California Certified Organic Farmers (CCOF)	
  Dominique Navarro
March 2012
Peter Gourevitch
Corporate Social Responsibility
	
  

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Table of Contents
Organics

2

CCOF

3

Accreditation and Clients

5Standards

7

Certification

10

Certification Services

11

Costs

12

Noncompliance

14

Credibility Issues

17

Conclusion

20

Helpful acronyms:
CCOF – California Certified Organic Farmers
GVD – USDA Grading & Verification Division
GM – Genetically Modified
NOP – National Organic Program
USDA – United States Department of Agriculture

Executive Summary
California Certified Organic Farmers (CCOF) is one of the oldest, largest, and mostrespected organic certification agents in the United States. Although in compliance with dozensof domestic and international standards, CCOF primarily works on behalf of the United States
Department of Agriculture National Organic Program. The organization certifies organic farms,
processors, and handlers through a six-step process including a yearly on-site inspection.
However the process is costly and has the potential to push out smaller firms from the market.
Additionally, on-site inspections are scheduled beforehand, provoking some questions into thecredibility of the process. Nevertheless CCOF maintains a relatively open discussion with both

	
  

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members and the public in order to sustain its credibility and reputation and the integrity oforganic products.

Organics
The modern organic agriculture movement is thought to have begun with British botanist
Sir Albert Howard who famously documented traditional Indian farming practices in his 1940
book An Agricultural Testament1. The book was highly popular and influenced many scientists
and farmers of the day including Lord Northbourne who first coined the term “organic farming”.
As part of the environmental movement spurred by Rachel Carson’s book Silent Spring, theorganic movement sought to encourage consumption of local food grown without the use ofsynthetic fertilizers, pesticides, or genetic engineering. The current definition of organic
maintained by the United States Department of Agriculture is “[…] a food or other agricultural
product that has been produced using cultural, biological and mechanical practices that foster
cycling or resources, promote ecological balance, conserve biodiversity and do not the use ofsynthetic fertilizers, sewage sludge, irradiation, and genetic engineering”2.
The United States Department of Agriculture currently oversees the National Organic
Program that regulates all organic products, livestock, and agricultural products. Products thatwish to use the USDA organic seal must be verified by a USDA-accredited certifying agent andshown to be in compliance with the organic standards developed by the National Organic
	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
1

	
  “HRH	
  delivers	
  the	
  Sir	  Albert	
  Howard	  Memorial	
  Lecture”.	
  Latest	
  Speeches	
  and	  Articles.	
  1	
  October	
  2008.	
  The	  Prince	  of	
  Wales.	
  <http://www.princeofwales.gov.uk/speechesandarticles/hrh_delivers_the_sir_albert_howard_memorial_lecture_471496085.html>.	
  2
	  “What	  is	
  Organic?”.	
  National	
  Organic	
  Program.	
  27	
  October	
  2011.	
  United	
  States	  Department	
  of	
  Agriculture,	  Agricultural	
  Marketing	
  Service.	
  <http://www.ams.usda.gov/AMSv1.0/ams.fetchTemplateData.do?template=TemplateC&navID=NationalOrganicPr
ogram&leftNav=NationalOrganicProgram&page=NOPConsumers&description=Consumers&acct=nopgeninfo>.	
  

	
  

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Program. Unless gross farm income is less than $5,000 per year, a facility cannot call itself“organic” without certification by the USDA or an accredited certifying agency. Similarly,
production or handling operations that have gross income from organic sales less than $5,000 are
also exempt from certification. Any retail food establishment that handles organically produced
products but does not process them is exempt from requirements.
Although the USDA does certify facilities, it relies mostly on accredited certifying
agents. Certifying agents are private, foreign, or State entities authorized to certify farms orprocessing facilities to the USDA organic standards3. There are currently 50 domestic and 41
foreign certifying agents offering accreditation to USDA standards. California Certified Organic
Farmers is the largest organic certifier in California and one of the largest accredited certifying
agents in the nation.

CCOF
California Certified Organic Farmers was founded in 1973 as an organic certification
organization and is based in Santa Cruz, California. It was one of the first certifying agencies inNorth America and its standards became the basis for the 1990 California Organic Foods Act andlater the USDA National Organic Program4 The organization currently has more than 2,000
certified members in the farm and food processing community and works with over 1,300
different organic crops and products in four different countries: U.S., Mexico, Costa Rica, and

	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
3

	
  “Information	
  for	
  Certifying	
  Agents.”	
  National	
  Organic	
  Program.	
  5	
  March	  2012.	
  United	
  States	  Department	
  of	
  Agriculture,	
  Agricultural	
  Marketing	
  Service.	
  <http://www.ams.usda.gov/AMSv1.0/ams.fetchTemplateData.do?template=TemplateN&navID=CertifyingAgentsli
nkNOPCertifiedOperations&rightNav1=CertifyingAgentslinkNOPCertifiedOperations&topNav=&leftNav=NationalOr
ganicProgram&page=NOPCertifyingAgents&resultType=&acct=nopgeninfo>.	
  4
	  Rappaport,	
  Scott.	
  “New	
  book	  traces	  UCSC’s	
  role	  in	
  organic	
  and	
  sustainable	
  farm	  movement”.	
  UC	
  Santa	
  Cruz	  News.	  09	  February	  2012.	
  <http://news.ucsc.edu/2012/02/history-­‐organic-­‐book.html>.	
  

	
  

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Canada5. CCOF is an accredited certifying agency for the United States Department ofAgriculture National Organic Program. Thereby, CCOF certifies to the standards of this program
as well as other international standards. CCOF is comprised of three separate components:
CCOF Trade Association, CCOF Foundation, and CCOF Certification Services. The CCOF
Trade Association works to build consumer demand and public support for organic products
through education, marketing, and public relations. CCOF Foundation is the nonprofit branch of
the organization with the following aims: 1) To support organic farmer’s efforts to conserve
biodiversity, 2) To accelerate the transition to organic agriculture, and 3) To educate consumers
about the benefits of organic food and farming. CCOF Certification Services is a wholly owned
subsidiary of CCOF Trade Association that certifies farm and livestock operations, processors,
retailers, private labelers, and restaurants. For the purpose of this analysis, focus will be
primarily on CCOF Certification Services. CCOF also has two other subsidiary organizations:
the Organic Farming Research Foundation (OFRF) and the Organic Materials Review Institute(OMRI). OFRF funds research related to organic farming practices while OMRI researches anddistributes information about the materials that can be used in organic food production.
CCOF’s Board of Directors is comprised of 8 directors and 4 officers, elected by certified
members for two year terms. Of the four officers, three come from organic farms that are
certified by the CCOF. All eight of the directors are from organic farms, orchards, or vineyards
certified by the CCOF. The organization also has several committees dedicated to certain topics
such as Certification Standards, Finance, Bylaws, Marketing, Personnel, and Government
Affairs. The most important committee with regards to this analysis is the Certification Services
Management Committee. This committee of six members is in charge of establishing and
	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
5

	
  Unless	
  otherwise	
  noted,	
  all	
  information	
  is	
  from	  the	  “CCOF	  Certification	
  Services,	
  LLC	  Manual:	
  A	
  Guide	  to	
  CCOF	  Certification	
  Services”	
  

	
  

5	
  
	
  

updating CCOF organic certification standards and managing the certification component of theorganization. Members are appointed by the CCOF Board of Directors for three-year terms. Of
the current six members, one is from a CCOF certified farm, another is retired, three are fromwest coast universities, and the last is a representative from CLIF Bar & Company.
The composition of the Certification Services Management Committee adds to thecredibility of the organization and the certification process. Having only one CCOF certified
farm on the committee helps to ensure that farms are not allowed to influence the certification
standards for their own benefit, against the consumer. Additionally, the presence of three
agricultural specialists in academics further contributes to the credibility of the standards in that
there is more probability that the standards have been researched and demonstrated to be both
attainable and of some benefit to organic consumers. However, regulatory capture could still
occur within CCOF since the committee members are appointed by the Board of Directors, all ofwhich are CCOF certified facilities. It is highly unlikely that the Board of Directors would
nominate a candidate that would work against their interests as business owners so their
appointments will probably not be people who want to make standards more difficult to comply
with.

Accreditation and Clients
CCOF was accredited to the National Organic Program as a certifier on April 29, 2002,
shortly after the creation of the NOP standards6. The USDA accreditation is a four-step process
handled by the USDA Grading & Verification Division (GVD). To begin the process,prospective agents must submit their quality manual for adequacy review in order to evaluate
	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
6

	
  “USDA	  Accredited	
  Certifying	
  Agents	
  (ACAs)”.	
  National	
  Organic	
  Program.	
  22	
  March	  2012.	
  United	
  States	  Department	
  of	
  Agriculture,	
  Agricultural	
  Marketing	
  Service.	
  <http://www.ams.usda.gov/AMSv1.0/ams.fetchTemplateData.do?template=TemplateJ&page=NOPACAs>.	
  

	
  

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their compliance with NOP regulatory parameters. Then an assessment team will visit the officelocation/sites to assess the employees and system of records. Once GVD has completed theinitial audits, the Accreditation Committee will recommend approval or denial for accreditation
to the NOP Administrator. A $500 application fee is charged as well as the $108 per hour charge
for the on-site assessment. The average cost for the process is $4,428 per year7. After theorganization is approved, it is accredited for five years. At the two and a half year mark andagain at the 5 year mark (for renewal purposes), on-site assessments will again be conducted by
GVD staff. The USDA conducts audits of more than 90 organic certification agencies annuallyin order to ensure that they are properly certifying organic products2.
With over 80% of the organic farmland in California under its certification, California
Certified Organic Farmers is undoubtedly the largest organic certifying agency in the state. The
organization certifies both crops and livestock and their certified products range from beef tochocolate. The top three crops that it certifies are: 1) Grain, 2) Mixed vegetables (including
herbs), and 3) Tree fruits and vines. Meanwhile the top three livestock types it certifies are:1) Dairy, 2) Poultry/eggs, and 3) Beef8. CCOF also certifies some of the largest and mostrecognizable organic farms, handlers, and processors in the nation. Included in this category are:Acai Roots, Dole, Campbell’s, Foster Farms, Driscolls, and Whole Foods. With such large
clients, CCOF has an important responsibility in maintaining the organic reputation of not only
itself but of these firms as well.

	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
7

	
  “Becoming	
  a	
  Certifying	
  Agent”,.	
  National	
  Organic	
  Program.	
  14	
  September	
  2011.	
  United	
  States	  Department	
  of	
  Agriculture,	
  Agricultural	
  Marketing	
  Service.	
  <http://www.ams.usda.gov/AMSv1.0/ams.fetchTemplateData.do?template=TemplateN&navID=NOPFAQsHowAcc
redited&topNav=&leftNav=NationalOrganicProgram&page=NOPFAQsHowAccredited&description=FAQ:%20%20B
ecoming%20a%20Certifying%20Agent&acct=nopgeninfo>.	
  8	  “CCOF	  Certifier	
  Profile”.	
  Guide	
  to	
  U.S.	
  Organic	
  Certifiers.	
  28	
  October	
  2008.	
  Rodale	
  Institute.	
  <http://newfarm.rodaleinstitute.org/ocdbt/displayCert.php?id=27>.	
  

	
  

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Standards
CCOF’s certification programs operate in compliance with local, state, federal, andinternational organic regulations and standards. The primary regulations and standards it aims tocomply with are: USDA’s National Organic Program (NOP) Federal Rule, International
Standardization of Organization (ISO) General Requirements for Bodies Operating Product
Certification Systems, ISO European Economic Community Regulations 834/2007 (EEC), andthe Canadian Organic Regime (COR).
To be sold or labeled as organic, the product must be produced and handled without theuse of:•synthetic substances and ingredients•nonsynthetic substances prohibited by the National Organic Program•

nonagricultural substances used in or on processed products•

excluded methods, except for vaccines provided that the vaccines are approved by the
USDA•

ionizing radiation or•

sewage sludge

For certification a producer or handler of the organic product must develop an organic
production or handling system plan that is agreed upon by the producer/handler and theaccredited certifying agent. The organic production or handling system plan must include:
1) A description of practices and procedures to be performed and maintained including
the frequency with which they will be performed

	
  

8	
  
	
  

2) A list of each substance to be used as a production or handling input, indicating its
compositions, source, location(s) where it will be used, and documentation of commercial
availability3) A description of the monitoring practices and procedures to be performed andmaintained, including the frequency with which they will be performed, to verify that the plan iseffectively implemented
4) A description of the recordkeeping system implemented to comply with therequirements of the USDA National Organic Program5) A description of the management practices and physical barriers established to prevent
commingling of organic and nonorganic products on a split operation and to prevent contact oforganic production and handling operations and products with prohibited substances
6) Additional information deemed necessary by the certifying agent to evaluate
compliance with the regulations
The land requirements for any field or farm that intends to produce organic products must:•

Have had no prohibited substances applied to it for 3 years preceding the harvest of thecrop•

Have distinct, defined boundaries and buffer zones to prevent the unintended applicationof a prohibited substance from adjoining land that is not under organic management to
the organic crops

CCOF also requires that producers manage soil and crops according to their definition ofsustainability:

	
  

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•

The producer must select and implement tillage and cultivation practices that maintain or
improve the physical, chemical, and biological condition of soil and minimize soil
erosion•The producer must engage in crop rotation, cover crops and the application of plant andanimal materials to manage crop nutrients and soil fertility, specifically compost•

The producer must manage plant and animal materials to maintain or improve soilorganic matter content in a way that does not contaminate crops, soil, or water withpathogenic organisms, heavy metals, plant nutrients or prohibited substances. Included inplant and animal materials are: raw animal manure, composted plant and animal material,and uncomposted plant material.

Seeds and planting stock are also regulated under CCOF standards. The producer must use
organically grown seeds, seedlings or planting stocks unless an equivalent organically produced
variety is not commercially available.
As a USDA accredited certifying agent, CCOF is obligated to use NOP standards in its
certification process. By enforcing these standards to the fullest, CCOF is seeking to convince
the USDA that it is a credible third-party agent capable of undertaking the responsibilities
delegated to all certifiers. Simultaneously, the organization is attempting to prove the same toorganic consumers, producers, handlers, and processors. Clearer and stricter standards will draw
in consumers genuinely interested in organic products who tend to be more loyal to the
movement, rather than embracing it as a cultural fad. If CCOF is able to establish itself as acredible and capable third-party agent, it will attract more clients by demonstrating that
consumers trust their certification and label.

	
  

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Certification
The organic certification process is a six step process that typically takes between six toten weeks. A person seeking to receive or maintain organic certification must request an
application packet from CCOF. The first step in the process is the completion and submission of
the Organic System Plan (OSP) and the application. The Organic System Plan, as previously
mentioned, is a documentation of the organic operation of the facility and how the operation
fulfills required organic standards promulgated by the USDA National Organic Program. The
application and OSP must be submitted with a one-time $275 application fee. The second stageof the process is the review. In the initial review stage, a CCOF certification specialist will assess
the OSP and application. If the specialist believes that the facility/operation is ready to move
forward towards organic certification, then a Regional Service Representative (RSR) is assigned.
The RSR will arrange for a trained inspector to perform an on-site inspection, which is the third
step in the process.
The inspection will be scheduled beforehand with the facility and the inspector will
request what they want to see, who they want to talk to, and what records they need prior to thevisit. This pre-planning could potentially compromise the legitimacy of these evaluations. If
facilities/operations are given the opportunity to prepare for an on-site inspection, they could
take advantage of the prior notice and essentially “clean up” for the inspector. While on-site theinspector must verify that the details in the Organic System Plan and application are being put
into practice. Although not very probable, there is the possibility that facilities could cover up
violations in their Organic System Plan in preparation for the inspection.
With regards to costs, the inspector bills CCOF who in turn bills the inspected party forthe time and expenses of each inspection. The inspection is billed at $60 per hour (minimum one

	
  

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hour charge), travel time is billed at $42.50 per hour and expenses including mileage, food andlodging are billed in addition. A report of the inspection will be submitted to CCOF. The fourthstage of the process is a second review stage. A CCOF certification specialist will review theinspection report alongside the OSP and the initial application. The facility will be contacted in
the case of any non-compliance issues.
After the completion of the second review process, the fifth stage of the certification
process begins: the certification status notification. CCOF will inform the facility/operation of
their certification status and any requirements for ongoing certification. The final step in thecertification process is the annual renewal phase. To remain certified, facilities and operations
must be re-inspected annually. Again, the inspection process is scheduled beforehand and thefacility is charged for the cost of the inspection. After a positively reviewed inspection andpayment of annual certification fees, certification is renewed. Following the initial certification, afederal license will be issued to the facility until it is withdrawn, suspended or revoked.

Certification Services
CCOF provides clients with access to the CCOF seal of certification however the client is
responsible for use of the seal. The client is allowed to alter the colors of the CCOF seal however
it may not be modified in other ways. Clients are also given the option to use the USDA Organic
seal and all labels must be pre-approved by CCOF prior to printing. CCOF is also responsible forpre-harvest or post-harvest testing of any input or final product when there is reason to believethat the agricultural input or product has come into contact with a prohibited substance. CCOF
will collect and test soil, water, waste, seed, plant tissue, and animal and processed productsamples. The client will be provided with the testing and results free of charge. If the tests

	
  

12	
  
	
  

indicate pesticide residue or contaminants that exceed the FDA or EPA’s regulatory standards,
CCOF will report the data to the appropriate Federal health agency. CCOF will provide a free
investigation to determine the cause of the prohibited substance. If a client applies a prohibited
substance due to a Federal or State emergency pest or disease program and the client otherwise
meets CCOF requirements, the certification status of the client will not be affected. However theclient is not able to sell, label or represent the product as an organic product.
The concern with which CCOF deals with prohibited substances contaminating organic
products speaks to the organization’s dedication to the quality of organics. Since CCOF is
willing to take on the cost of testing for any facility that requests it, the organization
demonstrates that it is prepared to front some of the expenses involved in maintaining the
integrity and status of organic products, disproving the notion that the organization is engaging
in “cheap talk”.

Costs
Annual certification costs vary according to facility size but most small farms andprocessors are certified for anywhere between $400 and $1000 however the total maximum
certification fee is $35,000. Fees are based on the Organic Production Value (the amount oforganic product produced, even if it is not sold) of the facility for the previous year. The Organic
Production Value is determined using sales records and production information that must be
provided for review at the annual certification inspection. This information is made available to
the CCOF, USDA Secretary and applicable State Organic Program Governing Official. New
organic farms are routinely certified for approximately $700 the first year and between $300 and$500 in later years. New organic processors are routinely certified for about $1200 in the first

	
  

13	
  
	
  

year and approximately $900 in the later years. Costs include the $275 application fee, theinspection costs, and the annual certification cost. Annual certification fees are payable on
January 1 of each year and CCOF may charge a $75 late fee for missing the due date. Larger
operations must pay higher fees but also benefit from services not offered to smaller clients suchas political advocacy, PR support, multiple facility programs, export document processing andother services that CCOF doesn’t publicly specify. CCOF also offers additional services for a fee
such as international standards verification, mid-year additions of acreage or processed products
and completion of export documents. The organization also certifies clients outside the UnitedStates but there is a $1200 minimum fee.
Although the certification costs are highly affordable for large Clients like Whole Foods,
the costs may be too high for smaller farms and processors. Since any farm producing over
$5,000 worth of product a year must be certified by the USDA or an accredited agency in order
to sell certified organics, some small farms may be overly burdened with the certification costs.
A farm with only $5,000 of income a year would have to dedicate up to $1,000 for certification
by CCOF, 20% of its income (not including costs). This has the potential to push smaller
businesses out of the organic industry, leaving CCOF with only medium and large Clients.
Besides the lack of diversity in the organic market caused by this exclusion, it could also givelarger businesses more sway in the CCOF standards and operations. With a more concentrated
number of large Clients, CCOF might be more easily influenced to please these Clients,
potentially giving in on standards or enforcement in order to keep a valuable customer.

	
  

14	
  
	
  
ANNUAL CERTIFICATION FEE TABLE CCOF Certification Services Fee
Schedule (all amounts in dollars)
Effective October 1, 2011
Organic Production ValueFee (in dollars)
At Least
Not More Than
Producer
Handler$0$10,000
200
10,00020,000275
20,00150,000350
50,001
100,000
525
600
100,001
200,000
600
650
200,001
300,000
725
725
300,001
400,000
875
875
400,001
500,000
1,050
1,050
500,001
600,000
1,500
1,500
600,001
700,000
1,700
1,700
700,0011,000,000
2,200
2,200
1,000,001
1,500,000
3,300
3,300
1,500,001
2,000,000
3,850
3,850
2,000,001
2,500,000
4,400
4,400
2,500,001
3,000,000
4,950
4,950
3,000,001
3,500,000
5,500
5,500
3,500,001
4,000,000
6,050
6,050
4,000,001
5,500,000
7,150
7,150
5,500,001
10,000,000
9,900
9,900
10,000,001
15,000,000
17,00017,00015,000,001
150,000,000
25,00025,000Greater than 150,000,000
35,00035,000$350
Minimum fee for mixed organic and nonorganic (all types, all crops).
$525
Minimum fee for livestock operations withgreater than 10 animals.
$1200
Minimum fee for clients outside of the 50
United States.

NoncomplianceIn the case of noncompliance after an inspection, review, or investigation, a written
Notice of Noncompliance will be sent to the Client. The notice will include a description of eachnoncompliance, the facts upon with the noncompliance is based, and the date by which the Client
must rebut or correct each Noncompliance and submit supporting documentation of each

	
  

15	
  
	
  

Corrective Action. Copies of all Notices of Noncompliance are submitted to the USDA National
Organic (NOP) Program Administrator. The Client is then given the choice to: 1) Correct
Noncompliance and submit a description of the Corrective Actions and supporting documents to
CCOF, 2) Surrender certification, correct Noncompliance and submit a new application to CCOF
or another certification agency, or 3) Submit written information to CCOF to rebut theNoncompliance. CCOF will evaluate the Client’s supporting documentation or the rebuttal,
perform an on-site inspection if necessary, and issue the Client an approval of certification. If theCorrective Action or rebuttal is not sufficient or if the Client fails to respond to the Notice ofNoncompliance, CCOF may deny certification or propose suspension or revocation. Clients are
responsible for the fees and invoices due at the time of their revocation or withdrawal from theprogram. Any outstanding invoices that are not paid within 120 days from the date of the invoice
will be sent to collections and a collection penalty of 35% of the amount will be charged.
For new producers or handlers, if Corrective Action or rebuttal is not sufficient to qualify
for certification, CCOF will provide a Notice of Denial of Certification. Applicant’s have theoptions to: 1) Reapply for certification, 2) Request mediation, or 3) File an appeal of the denial.
The USDA NOP Administrator receives a copy of all Notices of Denial of Certification. When
the Corrective Action or rebuttal is not sufficient in the prescribed time period for previously
certified producers and handlers, CCOF sends the Client a written Notice of Proposed
Suspension or Notice of Proposed Revocation of the entire Operation or a portion of the
Operation. The CCOF may also send the Client a Notice of Proposed Suspension or Notice of
Proposed Revocation if the CCOF has reason to believe that the Client willfully violated theapplicable standards. The USDA NOP Administrator also receives a copy of the Notices ofSuspension and Revocation. In the case that a Client knowingly sells or labels a product as

	
  

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organic when it is not in accordance with the organic regulations, the Client shall be charged apenalty of not more than $11,000 per violation.
This penalty is levied by the U.S. Department of Agriculture and may also be applicableto certification agencies that certify a Client that is not in accordance with organic regulations.
Therefore, if a CCOF Client is certified as organic when they are not, CCOF maybe also be
penalized up to $11,000 per violation. Therefore, CCOF must absorb a substantial cost if they
fail to be credible. This penalty demonstrates that CCOF is not engaging in cheap talk, but rather
risking up to $11,000 per Client if they fail to properly certify and verify compliance.
A Client whose certification has been suspended may submit a request to the Secretary
for reinstatement of its certification. The request must include evidence demonstrating thecorrective actions taken to comply with and remain in compliance with the organic regulations
and standards. The Client must pay any applicable review and processing fees. The reinstatement
request and evidence will be provided to the USDA for a decision.
When a facility’s status is suspended or revoked, the USDA National Organic Program
publishes the facility’s name, location, certifying agency, and reason for suspension/revocation
on a PDF list on the USDA website. Between January 2010 and February 2012, 473 facilities
were placed on the list of “Suspended and Revoked USDA Organic Operations”9. Forty-threeaccredited certifying agencies were associated with the facilities on the list. Of those listed, 33
were CCOF accredited operations. Considering that CCOF is one of the accredited agents withthe most facilities, their share of operations on the list is relatively minimal. CCOF’s competitors(Organic Certifiers, Oregon Tilth, and Organic Crop Improvement Association) have a muchhigher percentage of facilities on the list than CCOF. This can have multiple meanings for the
	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
9

	
  “Suspended	
  and	
  Revoked	
  USDA	  Organic	  Operations”.	
  Jan	  2010	
  –	
  Feb	  2012.	
  <http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5083817&acct=nopgeninfo>.	
  

	
  

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reputation of the agency. One possibility is that the agency provides enough support andeducation to Clients throughout the certification process that the facilities are more likely tocomply with the standards. If CCOF offers full information regarding the standards andexpectations, then Clients would be better prepared for the process.
The other likely possibility is that CCOF makes the certification process easy enough thatthe vast majority of its Clients fulfill all requirements. In the reasons listed for suspension or
revocation in the USDA published list, “failure of on-site inspection” appears only twice for exCCOF operations. The rest of the reasons are mostly the following: “failure to pay fees”, “failure
to meet general requirements”, and “inadequate documentation/recordkeeping”. The rarity withwhich ex-CCOF clients fail certification suggests that the on-site inspection is not a credible
monitoring strategy; this is likely due to the fact that the inspections are not random orspontaneous. Although these inspections may be quite thorough, the scheduling of them
beforehand with the site reduces the chances that the facility will be caught in violation of one of
the standards.

Credibility Issues
California Certified Organic Farmers has established both historical and reputational
credibility in the organic industry. CCOF’s standards were used as the model for both the
California Foods Act of 1990 and the USDA’s National Organic Program. In fact, the firstorganic legislation in the nation, the California Organic Food Act of 1979, directly copied CCOF
standards10. However, as a USDA accredited certifying agency, California Certified Organic
Farmers must use the standards set by the USDA NOP and to the dismay of many organic
	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
10

	
  Newman,	  Patrick.	
  “A	
  Brief	
  History	
  of	
  Ethical	
  Stamps	
  and	
  Seals”.	
  FairTruth	
  Certified.	
  <http://fairtruth.org/history.php#_ftn23>.	
  

	
  

18	
  
	
  

advocates, these standards are lower than those previously held by the CCOF suggesting that the
CCOF has been even more historically credible than its federal overseer.
The composition of both governing bodies and CCOF membership also contributes to thecredibility of the organization. Members of California Certified Organic Farmers range from thesmall to large facilities though the majority of accredited facilities are medium sized farms andprocessors. The diversity in membership suggests that the certification process is standardized,
applicable, and fair to all facility sizes. The members of the governing bodies are also relatively
diverse. Farmers, processors, academics, and even a retired community member make up thecertification committee suggesting that there is effort to keep interests relatively balanced.
CCOF also increases its credibility through its frequent and public communications withmembers. Once a year, the organization holds an annual meeting in California for clients togather and discuss organic issues both within CCOF and in the sector in general. During thismeeting CCOF seeks out the input from its clients on important decisions. A recent issue waswhether to drop one of the EU standards from its requirements. Clients were asked to give theiropinion on the issue both in the meeting and through online surveys that were distributed to allmembers who could not attend. CCOF also publishes a monthly magazine (available only inprint to CCOF clients but in electronic form to the general public) in which it publishes a variety
of information relevant to both consumers and clients. In this magazine, the organization
publishes a list of facilities no longer organically certified by CCOF. This list is also publishedby the USDA NOP Administrator. The availability of this information to consumers suggeststhat CCOF cares about the consumer in addition to their own reputation. By distancing
themselves from ex-clients, CCOF is seeking to maintain their reputation in the organic industry

	
  

19	
  
	
  

and better inform consumers about their purchasing options. This relatively open dialogue withboth clients and the public contributes to CCOF’s credibility as a third-party certification agent.
Some of the biggest issues affecting CCOF credibility are industry-wide and affect all
certifying agents. Because CCOF and other certifiers are under the authority of the USDA, theymust abide by the decisions made by department. One credibility issue that has distanced someconsumers is the variety in the definitions of “organic”. There are four designations of organic
signifying different variations in the level of organic production. CCOF and the USDA certify
the two most stringent levels: “100% Organic” and “Organic”, the latter of which means that the
product contains at least 95% organic ingredients. The other two definitions that are not as
closely monitored or certified are “Made with Organic Ingredients” and “Contains Organic
Ingredients”. The first is defined as having at least 70% organic ingredients and the second is any
level below 70%. With such variance in the use of the word organic, some consumers have been
turned off by these products due to the confusion. Consumers who prefer organic diets have been
particularly turned off by the ambivalence with which some companies designate their products
as organic. Unfortunately some of the criticism has fallen on CCOF and some consumers are
calling for stricter rules on the usage of the term organic despite the fact that this falls outside of
CCOF’s limitations and the organization can only press the USDA on behalf of consumers.
Another issue that CCOF is taking heat for on behalf of the USDA is the recent
legislative decision made by the department. In January 2011, the USDA deregulated the use ofRoundup Ready Alfalfa for use as feed for cattle11. Opponents are upset because geneticallyengineered alfalfa necessitates the use of more toxic herbicides, threatens biodiversity, andwould be unaffordable to small farmers should they decide they wanted to use it. Without
	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
11

	
  Markowitz,	
  Eric.	
  “Organic	
  Industry	
  Fuming	  Over	  Obama	
  Ruling”.	
  1	
  February	  2011.	
  INC.	
  <http://www.inc.com/articles/201101/organic-­‐industry-­‐fuming-­‐over-­‐obama-­‐ruling.html>.	
  

	
  

20	
  
	
  

regulation, Roundup Ready Alfalfa would be able to be grown anywhere, even near organic,
heirloom alfalfa, potentially cross-contaminating these crops. Both producers and consumers
have boycotted the decision and expressed their disappointment with the USDA. Some worry
that this could lead to further de-regulation of genetically modified crops, leading to lessintegrity in the organic brand.
This worry and disappointment was compounded later in the year when consumers
discovered that strawberries from Driscoll Strawberry Associates were not as pesticide-free as
represented. Although the strawberries themselves have never been treated with pesticides, moststarts grown by farms subcontracted by Driscoll have been treated with methyl bromide before
the plants bear fruit12. As a CCOF certified facility, Driscoll’s is a potential liability for theorganization however it must follow USDA regulations and standards. The Driscoll case is yet
another example of the lack of transparency in the general USDA standards and how USDA
decisions can inevitably affect the credibility of its agents, including CCOF. Nevertheless, it
should be noted that CCOF does not have credibility issues that cannot be generalized to theentire organic industry or traced back to the decisions undertaken by the USDA.

Conclusion
Although CCOF and the organic industry are currently facing several credibility issues,
California Certified Organic Farmers has proved itself to be one of the most historically credible
certification agents in the USDA National Organic Program. Despite some of these issues being
beyond the scope of CCOF’s capacity, the organization could undertake some actions to increase
their credibility to consumers and facilities.
	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
   	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
12

	
  Gross,	
  Rachel.	
  “Organic	  Strawberries?	
  Not	  so	
  Much”.	
  22	
  September	
  2011.	
  The	  Bay	
  Citizen.	
  <http://www.baycitizen.org/food/story/organic-­‐strawberries-­‐not-­‐so-­‐much/2/>.	
  
	
  

	
  

21	
  
	
  

To diversify its general membership and potentially that of its governing bodies as well,
CCOF could offer additional assistance funds or subsidies to cover certification costs for small
facilities. The organization has offered this before in the past, yet during the current economic
downturn, this assistance would be especially beneficial. With more diversity in theirmembership and in the board and committees, CCOF could increase its credibility bydemonstrating that no interest group is more represented or given more input than another.
In order to combat some of the issues arising out of the USDA and its decisions, CCOF
should first carry out an educational campaign to explain the differences in organics existent
within the industry. By better informing the consumer, the organization could help reestablish
consumer confidence in the integrity of organic products and certification. As a second option,
CCOF could choose to expand the standards they enforce beyond those of the NOP. Fulfilling
the NOP organic standards and then adding some of their own relating to CCOF specific values,
like the prohibition of fumigants or GM plants, would help set the organization apart from recent
USDA scandals. This could increase consumer confidence in their certification process andappease clients that have been advocating for stricter standards in order to further distinguishtheir products as a product of value, worthy of a higher price and reputation. Of course, thissecond move should be taken after extensive discussions with clients in the annual meetings,
surveys, and newsletters.
Finally and most importantly, California Certified Organic Farmers could easily increasecredibility in its certification process by engaging in random checks on facilities. Since clients
will undoubtedly undergo different business cycles, the one pre-scheduled inspection willcontinue to be a fair assessment of compliance with the standards. However, conducting random
checks will allow for a more realistic picture of the day-to-day operations of facilities and their

	
  

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daily compliance. Though this move might be unpopular with some clients, those that care about
the reputation of organic products would likely not be opposed as this will only increase thecredibility of CCOF and the integrity of the products it certifies.