What does it mean when the label says "organic"?  
And who says so, and how do we know they are telling the truth? 
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July 10, 1999    
We present the first installment of our ongoing research:
THE CALIFORNIA ORGANIC FOODS ACT OF 1990
[Full text of COFA 1990] (109 kb - load time 45 seconds @ 28.8k)
[Private Organizations Certifying organic producers for California Registration]

    Next time you are shopping for organic foods, read the labels on the organic items carefully.  Look at the packaged foods and at the binders on the produce.  Many of the labels, except for some of the locally grown produce, will say 

ORGANICALLY GROWN IN ACCORDANCE WITH THE CALIFORNIA ORGANIC FOODS ACT OF 1990 
(raw agricultural commodities)
or
ORGANICALLY GROWN AND PROCESSED IN ACCORDANCE WITH THE CALIFORNIA 
ORGANIC FOODS ACT OF 1990
(processed food)
or
ORGANICALLY PRODUCED IN ACCORDANCE WITH THE CALIFORNIA ORGANIC FOODS ACT OF 1990 (unprocessed meat, fowl, fish, dairy products, or eggs).

Now look at where the item comes from.  Much of the raw produce, especially in the winter months (if you live where there is a cold season), is actually grown in California. But many of the processed or packaged items are not.  They can come from anywhere, including outside the U.S.  How does California manage to get its seal of approval on such a large proportion of organic foods from around the world?

 1. Because of the size of the California specialty agriculture industry, including a large number of organic farms, not surprisingly much of  our organic produce and other items actally comes from California.
2. California Organic registration is required to sell any product labeled organic in the state of California.  Given  the immensity and commercial importance of the California consumer market,  a grower's or processor's desire  to obtain California registration is understandable.  
3. Any private certifying agency, in California or elsewhere, may register with the California Department of Food and Agriculture (CDFA) as such, and may then conduct inspections and provide California certification for organic farms and processors anywhere, include nations other than the U.S.  The CDFA Organic program lists ten groups currently providing such certification. In California, the largest of these is California Certified Organic Farmers (CCOF), with 800 "clients".  Certifying agencies may compete with one another for business.  One private certification label that we have personally seen on produce and packaged organic foods from a variety of sources, including Mexico, is that of  QUALITY ASSURANCE INTERNATIONAL (QAI).  

Note the distinction between registration and certification in California.  
Registration is administered by the California Department of Food and Agriculture (CDFA) under the THE CALIFORNIA ORGANIC FOODS ACT (COFA) of 1990.   State inspectors perform 500 unannounced  inspections every year.  According to Ray Green, head of the California Organics program, "The inspectors know who the organic farmers are."  All farms are required to report pesticide use, and this too would show up violations in meeting organic standards. Mr. Green emphasizes that the California registration standards are "minimal", dealing with such basic issues as the use of pesticides, herbicides, antibiotics,  hormones, and irradiation.  Issues such as soil management and sustainability are not addressed.

A brief review of COFA 1990 reveals a few interesting points.
The law comprises two sections, which are sufficiently alike in the most part to be repetitive: those provisions which are part of the CALIFORNIA FOOD AND AGRICULTURE CODE, and those which are part of  the CALIFORNIA HEALTH AND SAFETY CODE.   Use of composted municipal waste ("sewage sludge") is not addressed, nor is the issue of genetic engineering.  Use of hormones and antibiotics are permitted only for therapeutic vetinary use, and must be discontinued either 30 days or 90 days before slaughter, depending on which section is invoked.  The list of prohibited practises and substances are very much like that seen in the Northeast Organic Farmes Association (NOFA) standards.

Registration of farms and processors
Every person engaged in this state in the production or handling of raw agricultural commodities or eggs sold as organic, or in the production, handling, or processing of meat, fowl, or dairy products sold as organic, excluding retailers of food sold as organic, shall register with the agricultural commissioner in the county of principal operation prior to the first sale of the food, and shall thereafter annually renew the registration unless no longer engaged in the activities requiring the registration. Each registrant shall provide a complete copy of its registration to the agricultural commissioner in any county in which the registrant operates.

Enforcement: Any person may file a complaint with the director concerning suspected noncompliance with the COFA 1990. The director and the county agricultural commissioners may conduct a program of spot inspections growers and processors.  At the request of a county agricultural commissioner, the district attorney for that county may bring an action to enforce  the COFA standards. In lieu of prosecution, the director or a county agricultural commissioner may levy a civil penalty against violators of not more than five thousand dollars ($5,000) for each violation. If the violation was not intentional, the director or county agricultural commissioner may levy a civil penalty of not more than two thousand five hundred dollars ($2,500) for each violation. For a first offense, in lieu of a civil penalty as prescribed in subdivision (a) or (b), the director or county agricultural commissioner may issue a notice of violation if he or she finds that the violation is minor.


Third-part Certification 
"This chapter applies to all food sold as organic within the state, wherever produced, handled, or processed, and to all food produced, handled, or processed in the state, wherever sold as organic, except that in lieu of registration under this chapter, the secretary may recognize a certification organization operating outside of the state that certifies raw agricultural commodities, eggs, meat, fowl, or dairy products if the secretary determines that the organization meets minimum standards substantially similar to those contained in subdivision (c) of Section 110850, and Sections 110860 to 110870, inclusive, of the Health and Safety Code. The secretary shall establish, administratively, a procedure for organizations to apply and obtain recognition."  Third-party private certifiers are free to impose more stringent standards.


Inspection and enforcement.
COFA 1990
is clear in its requirement of a minimum inspections schedule of all client producers that registered third-party certifiers must follow.  It is not clear how enforcement is imposed upon producers who are not located in California, and who violate either COFA 1990 or the private certifiers own standards.  The individual certifying agencies hire inspectors in the areas where the farms/processors who subscribe to there services are located.  They undergo an intensive two-week training, plus an internship and apprenticeship.  They may be part-time inspectors who are also, farmers, teachers, on vacation, food scientists, etc.  [At least one certifier we talked to hires only full-time professional inspectors.]
We may infer that the threat of loss of certification with consequent loss of the California Market is a sufficient motivator for good behavior; but we wonder what happens to a producer or processor who is not located in California and remains in gross violation of COFA or private standards and continues to obtain and apply labels indicating compliance.

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