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Access Link to Town Hall Recordinghttp://cc.readytalk.com/play?id egk4o6 or see slides, chat and attendee listsin the pages that follow1

Town Hall Logistics & Ground RulesWebinar Rules & Reminders:If you are online but cannot hear, be sure to turn on your speakers.Your name is visible to all Town Hall participants.This session is being recorded.Use the chat box to submit input or questions.The slides and webinar recording will be available to the public viathe NOP website. We are sharing the screen, so your chat messages can be seen byeveryone, not just the presenters. This Webinar will last 60 minutes. For help, visit https://support.readytalk.com/SP/

Town HallStrengthening Organic EnforcementUSDA Agricultural Marketing Service (AMS)National Organic Program (NOP)Jennifer Tucker, Ph.D., Deputy AdministratorMatthew Pavone, Policy AnalystJuly 17, 20183

NOP Regulatory Pathways Forward1Strong OrganicControl SystemsTrusted People,Processes, and Rules2Farm to MarketTraceabilityWorldwide SupplyChain Integrity3RobustEnforcementA Level PlayingField for All

NOP Webinar FormatOverview of potential topics - two at a time.Display 2-3 questions for response.5-minute pause to ‘chat’ responses to thequestions.

How do I ‘Chat’ My Input? Go to your chat box located in your lower left corner. Enter the question number followed by your input. For example, typing “2” followed by input shows usyou’re addressing question #2.“2 Your Input ”

Rule Making TopicsAreas of Focus Federated Organic Certificates Satellite Offices7

Rule Making QuestionsQuestionsQ1: What challenges would Certifiers face ifrequired to use a federated organic certificate? Isthere an alternative you would suggest?Q2: What should NOP consider with respect toaccrediting satellite offices?8

Rule Making TopicsAreas of Focus Inspectors: Qualifications, Trainingand Field Evaluations Certification of Grower Groups9

Rule Making QuestionsQuestionsQ3: What should the minimum qualification andtraining requirements be for organic inspectors?Q4: What specific practices might NOP consider forGrower Groups that are not already addressed by the2002 and 2008 NOSB recommendations?10

Rule Making TopicsAreas of Focus Operations excluded from organiccertification Increased reporting to the organicINTEGRITY database11

Rule Making QuestionsQuestionsQ5: Which types of excluded operationsshould be required to be certified and why?Q6: Should any of the current exclusions in theUSDA organic regulations remain in place?12

Rule Making TopicsAreas of Focus Import Certificates Update regulatory requirementsfor equivalency arrangements13

Rule Making QuestionsQuestionsQ7: How might the rule address full supply chaintraceability from farm to table?Q8: How can the rule address the integrity oforganic products imported to the United States?Q9: What should NOP consider about existing orfuture trade arrangements?14

Rule Making TopicsAreas of Focus Unannounced Inspections Updates to noncompliance andappeals process15

Rule Making QuestionsQuestionsQ10: What should NOP consider about thecosts of unannounced inspections?Q11: Which parts of the noncomplianceand appeal processes might NOP need tofurther clarify?16

Next Steps Ongoing Engagement– Meetings– NOP.guidance@ams.usda.gov National OrganicStandards Board FallMeeting Spring 2019 ProposedRule Feedback17

Tell Us How We Did!How did you findthis Town Hall?What might we do differentlynext time?

Strengthening Organic EnforcementUSDA Agricultural Marketing Service (AMS)National Organic Program (NOP)THANK YOU19

Strengthening Organic Enforcement Town Hall Chat, July 17, 2018USDA Agricultural Marketing Service, National Organic ProgramSenderletis letisKelly AbbottWestley BakerColette Piperveronica reyesBeth Ungerellis collierElise GeorgeMegan Meganletis letisRichard BertrandRebekah RitsonMegan McDonaldLynn CoodyIrazu LopezYutaka YokoteMary CapehartShelby FrenchVal SchmaleGeorge KalogridisSusan HalstedAnnette SemperMarni KarlinMarisol OviedoGretchen ZimmerJared ClarkShelby FrenchBrittny BauerDimitris SotiropoulosMessagehello!Kelly Abbott-ICS yes!Wes Paramount Coffee yesColette, Oregon Tilth. Yes! I can hear you.VeronicaBeth Unger Organic Valley, yesEllis Collier- National Ag Law Center. YesElise George, OEFFA Certification - yesMegan Hoveland, Ciranda. YesMatias Dortona - LETIS yes!Hello Ventura FoodsRebekah Ritson, Grain Millers Inc. YesMegan. Food & Beverage Consulting Group. Yes ma'am!Lynn Coody, Organic Agsystems Consulting. Yes, I hear you.Yes, Irazu Lopez CERTIMEXYutaka Yokote -Yamasa USA- Yes.Mary Capehart CROPPyesNOP CE yes i can hear youGeorge C Kalogridis ECOCERTSusan - Allen Flavors - I can hear youGreetings from Organic PartnersMarni Karlin, Karlin Strategic ConsultingMarisol Oviedo, Northwest Horticultural CouncilGretchen Zimmer, Only Natural/Bio NutritionJared Clark, Oregon TilthBill Wolf - WD A -- yesBrittny Bauer - Everbest Organics, Inc.Dimitris Sotiropoulos: Agronomist - DS CONSULTING, Consultant forOrganic Control Systems, GreecePeter NellJoan AvilaJackie DeMinterJoan AvilaBob BobRebekah FinnPeter Nell, California Certified Organic Farmers (CCOF)I can hear you!Jackie DeMinter - MOSA Certification Policy ManagerSecretary, NOPBob Turner GrainCorp can hear youRebekah Finn True Organic Products, I can hear you

Johanna MirendaAli HudsonCindy ElderLeslie FernandezElizabeth TiganFeliciana PuigMax MaxLeslie FernandezKelly MonaghanJustina vasquezMichael MenesSandia MartinDarice WraspirAllison BurkeBeth RotaDaniel BurkardKyla SmithNeil MillmanAlexis RussellPaul SchockmanJulie PaillatLeslie FernandezBob PuruleskiGenevieve AlbersGibbs WilsonBrittany JordanVal SchmaleAlexis RussellGwendolyn WyardLeslie FernandezAnna Maria Gottmannmeredith smithRichard Siegelroger griessTerry Smithmike crotserJohanna Mirenda, OMRIAli Hudson - Oregon Tilth Certification OfficerCindy Elder, OCIALeslie Fernandez - CDFAElizabeth Tigan - NICS! Thank youFeliciana Puig - MOSAMax Goldberg - Organic InsiderIf you can't hear, use a different browser.Kelly Monaghan, Ash Street Organics, TorontoJustina Vasquez, Bloomberg News, yes can hearMike Menes - True Organic Products. we can hear you :)Sandia Martin of TAB AG GROUPDarice Wraspir - Pacific Foods (Campbell's Soup Company)I can hear youBeth Rota - Quality Certification Services (QCS)Daniel Burkard, Holland & KnightKyla Smith, PCONeil -- I Love ProduceAlexis Russell, Ayrshire Farm in Upperville, VAPaul and Isaac, we don't have audio yetCanadian Horticultural CouncilIf you can't hear, use a different browser.Bob Puruleski - Big Dutchman (Cage Free Poultry Equipment)no audio, trying a 3rd browser option.Gibbs Wilson, Valent USA in Georgiai have audio but its very mutedgoogle chrome or firefox work bestCouldn't hear on Safari, but switched to Chrome and got soundGwendolyn Wyard, Organic Trade Associationchrome works bestAnna Maria Gottmann @Jean NielHello, Meredith Smith from ED&F Man, hereRichard Siegel, Richard D. Siegel Law OfficesRoger Griess Ag Tec ResourcesTerry Smith, Nature's Way DairyMike Crotser - Certification Manager Organic Valley/CROPPCooperativeRandy kriegStacy SwartwoodRandy Krieg Sacramento Ag Dept. CAFor audio: You can also try clicking the settings gear icon and select"Join with our Flash version at the bottom of the window" thatappears

Özlem Emirler ÖzsanGlenn KernRebeca RabagoAnn GaitanJeff JeffHi, Özlem from ETKOGlenn Kern, Carolina Farm Stewardship AssociationWholesum HarvestHello, Ann Marie Gaitan and Laurie Hale from Diversey, Inc.Jeff Yorzyk - Green Chef Organic-certified company in meal kit homedeliveryShannon BrubakerBrittany JordanAshley VulinMichelle O'BrienArturo GonzalezLUIS LOPEZJacob NeufeldElizabeth FigueredoMadison KempnerOregon Dept. of Agegg innovationsDavis Wright TremaineMichelle O'Brien - Wegmans Food MarketsArturo Gonzalez - Ground-Fresh International hereLuis López, CCOFSunrise Foods InternationalLiz Figueredo - Technical Quality Manager, QAI, Inc.Maddie Kempner, Northeast Organic Farming Association of Vermont(NOFA-VT)Paul SchockmanSam WelschCydnee PletcherMarcus CaswellJessica WaldenJodi SnyderNicole DehneANDRES ARMSTRONGBill WolfGenevieve AlbersAnn Marie HouriganMichael CorbettGianfranco Santaliz-RogersRhonda PudwillLeslie Fernandezmiraj patelPaul and Isaac NaturefreshSam Welsch - OneCert, Inc.Cydnee Pletcher - Progressive Agricultural ManagementMarcus Caswell- Wish FarmsJessica Walden - QAIJodi Snyder: Global Organic AllianceVermont Organic FarmersChilean Blueberry CommitteeWolf, DiMatteo AssociatesTraditional MedicinalsWhole Foods MarketSunrise Foods InternationalHello, Is there a call in number?Has the webinar started yet?yeswhat is prior university graduation year that got the snap workregistration or tanf work registrationmiraj patelErica LundquistLeslie FernandezStacy Swartwoodhow does usda interveneNo Audio for meIf you can't hear, use a different browser.For audio: You can also try clicking the settings gear icon and select"Join with our Flash version at the bottom of the window" thatappearsmiraj patelduring prior 4 years, people are waiting for usda intervention. theyexplained they are the snap work registration personnel.

Marty Dagobertopre-test said it was configured correctly, but I'm not getting audio.will you be sending out a recording?Chairpersonmiraj patelMelissa ElkinsThanks so much for joining us today!fruits, vegetables, grains, oats, coffees, teasSustainability Coordinator, Community Food Co-op, Bellingham, WAChairpersonChairpersonThais AgostiniValeria FrancesStacy SwartwoodYes, there will be a recording.Your Chairperson is NOP.Is there a phone number to call?can not hear a thing and my headphones are workingIf the audio is still not working, try using a different browser. Chromeand Firefox are recommended by other participants.Amalie LipstreuMarty Dagobertomiraj patelJAIME GARCIAJAIME GARCIAErin HeitkampTessa Trippmiraj patelAmalie Lipstreu-Ohio Ecological Food and Farm Associationyeah call in number would solve this audio problem.i rather be able to earn my wages for my breakfast oatmeal and teaJaime Garcia - Kingdom Fresh ProduceSteve Garza - Kingdom Fresh ProduceI cannot hear the audio despite electing to use the Flash PlayerTessa Tripp, International Certification Services, Inc.i paid for my lunch at lasalle bank abnamro 540 madison chicagoillinois december 2007 to may 2009, prior to 99 weeksunemployment insurance claim. i remember the usda salad bar at myfirst employerChairpersonAs new folks are joining, please type in your name and affiliation. Allchats and this webinar are being recorded.Miles MilesErin HeitkampJody KenworthyKarlin WarnerColleen O'BrienMarty DagobertoRudy AmadorLeona PropsonJessie JessieMelinda DeNobregaAndy HuppAllison Dermondlila HaddoucheDaniel GagnonErica LundquistMiles McEvoy, Lacewing Auditing and ConsultingErin Heitkamp - Pipeline FoodsJody Kenworthy, Maryland Farm Service AgencyKarlin Warner - OneCert, Inc.Colleen O'Brien, WSDA Organic ProgramNortheast Organic Farming Association, Massachusetts ChapterRudy Amador - Dole Fresh FruitLeona Propson, Briess Malt & Ingredients Company.Jessie Bovay, MercarisMelinda DeNobrega OEFFA CertificationWSDA Organic ProgramLila Haddouche - QualityDaniel Gagnon: Herbs, Etc., Inc.Erica Lundquist, NRCS No Audio, flash player not available, installedChrome yesterday and had all green arrows.ChairpersonThanks for joining, all! Pease introduce yourself as you join.

hande kemerliAnn GaitanMayze Fowler-RiggsBrad JohnsonSarah ReedGisele AtkinsonCynthia TroetschlerChris GrigsbyKara NagelAngela AnegonBritt BrittMike ChansilpMartina MelapieAnnie BericalChairpersonIgnacio Guntinyasmin cedamanosMonique SalhabHande Kemerli , Control UnionCan you minimize the chat? It is very distracting.Mayze Fowler-Riggs, California State Organic ProgramBrad Johnson-Kalmbach Feeds, Inc.Sarah Reed - CCOF Certification ServicesGisele Atkinson, Council for Responsible NutritionCynthia Troetschler: CytoSport Inc.Chris Grigsby: MOFGA Certification ServicesKara Nagel, NOW FoodsAngela Anegon - WSDA Organic ProgramBritt Lundgren, StonyfieldMike Chansilp/Vanessa Dyckman - Hain CelestialSRS CertificationAnnie Berical, OCIA InternationalIf you cannot hear, we will post a recording.Ignacio Guntin from OIAYasmin Cedamanos, CUCMonique Salhab, Community Development La Montanita CooperativeSOPHIE MONTEIROmiraj patelSophie Monteiro: Flavor Producershow would usda offer explanation of the usda approach with lasallebank abnamro 540 madison chicago illinois cafetaria novemebr 2007to may 2009 ? how did usda select the choices there, with thecoffees, smoothies, salads, paninis, pizza toaster ovens ?Ryan KooryBrittany JordanJennifer RobinsonCali AlexanderAubrey LopatinLindsay JacobBhagya KajaKatriana GarciaJuan GuzmanFatima McClainCynthia Morphetmiraj patelRyan Koory with Mercarisok thank youI cannot hear.Cali Alexander, H. O. NOFA-NJ Bd. MemberAubrey Lopatin, Arbor TeasAgroThrive, Organic fertilizerBhagya Kaja, Tastepoint by IFFKatriana Garcia, BayerJuan Guzman - Bard Valley Date Growers AssociationFatima McClain, Clover Stornetta FarmsCynthia Morphet: Global Organics, LTd.what are we learning now week to week with usda approach to thesegovernment efforts. when we are at local grocery stores, usda is veryvery very silentThais AgostiniErica LundquistClara OrdoñezIs there a phone number to call in?Will listen to recording. Try another platform next time!Clara Ordoñez, OIA

Lee FrankelCameron Harshmiraj patelLynn JohansenChairpersonEmily Brown RosenJim Sattelbergmiraj patelLee Frankel - CSOCameron Harsh, Center for Food Safetyusda simply ignores the webinars at the grocery storeLynn Johansen Natures International NICSNo phone, listen through your computer.Emily Brown Rosen, Organic Research AssociatesJim Sattelberg: Everbest Organicsthe salad bar at jewel osco indicate be silent about the faming rulesin progressmartin LichtyGwendolyn WyardMartin Lichty Farm Service AgencyWill be able to provide answers to the questions after the webinar?James CookLori KenyonJodi Snydermiraj patelJerry Combsmiraj patelmiraj patelJames Cook, SGSNOFA-NY Certified OrganicNo sound.whats really occurring at usda officesJerry Combs from Crosset Company, a produce distributorwhat do the usda staff really knowhow much information does usda staff know about usda's approachChairpersonMost folks report being able to hear - if you cannot, try a differentbrowser, turn up speakers. If that doesn't fix it, call support.marissa pylemiraj patelmiraj patelmiraj patelValeria FrancesSherine KanagasunderamMark Rokalamiraj patelMarty Dagobertomarissa pyle & jen berkebile - pennsylvania certified organichow would usda staff think about agriculture economics taskspricing of food itemsnew food items available in usa after 2000Google chrome workedSherine Kanagasunderam - QTrade TeasMark Rokala, Organic Farmers Associationnew food items available in usa in 1990s, in 2000s, after 2010Every other webinar I've ever been a part of had a call-in option foraudio.Stacy SwartwoodFor audio: You can also try clicking the settings gear icon and select"Join with our Flash version at the bottom of the window" thatappearsmiraj patelmiraj patelChairpersonusda approach state to stateusda's knowledge on jeanne kitchens grocery store creditWe anticipated a lot of interest, that's why we are using computeroption. The phone option has a ceiling on users.Chairpersonmiraj patelQ1 and Q2how does employment network staff think this is town hall

Sam Welsch1. The problem with certificates is not the validity of the certificate, itis the easy availability of certificates that are being used by personswho are not authorized to use it. This is the basis for much fraudulentactivity.Chairpersonmiraj patelReminder - Start your answer with the number of the Qhow many weeks more does usda think social security is requiringthis sacrificemiraj patelSam Welschhow does usda determine how to set up farms1. There is no need to required a federated certificate. It would besufficient to require a link to the Integrity database on a certificate.Cynthia MorphetRudy Amador1 - How do address equivalencies (e.g. EU and COR)1. How would a federated organic certificate system deal withinternational organic farming ops that export to US?Richard MathewsAlexis RussellQ1 WODPA supports.Q1 : As a company that has to source organic ingredients and keepcertificates current it would be much easier having a uniformcertificate across all certifiers so I don't have to guess when thecertificate expiresRichard Mathewsmiraj patelQ2 WODPA supportswhat at jewel osco you are going to remember about your questionJAIME GARCIA1. Federate organic certificate will need to cover internationalproductionsmiraj patelCynthia Morphetat meijer what are people going to remember1 - challenges foreign certifiers may face with language/translationissuesJuan GuzmanQ1 - A Challende would be to reconcile all of the current certifyingagencies with a Federated Organic Certificate.Megan MeganQ1: How would a federated organic cert work with EU traces system?How would it impact equivalency?Sam Welsch2. That is a good idea. OneCert has already applied for separateaccreditation of our satellite office.Annie Berical2: Accreditation audits should visit and review the practices of allsatellite offices. If satellite offices are being accredited under theumbrella of the "home" office, they MUST be part of theaccreditation audit and their practices and procedures should reflectthose of the "home" office.SOPHIE MONTEIROJerry Combs#2 I support this actionQ1 What is wrong with current accreditation and NOP certificates,and why are you wanting to change it?Cali Alexander2. Does/Will equivalency confer regulatory authority, fully?

Elise GeorgeQ1: The ability to tailor certificates to the certifier's policies and theoperation's specific products is essential.Erin Heitkamp1- Pipeline Foods supports the idea of a federated organic certificateand believes it would go a long way toward efficiently bolsteringtransparency and traceability.Devin Dowell (WSDA)1 - Issuing a federated certificate would require everyone to conformto the same taxonomy, which would not be a feasible endeavor totake on at this point. For most certifiers this would mean using 2databases, their own db to manage inspections, workload, andprocesses, as well as the OID for the sole purpose of generatingcertificates.miraj patelyoua re at the meijer produce section, jewel-osco produce section,costco wholesale usda produce section, what specifically will beremember here. when can people purchase their own groceriesunder usda organic webinars this extentKimberly Bousquet1 - uniformity might make it easier for certifiers to ensure theircustomers they are a valid entity.Mike Chansilp1. We support the proposal but with an option to link to Organicintegrity DB.Kyla Smith1: duplicating work. i.e. how to integrate with existing database dataJAIME GARCIA1. FSVP will need to be involved being that some of these items willcome from foreign countriesSarah Reed1. As long as we can produce it using our own database system, nosignificant burden for CCOF. If it's through Integrity, it would have ahuge impact on our effectiveness and efficiency and therefore cost ofcertification.miraj patelwhat is the federal certificate. you dont learn this certificate atmarianos, meijer, jewel oscoSynthia MoralesQ2 - Synthia Morales Biolatina - respect to accrediting satelliteoffices, we think it would perhaps increase the cost of accreditationsbecause if we have many offices then we must pay a fee for each onethat may be audited at the same time during external audit?Richard MathewsMike ChansilpNicole DehneRichard Mathews - WODPA1. How would this capture international certifiers?Q1 Certifiers would need to be able to update certificates at any timeduring the year. In addition, we would need to decide on exactlywhat categories of products are listed on certificates- for exampleorganic tomatoes vs. organic brandywine tomatoes. Or at least needthe ability to tailor the products to whatever we might need.

Lori KenyonQ1. support if level of detail is present and not as general as currentNOP certificate program.miraj pateldominicks grocery store used to work in my building at lasalle bankand i think they are asking usda for the mediation and connection ofevents from march 2009 staged to march 2001 time.Rudy Amador1. Could this system include transaction certificates (such as used forexports to EU) in addition to site certification information?Andy Hupp1 - It is not clear what problem federated certificates would solve.NOP 2603 should be edited and straightened if additional elementsare necessary to ensure organic integrity. Challenges includetechnology, loss of unique certifier value, and loss of flexibility inadapting to the needs of operations.Lori KenyonRichard SiegelQ2. SupportQ2 I support accreditation of satellite offices. I just learned yesterdaythat In India, there is recognition agreement with NOP. Operations inIndia certified by certifiers in India are not listed on IntegrityDatabase. This is a gap in the database. These operations should beon the Integrity Database. As for satellite offices, some of thecertifiers in India are satellites of certifiers who have NOPaccreditation. Those clients in India should be on the IntegrityDatabase.Juan GuzmanQ1 - Another challenge would be the timing, in order to get acertificate as a grower, you need to be audited during harvest; if weonly harvest once a year this means there could be a gap withoutcoverage.Devin Dowell (WSDA)1 - (continued) Additionally a federated certificate would not have ameasurable impact of fraud. Any certificate that is transmittedelectronically would be able to vulnerable to editing.Arturo Gonzalez2 NOP should consider sattelite offices comply to the program thesame as HQKyla Smith2: need to have clear definition of what a satellite office is. want toensure remote work would necessitate additional accreditationsJudy Baldwin1. It would delay the process of certifying the organic certificationand make the transaction take longer.miraj patelhow many times have i worked with dominicks grocery store, thatworked at lasalle bank building, in illinois, on the mediationclearances. usda apricot scrub approachSam Welsch1. The QR code on the certificate is not useful or necessary. The linkto the Integrity database is sufficient.Lee FrankelQ2. How are satellite offices not already covered during the USDAprocess of reviewing the operations of the main office?

Kimberly Bousquet2 - whether false certificates normally originate from satellite offices.Is there really a problem here?Beth RotaQ2. If they maintain their own procedures and policies, staff training,and make certification decisions accreditation may be appropriate. Ifnot, satellite offices should not need their own accreditation.megan fierstQ1- This would add more leadtime from a business prespective. Italready takes a long time frame to get a label approval. Would thisadd more cost to what we already incur from the certifying agency.Would USDA charge a fee for this cert?Alexis RandolphQ1 it is important that a certificate include brand names of productsto ensure the exact product and label (ingredients) have beenapproved. However, disclosing brand names on a public websitediscloses confidential supply chain information. Time would beneeded to integrate certifier and NOP databases.Michael MenesQ1- if federated organic certificates are made public, this mayindicate volume information that could be considered private bycompany. consider overall numbers but keeping company nameconfidential.miraj patelwhere is it . dominicks rebranded as marianos, however dominicksstaff that worked at lasalle bank building have not gotten resolutionyetSarah Reed2. Devil is in the details. What constitutes a satellite office giventechnological connections to centralized offices. What is and is not asatellite office, how is training of satellite office conducted, how arethey managed, what is the oversight.miraj patelMelissa ElkinsNeil Millmanthe fda salads approach with 1999 sams club1 and 2 - would need to have translation servicesQ1 -- What options exist for digital certificates? Digital offers security,validation, searchability.Aubrey LopatinQ2: NOP needs to consider cultural differences in satellite officesabroadKimberly Bousquet2 -- maybe not separately certified, but some higher level of oversight-- maybe increased frequency of inspectionmiraj patelhow is usda organic thinking usa citizens are thinking about usdaorganic outside usaAnnie Berical2. I doubt that separately accrediting satellite offices would beaffordable for most certifiers.

Devin Dowell (WSDA)1 - (continued) a more effective but still difficult task would be torequire that all valid organic certificates are publicly available online.Then a physical or electronically certificate would be moot andinstead they would need to access the certificates from a specificallyapproved office--but this would take a substantial amount of effortand maintenance from certifiers to keep this up to date.meredith smithQ2 - I do not believe that the satellite office should be SEPARATELYaccredited. If they have a main office and follow all sameprocedures, I believe that a multi-site audit should be used androtate which office gets the audit each year.Nicole DehneQ1 I would like to better understand how a federated certificateprevents fraud. Also, many certifiers have invested heavily in our owndatabase systems, we would like to be able to generate certificatesfrom these systems for a more seamless system for our staff.Sarah Reed1. The products and fields profile is highly variable and integrity doesnot contain sufficient info to meet market needs, e.g. brands,acreage. We would not support federating this portion.Kate MendenhallQ2. Would only international (located in a seperate country frommain office) need seperate accreditation?Kyla Smith2: clarification. I meant to say would NOT necessiate additionalaccrediationsJAIME GARCIA2. Satellite offices should be regulated and checked frecuently so thestandars will be the same onesArturo Gonzalezmiraj patelmiraj patelmiraj patelmiraj patelYutaka Yokote2 why do satellite offices are often under a different name?inventorycoffeesteasmangos#1 The challenge is the related with other country regulation. How tohandle with that.There are so many language.Sam Welsch1. A major challenge of using a federated certificate is the need toinclude information in a format that is not available on the federatedversion.miraj patelmiraj patelEd TreacycerealsoatmealsQ1. Fraud is a challenge. Has there been consideration for usingTrellis, the framework (www.trellisframework.org) for securelysharing audit and certificate data data that would prevent fraud?Kimberly Bousquetmiraj patel2 -- satellite offices should be clearly tied to their home officeuscis field office explains what about usda

Beth RotaQ1 Alternative - linking to certificate on the OID to allow forverification and reduce altering certificatesErin Heitkamp2- I think it is more important to think about sub-contractedoffices/inspectors. If the individuals are not employees of thecertifying body, they should be separately accredited.Rudy Amador2. Separate accreditation for satellite offices would not be necessaryif accredited entities oversight system is robust and adequatelyreviewed by NOP.Juan GuzmanQ2- Accredited offices should be required to meet a timeline of howlong it would take to certify or validate a certification, this means thatif the do not meet the timeline, the could lose their status.Judy BaldwinQ2. what determines where the satellite offices are placed? If theyhinder the process, why use them?Alvaro MartinezQ1: Maintain the CBs database to issue the Federated Certificates.Take into consideration if the Certificates will be only issued if theproduct arrives into the US or should be used for each transaction oforganic NOP certified product. For complete traceability it should befor each transaction.Alexis RandolphQ2 - Satellite offices that do not make any certification decisionsshould not need accreditation. I would define the satellite officebased on steps of certification and responsibility from sales to certdecision and what activities are under the control of central officeversus satellite office from a quality management stand point.James Cookthe clear procedures for accreditation must be outline and ampletime to comment on.Stephen WalkerQ1 - concern about inconsistency between expiration dates andfluidity of annual certification process.Annie Berical2. What problem is separately accrediting satellite offices meant toaddress if they are already visited by accreditors?Andy Hupp2-Satellite offices should be subject to the same oversight as mainoffices. If that requires additional audit time, then the time should betaken. If policies and procedures differ substantially from the mainoffice, an additional annual report may be appropriate. Separateaccreditation may have the unintended side effect of differentcompliance issues being dealt with for separate offices of the samecertifier.Kyla Smith1: additional training would likely be needed as ACAs have distinctand different ways we approach issue certificates to operations withadditional locations under one legal entity and likely different wayswe are using the taxonomy.Rudy Amador3. Agree that it would be good to include minimum requirements andannual training for inspectors.

Sandia MartinQ2: I don't think satellite offices should be run by non-governmentcompanies and then certified by the government. They should beRUN by the government and gov employees. This would hopefullycreate consistency throughout the country.Mark KastelThe NOP is breaking with decades of precedent in bypassing theNOSB in creating rulemakin

Karlin Warner Karlin Warner - OneCert, Inc. Colleen O'Brien Colleen O'Brien, WSDA Organic Program Marty Dagoberto Northeast Organic Farming Association, Massachusetts Chapter Rudy Amador Rudy Amador - Dole Fresh Fruit Leona Propson Leona Propson, Briess Malt & Ingredients Company. Jessie Jessie Jessie Bovay, Mercaris