Inspectors' Technical Advisory Panel

Community Grower Groups

NOTE TO INSPECTORS:
The information presented in this CGG TAP is a compilation of documents from different sources that can help inspectors understand better what is a Community Grower Group, what are the criteria to its certification and some protocols to its inspection. Inspectors are refered to the specific
policies that each particular certification agency might have.

For example: inspectors working for OTCO, Naturland, OCIA and EcoLOGICA, please refer to their Inspector Manual or other documents for particular instructions (see links below).

INTRODUCTION:
"Grower group certification refers to the certification of a group of producers whose farms are uniform in most ways, and who are organized under one management and marketing system. Grower group certifications have historically been used for the certification of cooperatives or groups of
producers located in a geographical or social region, whose crops are marketed collectively. Primary crops produced by grower groups include
coffee, cocoa, tea, spices, and tropical fruits". (from NOSB adopted recommendation Oct 20, 2002)

""It was estimated in 2001 that in Less Developed Countries, close to 350 different smallholder groups exist,comprising close to 150,000 smallholders, whose organic products are exported to markets in the North. Some estimates say that 60-70%of what is imported into Europe is produced by smallholders.It may be similar for North America. With that organic smallholder farms contribute greatly to the growth of the organic sector in the North, while this premium price market offers opportunities for them to improve their livelihoods. Given the size of their holding,it is impossible for most of these producers to pay for an annual inspection visit by an external certification body as is required in the EU, US and Japanese regulation. Especially when inspection must be done by a northern inspector due to absence of local certification bodies or import market requirements. Since the mid-eighties a system has developed, taking that the smallholders were organised,that there was an internal support structure, that there was an annual inspection, that allowed for group certification. IFOAM,in its Critera for Certification Bodies, regulated this exception for the first time in 1996. However, different certifiers have different approaches as to what the internal control should include and have different ways of how to inspect such situations. Systems waver between at random sampling of a sufficient number of producers to be relatively sure that 100% of them comply with the standards, to accepting elaborate internal control systems, to inspecting as many smallholders in the few days given, to doing exactly what the importing authority requires, to making elaborate risk assessments and a few targeted inspections" (from Smallholder Group Certification: Compilation of findings so far" Commissioner: IFOAM, Author: Agro Eco, July 2002, Report no:02-20)

Intro to Certifying CGG's IFOAM
Findings - Definition of a Smallholder (pdf) IFOAM
EC Guidance document (pdf) European Commission, Agriculture Directorate-General Directorate B. Relations with other institutions; Communication and Quality. B.3. Agricultural product quality policy
Guideline Questions (pdf) IFOAM
Reinspection Findings (pdf) IFOAM
CGG Under NOP (pdf) NOSB Recommendation as adopted by USDA, October 20, 2002
ICS Compilation (pdf) IFOAM
Upcoming Workshop on CGG's

The Weakest Go to the Wall: Inspection Overkill for Small Farmers
by Gerald A. Herrmann and Petra Heid, as published in IFOAM´s Ecology and Farming

Inspection of Small Farmers' Co-operatives
Organic products are enjoying ever-greater popularity in Europe, and a wide variety are now available on the market. Even products not originating in a member state of the European Union are subject to inspection according to the guidelines of the current European Regulation 2092/91. Under this system, such organic products are deemed to comply with these standards if it can be proven that they have been subject to comparable guidelines and monitoring procedures.
It makes sense to allow this leeway, given the wide divergence from Europe's climate and agrarian structure. To give one example: it has proven extremely arduous to monitor small farmers' groups (normally co-operatives) in Latin America, Africa and Asia, who are the main producers of organic coffee. Here the aim is to develop a practical and sophisticated monitoring procedure that both is applicable to this particular farming structure and meets the requirements of the EU regulation for a 100% inspection rate besides spot checks. This procedure therefore must be tailored to local conditions, but compromising stringency.
Over the years the various international certification organisations have independently managed to develop just such modified monitoring systems. Eventually they were incorporated into the requirements of the IFOAM Accreditation Programme and were accepted by the EU authorities, who have granted import licences accordingly.

A Challenge to the Inspection System
Now, however, several European member states are voicing doubts about the reliability of the control mechanisms. The principle objections have been raised by France, which is demanding changes to and stricter regimentation of the spot checks on small farmers' organisations. This would inevitably lead to higher inspection fees for these organisations. An even less acceptable consequence, however, would be that if the facts are considered more carefully, the results would be precisely the opposite of the improvement in quality envisaged by this measure.
An ever-increasing number of small farmers' co-operatives, especially in Latin America, have converted their production to conform to the guidelines for organic agriculture. Sustainable farming of the declining agricultural areas has brought the farmers more dependable and in some cases even higher harvests, which they can sell at higher prices on the international organic market. This has made a major contribution to improving the living standards of the previously economically disadvantaged small farmers and to strengthening their self-governed organisations.
Those small farmer groups wishing to sell their organic produce to EU member states must agree to be inspected at least once a year according to EU Regulation 2092/91. This involves experienced inspectors from monitoring organisations recognised by the EU making on-site inspections, interviewing the farmers, and checking their records. This information is used to decide whether the production, processing and marketing of the organically cultivated products meets the requirements of the European regulation. The insurmountable difficulty is to inspect every one of the small farming units of each group. In the large organisations, comprising hundreds or even thousands of small farmers in several villages scattered over an area of up to 10,000 square km, it is impossible for an inspector to perform this task in a reasonable time and at reasonable expense.

Naturland's Quality Control System
Years ago, with the primary objective of solving this difficult problem, Naturland, together with various international certifiers and in compliance with the IFOAM Accreditation Programme, IAP, managed by the International Organic Accreditation Services Inc., introduced a 'quality control system' (see box for more details) as a major component of inspection procedures applied to small farmers' groups. The idea principally was to establish a framework for these organisations, enabling them to establish and develop internal control mechanisms. In special courses and with communication of the requisite know-how, certain employees are trained to become qualified inspectors able to assist the inspectors recognised by the EU in their wide and complicated scope of work. This means that the local inspectors are entrusted with the inspection of every one of the small farmers' units according to EU Regulation 2092/91, enabling the EU recognised inspector, on his annual visit, to concentrate on the processing and marketing of the organic products and to determine whether the internal quality control system is operating satisfactorily.
A precondition for the establishment of such quality control systems is a great transfer of know-how from the certification organisation to the small farmers' groups. This is the only way for small farmers' groups to be educated step-by-step towards assuming some of the demanding tasks involved under the requirements of the European regulation. For example, this involves evolving standards within the small farmers' organisation that as stringent as those of the European regulation, but are worded in a way that makes them understandable to its members. Furthermore, they refer to local conditions and to the organic cultivation of indigenous crops. A team of advisors must ensure that these internal standards are communicated to every small farmer wishing to participate in the organic program.
The local inspectors trained this way are then expected to check whether each of the organic units is complying with these internally evolved standards. The local inspectors not only have exact knowledge about their region, its inhabitants and the farming methods practised, but also can also perform their part in the inspection procedure much more intensively, with more insight and more cheaply than an official from an EU-recognised inspection organisation.
The introduction of such internal inspection systems has been the result of much effort by Naturland and other internationally operating certifiers in convincing and guiding the small farmers. In turn it has demanded much time, considerable internal development work, restructuring and investment by the small farmers. However, the effort has been rewarded. Within a short time, many production co-operatives established economically viable quality control systems, with the added benefit of supplying data for statistical purposes and for eliminating the weaknesses thus revealed.

The Threat from the EU
Current plans will mean that most of this effort was a waste of energy. Officials in Brussels are discussing a procedure whereby EU controls of small farmers' groups are to be put on a different footing. The main idea is to fix the proportion of small farmers to be subject to spot checks by the external inspector. No matter how good the internal inspection system is, at least 10 to 30% of all the small farmers of an organisation will have to be inspected annually by the external inspector, who will visit their farms and duplicate the interviews. Until now, the rate of spot checks was decided by the external inspector after consulting the certifying organisations. With the large, well-organised small farmers' groups, this was significantly below the envisaged percentage (about 2 to 5%), whilst for the smaller organisations it was considerably higher (20 to 50%).
The determination of a spot-check rate will reduce the flexibility and adaptability of the system, and in extreme cases it will deteriorate into a rigid, overly expensive and unrealistic arrangement. Even if the level of spot checks is only 10%, this will lead to increased inspection charges, especially for large groups (500 members or more). Particularly in such cases a rapid deterioration in the quality control system is to be expected, since the available time cannot be expanded at will to accommodate the disproportionate increase in the number of spot checks required, without leading to a drastic increase in inspection charges.
Take as an example a coffee co-operative in Mexico with 2,100 members, cultivating organic coffee on 4,200 hectares. At an inspection rate of 10%, this would mean that the external inspector has to visit 210 farms, even though every one of the 2,100 members had already been inspected internally. An inspector who is expected to verify the documentation provided must allow enough time to visit the farms and to interview the farmers. At most, between four and eight farmers could probably be visited each day, not counting the more remote farms or those that can only be reached on foot. This means that an inspector would need at least thirty days, possibly twice as long, just for the spot checks of the small farmers. Even if local specialists are called upon to assist, this procedure would cost the small farmers' association a fortune (up to US$10,000), making organic production completely uneconomical.
What will be the result if the change planned in Brussels is passed? 'Time is money' is the motto. To save time, therefore, the interviews will be shortened. It will become a luxury to have probing conversations and skilled questioning to reveal less obvious but important details, enabling the situation to be judged more realistically. These will be the first things to be jettisoned as unnecessary ballast. Another consequence will be that only plots easily accessible on foot or by car will be checked regularly, to save time and money. These 'showcase farms' will possibly be managed in an exemplary manner, since they will expect to be visited by the external inspector each year. To cope with visiting the many farmers to be inspected within a few days, it will be very tempting to enrol low-paid assistants. Conceivably, inadequately prepared and poorly instructed assistants will be used to achieve the inspection target. In short, the practical side of the external inspection may deteriorate so badly that it no longer makes any sense at all.
An inspection rate that is too high for a large organisation can be too low for a very small one. For small farmers' groups with only 20 members, the inspector would in theory only have to check two farms. This is far too few to judge how well the internal inspection system is working.
These examples make it clear that strict regimentation of the inspection procedure, as in the current concept, will do nothing to produce the intended results. Besides impairing the quality of the inspections, it will deprive the organisations of some of their hard-won autonomy and credibility. They will ask themselves why they should bother maintaining a sophisticated system of internal quality control if they are to be double-checked at great expense.
Therefore, Naturland is making a case for adjusting the rate of spot checks reasonably, bearing in mind the number of members in the small farmers' group. The aim is to keep the expenses and quality acceptable and to enable the small farmers' groups to take an active part in running their organisation as partners in organic agriculture, whilst not denying the EU or consumers their right to be supplied with organic produce of guaranteed quality.

Criteria for Quality Control of Small Farmers' Organisations
A severe challenge to any certifying organisation is to inspect small farmers' groups with up to several thousand members with widely scattered plots averaging less than two hectares in poorly accessible regions. The aim is to follow a practical procedure that will meet the requirements of 100% inspection under EU regulation 2092/91 while keeping inspection charges acceptable to all parties. Naturland, as one such certifying organisation, has devised special criteria of quality assurance, in co-operation with the inspection organisation IMO (Institute for Market Ecology) and in accordance with IFOAM's accreditation programme. These criteria are the basis for Naturland's certification of small farmers' groups.

Development of internal standards
Every organisation is obliged to develop internal standards for organic agriculture applicable to the crops cultivated and in compliance with EU regulation 2092/91, and to pass these on to all its members farming organically.
Proof of a well-managed advisory system
Proper advisory services are indispensable for successful application and development of any method of organic agriculture. This can be achieved by either an external advisory service or an internal advisor, whereby agricultural experts experienced in organic agriculture form the core of a team of advisors. This team, in turn, instructs experienced farmers who have contacts with every member of the organisation. In this way they ensure that every farmer is familiar with internal standards determined by the organisation and applies them successfully.
Performance of qualified inspection
To comply with EU Regulation 2092/91, every small farmer must be inspected at least once a year. This inspection is performed by specially trained and qualified staff of the small farmers' organisation, who visit every plot and document the results in exhaustive survey files. Particular attention is paid to ensuring that the inspectors do not visit their own locality.
Documentation of all procedures and organisational structures
A contract must be drawn up between each small farmer and the organisation of which he or she is a member. In this contract the farmer pledges to maintain the internal standards, and specific penalties are agreed upon for every infringement. The organisation is obliged to provide comprehensive proof of the results of the each inspection before the harvest begins, and to maintain lists of the producers. Purchasing lists and all records documenting the flow of goods to the point of export are an equally important component of the organisation's internal quality assurance system.

Other Certification Agencies Links:
OCIA CGG documents as available in their website::
http://www.ocia.org/members/services/documents/search_results.asp?SearchValue=CGG&Submit2=Search

OTCO Procedures Manual as available in their website:
http://tilth.org/Publications/OTCOProcedures.pdf read Part I.B.4 as in page 5.

NATURLAND Manual for Quality Assurance: A guideline for Internal Control System (ICS) in Smallholder Organizations. Manual available in Spanish and
English, check the News section at http://naturland.com

DO YOU HAVE OTHER LINKS OR USEFUL INFORMATION RELATED TO CGG?
Please contact Luis Brenes,
lbrenes@racsa.co.cr
PO Box 869-1011
Y-Griega, Costa Rica
tel/fax (506) 226-1681