CERTIFICATION MANUAL

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1 CERTIFICATION MANUAL Pennsylvania Certified Organic 106 School Street, Suite 201 Spring Mills, PA Tel: Fax:

2 CONTENTS INTRODUCTION...1 QUESTIONS AND ANSWERS..2 STEPS TO CERTIFICATION.4 PCO 100% GRASSFED STANDARDS 5 Part 1- Terms Defined. 5 Part 2- Livestock Production Part 3- Handling...7 Part 4- Labeling 8 STANDARDS POLICIES...9 Use of PCO 100% Grassfed Seal 9 Standards Revision Sprouted Grain 9 CERTIFICATION PROGRAM POLICIES.. 10 Compliance 10 Certification of Contracted Operations...10 Appeals.. 10 Page 1 of 10

3 INTRODUCTION The PCO 100% Grassfed certification program establishes an optional additional certification scope for organic operations certified by Pennsylvania Certified Organic (PCO). The program standards apply to producers of ruminant livestock and to handlers of meat and dairy products derived from ruminant livestock. PCO developed the PCO 100% Grassfed certification program in response to membership interest in third-party verification of food products that are sourced from pasture. Throughout the development process, every effort was made to assure the quality and integrity of the standard. The standards were developed by the PCO Standards Committee through research of existing private certification programs, consultations with industry professionals, and information from scientific publications. Members also had an opportunity to provide comments and feedback prior to finalizing the standard. QUESTIONS AND ANSWERS Who is eligible to apply for the PCO 100% Grassfed Certification Program? Operations currently certified or applying for certification by PCO under the USDA's National Organic Program. What types of operations can be certified under the PCO 100% Grassfed Certification Program? All producers of ruminant livestock and handlers of meat and dairy products derived from ruminants. Will my operation need to be inspected in order to be certified under the PCO 100% Grassfed Certification Program? Yes. The on-site inspection to verify that your operation meets the PCO 100% Grassfed Standards will be conducted annually in conjunction with your organic inspection. How much will it cost? You will be charged an additional certification program fee annually, along with the additional time the inspector will spend during your organic inspection to verify that your operation meets the requirements of the PCO 100% Grassfed Certification Program. See current PCO Fee Schedule. How do I apply? Contact your certification specialist to request an Organic System Plan specific to your type of operation. Submit the completed form, along with the certification fee, to PCO. Once I am certified, how often do I need to renew my certification? In order to maintain your certification, it must be renewed annually as part of your annual organic update submission. The renewal process includes updating PCO of changes to your Organic System Plan and paying the annual certification fee. Page 2 of 10

4 o What happens if my operation does not comply with the PCO 100% Grassfed Standards or certification program requirements? If your operation is not in compliance you will be given an opportunity to correct the noncompliance. If correction of the noncompliance is not possible, your application for certification will be denied, or your certification may be suspended or revoked. Operations are given the opportunity to appeal PCO s noncompliance decisions according to PCO s appeals process. Operators certified under the PCO 100% Grassfed certification program must first comply with all the requirements of the USDA's National Organic Program in order to be considered compliant under the PCO 100% Grassfed certification program. Can I contract production and/or processing of my 100% Grassfed product to another certified organic operation even though it is not certified by PCO? Yes, as long as the contracted operation is inspected and approved by PCO. See Certification Program Policies section for additional information. A supplementary form must be completed for each contracted operation and submitted, along with the additional certification fee, to PCO. What are the benefits of becoming certified under the PCO 100% Grassfed Certification Program? Successful completion of the certification process means that your operation has been inspected and verified by PCO, an independent third-party certification agency, to meet the requirements of the PCO 100% Grassfed Standards. Your certified product can claim that it is certified under the PCO 100% Grassfed Certification Program, and you may also use the PCO 100% Grassfed seal on certified product labeling and marketing materials. Page 3 of 10

5 STEPS TO CERTIFICATION Step 1. Submit completed Organic System Plan and certification fee Step 2. PCO reviews completed Organic System Plan Step 3. PCO conducts on-site inspection Step 4. PCO reviews inspection report Step 5. PCO notifies you of the certification decision and any requirements for certification Step 6. PCO issues certificate Annual renewal at time of annual organic update submission Page 4 of 10

6 PCO 100% GRASSFED STANDARDS Part 1 Terms Defined Boot stage. Growth stage when a grass inflorescence is enclosed by the sheath of the uppermost leaf. [1] In small grains, this stage of growth is identified on the Feekes Growth Sale as Stage 10. [2] Forage. Vegetative material in a fresh, dried, or ensiled state (pasture, hay, or silage), which is fed to livestock. [3] V10 stage. Growth stage of corn development when the stalk is in rapid growth phase accumulating dry matter and nutrients. The tassel has begun growing rapidly as the stalk continues to elongate. [4] Vegetative state (pre-grain/pre-boot). Stage of growth prior to boot stage or grain development. [1] Forage Information System, Oregon State University [2] Managing Wheat by Growth Stage, Purdue University Extension [3] 7 CFR [4] Corn Growth Stage Development, University of Illinois Extension Part 2 Livestock Production 2.1 General. Livestock intended for PCO 100% Grassfed certification of dairy or meat products must be PCO-certified organic. 2.2 Origin of Livestock Livestock products that are to be sold, labeled, or represented as PCO 100% Grassfed must be from livestock produced under the requirements of this standard throughout the animal s lifespan, except that dairy livestock must be managed according to the provisions of this standard for a transition period of 90 days prior to representing the animal or dairy products derived from the animal as PCO 100% Grassfed certified. a. Once an entire distinct herd has been converted to grassfed production, all animals shall remain under grassfed management, except that a herd or part of a herd may undergo the transition period again in extenuating circumstances as determined on a case-by-case basis by PCO. b. All management practices must be documented Up to 3 years from implementation date of this standard, livestock for replacement or expansion purposes may be purchased from organic herds or flocks and must comply with the requirements of Part of this standard. After 3 years from implementation date of this standard, all purchased livestock must come from equivalent (as determined by PCO) grassfed certified herds, except that PCO will re-evaluate this provision prior to this deadline to assess the availability of grassfed certified animals and may issue an extension of Part of this standard. Page 5 of 10

7 2.3 Livestock Feed % dry matter intake must be derived from pasture or forage, except that a. Livestock may be fed milk prior to weaning. b. Dairy livestock may be fed the following non-forage feedstuffs: i. Molasses ii. [Reserved] c. PCO will review other non-forage feedstuffs for dairy on an as needed basis according to the following criteria: i. Feedstuff must not be a prohibited in Part of this standard. ii. Feedstuff must not be starch-based. iii. Feedstuff must not change the nutrient profile of the meat or milk product Agricultural products, including pasture and forage, must be certified organic and meet the requirements of 7 CFR Livestock may be fed forage that consists of grass (annual and perennial), forbs (e.g., legumes, Brassica), browse, cereal grain crops in the vegetative (pre-grain/pre-boot) state, hay, haylage, baleage, silage, crop residue without grain, or other roughage, provided that a. Crops normally harvested for grain (including but not limited to corn, soybean, rice, wheat and oats) are foraged or harvested in the vegetative state (pre-grain/pre-boot). Forage may include seeds naturally attached to crops not normally harvested for grain. b. Grain crops have not matured to boot stage or later. c. Corn has not matured past the V10 stage or into tassel stage. d. Forage is not fed in concentrated (i.e. pelletized) form Livestock may be fed trace vitamins and minerals in accordance with 7 CFR (d). Organic grain or grain by-products used as carriers within a vitamin or mineral supplement are allowed, provided that a. The supplement is fed at labeled rates or does not exceed a rate within the normal range of consumption as prescribed by the manufacturer, a veterinarian, or qualified nutritionist. b. The supplement is not used with the intent of utilizing it as a grain supplement Livestock must not be fed the following feedstuffs: a. Grain and grain by-products Page 6 of 10

8 b. Corn kernels or corn kernel by-products c. Cake or meal feedstuffs d. Concentrates e. Food processing by-products or waste f. Small grain or corn allowed to mature past the vegetative (pre-grain/pre-boot) state 2.4 Livestock Health Care Livestock must be managed in accordance with 7CFR Operator must not withhold grain or other nutritional supplementation from a sick animal in an effort to preserve its PCO 100% Grassfed status. All appropriate feedstuffs must be used to restore an animal to health when feedstuffs that are allowed under this standard fail. If grain supplementation is provided to an animal, the operator must, a. Document the supplementation and notify PCO. b. Clearly identify the animal as not part of the grassfed certified herd. c. Not sell, label, or represent the animal or products from the animal as PCO 100% Grassfed Pasture Management Pastures that contain grain or corn crops shall be managed to not intentionally allow grain or corn crops to mature past the vegetative (pre-grain/pre-boot) state Livestock must be grazed to meet or exceed the requirements of 7 CFR (c). 2.6 Split Production. Livestock certified as PCO 100%Grassfed may be managed alongside organic livestock that are not certified as PCO 100% Grassfed provided that the operator establishes management practices and identification methods to prevent misrepresentation of certified and noncertified PCO 100% Grassfed livestock. Part 3 Handling 3.1 Livestock products must be handled in accordance with 7 CFR Operator must establish practices that prevent commingling of certified and non-certified PCO 100% Grassfed livestock products and to prevent contact of PCO 100% Grassfed livestock products with substances prohibited by this standard. Page 7 of 10

9 Part 4 Labeling 4.1 Multi-ingredient products labeled as PCO 100% Grassfed must not contain any ruminant livestock products that are not certified to this standard. All other ingredients must comply with NOP regulations for product composition (7 CFR ) as applicable. 4.2 The term PCO 100% Grassfed may only be used to represent products that are produced and handled in accordance with this standard. 4.3 The PCO 100% Grassfed seal may only be used to represent products that are produced and handled in accordance with this standard. Page 8 of 10

10 STANDARDS POLICIES Use of PCO 100% Grassfed Seal The PCO 100% Grassfed seal may only be used to represent products that are certified by PCO under the PCO 100% Grassfed Certification Program. The PCO 100% Grassfed seal may also be used on marketing and public information materials such as flyers, posters, websites or signs used to advertise the certification of an operation and/or the sale of products certified under the PCO 100% Grassfed Certification Program. The use of the PCO 100% Grassfed seal is voluntary and not required of certified operations. Packaging materials that bear the PCO 100% Grassfed seal must be submitted to PCO for review and approval prior to use. The PCO 100% Grassfed seals that may be used on product packaging, marketing materials, and public information materials must replicate the form and design of the figures below. Alternative colors and aspect ratios of the seal are prohibited. Contact PCO for access to these seals. If PCO has reason to believe that the PCO 100% Grassfed seal has been used to misrepresent products as certified by PCO, PCO will conduct an investigation. PCO reserves the right to take legal action against misleading or unauthorized use of the PCO 100% Grassfed seal. Standards Revision PCO seeks to maintain a 100% Grassfed certification program of high quality and integrity. To ensure that the certification standard is current and accurate within an ever-changing environment, PCO will evaluate the 100% Grassfed certification program standards every 3 years. PCO will accept comments from certified operators and members regarding ways to improve this standard. These comments will be taken into consideration during the periodic evaluation process. Sprouted Grain Whole sprouted grains are not allowed for use as feed in PCO-Certified 100% Grassfed livestock production. Sprouts with the roots attached do not meet PCO requirement for allowable forage (Part 2.3.3). The root portion of germinated sprout is made up of pericarp and endosperm that contribute a significant starch content to the plant and was produced by a plant that matured past the boot stage. Sprouts without the root portion would be an allowable form of forage. Page 9 of 10

11 CERTIFICATION PROGRAM POLICIES Compliance Operations certified to the PCO 100% Grassfed Standards must comply with all provisions within the standards. If PCO has reason to believe, based on the on-site inspection and a review of the information provided by the operator, that an operation is not able to comply or is not in compliance the standards, PCO shall provide written notification of noncompliance to the operation. When the operation demonstrates that each noncompliance has been resolved, PCO will send the operation a written notification of noncompliance resolution. When correction of a noncompliance is not possible, PCO may issue a denial of certification to an applicant, or may issue a proposed suspension or revocation to an existing certified operation. If the certified operation fails to correct the noncompliance or resolve the issue through appeal, PCO shall send the certified operation a written notification of suspension or revocation. o Certification of Contracted Operations A PCO-certified 100% Grassfed operation may contract production and/or processing to another certified organic operation, provided that the following aspects of the contracted operation are verified and approved by PCO: Compliance with NOP Regulations Compliance with PCO 100% Grassfed Standards The contracted operation must be inspected and approved by PCO before the services of the contracted operation are used by the PCO-certified operation to produce PCO 100% Grassfed products. The contracted operation must be inspected annually by PCO. The contracted operation will not be issued a certificate of any type. The contracted operation is precluded from the marketing of PCO 100% Grassfed products and must not use the name or seal of this program on any products or marketing materials. Marketing privileges are reserved solely for use by the PCO-certified operation. The PCO-certified operation is fully responsible for the production and/or handling performed by the contracted operation and will be subject to sanctions in the event of non-compliances of the contracted operation. Fees will be assessed to the PCO-certified 100% grassfed operation. Appeals Operators may file an appeal of a noncompliance decision within the time period provided in the decision notification or within 30 days from receipt of the decision notification, whichever occurs later. Appeals must be made to the PCO Appeals Team and must include a copy of the adverse decision and statement of the appellant s reasons for believing that the decision was not proper or not made in accordance with applicable standards, policies, or procedures. The PCO Appeals Team will consider the appeal in a timely manner, and inform the operation of the decision to sustain or deny the appeal. Decisions of the PCO Appeals Team are final and binding. Page 10 of 10

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