Q: How does the certification process in China work?
A: Certification is a form of auditing. The applicant — the organic operator or potential operation — submits an organic plan of how it’s going to manage the farm or processing plant to a certifier. Based on that, there are quite a few different programs out there now that organic operations can apply to. Your readers would be interested in the standards through the National Organic Program (NOP).
We do a pre-inspection review to determine if the applicants are eligible based on their paper work submission and organic management plan. They’re telling us what they’re going to do. We have staff that knows the standards and makes the assessment if they have met those standards. If they’re eligible, then an inspection is assigned.
Q: Who does the inspections?
A: The inspections are completed by a second party that is aware of the standards. We have a staff in house to review the work. OCIA at the present time only has three inspectors on staff. All other inspections we contract out through a body like Independent Organic Inspectors Association (IOIA), which is not related to OCIA.
Q: Who are these contracted inspectors? What are their qualifications?
A: Qualifications could be a combination of educational background and agricultural experience that could get you qualified to do inspections; these are not necessarily PhDs. We have an approval system for inspectors.
We operate in quite a few different countries throughout the world. In China there is a lot of interest in food safety. This is the same process we apply in China. Once inspectors are assigned, they’re given the organic operation plan, and any notes from the pre-inspection review. They do an on site audit of what the operation is doing at that point and they compare that with the organic management plan previously submitted.
Q: Are these U.S. inspectors?
A: Typically they’re local inspectors. Anywhere we operate in the world, we work with local people. If we had to fly U.S. inspectors to China, the cost would be so high. We look for local inspectors and make sure they are trained.
Q: Do you have an office in China?
A: We have three people working directly for us in China. The office manager there who’s responsible has a Ph.D. I’m not sure of the current number of Chinese inspectors now. It’s a group we contract individually. Your readers have to realize that’s the way we operate everywhere. Even in the U.S., the only staff inspectors we have are three training personnel. It’s a common practice.
Q: Do you find inspections and verifications more challenging in remote areas where technology systems are less advanced, or because of cultural differences?
A: We have a lot of small farms that we verify in North America, including the U.S., that don’t have access to computers and the Internet. It doesn’t matter if the operators are in China, Japan, Africa, or the U.S.; they have to demonstrate they have an organic management plan and are following it.
Q: Doesn’t much of this process depend on the truthfulness of the operator? Haven’t many of the reported food safety problems coming out of China been traced to fraudulent practices?
A: The biggest issue of fraud certification that has been exposed has been in the U.S. from an operation out of Texas about a year ago running conventional soybeans as organic. NOP was alerted to that and dealt with the deceptive practice swiftly.
With organic certification you have to realize we’re not sitting out there on the farms 100 percent of the time. So you rely on the integrity of those involved. This is an accepted method developed over the years. OCIA was one of the original certification groups. We’ve been applying the same methods about certificates and standards made about organics since the mid-1980s and before. In the process, we have things in place.
Once the inspector goes out, he writes a report, it’s brought back and the inspection plan and report are all looked at by a third party trained by our staff directly. We control that, providing another level of review. That’s when the certification decisions and any recommendations and requirements are made. We have checks and balances.
When a retailer buys something from an OCIA producer, we issue a transaction certificate, generally within 24 hours. If a Chinese operator is making a transaction with a retailer in the U.S., we keep track in our data base of who is certified.
These are not fraudulent documents. These papers come from us. From time to time, we get questioned whether this is real. We issue a transaction certificate saying this is an operation that has gone through the process and has done what is claimed on the certification. This process is done to reduce fraud of product coming into the market.
Q: But the certificate you issue is still based to a great extent on the integrity, as you said earlier, of the operator in continuing to follow the OCIA-approved plan since you are unable to monitor the practices regularly.
A: We do oversight. One of our goals is to increase inspections since the Dallas Morning News started this whole disparaging report questioning the legitimacy of organic certifications coming out of China. They had made some erroneous claims regarding three of our certified operations in China.
Q: Did you take any actions to refute the claims?
A: We contacted Mr. Yutaka Marianos, an independent, reputable Japanese inspector, to investigate and conduct an inspection of the Rizhao Huassai operations to confirm or dispel the newspaper accusations. We don’t hire him directly, but we use him in Japan to do organic certification. Claims made were very serious, and we wanted someone outside China to go in and do an unannounced inspection on these three operations. And all three were found by Marianos to be in compliance. Of course, that wasn’t written about after the sensational news story.
Q: What specific statements published in the Dallas newspaper article do you believe were erroneous? Did the reporters provide any documentation to back up these claims?
A: They called some of our operations, which were targeted as a prime concern because we’re seen as the only U.S. operations based in China for certification. Although our head office is in the U.S., we do have offices in other countries. Location of the head office isn’t really a concern in this case.
They had an interpreter, according to the reporter. One of the operations had claimed they had never seen an OCIA inspector. The person they talked to had actually signed an exit interview. At another operation they called, they weren’t speaking to the person responsible for the organic certification. The operator was also handling conventional product.
The reporter had asked if the operator used night soil — human feces to enrich the soil. Traditionally in China that’s used to fertilize crop. The person on the phone said, yeah, we use night soil in the field. When Mr. Marionas went out there, he showed that night soil wasn’t used in the organic fields, but was used in conventional fields.
Farm workers in a broccoli field
Q: We’ve heard from various sources, including scientists who have done work in China, that the widespread water pollution and other contaminants that have built up in the field over time makes it difficult to say any food grown in China truly meets U.S. organic standards.
A: A lot of our rivers are used to fertilize crops, so you don’t know if you’re ever far from human feces whether organic or conventional. We have six billion people on this planet. It’s is a fact of life. In organic standards, this is not allowed as direct input. At least in the operations called by the Dallas Morning News reporter, it wasn’t happening.
Q: Well, at least you could verify that to be the case during the time of the unannounced inspection. You mentioned a goal of increasing oversight. What types of actions are taking on this front?
A: We sent our three-person staff in March of this year to China because of these concerns to do additional trainings and to visit some of these farms and reiterate organic standards and OCIA practices. This was done at OCIA’s expense. [Editor’s note — see the attached OCIA practices document here.]
And the goal through our staff we’ve hired in China is to have 100 percent of all new applicants undergo a second unannounced inspection annually.
Q: Would that be two unannounced inspections annually then?
A: No. The new applicants would have the initial inspection and within that year an unannounced inspection.
Q: What about the applicants already approved?
A: And 67 percent of all returning applicants will get an unannounced inspection each year.They would already have been certified with us. This is to show OCIA is committed to organics and the concerns of product coming out of China. We want people to be able to trust the organic certification system. We don’t feel we need to do this, but we want to address the concerns and we know there are errors.
Part of the inspection process is a learning process for the applicant. The operator presents the plan; there is a pre-inspection and final review with requirements and recommendations. Inspections are a method of verification but also an opportunity for applicants to improve operations further.
Q: Are you always verifying to NOP standards?
A: NOP, the body here in the U.S., delineates standards. There are different standards for different countries and we even implement our own private standards.
OCIA was founded in 1985 and has been incorporated since 1987. We are membership-owned and board-controlled. The plan for now is to keep it about the same.
We recently finished our audit with IFOAM, International Federation of Organic Agriculture Movement. Most of their offices are located in Europe, including the headquarters. They’re a private standard, not government-managed. Japanese Agricultural Standards (JAS) went into play in 2000. We are accredited to JAS through our Japan offices.
NOP came about in 2002. Prior to that, all organics were regulated by private standards. This was not that long ago. We are accredited to NOP, and also to the Canadian organic standards, as well as to those of the Costa Rican body. We’re accredited by ISO-65, which conducts internal audits to make sure we’re doing what we say we’re doing.
Q: Are you able to certify to EU standards?
A: We offer EU verification, not EU certification, to sell products in Europe. We can verify you’re in compliance with European standards. We are currently trying to get the ability to certify into Europe.
Q: Will you be expanding your office in China to be more hands on?
A: We hired the three staff in China to do the unannounced inspection. We started the office a year ago before this. We were beefing up our work with China and we wanted to do more in native Chinese. When you translate you can lose the meaning.
We’re not new to China for certification. We’ve been working with China since 1994/1995. We introduced organics into China. We started working with a group there that started as a chapter and is now a certification body that provides certifications to local Chinese standards.
We don’t implement the local Chinese standards ourselves, but there are quite a few similarities, a lot of the same concerns regarding the inputs you use. And there is a focus on standards; not just what you put on the fields but how you manage the lands. Organics is interested in sustaining the land, being able to continue this process for generations, not just doing what North American practices. It’s not just about the feeding of unnatural fertilizers and chemicals to be sure it grows; it’s not that, it’s about making the soil healthier.
Q: Are you unique in the NOP certification services you provide in China?
A: There’s another big certifier that has a partnership with Quality Assurance International (QAI). They share an office in Japan, have an office in China and operate in other places around the world. We’re probably the only major U.S. company with a home office here that has an office in China. There are four foreign bodies in China all accredited by USDA to allow NOP certification to bring product to the USA.
Worldwide we have 2,500 organic operations and less than 10 percent come out of China.
We appreciate the time Mr. See and OCIA International took to help the industry better understand the organic certification process in China. There is no question that OCIA is a reputable organization and trying to do the right thing.
Yet, the interview is unlikely to reassure those with doubts about the true nature of Chinese organics.
First, it has long been recognized that the organic consumer wants more than simply product grown without synthetic fertilizers. That is why the rules specifically prohibit things such as irradiation and GMOs. There are real questions as if, fundamentally, it is possible to grow produce in much of China that Americans would feel comfortable with. Why? The general environmental situation in China continues to deteriorate.
We extend a hat tip to Steve Nasiff of Nasiff Fruit Company. Showing that intellectuals lurk in every corner of the produce trade, Steve sent us a piece from Foreign Affairs entitled, The Great Leap Backward?:
China’s environmental problems are mounting. Water pollution and water scarcity are burdening the economy, rising levels of air pollution are endangering the health of millions of Chinese, and much of the country’s land is rapidly turning into desert. China has become a world leader in air and water pollution and land degradation and a top contributor to some of the world’s most vexing global environmental problems, such as the illegal timber trade, marine pollution, and climate change. As China’s pollution woes increase, so, too, do the risks to its economy, public health, social stability, and international reputation. As Pan Yue, a vice minister of China’s State Environmental Protection Administration (SEPA), warned in 2005, “The [economic] miracle will end soon because the environment can no longer keep pace.”…
China’s rapid development, often touted as an economic miracle, has become an environmental disaster. Record growth necessarily requires the gargantuan consumption of resources, but in China energy use has been especially unclean and inefficient, with dire consequences for the country’s air, land, and water.
The coal that has powered China’s economic growth, for example, is also choking its people…
Consumption in China is huge partly because it is inefficient: as one Chinese official told Der Spiegel in early 2006, “To produce goods worth $10,000 we need seven times the resources used by Japan, almost six times the resources used by the U.S. and — a particular source of embarrassment — almost three times the resources used by India.”
Meanwhile, this reliance on coal is devastating China’s environment. The country is home to 16 of the world’s 20 most polluted cities, and four of the worst off among them are in the coal-rich province of Shanxi, in northeastern China. As much as 90 percent of China’s sulfur dioxide emissions and 50 percent of its particulate emissions are the result of coal use. Particulates are responsible for respiratory problems among the population, and acid rain, which is caused by sulfur dioxide emissions, falls on one-quarter of China’s territory and on one-third of its agricultural land, diminishing agricultural output and eroding buildings….
…much of China’s arable soil is contaminated, raising concerns about food safety. As much as ten percent of China’s farmland is believed to be polluted, and every year 12 million tons of grain are contaminated with heavy metals absorbed from the soil….
Pollution is also endangering China’s water supplies. China’s ground water, which provides 70 percent of the country’s total drinking water, is under threat from a variety of sources, such as polluted surface water, hazardous waste sites, and pesticides and fertilizers. According to one report by the government-run Xinhua News Agency, the aquifers in 90 percent of Chinese cities are polluted. More than 75 percent of the river water flowing through China’s urban areas is considered unsuitable for drinking or fishing, and the Chinese government deems about 30 percent of the river water throughout the country to be unfit for use in agriculture or industry. As a result, nearly 700 million people drink water contaminated with animal and human waste. The World Bank has found that the failure to provide fully two-thirds of the rural population with piped water is a leading cause of death among children under the age of five and is responsible for as much as 11 percent of the cases of gastrointestinal cancer in China.
One of the problems is that although China has plenty of laws and regulations designed to ensure clean water, factory owners and local officials do not enforce them. A 2005 survey of 509 cities revealed that only 23 percent of factories properly treated sewage before disposing of it. According to another report, today one-third of all industrial wastewater in China and two-thirds of household sewage are released untreated. Recent Chinese studies of two of the country’s most important sources of water — the Yangtze and Yellow rivers — illustrate the growing challenge. The Yangtze River, which stretches all the way from the Tibetan Plateau to Shanghai, receives 40 percent of the country’s sewage, 80 percent of it untreated. In 2007, the Chinese government announced that it was delaying, in part because of pollution, the development of a $60 billion plan to divert the river in order to supply the water-starved cities of Beijing and Tianjin. The Yellow River supplies water to more than 150 million people and 15 percent of China’s agricultural land, but two-thirds of its water is considered unsafe to drink and 10 percent of its water is classified as sewage. In early 2007, Chinese officials announced that over one-third of the fish species native to the Yellow River had become extinct due to damming or pollution….
… Today, fully 190 million Chinese are sick from drinking contaminated water. All along China’s major rivers, villages report skyrocketing rates of diarrheal diseases, cancer, tumors, leukemia, and stunted growth….
Local governments also turn a blind eye to serious pollution problems out of self-interest. Officials sometimes have a direct financial stake in factories or personal relationships with their owners. And the local environmental protection bureaus tasked with guarding against such corruption must report to the local governments, making them easy targets for political pressure. In recent years, the Chinese media have uncovered cases in which local officials have put pressure on the courts, the press, or even hospitals to prevent the wrongdoings of factories from coming to light. (Just this year, in the province of Zhejiang, officials reportedly promised factories with an output of $1.2 million or more that they would not be subjected to government inspections without the factories’ prior approval.)…
…All countries suffer internal tugs of war over how to balance the short-term costs of improving environmental protection with the long-term costs of failing to do so. But China faces an additional burden. Its environmental problems stem as much from China’s corrupt and undemocratic political system as from Beijing’s continued focus on economic growth. Local officials and business leaders routinely — and with impunity — ignore environmental laws and regulations, abscond with environmental protection funds, and silence those who challenge them. Thus, improving the environment in China is not simply a matter of mandating pollution-control technologies; it is also a matter of reforming the country’s political culture. Effective environmental protection requires transparent information, official accountability, and an independent legal system. But these features are the building blocks of a political system fundamentally different from that of China today, and so far there is little indication that China’s leaders will risk the authority of the Communist Party on charting a new environmental course. Until the party is willing to open the door to such reform, it will not have the wherewithal to meet its ambitious environmental targets and lead a growing economy with manageable environmental problems.
It is a fascinating article and one can’t come away from reading it very confident that the air and water used in agriculture is of a standard acceptable to Americans, much less to organic consumers.
In our interview, Mr. See answers these concerns in an accurate, but not necessarily reassuring, manner:
In organic standards, this is not allowed as direct input.
In other words, the job of a certifier is not to evaluate the general quality of the environment. If the air is very polluted, it is polluted; the auditor is only looking at inputs. Yet this is probably no answer at all for a US organic consumer or for a buyer looking to reassure that consumer.
Second, it is well known that there is a culture of bribery in China. In fact, one of the major issues that has arisen in the past year is that although China will prosecute a government official for receiving bribes, it almost never will prosecute an individual for offering or paying bribes.
Mr. Lee and OCIA certainly have oversight and various procedures in place, but they are not operating on the assumption that bribes will be paid and taken — which is the only safe assumption to operate under.
And they don’t seem to be aggressively trying to find flaws in the system. The Japanese inspector whose notes we were given, as you can read here, was sent to China because of the allegations made in the Dallas Morning News article.
Yet his visit to China was strictly a matter of attempting to verify if they had a plan and were executing it. So when the issue was whether the fields were being fertilized with human waste — a common practice in China — he gives this report:
Overall consideration of the possibility to use Human waste:
Considering the above phenomena, I didn’t find the definitive evidence of usage of human waste, and they understand the standard well.
However Sales Manager Cui Min said that for the family garden field at the residence place, farmers, as a custom, use human manure, but he insisted that it is clearly separated.
Obviously, if the real interest is determining what has been used in the soil, they would be doing soil testing.
Same thing with food safety issues, such as composting:
Regarding the way of making compost, they wrote down that temperature keeping between 55-75 degree centigrade, but they said it was not the result of measurement by thermometer but based on their experience; they know it by looking at vapor, in the winter and spring season — it is very cold in this province.
Also regarding [carbon/nitrogen] ratio, they don’t measure but by their experience they wrote it down. I told them that periodically they should measure it, especially when they change the manure source.
According to the interview, I think they know that they will use completely fermented compost only.
Of course, he should have taken measurements with thermometers to compare to the claims of the Chinese farmers.
Even the explanations don’t reassure:
Mr. Cui Min’s comment about the Dallas Morning News Interview.
After finished all inspection procedure, I asked about this theme. The followings are explanation by Mr. Cui Min.
About two months ago, around 14:00 he received a telephone call form Chinese women who is a correspondent of this publish. On that day, they took a big lunch and drank beer too much, so he was just going to taking a nap. Generally speaking he is a sales person and he is not in charge of organic operation, so it should be answered by Li Zhendong, who is an organic certification coordinator, but at that time he was absent so Cui Min replied to her.
The correspondent had strong Hong Kong dialect and a little bit difficult to understand her questions. The telephone interview continued so long for 15 — 20 minutes and the number of the questions was more than 20.
Because of this situation, he thought troublesome and replied in a slapdash manner. At this moment he doesn’t remember what kind of questions he was asked, and he doesn’t remember the exact statement he told about human waste, what kind question was, and what he replied.
At this exit interview, he explained that in this area people use human waste as compost but for family garden use in residential place. Like a commercial farming field, the area is so large and volume of compost should be so large. So they need not to use such a small amount human waste. For conventional farming, there is such company that gathers human waste and sells as compost. But Rizhao Huasai does not purchase any fertilizer from out source.
He is very angry that his comment was distorted by its article.
(This is my guess so here is not a settled idea, but that he may have confused a certified organic and a traditional natural farming (like using human waste). He knows that it is not a certified organic but traditional way of growing. And he uses the term of “organic” for this growing way too.)
Is the problem that after drinking “too much beer,” the worker misunderstood or, at least as reasonably, that the worker told the truth?
More broadly, if the culture is so accepting of conditions that violate organic standards, such as the use of human excrement, well, what are the chances that the workers will see violating such a rule as serious?
Mr. See repeats many times that the standards used in China are the same that OCIA uses in audits all over the world, including the US.
We are not necessarily 100% certain about the legitimacy of everyone with an organic certificate in the US, but it does seem to us that there are additional risks in operating in an environment like China.
How much do they pay these inspectors? Considering the product value and the poverty of the country and the affiliation between the Chinese inspectors and their countrymen farmers, it seems very likely that many inspectors can be encouraged to overlook things.
Besides, the overall system just doesn’t seem rigorous enough to prevent opportunistic, perhaps buying some non-organic product and co-mingling it to meet an order.
The whole thing struck us as problematic, so we turned to Jack Bayless of Alishan Organic Center in Japan. Jack is a Pundit reader and friend who describes his background this way:
Graduate of the University of Maine in Animal Vet Science worked at Harvard School of Public Health in toxicology research, Merrill Lynch & Co. as a broker, moved back to Maine to pursue back to land life of building, craft and art.
Left America in 1980 and ended up in Japan a couple years later. Exporting antiques to Europe and US and importing natural foods for small group of friends.
Married a dynamo from Alishan Mountain in Taiwan and started our food imports company as a mail order service. 20th Anniversary will be celebrated in 2008. Now an inporter, repacker, wholesaler, mail order, single retail shop and cafe along with an event center. Staff of 35. The bulk of business is the import/repack/wholesaler business but the others are very important in other ways.
Fay and I hold ourselves and staff to the rule “If it ain’t fun and satisfying it is time to move on”. Live on top of office with wife and partner Fay and two children age 15 & 13.
Japan has a reputation for tough food safety standards. Because of Jack’s deep involvement with organics, we asked him to do some digging for us and come up with an assessment of what the Japanese industry thinks about organics from China:
China is growing honest organic raw materials, but anyone who relies solely on an organic certificate shown by an exporter is on shaky ground.
Visiting the farm operation is important anywhere. In China doubly (triply) so. I know of screw ups and deceptions in both Japan and USA.
Many of the organic farms exporting to Japan are managed/supervised by on-site Japanese staff.
Others in the industry made the following remarks to me:
An importer of fresh JAS cert tropical fruits —
These expressions based on their experiences I think are a pretty good sample of the reality.
I believe that the only way to grow organics safely in China is if you have people on site permanently.
There are a number of European and even Japanese companies that are taking that approach. I think if you have the commitment and the resources to work that way, then it is possible to do organics there.
An importer of dried (beans, seeds) organic ingredients from China:
Jack also does explain that there is market concern, as he puts it: “We are getting calls from customers to confirm what if any ingredients in any of our products are exported from China.”
We appreciate Jack’s help as we appreciate Steve’s tip and Jeff and OCIA International’s time with us.
What we take from all this is that a mere certificate is not sufficient to assure a buyer of legitimate organic product from China. It is certainly not sufficient to assure a buyer that it is both technically organic and also grown in a healthy, clean environment.
So procurement of Chinese organics requires one to either have actual control of the production in China or a trusted supplier who has control of production in China.
Jim Provost, Managing Member of I Love Produce, started his business with his step-brother, Neil Millman, basing it on the contention that Americans can’t just buy from the cheapest bidder in China or from a broker in Los Angeles who got product from some unknown place.
Jim contributed to many of the articles we started this piece by listing, and he has explained that his company, with an office in China and feet on the ground, can serve as a defacto agent for the consumer or trade buyer.
Whether his degree of control is sufficient is a matter for each buying organization to ascertain. But economics is a powerful thing, and although there has been a setback for Chinese agricultural due to food safety concerns, we suspect that, in time, China will still be a produce giant.
China will actually owe a great debt to companies such as I Love Produce, investing now to raise standards in China.
Sometimes he even brings a bit of the Pundit to China. After we ran a lengthy interview with Dr. Ron Voss, an expert in garlic formerly with UC Davis, we said this:
This led Jim to send us this note:
I know that you highly respect European Standards. One of the organic processing facilities we work with in China is BRC (British Retail Consortium) Certified as well. Attached is their certificate. At this point their frozen organic vegetable products are BRC certified, but we will have fresh garlic and ginger under BRC very soon. Partly due to your encouragement, we are asking all of our China suppliers to obtain BRC certification.
No certificate can be accepted as determinative but clearly these guys are trying. A lot of retailers have run away this year, but the economics of the situation dictate that they will probably be back one day. It is the kind of work that Jim is doing that is positioning his organization to be ready for that day.