National Organic Standards Board

Certification, Accreditation, Compliance Subcommittee (CACS)

Oversight to Deter Fraud: Residue Testing for a Global Supply Chain 

Discussion Document

February 6, 2024

Introduction: 

The Certification, Accreditation, & Compliance Subcommittee (CACS) presented a discussion document

at the Fall 2023 NOSB meeting on Residue Testing for a Global Supply Chain (RTGSC). Many 

commenters supported continuous improvement in testing to ensure integrity, considering the size of 

the organic marketplace and the program's global reach.

The RTGSC series aims to work with the community to provide a recommendation that ensures testing 

remains a relevant and effective tool for compliance verification in the organic global supply. A fall 

public commenter in support wrote, “An updated and more rigorous testing program will augment the 

ability for both ACAs and certified operations to verify compliance, deter fraud, and prevent 

contaminated/fraudulent products from entering organic supply chains.”

Foundational Focus and Timing:

Foundational work is needed first to accomplish the goals. Therefore, this document will focus on 

working with the organic stakeholder community to update the foundational elements found in the 

respective related guidance and instruction documents. As one commenter stated, “...ensure there can 

be clarity and consistency in the testing and response practices.” 

Next Steps: 

CACS is open to general feedback about the importance of residue testing, suggestions for incorporating 

residue testing more thoroughly in the organic compliance verification process, and barriers to 

implementing residue testing programs in the organic supply chain. Additionally, CACS has several 

questions about residue testing document instructions in the NOP Handbook. 

CACS will consider all general and specific comments in developing recommendations to NOP. 

Stakeholder Questions: 

NOP 2610: Instruction Sampling Procedures for Residue Testing 

1. Does this document instruction provide adequate information for certifiers and inspectors to 

collect samples in the field?

2. Are there areas pertaining to sample collection (sample size, when to collect samples, sample 

selection, etc.) that need to be developed or improved? Please provide suggestions.

3. How can additional instruction or guidance on sample collection support the voracity of testing 

results so that adverse actions are more defendable?

NOP 2611: Instruction Laboratory Selection Criteria for Pesticide Residue Testing 

1. Section 4.1 describes one type of residue screen that can be used for testing. What additional 

tests should be included in this section (e.g., heavy metals, synthetic solvents, fumigants, 

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herbicides, etc.)? What should be the threshold for validating additional testing methodologies 

in this section to ensure results are actionable?

2. Sections 4.2 and 4.3 describe laboratory selection criteria and suggested laboratory practices. 

Do either of these sections need to be updated to align with current best practices?

3. How can additional instruction or guidance on laboratory selection criteria and testing 

methodology support the voracity of testing results so that adverse actions are more 

defensible? 

NOP 2611-1: Prohibited Pesticides for NOP Residue Testing 

1. Does this list of prohibited substances provide value to certifiers in evaluating organic 

compliance? 

2. How can this document be improved?

3. Would certifiers find value in developing a decision tree to determine which tests should be 

conducted depending on the commodity, geographical location, and position within the supply 

chain? Please describe how a decision tree could assist certifiers with testing and compliance 

verification. 

NOP 2613: Instruction Responding to Results from Pesticide Residue Testing 

1. Section 5.3.3 describes how to respond to positive results when there is no EPA tolerance or 

FDA action level. Please describe experiences attempting to respond to results in this type of 

situation. How can this section be improved to facilitate and support sampling and testing for 

prohibited substances that do not have EPA tolerances or FDA action levels (e.g., synthetic 

solvents)? 

2. Are additional sections within this instruction needing updating or improvement? Please provide 

suggestions.

Subcommittee Vote:

Motion to accept the discussion document on Residue Testing for a Global Supply Chain

Motion by: Nate Lewis

Seconded by: Kim Huseman 

Yes: 7 No: 0 Abstain: 0 Recuse: 0 Absent: 1

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