

The process of reaccreditation is not as comprehensive as the process of initial accreditation since the SAS takes into consideration the history of previous assessments. As a result of the process the SAS issues an accreditation letter which specifies the scope of accreditation.

6.1.3 International CBs

Article 23 of the OFO provides the legal basis for the FOAG to recognise international CBs operating in third countries. Switzerland has 43 such CBs. In order to be recognised as an international CB under the OFO, each CB has to be accredited to ISO 17065 by an accreditation body (AB), for example the SAS, German National Accreditation Body, and the United Kingdom Accreditation Services before they can request recognition by the FOAG. They submit a request to the FOAG by completing a standard application form and, providing information on their accreditation and, their certification activities (geographical scope, product categories, standards to which they certify). The FOAG has developed a checklist to screen each application. The CFIA team noted that CB applications are only verified for completeness instead of being evaluated to confirm competency and sufficient resources.

The FOAG issues a letter of recognition to successful applicants. The rules are clearly stated in the "order" (legal letter) issued to the CB. For example, the validation is defined and the CB must inform the FOAG immediately if substantial changes are made to the information contained in the technical dossier submitted to the FOAG. Moreover, the recognition is not transferable, etc. The team observed that some recognition letters were issued for 2 years while others were for 3 years.

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. Again, they are just verified for completeness.

In addition, the AB responsible for the supervision of the international CBs is also required to provide annual surveillance reports to the FOAG. The quality of these reports was observed to vary between ABs. The reports are lengthy and cover all certification activities conducted by the CB. The FOAG does not review these reports. Instead, they rely solely on information provided by the EU to confirm ongoing recognition of the international CBs. The EU reviews these reports and issues non-conformities (NC). The FOAG receives copies of these NCs and information on how CBs address them.

6.2 Implementation of the OFO by the CB

6.2.1 General

The CFIA audit team visited the headquarters of two CBs which are accredited to multiple systems to conduct both domestic and international activities. They are adequately resourced and have invested resources to train their staff including inspectors.

Both CBs have a well-developed quality management system and related procedures and agile tools which comply with ISO 17065 and the requirements of the OFO.

Both CBs have developed impartiality committees as a result of a new ISO requirement, and databases which allow them to schedule inspections in a timely manner while ensuring a good rotation of inspectors. They have also implemented well-developed certification processes, and an infrastructure, procedures and tools to deliver their activities effectively.

Systems are in place to ensure that on-site inspections are conducted by well-trained inspectors. They prepare inspection reports which are used by the CBs Certification Committee to make certification decisions. The inspectors are subject to formal annual performance monitoring process by their CBs which identify the type of training needed by the inspectors.

The duration of inspections varies depending on the nature and complexity of the farm and/or processing facility. As a result of these inspections, the CBs can issue NCs. These are discussed with the operator at the closing meeting during which the parties agree on the timeframe to address them.

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. In addition, the sanction catalogue used by the CBs for the farmers differs from the catalogue used for the other operators.

During each inspection, inspectors are required to verify that all inputs used by famers and operators are on the permitted substances list (PSL). The OFO stipulates that it is responsibility of the CBs to verify that all inputs used by the operators are these on the PSL.

The CFIA team observed that the CBs rely and trust two independent organizations (the Research Institute of Organic Agriculture (FiBL) and Info X Gen) to generate a list of approved inputs which lists various trade names, etc. of for example fertilisers, processing aids, cleaning materials, etc. of the product on the PSL. This serves as an aid to both operators and inspectors. The approved inputs should only contain substances from the PSL.

The CFIA team observed that there is no contractual agreement between these parties 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 such a case, it is not clear who will take responsibility.

In addition to the annual inspections, both CBs conduct an additional 10% (of the total number of operators) of both risk-based inspections and unannounced inspections as required by Article 30 (2) of the OFO. Each CB has developed a risk assessment table based on criteria including the number of irregularities (infringements, positive tests), the nature and complexity of the operation, etc. The additional inspections are prioritized based on the outcome of the risk assessment process.

As part of the inspections, inspectors take samples according to the annual sampling plan developed by their CB. CBs are required to report to the FOAG any results of positive detection of chemical residues.

The team confirmed that in 2016, both CBs were subject to annual surveillance activities including witness audits by the FOAG and the SAS.

It was observed that there is good communication between the FOAG, the SAS, the CAs and CBs.

Verification of import controls are performed during annual inspections. Importers must submit a certificate of each consignment to their CB, and the CB must verify that the consignment and the certificate of inspection meet the requirements of the Swiss ordinance.

Once the inspection is finalised and all NCs addressed, the CB makes a certification decision and each operator receives a certification document which confirms that the operator fulfils the requirements of the OFO. The CBs publishes an up-to-date list of valid certificates of all operators they certify on their website.

The CBs keep their operators informed of any new organic requirements by issuing bulletins, brochures, etc. Generally, the operators are given up to a year to implement the new requirements.

6.2.2 Certification and supervision of operators

6.2.2.1 Certification of organic farms (crops, livestock)

The two organic farms included in the assessment have been certified as organic for a long period of time. In addition to the certification under the OFO, the farms have Bio-Suisse certification which is recognized private certification in Switzerland.

The CFIA team observed parts of inspections being conducted by inspectors from two different CBs at two organic farms, including both livestock and crop production. Each inspector receives inspection orders from their CB which direct them to conduct specific inspections. Both inspectors used electronic checklists to assess compliance to the OFO. The CFIA team observed consistencies in how the inspections were conducted: they both included a tour of the farm, review of relevant documentation, condition of the soil and animals, inputs used, storage, etc.

The OFO requires the domestic CBs to take samples and test at least 5% of the number of operators subject to inspection. No samples were taken at the operators visited.

The inspection checklist served as the inspection report. It was signed by both parties at the closing meetings. A copy of the report was sent to the operator by mail.

Each farmer had a contract with a CB and had been certified under the same CB for some time. Both farms were subject to annual inspections as well as unannounced inspections. The team confirmed that the inspections were conducted by different inspectors and, that inspections generally lasted between 2.5 – 3 hrs.

Operators have 3 days in which to request a second inspection if they are not satisfied with the first one.

No NCs were issued during the inspections observed; however, operators were knowledgeable about the process involved, that is that NCs are assigned based on a points system which is linked to the subsidy program via a national sanctions catalogue. The penalties associated provide motivation to the operators to correct and prevent non-compliance.

All operators submit their organic plan to both the CB and, to the canton - which is responsible for administering the subsidy program.

6.2.2.2 Certification of organic processing

The CFIA's assessment team visited two processors of single and multi-ingredient organic products. Both operators trade internationally. They have been certified for a long period of time by the same CBs, and are certified against multiple standards.

Company A: Operation manufacturing dehydrated organic fruit and vegetable products

The certified products included dehydrated (fine powder) organic fruit and vegetable products. Some of the products are exported to Canada as raw materials used in production of baby food. The company is aware of the SCOEA.

The CFIA team did a tour of the processing facility. The traceability and the import controls were discussed with the representatives from the company.

The company explained that raw material sourcing is coordinated by the parent company and that all suppliers go through an approval process. Each ingredient comes with an organic certificate, label, CB control number and any additional documentation required by the company.

Raw materials are received in bulk from external storage areas which are certified separately. All raw materials are subject to pre-shipment sampling and additional sampling at receipt. The facility has its own laboratory to test for sensory, micro quality and heat resistance. Samples for chemical residues are sent to Germany for analysis. The company has a process in place to control the movement of any raw ingredient which contains chemical residues. The company develops a risk-based sampling plan which is based on trust and confidence in (history with) suppliers.

During the interview with the company representative the CFIA team confirmed that the annual inspection lasts from four hours to one day. The company had not been subject to an unannounced inspection; however, this site has been subject to regular inspection by the food safety authorities from the canton.

In the last 5 years the company was inspected by 3 different inspectors from the CB.

The company is required to submit an updated organic plan (profile) to the CB on an annual basis. This is used by the CB to prepare for their annual inspection.

Notification of the inspection is usually sent to the operator 4 weeks in advance. If no organic runs are scheduled for the identified timeframe, the operator notifies the CB and the inspection may be rescheduled or, conducted on a conventional product run.

During the inspection, inspectors tour the facility, check the equipment, discuss procedures for storage and cleaning, and verifies the list of suppliers, organic certificates for national and international raw materials, list of product range (organic and conventional), and list of organic products that are sub-contracted or stored. They also conduct an input/output balance.

Inspection findings are classified as NCs. The inspector leaves a record of the NCs which is signed by both parties. A final inspection report is provided by letter within a week. It identifies the specific timeframes in which to address the NCs. Once the NCs have been addressed, the CB makes a certification decision and issues an updated certificate to the client.

Company B: Operation processing organic fruit and vegetable juices

The certified products include range of organic fruit and vegetable juices. Some of the products are exported to Canada and the company is aware of the SCOEA.

The team observed how labelling and traceability verification activities are conducted by an inspector as part of their annual inspection.

The inspector followed the CBs established procedures for validating the company's traceability controls for raw ingredients (certificate of inspection, labelling, invoices, input/output balance, etc.) and the import controls. The documentation accompanying shipments of any organic ingredient need to prove their organic origin. The inspector did the traceability exercise by selecting one multi-ingredient product and tracing back all ingredients back to the suppliers. The outcome from the exercise was determined to be satisfactory.

It was discussed that the company samples raw materials for chemical residues prior to using them in their production.

Both the company representatives and the inspector are aware of the labelling requirements in Canada and examples of organic labels intended for the Canadian market were reviewed.