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Final Questions and answers - Canadian Organic Standards

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Questions and Answers 

Canadian Organic Standards 

CAN/CGSB-32.310-2020 and CAN/CGSB-32.311-2020

CAN/CGSB-32.310-2015 and CAN/CGSB-32.311-2015  

 

Abreviations

32.310 CAN/CGSB-32.310
32.311 CAN/CGSB-32.311
CB Certifying body
CFIA Canadian Food Inspection Agency
CGSB Canadian General Standards Board
COS Canadian Organic Standards
COR Canada Organic Regime
GE Genetically engineered
GMO Genetically modified organism
PMRA Pest Management Regulatory Agency
PSL Permitted Substances Lists - CAN/CGSB-32.311
SFCR Safe Food for Canadians Regulations
SIC Standards Interpretation Committee

References

Canada Organic Regime Operating Manual - https://www.inspection.gc.ca/organic-products/operating-manual/eng/1389199079075/1554143470958

Safe Food for Canadians Regulations - https://laws-lois.justice.gc.ca/eng/regulations/SOR-2018-108/index.html

 

About the Organic Standards Interpretation Committee of Canada

The role of the Standards Interpretation Committee (SIC) is defined in Section C.5 of the Canada Organic Regime operating manual.

The SIC answers questions submitted by certification bodies and operators about the Canadian Organic Standards (COS). By interpreting the standards through questions and answers, the SIC can help people better understand the COS.

The SIC cannot, however, issue an exception or relax the standards: the SIC supports a strict adherence to the COS. If operators want to challenge an aspect of the COS, they can apply to the Canadian General Standards Board for an amendment to the COS.

 

Important notice
 

The Standards Interpretation Committee's Questions and Answers have been updated to reflect the content of the Canadian Organic Standards 2020 published in December 2020.


The 2015 COS remains applicable for one year after the publication of the 2020 COS. For this reason, both editions are taken into account for every question and answer. If the answer is written completely in black, this means the answer applies to both the 2015 and 2020 editions.

If the answer has both blue and black text, the part of the answer written in black corresponds to the 2015 COS and the part of the answer written in blue corresponds strictly to the 2020 COS.

 

CLICK ON ANY ITEM OF THE TABLE OF CONTENTS TO REACH AND READ THE SIC INTERPRETATION

General Principles and Management Standards

 

 

Permitted substances lists

 

 

Questions & Answers

General principles and management standards

1 Scope

1.4 Prohibited substances, materials or techniques in organic production and preparation

3  Terms and definitions

4 Organic Plan

5 Crop Production

5.1 Land requirements for organic production
5.2 Environmental factors
5.3 Seeds and planting stock
5.4 Soil fertility and crop nutrient management
5.5 Manure management

 

5.1 Land Requirements for Organic Crop Production

5.2 Environmental factors

5.3 Seeds and planting stock

5.4 Soil fertility and crop nutrient management

5.5 Manure Management

CLICK ON ANY ITEM OF THE TABLE OF CONTENTS TO REACH AND READ THE SIC INTERPRETATION

6  Livestock production

6.1 General
6.2 Origin of livestock
6.3 Transition of livestock production units to organic production
6.4 Livestock feed

6.5 Transport and handling

6.6 Livestock health care
6.7 Livestock living conditions
6.11 Additional requirements for cattle, sheep and goats
6.12 Additional requirements for dairy cattle housing
 6.13 Additional requirements for poultry
6.14 Additional requirements for rabbits

 

6.1 General

 

6.2 Origin of Livestock

6.3 Transition to livestock production units to organic production

6.4 Livestock Feed

 

6.5 Transport and handling

 

6.6 Livestock Health Care

6.7 Livestock living conditions

6.11 Additional requirements for cattle, sheep and goats

6.12  Additional requirements for dairy cattle housing

 6.13 Additional requirements for poultry

 

6.14 Additional requirements for rabbits

 

 

CLICK ON ANY ITEM OF THE TABLE OF CONTENTS TO REACH AND READ THE SIC INTERPRETATION

7  Specific Production Requirements

7.1 Apiculture

7.2 Maple products
7.3 Mushroom production
7.4 Sprouts, shoots and micro-greens production
7.5 Greenhouse crops 
7.6 Wild Crops
 

7.1 Apiculture

7.2 Maple products

7.3 Mushroom production

7.4 Sprout, shoots and micro-greens production

7.5 Greenhouse crops production

7.6 Wild Crops

 

8  Maintaining organic integrity during cleaning, preparation and transportation

8.2 Cleaning, disinfecting and sanitizing

8.3 Facility pest management and post‐harvest  management

9 Organic product composition

 

CLICK ON ANY ITEM OF THE TABLE OF CONTENTS TO REACH AND READ THE SIC INTERPRETATION

Permitted substances lists

General information

Brand name approval

Formulants

Table cross-referencing

About ‘Origin and usage’

Annotations to permitted substances

 

4  PSL for crop production

Table 4.2 Soil amendments and crop nutrition - Table 4.2 - column 1

Table 4.3 Crop production aids and materials  Table 4.2 - column 2

 

5  PSL for livestock production

Table 5.2 Feed, feed additives and feed supplements

Table 5.3 Health care products and production aids

 

6  PSL for preparation

 

7 PSL for cleaners, disinfectants and sanitizers

 

General principles and management standards

1 Scope

1.4 Prohibited substances, materials or techniques in organic production and preparation

GMOs – Substrates and growth media
 

Can inputs, which have been produced using substrates from GE plants, be used in organic food production? (88) 

Yes and no. Inputs from GE plants are prohibited with the following allowances for input substrates (growth media). 

If the substance (input) includes the substrate or growth medium, the ingredients contained in the substrate must be listed on Tables 4.2 or 4.3 (Table 4.2, columns1 & 2) for crop inputs; 5.2 or 5.3 for livestock inputs and 6.3, 6.4 or 6.5 for prepared products. All substance annotations apply. If the substance does not include the substrate or growth medium, and that is confirmed in writing from the supplier, the substance has to have been produced on a non-GE substrate or growth medium, if commercially available. Refer to 4.1.3, 5.1.2 and 6.2.1 of CAN/CGSB-32.311.

 

Mutagenesis - cisgenesis

Do seeds resulting from mutagenesis or cisgenenis fall within the Standard's prohibition of genetic engineering? (255)
Mutagenesis and cisgenesis are not prohibited by the Standard. The use of these techniques is limited to combining plant materials that will cross or breed through natural processes".

 

3 Terms and definitions 

Genetic engineering – Cell fusion

Is cell fusion allowed in organic production? (199)
No. Cell fusion which combines plants of different taxonomic families (such as sagebrush and grape) is not allowed. Cell fusion is only allowed between members of the same taxonomic family. See the definition of 'Genetic engineering' in 3.27 (3.31) of 32.310.

 

Visually indistinguishable

What is the criteria or definition for “visually indistinguishable” (3.46) (3.52) ? Is a crop considered visually distinguishable if can be identified by an expert such as a grader or plant breeder OR must it be visually distinguishable to a common person? (349)
The criteria for 'visually indistinguishable' is that a common person could not distinguish one from the other if the products were positioned side by side.

 

Biodegradability

What is the definition of biodegradability as it pertains to the Canadian Organic Standards? (263)
Biodegradable is defined in the standard as “capable of microbial decomposition within 24 months in soil (with the exception of plant biomass), one month in aerated water, two months in anaerobic water, with minimal impact on the environment” (see 3.10 (3.11) in 32.310).

 

Definition of ‘production unit’

What is the definition of production unit for agricultural enterprises? Does each field, each greenhouse or each livestock building constitute a production unit or is it all fields, greenhouses, buildings managed by a company? (403) 
A production unit is defined as "identifiable portion of an operation in which production or preparation of an organic product occurs." Therefore, each field, greenhouse, or livestock building - even a contiguous portion thereof that is identified separately in an operation's organic system plan - would be considered a separate production unit if requirements pertaining to segregation, traceability, buffer zones, organic integrity, etc. were maintained for that identifiable portion. All production units shall have distinct, defined boundaries (5.1.6 in 32.310).

 

4  Organic plan


Recordkeeping – Format

Is there is a specific format required for recordkeeping? (100)

No. There is no specific format for record keeping prescribed in the standard.  Records must be readily auditable and contain sufficient detail to satisfy the requirements of 4.4.     

 

Records for short shelf- life products

Do operators producing short-shelf life products need to keep 5 years of daily production records to satisfy 4.4.5 of CAN/CGSB 32.310? (469) - 2 December 2019
Yes.

 

 

 

 

 

 

 

               

5  Crop production 

5.1 Land requirements for organic crop production


Alternating between organic & non-organic

Are there any exceptions to the rule against alternating between organic and non-organic production outlined in 5.1.7? (6)
The intent of 5.1.7 is to prevent deliberate abuse. CBs may be faced with situations that appear to fall in this definition; but that do not demonstrate a deliberate abuse of alternating production. In these cases, the CB should note that although the organic certification lapsed for a period of time, the operator has not intentionally violated 5.1.7. These cases could include instances where the loss of certification where the cause was beyond the operator control (e.g.,, mandated use of a prohibited substance, natural disaster, financial failure of the enterprise) or is unconnected to the management or operational decision-making connected to the organic operation (death of a family member, marital distress, intergenerational transfer).

What is required for a certified farm to retain the possibility of future certification beyond an intervening period when no certification is required for the sale of products? (97)
In the event that the operator has no crops to sell, and wishes to allow certification to lapse, an application to recertify would have to be done in compliance with requirements of the Safe Food for Canadians Regulations as they apply to new operations. 

 

Owning organic and non-organic operations

If an operator owns two land-based operations, where one is organic and the other conventional, does the non-organic operation have to transition to organic as outlined in 5.1.3 and 5.1.4? (488) - 29 June 2020
If the non-organic operation is a separate legal entity, then it is not subject to organic transition certification requirements in 5.1.3 and 5.1.4. But if the non-organic operation is not a separate legal entity 5.1.3 & 5.1.4 are applicable and the operation is subject to the purview of the CB. (See 'legal entity' description in C.2.4.4 in the COR Operating Manual).

 

Buffers

How should the minimum buffer zone be measured in an orchard? (138.1)
The distance is measured from drip line to drip line between an organic orchard and adjacent non-organic block. If a portion of some of the trees is within the 8 meters, the entire harvest from those trees is sold as non-organic. As tree canopies expand with time, such buffer areas need to be checked annually to reaffirm compliance.

Could a buffer zone larger than 8 m. be required in special circumstances, for example when prohibited substances are being applied on the windward side of the organic crop? (138.2)
Yes. 5.2.2 states that "distinct buffer zones or other features sufficient to prevent contamination are required". If there is a risk of contamination, a 8 m or wider buffer (5.2.2 a)) or other effective barriers (5.2.2 b)) must be employed. For isolation distances relevant to GE crops, refer to 5.2.2 d). " 

Does the crop in a buffer zone need to be visually distinguishable from the organic crop? (272)
No. The same crop can be planted in the buffer zone as long as the buffer crop is harvested and directed out of the organic stream, and such activity is documented.

 

External buffer zone
 

Can a buffer zone be established on land not owned by the operation? (499.1) - 18 Dec 2020
Yes. The buffer zone is measured from the edge of the area treated with a prohibited substance to the edge of the organic crop, regardless of the entity owning/managing the land in the buffer zone, but the CB must be able to verify compliance of such a buffer.

Buffer zone – immature hedgerow

Does a newly planted, immature hedgerow eliminate the requirement for an 8m buffer zone? (499.2) - 18 Dec 2020
No. When a risk of contamination is present, this new planting is insufficient, and an 8 m buffer zone will need to put in place until the hedgerow fills in. An effective physical barrier does not have to be 8 metres wide.

 

 

Parallel production 

Is it parallel production if the same type production is separated by time? (73)
No. The growing of visually indistinguishable crops (organic and non-organic) non-simultaneously does not constitute parallel production. See definition 3.46 (3.52).

Can parallel production be allowed if management to avoid co-mingling is documented? (1)

5.1.4 prohibits parallel production of most non-distinguishable crops by the same enterprise. Some exemptions do exist (e.g.,, perennial crops (already planted), agricultural research facilities, and production of seeds, vegetative propagating materials and transplants) with conditions. Refer to 5.1.5 for further details.  Post harvest operations are not subject to this prohibition.

Is the word 'simultaneous' in 3.46 (3.52) defining “parallel production” applicable to:

1) geography? - For example, a farm in isolated from other farm sites owned and operated by the same organic operation)? 

The requirement is that the same or similar crops grown conventionally and organically within an operation are visually distinguishable by a common person, regardless of location,

2) crop rotations? For example,  where an operation has two production units(one organic and the other not), can a non-organic crop be grown in Field 1 (always conventional) in Year A and then the same crop  grown in Field 2 (always organic) in Year B when Field 1 has a different crop? (450.1) - 26 Sep 2019

In the example given this same crop would be planted in different years, therefore the growing of that crop would be considered neither simultaneous nor parallel.


5.1.4 states that parallel production is an exception to an enterprise’s entire conversion to organic. “Operation” is defined at 3.41 (3.47) and may have multiple production units but “enterprise” is not defined in the Standards. What is the difference between enterprise and operation? (450.2) - 26 Sep 2019
Enterprise and operation are synonymous. 


Does the term “farm, company or organization” included within 3.41 (3.47) definition of an operation encompasses separate and distinct divisions of one overall food conglomerate, each division having a separate business name, management and geographical location for crop production? (450.3) - 26 Sep 2019
If each division is a legal entity they need to be certified individually. If the food conglomerate is the certified entity then regardless of its divisions having separate names, any parallel production of a crop within the conglomerate (even if the production took place at different divisions) would be prohibited. (See 'legal entity' description in C.2.4.4 in the COR Operating Manual)

 

Parallel production & hydroponics

Can an operator engage in hydroponic production (not organic) and produce the same products using organic methods? (261)
No. 5.1.4 does not allow parallel production of visually indistinguishable products of  annual crops, regardless of the non-organic method of production.

 

Transition – Management change

In the case where there is a change in management, is a 12-month transition period necessary? (58)
A change in management or control of an organic operation does not necessitate a 12-month transition period. It is a new operation that requires a minimum of 12 months of oversight by a CB, not a new operator.

Transition – Adding new fields

Does the requirement, in 5.1.1, that land be in compliance with the standard for 12 months prior to harvest apply to new fields added to an existing operation? (8)
If it can be verified that no prohibited substances have been applied for the past 36-months, no transition period is required for new fields added to for existing operations holding organic certification (5.1.2 of 32.310)

 

Transition of a GE crop field

When calculating the 36-month transition period, does it begin on the date that a prohibited GE crop was last sown? Or last harvested? (459.1) - 21 June 2019 - confirmed 18 August 2020
The 36-month transition period is calculated from the date on which a prohibited GE crop was destroyed (e.g.,, harvested, tilled, ploughed).

 

Oversight of the CB during transition

During the transition period, does an operator need to consult with their CB before applying any crop amendments? (459.2)  - 21 June 2019
Detailed input records must be kept during the 36-month transition period so that compliance can be verified by the certification body. The standards require a certification body's oversight during the last 12 months of transition, not the full 36-months. But new operations must apply for certification 15 months in advance of when they want to market products as organic to allow for the certification body's oversight during the last 12 months of transition.

 

Type of plant grown in containers

Can any type of plant, including perennials, be grown in containers or any off-the-ground structure (e.g., elevated gutters) and be compliant? (396)
Yes. Plants, including perennials, can be grown in containers or any off-the-ground structure in a greenhouse or outside if the growing medium substrate meets the requirements of 7.5.2 (7.5.2.1) and the soil definition (3.62 (3.73) in 32.310). Keep in mind that if the crop is typically trellised / staked - the production system must also comply with the requirements of 7.5 of 32.310.

 

Non-organic trees or grapevines planted before end of transition

If non-organic trees or grapevines are planted before the land has completed the 36-month transition, how long before the fruit would qualify as “organic”? (431) - 19 Apr 2019
The fruit would qualify as organic either after the completion of the 36-month transition period (5.1.1), or 12 months after the planting date (5.3 b) – whichever is later. For example, there is 4 months left in a land transition and the producer plants non-organic planting stock. The fruit could not be harvested as organic until 8 months after the land meets the 36-month transition requirement.

 

5.2 Environmental factors

Isolation distances

How should the note in 5.2.2 on isolation distances for preventing GE contamination be used in the enforcement of 5.2.2 d)? (282)
Isolation distances are one of many strategies that could be used to minimize contamination risk. Shorter distances other than those provided in the Note (5.2.2) may prove to be as effective depending on wind direction, topography, vegetation, etc. Other mitigation strategies such as delayed planting, border rows, etc., could also be effective on their own, or in combination with other tactics. It is critical to understand that Notes and examples in the standard are not themselves enforceable, and are used to give insight or direction on how to implement the standard.

Note 5.5.2 d)

Does the note in 5.2.2 d), “(for seed production)”, refer to the organic alfalfa or to the GE alfalfa? (282.1)

Organic alfalfa seed fields should be 3 km from ALL GE alfalfa fields (i.e.,, both GE seed production fields and GE hay fields).

 

Corn field is surrounded by GE corn

My sweet corn field is surrounded by GE corn. Since I do multiple plantings, I know that there are times when pollen from the GE corn contaminates my crop, but I have nowhere to locate the corn where this will not be the case. Can this crop still be compliant in light of the GE risk management criteria in 4.4.4 and 5.2.2 d)? (296)
The product of farms whose operators engage consistently in implementing mitigation strategies aimed at eliminating risks of GE pollen contamination will be considered compliant.

Contamination – Accidental

What are the effects regarding certification, of an unintentional spill of plastic pellets onto an organic field or contamination by pesticide applied in a government-sponsored pest control program? (67, 69)

The standard requires 36-months transition after the application of a prohibited substance (5.1.1 - 32.310). Depending on the nature and extent of contamination, buffer strips around the contaminated zone and/or a transition period may be reasonable ways of maintaining the organic integrity (refer to 5.2.2). A prescriptive solution that applies universally to all cases of potential contamination is not possible, but in every case the degree of risk must be assessed and every attempt must be made to mitigate the negative impact on the final product. (See Introduction III- Organic practices paragraph 5).

GE seeds in an organic field

If GE (untreated, treated) seeds are accidentally dumped in an organic field, would that field require a 36-month transition to regain compliance? (313.1)
No - if the seeds are untreated. However, the pile of untreated seeds has to be removed as soon as the accident is discovered. If the seeds are treated, the area where the dumping occurred must go through a 36-month transition and a 8-metre buffer around the area would be required as well (5.2.2).

If GE seeds are accidentally planted in an organic system, is a 36-month transition required? (313.2)
Yes. Prohibited substances / products (see definition 3.57) references 1.4, (Prohibited materials (see definition 3.63) and techniques (1.4),therefore fields contaminated with products of genetic engineering require a 36-month transition to return to organic status. Any plants that have sprouted from these GE seeds have to be destroyed prior to seed set as soon as the accidental planting is noted. The 36-month transition, in this circumstance, will be calculated from the point in time at which the GE plants have been destroyed (e.g., tilled, mowed).

If GE seeds were purposefully planted in an organic system, would the 36-month transitional period be required after removal of the plants? (313.3)
No. Transition periods are irrelevant and do not apply to this scenario. Alternating in and out of organic production methods is prohibited (see 5.1.7 of 32.310), the operation's certification would be cancelled for current and future crops grown on that production unit.

 

Equipment – Lubricants

Are the lubricants used in harvesting equipment regulated by the standard? (122)
There is no specific reference to the maintenance materials such as lubricants in the standard. But equipment must be well maintained to minimize potential contamination of land (5.2.1).

Equipment – Shared

Are there any guidelines for cleaning farm equipment that is shared with non-organic operators? Could the sharing of equipment jeopardize certification? (147)
Where there is a risk that shared equipment could convey prohibited substances, seed, or crop, it must be adequately cleaned to ensure that contamination of organic products or land is prevented. The operator must document the cleaning process (5.2.1 of 32.310).

Irrigation – Shared

Can a farmer irrigate land from an irrigation system that uses Magnicide, an aquatic weed herbicide? (19, 104)
Active substances included in Magnicide cannot come in contact with organic land or crops. If the irrigation system can be shown to be free of such residues, it may be used to irrigate organic farms (5.7).

Treated posts

Would dipping untreated wooden posts in paraffin wax or using a polyethylene sleeve be allowed under 5.2.3? (186) 

Yes. Paraffin or polyethylene coverings can be used.The prohibition of wood treatments in 5.2.3 was aimed at eliminating toxins commonly used to prolong the life of wooden posts.

 

Is the buffer zone around treated posts permanent or transitional? (12.1)
The standard does not prescribe any buffer zone surrounding treated fence posts. The only time a buffer zone may be necessary is when a neighbour installs treated posts adjacent to your cropping zone. The status and width of the buffer in these circumstances will be determined on a case-by-case basis.
 

What happens when an applicant installs treated posts? (12.2)
If a commercial availability search was not done, a 36-month transition period dating from the installation of the treated posts applies to the specific production unit (e.g., field(s) where the posts were installed.
 

Version 2020

A 36-month transition period dating from the installation of the treated posts applies to the specific production unit (e.g., field(s)) where the posts were installed. 5.2.3 a)

 

What happens when an existing organic operation installs treated posts? (12.3)

This could lead to decertification if proper commercial availability due diligence (5.2.3a) cannot be demonstrated.

Version 2020

This would lead to decertification of the production units (e.g., field(s) where the posts were installed. 5.2.3 a).

 

Treated fence posts in livestock production

Do the treated wood restrictions in 5.2.3 a apply to barns and livestock facilities? (314)
Yes. As livestock production is a land-related activity (6.1.3) the treated wood restrictions in 5.2.3 a) applies to both organic crop and livestock production units including livestock facilities.

 

Certification of plantations - culinary oils

If culinary oils are harvested from an on-farm tree plantation, aka blocks of trees planted on a farm for this specific purpose, should these oils be certified under 'Crop production' (clause 5) or 'Wild crops' (clause 7.6) of the Canada Organic Standards? If the same culinary oils are harvested from private wood lots, or from Crown land timber which clause in the standards is applicable? (341)
The 'Crop production' requirements in the standard are applicable for the on-farm tree plantation scenario while the 'Wild crops' requirements are applicable for the wood lot and crown land situation. 'Wild crop' is defined in 3.71 (3.85) of the standard as "plants collected or harvested in their natural habitat."

 

5.3 Seeds and planting stock

Perennials – Transitioning

If perennial planting stock not treated with prohibited pesticides is planted on an organic farm, can the harvest be considered organic in the first year? (200)
Back to the Standards Interpretation Committee (October 2020).

 

Seed – Buffers

Are seeds produced on buffer strips able to be planted in organic fields? (17.1)
Seeds grown on buffer strips under the standards are the same as those grown on conventional farms (see 5.2.2 c). Exceptions to the use of organic seeds are specified in section 5.3 a).

Seed – Common

Can non-organic common seed be used if organic common seed is not available? (17.2)
Yes. For the purposes of 5.3 a),  "common" could be considered a varietal distinction subject to the exceptions to the use of organic seeds. See 3.13 (3.17), definition of "commercially available."

Seeds for green manure crops

Are the seeds used to grow green manure crops, intended for incorporation into the soil, required to be organic? (269)
Yes. All seeds used in the organic production system, whether the plant is used for food, feed or soil incorporation have the same requirements outlined in 5.3 - Seeds and planting stock. They must be organic except under the specific exceptions listed.

 

Seeds – GMOs

What level of GE contamination would be acceptable in seeds used for production under organic standards? Is it the responsibility of the operator or of the seed trader to check the GE contamination of the seeds sold for organic production? (41)
As testing for GE contamination is not mandatory, the standard does not specify who is responsible for checking for GE contamination, or what level of contamination is acceptable. But all operations, growing high-risk crops, have the responsibility to mitigate the risk of GE contamination (5.2.2 f) to the best of their ability, as outlined in their GE risk management plan (4.4.4). Testing could then be done to evaluate the effectiveness of the implemented plan. Certification Bodies also have the discretion to test when fraud or contamination is suspected. 
 

Use of non-organic planting stock

When using non-organic planting stock (such as plant tissue/cuttings) due to the fact that the organic form it is not commercially available (as permitted under 32.310 Section 5.3), at what stage would the resulting plant or transplant considered to be organic and can be sold as such? (475) -17 February 2020
A cutting is not considered organic until one year (perennial) or one crop season (annual) under organic management.

 

Seed – Transitional fields

Can seed grown on transitional land qualify as organic seeds/tubers (5.3) if used on the same operation where it was produced? (113)
Yes. Unlike the buffer zone where there is potential for exposure to non-permitted substances (spray drift), transitional land is managed using organic standards.Therefore, seed grown on transitional land is acceptable as it meets the requirement of 5.3 and as it has not been grown using prohibited substances or techniques.

 

Use of GE seeds before transition

Can prohibited substances, including GE seeds, be used by an operator in fields not yet in the 36-months transition period? (468) - 2 December 2019
Yes. Prohibited substances can be used prior to the start of the 36-month transition period providing the crop is not parallel production with organic crops on the operation. Take note that in the case of GE crops, calculation of the transition period begins after harvest and /or destruction of the crop per SIC Q&A 459a.

 

Seed – Treatments

About untreated seeds:
a) What is the definition of “untreated seed” as it applies to 5.3 in 32.310?

Untreated seed is seeds to which no pest control products, plant growth regulators, inoculants, or fertilizers, pelletizing agents, coatings, priming substances, etc., have been added. 
Pelleting of organic and non-organic seeds is allowed, but in both cases the pelleting substance must comply with restrictions in tables 4.2 and 4.3 (Table 4.2, columns 1 & 2). Priming of non-organic seeds is allowed if solely for the purposes of improving speed and uniformity of germination by getting water into the seed. Treatment of organic and non-organic seed, with substances on 4.2 and 4.3 (Table 4.2, columns 1 & 2) is allowed.

Version 2020 - this QA will be deleted.


b) Can a bleach solution be used on organic seeds? On non-organic seeds? (77)
No. A bleach solution containing a concentration of chlorine higher than municipal drinking water (see Table 7.3 Chlorine compounds) cannot be used on organic seeds to either clean or treat them prior to use. Chlorine can be used on non-organic seeds only between harvest and storage. Once non-organic seed is purchased by an organic operation, it must be handled the same as organic seeds.

 

Organic percentage for seeds

Do seed coatings or treatments need to be considered when calculating the organic percentage of an organic seed product? (472) - 2 December 2019
No. Seed does not fall under Clause 9, therefore a calculation of the percentage of organic ingredients is not applicable. The seed needs to be organic and any coating or treatment must be listed in PSL 4.2, 4.3 (Table 4.2, columns 1 & 2).

 

Tissue culture

Are propagules produced through plant tissue culture micropropagation included within the provisions of 5.3 (32.310) requiring that they be produced in accordance with the standard? (203)
Back to the Standards Interpretation Committee. (October 2020)

Offspring of GM seeds/plants

Can the offspring of GE seeds/plants be organic? (256)
No. The use of GE plants or seeds is prohibited.

 

5.4 Soil fertility and crop nutrient management

Crop rotation

Does the definition of crop rotation (3.17) (3.21) mean that growing the same crop 2 years in a row is not permitted? (134)
While the standard states that crop rotation shall be as varied as possible, growing the same annual crop two years in a row is not prohibited. 5.4.1 and 5.4.2 require that a soil fertility and crop nutrient management program be maintained. A regular soil monitoring program can be used as evidence of "practices that maintain or increase humus levels that promote an optimum balance and supply of nutrients, and that stimulate biological activity within the soil". 

 

Rotation with crops not under COR

Can an operator use crops not covered under the Canada Organic Regime (COR) (tobacco or cannabis) as part of the operation’s rotation and still keep the organic status of the fields? (466) - 2 December 2019
Yes. Crops that are not covered by the scope of the COR may be grown in a rotation without affecting the organic status of the field(s), provided that they are managed in accordance with the standard.

 

Hydroponics

Is the prohibition on hydroponics applicable only to greenhouses, or to all types of crop production? (74.2)
The prohibition of hydroponics is universal and not limited to greenhouses. See 5.4 (soil fertility requirements) and 7.5.3 (7.5.2) (hydroponic prohibition).

 

5.5 Manure management

Manure sources

Can manure from livestock raised in cages be used, if the farm has a nutritional deficit and no other manure is available within a reasonable distance? (83)
As per 5.1.1 a), only manure from caged animals that cannot turn 360°is prohibited (e.g., manure from sows in farrowing crates). There are no exceptions.

Is the manure from a conventional farrowing operation compliant with the standard? (90)
Manure from sows that are kept in traditional farrowing crates and not able to turn around is prohibited under 5.5.1 a). This is the intent of the standard. The wording of 5.5.1 a) leads to the need for interpretation of the term 'fully caged system'. The part of the operation where traditional farrowing crates are used constitutes a 'fully caged system' under the standard and manure from those animals is prohibited, notwithstanding the fact that some other animals in the barn are housed differently. If the manure from the sows in the traditional farrowing crates can be segregated, the rest of the manure will be acceptable.

Does the presence of animal droppings in fields, orchards and vineyards require a waiting period as prescribed in 5.5.2.5? (31, 159)
5.5.2.5 does not apply to incidental animal droppings such as those from wild animals or birds, grazing or working animals; however, 5.5.2.4 (a) does apply and requires diligence on the part of the operator to ensure that any activities under his/her control do not cause pathogenic microbial contamination of the crop. 5.5.2.6 clearly states if livestock are part of the cropping or pest control program there has to be a management plan in place regarding manure-related contamination and the edible crop.

 

Manure from nonorganic animals raised on an organic operation

5.5.1 states "Animal manure produced on the operation shall be used first." If the operation raises non-organic animals, should this manure be used first before the operation attempts to source organic animal manure from off farms? (438) - 21 June 2019
Yes. Animal manure, whether from organic animals or not, produced on the farm shall be used first. On-farm nutrient cycling is an important principle of organic production. The organic matter produced on the operation shall be the basis of the nutrient cycling program. There is confusion on this issue between the English and French versions of the standard which this also seeks to address.

 

Manure from confined operations

Can manure from confined animal feeding operations be applied on organic land? (322)
Yes. Manure from such operations may be used providing requirements of 5.5.1 and 5.5.2 are met.

 

 

6  Livestock production

 

6.1 General

Outdoor pastures and outdoor areas

What is the difference between outdoor pastures and outdoor areas? (458.1) (17 February 2020)

“Outdoor pastures” provide vegetation and nutrition to animals and are required during the grazing season (see 32.310 6.1.3 a) for the purpose of feeding livestock. ”Outdoor areas” may or may not contain vegetation. Outdoor areas are used to accommodate livestock health and allow for natural behaviours throughout the year when the animals are not on pasture (see 32.310, 6.7.1 a)).

 

Poultry peepers/blinders

Are poultry peepers/blinders, with or without attachment pins allowed to prevent cannibalism? (350)
Poultry peepers / blinders are permitted only without pins and only when all other management methods have been tried and have failed. As required per 6.1.6 documentation must be maintained to demonstrate strategies are in place for the reduction of peeper/blinder use.

 

6.2 Origin of livestock

Breeding stock – Alternating organic and non-organic management

Please clarify the meaning of 6.2.3.2 (6.2.4).  Does it allow that animals could be given conventional feed repeatedty until the last trimester of pregnancy, and still give birth to offspring compliant with the Standard (i.e., have offspring that are considered organic)? (87)
No, this practice would not be permitted. 6.2.3.2 (6.2.4) applies only to the transition of whole herds or individual animals used as new breeding stock (whether from within the operation or from another operation). For animals already under organic management, the feeding of non-organic feed at any time during gestation would render the mother and offspring non-compliant (i.e., non-organic). Beef cattle and dairy breeding herds cannot be rotated in and out of organic production. Refer to 6.2.5.

Breeding stock

Can non-organic animals that have been transitioned to organic management become acceptable a) for breeding? b) for slaughter? (48.1, 48.2)
a) Possibly. Breeding animals may undergo transition from conventional to organic management and be used as breeding stock in organic production according to the terms specified in the standard (see 6.2.2, 6.2.3, 6.2.3.2 and 6.2.4). Breeding males used on organic farms do not have to be organic but cannot be cloned or be the descendants of cloned animals (1.4 ).
b) No. Meat from a non-organic animal will never be considered organic even if the animal has gone through transition and is allowed to be used as organic breeding stock.

Definition of dairy animal

What is the definition of a “dairy animal” under the standard? (24.2)
A dairy animal is any animal in a herd that produces milk for human consumption.

Sexed semen

Can sexed semen be used in organic production? (40)
Yes, the use of sexed semen does not violate the standard (refer to 6.2.2 a).

Embryo transfer

Is embryo transfer allowed? (Embryo transfer is the collection of eggs from one female and subsequent implantation of the eggs in another animal to complete gestation)? (240) 

No. In 6.2.2 b), the standard prohibits embryo transfer techniques in organic livestock.

 

Can an animal which is the product of an embryo transfer be brought into organic production? (214)

Yes, however the animal cannot be sold for slaughter but may be used for breeding or dairy production, subject to the transition requirements of 6.2.4 and 6.3.

 

Fertilized eggs

Can birds hatched from eggs treated with antibiotics be certified organic? (271)
No. 6.2.3.1.2) (6.2.3.2 b) states "no medication other than vaccines shall be used to treat fertilized eggs or day-old poultry".
 

Health care for poultry

Does clause 6.2.3.1 (6.2.3.2) mean that day-old birds and/or fertilized eggs can ONLY be given vaccines (i.e., no other medication), while birds that are two day old or older can be given vaccines and/or other medications, if required? (339)
Yes, fertilized eggs and one day-old birds may only be given vaccines, no other medications. Vaccines and certain other medications can be used on older birds as specified in 6.2, 6.6.10, 6.6.11 and 6.6.12 (32.310).

 

Raising pullets for layer organic operations

May non-organic operations raise pullets for organic layer operations? (428) - 19 Apr 2019
No. Pullets must be produced by certified organic poultry producers. It is not sufficient for an organic farm to subcontract pullet production to a non-organic operation even if the pullets are raised under conditions that meet the requirements of the standard in all other ways from the second day of life and the sub-contracted operation is inspected annually by the certifier of the organic layer operation.

 

Transitioning of dairy calves
 

Can a dairy calf which is part of an organic operation be fed conventional milk, then transitioned back to organic status? (See 6.2.3.2 (6.2.3.3)) (259)

No. 6.2.3.2 (6.2.3.3) applies only to the transtion of herds and to individual animals used as breeding stock.

 

Breeding sows – Synchronized estrus

If a producer purchases non-organic non-gestating sows for breeding, brings them into a new operation site, uses hormones to trigger and synchronize estrus, and keeps these females under continuous organic management from the beginning of the last third of their gestation period, would the piglets born from these sows on this site be considered «organic»? (195)

No. The piglets would not be considered organic. Although the standard allows for the introduction of non-organic breeding stock into an organic operation, it requires that from the moment of introduction, the operator complies with all the rules for organic livestock husbandry. The use of hormones to trigger estrus is specifically prohibited in 6.2.2 c), therefore the use of this technique would be a serious non-compliance.

Cloning

Is the use of cloned animals allowed? (148)
No. All of the conditions listed in 1.4 are forbidden. The origin or lineage of animals needs to be known to ensure that no cloned animals are used nor the descendants of cloned animals (1.4 g 2015  1.4 d 2020).

 

6.3 Transition of livestock production units to organic production

Pasture – Poultry

Does 6.3.3 apply to pasture used for poultry? In other words, can the raising of pullets be timed to coincide with the transition of land rather than waiting until the pasture is CO to start a new flock? In this case, if pullets hatched when the range was only  partway through the transition, when these birds become layers, are they allowed to forage on the land for the last twelve months of transition? (99)

No. 6.3.3 applies to pasture used by a herd or a flock of sheep and not to pasture used for poultry. Pasture for poultry is considered an orgainc crop (5.1.1) and must be free of prohibited substances for 36-months prior to use (6.13.1 b). In other words, land can be in transition still when pullets are started, but the land must have completed the necessary transition period and been granted organic status by the time birds are ready to go out to pasture. 

Transition - Outdoor runs

Does the requirement for a 36-month transition of land for crop production apply to the outdoor runs required to permit poultry access to the outdoors? (225)
Yes. Poultry eat when they go outside, including ingesting small amounts of soil. Since organic feed is required (6.4), all outdoor runs/pasture must have completed the necessary 36-month transition period and been granted organic status before being accessed by organic poultry.

 

Offspring born under transition

Can livestock offspring be considered organic for meat, if they were born on a production unit in transition, prior to the end of the final 12 months of transition, as long as the dam has been under organic management for the last third of gestation (6.2.3.2 b) (6.2.3.3 b), including eating pasture and feed produced within the operation, which is considered organic when consumed by the transitioning herd or flock on the same production unit, as per 6.3.3? (409) - 29 April 2020

No. With reference to clauses 6.2.3.2 and 6.3.3 (6.2.3.3 and 6.3.3) , livestock offspring born on land in transition would not be considered organic for meat. 6.3.3 allows for the final third of gestation to occur during the final months of transition. Offspring can be considered organic for meat if they were born on or after the day that the land has completed the necessary transition period and been granted organic status.

 

Transitional feed

When a beef cow herd is being transitioned to organic, does 6.3.3 give permission to use transitional feed that is produced on the farm to feed gestating animals whose offspring will be eligible for sale as organic? (179)
Yes. However the offspring will only be considered organic if they are born after the 36-month transition period for the land has ended.

Can the use of feed from transitional land allowed in 6.3.3 be allowed after the transition of the livestock is complete? (257)

No. Feed produced on land in the final year of transition (commonly referred to as T-3 feed) is considered organic within the farm unit while the herd or flock of sheep is in transition. The T- 3 feed produced and harvested before herd transition is complete may continue to be used as organic within the farm after herd transition is complete. T-3 feed harvested after herd transition is complete has no organic status even within the farm.

 

Non-organic feed when transitioning entire dairy herds

Is GE feed permitted in the 20% non-organic feed allowance for first time transitioning entire dairy herds (6.3.1 a)? (407)
Yes. GE feed may be used in the 20% non-organic feed allowance when initially transitioning an entire dairy herd, and this information should be documented in the operation's organic plan.

 

Parallel production in livestock production

Is parallel production in livestock prohibited?  If not, under what circumstances might it be allowed? (283)

Within the same production unit, parallel livestock production is prohibited. See the parallel production definition (clause 3) which includes livestock. See also 6.7.5, which stipulates all animals in a production unit must be managed organically whether or not all the animals have organic status and that the non-organic animals must be clearly identified.
An exception exists when there is more than one production unit in an operation and complete separation is ensured. This would require separate records, barns, separate feed and input storage areas, separate runs, and separate pasture, etc.

 

6.4 Livestock feed

Buffers – Livestock feed

Can livestock feed harvested from the buffer zones around organic cropland be fed to livestock in transition to organic? (149)
No. As per 5.2.2 c), feed harvested from the buffer zones is non-organic. Feeding buffer zone feed would be the same as feeding conventional feed and is not permitted.

 

Treatment of stored feed

Can stored livestock feed (6.4.4) be treated with substances listed in PSL Table 4.3 (4.2, Column 2) or Table 5.2? (330)

Substances listed in Table 5.2 can be applied to, or combined with, stored livestock feed (6.4.4). Substances listed in Tables 8.2 and 8.3 may be used if their substance listing annotation does not prohibit direct contact with organic products. Substances in Table 4.3 (Table 4.2 (Column 2) can only be used during crop production - not post-harvest.

 

Feed storage – Commingling

An organic grain producer is using all his organic livestock feed to feed to non-organic livestock. During storage, the organic feed may have been mixed or commingled with non-organic feed purchased from off the farm. Is there any risk that this would compromise the producer's  ability to certify future crops from the same fields? (97.1)

No. At the point in time where the separation between organic and non-organic feed is compromised, the feed in question loses its organic status. This has no effect on the organic integrity of the field and the capability to produce organic feed in subsequent years. 

 

Emergency feed

Can the allowance of non-organic feed in catastrophic circumstances (6.4.7 a)) be expanded to include commercial or logistical challenges outside the operator's control? (e.g., a shipment is held up by border inspection) (156)

No. The examples of farm-scale catastrophic events cited in 6.4.7 a) (fire, flood, extreme climatic conditions) do not extend to commercial or logistical problems.

Is the operator required to obtain pre-approval for use of non-organic feed during a catastrophic event? (89.1)
No, the operator does not need preapproval. However, the operator should notify their CB and explain the situation as soon as possible. It is the responsibility of the operator to adequately and successfully demonstrate to the CB that 6.4.7 a) is applicable and the operator has met the instructions laid out in 6.4.7 a) (See note to 6.4.7).

 

Can you give some guidelines around the use of the 10-day maximum in 6.4.7 a)? (89.2)

Ten consecutive days from any catastrophic event is the maximum permitted to provide completely non-organic feed given the intent of 6.4.7 a) which was to allow the operator time to source organic feed.

In 2020, however, a change was made to allow “up to 30% non-organic feed for up to 30 days.” This helps farmers who can find organic sources for some, but not all, of the necessary feedstuffs within ten days of the catastrophic event.

 

 

6.4.7 b) allows for the feeding of non-organic forage to breeding herds in the case of a regional forage shortage. If a producer anticipates running out of organic forage: (157)
a) Can they prepare by sourcing the non-organic feed before they run out?

Yes. The operator may source the non-organic forage ahead of time, but before feeding, the regional feed shortage must be confirmed by the CB. Also all other conditions of 6.4.7 b) must be addressed including: maintenance of detailed records to track feed and animals fed, to confirm non-GE status of the feed. Animal must be segregated and effort should be taken to use transition feed or at least forage grown without prohibited substances.
b) Which animals can be fed the non-organic feed and what are the implications for the status of meat and milk?
With the agreement of the CB, the non-organic forage may be fed to:

1) non-lactating dairy animals - without affecting their status in future lactation.

2) beef cows or ewes that are not nursing offspring, during the first 2 trimesters, without affecting the status of future offspring in utero.

 

6.4.7 b) allows for the feeding of non-organic forage to breeding herds in the case of a regional forage shortage. Which animals can be fed the non-organic feed and what are the implications for the status of meat and milk? (157)

As per 6.4.7 b) and c), in the case of a forage shortage, the operator shall first feed non-organic forage to breeding stock but only if the CB agrees and if the operator has a plan to avoid future shortages. The breeding stock will then lose their organic status and must be re-transitioned. Normally switching back and forth from organic to non-organic production is not permitted. However, this exception allows for breeding stock under these specific circumstances to be fed non-organic feed and then re-transitioned. If  non-organic forage is fed to animals during the last trimester of gestation, the offspring will not be organic. Similarly, if lactating females are fed non-organic forage, the nursing young will lose their organic status.

If organic forage is in such short supply that the shortage continues even after the breeding stock is fed with non-organic forage, the remaining animals in the ruminant herd can be fed non-organic forage but (i) it can make up no more than  25% of their forage intake, (ii)  the operator must have a plan to avoid future shortages, and (iii) all other requirements of 6.4.7 c) are met (including the order of preference of sources). The animals fed with 25% non-organic forage will then remain organic (milk and meat).

Note, the 25% non-organic forage allowance differs from the limit of 20% non-organic feed permitted under specific transition requirements  for dairy cows in 6.3.1.

 

Use of non-organic feed

Under what circumstances can a dairy operation use non-organic feed? (260)
1. Catastrophic event: Following a catastrophic event that directly affects the operation, a dairy herd may be provided non-organic feed for a maximum of ten consecutive days, as specified in 6.4.7 a. In this case there is no interruption of the production of organic milk and all animals retain organic status for sale as meat.

2. During a regional organic shortage, lactating animals must be provided a 100% organic ration for their milk to retain its organic status. In other words, milk from dairy cows provided non-organic forage as a result of a regional organic feed shortage loses its organic status. For milk from these cows to regain organic status: a) these cows must have been provided a minimum of 80% organic feed during the regional organic forage shortage; and b) a three-month transition period in which these cows have been fed 100% organic feed must be completed.

3. Dairy herds in transition to organic production may be provided non-organic feed, in accordance with the rules in 6.3.1 a and b, which allow cows to be fed for 9 months with a minimum of 80% organic feed ration, followed by 3 months of 100% organic feed. Transitional feed in the last year of transition, produced on a farm transitioning its whole dairy herd to organic production may be considered to be organic on the same farm. (32.310-6.3.3)


1. Catastrophic event: Following a catastrophic event that directly affects the operation, a dairy herd may be provided non-organic feed for a maximum of ten consecutive days (or up to 30% non-organic feed for up to 30 days), as specified in 6.4.7 a. In this case, there is no interruption of the production of organic milk and all animals retain organic status for sale as meat.

2. During a regional organic shortage: refer to QA 157 above.

3. Dairy herds in transition to organic production may be provided non-organic feed, in accordance with the rules in 6.3.1 a and b, which allow cows to be fed for 9 months with a minimum of 80% organic feed ration, followed by 3 months of 100% organic feed. A farm that is transitioning its whole dairy herd to organic production may use T3 feed grown on that same farm (i.e., feed from fields in the last year of transition) (32.310-6.3.3). 

Note, the 20% non-organic feed refers to the specific transition requirements of 80% organic feed for dairy cows in 6.3.1; this differs from the limit of 25% non-organic forage as permitted under specific circumstances in forage shortages as outlined in 6.4.7 c.

 

Bypass fat

If the conditions outlined in 6.4.7 which allow for temporary use of non-organic feed are met, would this allowance also extend to the use of non-organic bypass fat? (95)

No, this is not permitted because the feed energy could be sufficiently provided by  non-organic grains, silage or haylage after the catastrophic event. The allowance to use non-organic feeds is intended to allow the operator to maintain the health of animals following a farm catastrophe.

 

Milk for replacement kids

Can non-organic reconstituted milk be given to the replacement kids in an organic goat dairy herd if the 12-month transition for the kids is respected? (394)
No. The exception for 6.2.3 only applies to herds and animals in transition to organic production. 6.4.3 d) provides specific requirements for lambs and kids which only permit organic milk (fresh whole or reconstituted). 6.4.7 only permits non-organic feed in the case of a catastrophic event or a regional shortage. 6.4.7 b) also specifies that 6.2.3 applies to offspring.

 

Feed – Transitional

When a beef cow herd is being transitioned to organic, does 6.3.3 give permission to use the transitional feed produced on the farm, to feed gestating animals whose offspring will be eligible for sale as organic? (179)
Yes, provided that the offspring are born after the completion of the 36-month transition of the land on which the feed has been grown.

Silage inoculant additives – Colour

If a silage inoculant contains synthetic colouring agents, does that mean that it is prohibited for use in organic livestock feed production? (94)
Yes. The use of synthetic colouring agents (6.4.4 j)) makes the product non-compliant for use in organic feed.

Yes. Only colouring agents from biological sources, such as dehydrated beets, can be used in livestock feed or forage as described in Table 5.2 of the PSL.

 

Summer ration – Long-fibre forage

When calculating compliance with 6.4.3 g) & h) (6.4.3 i) & j) of a summer ration for ruminants, can pasture be considered “long-fibre forage”? (194)
No. 6.4.3 g) & h)  (6.4.3 i) & j) address feed rations when animals are not on pasture. During the grazing season 6.1.3 a) applies, and requires that sexually mature ruminants obtain a minimum of 30% of their total forage intake from grazing calculated on dry matter basis.

40% grain ration in early lactation

6.4.3 g) (6.4.3 i)  allows for increased grain feeding during uncommonly cold conditions or when forage quality is compromised to ensure that nutritional requirements of ruminants are met. Can dairy cows be fed more than 40% grain in early lactation when their energy requirements are highest? (295)
No, dairy cows cannot be fed more than 40% grain to meet their nutritional needs in early lactation. The allowance for feeding more grain in 6.4.3 g) (6.4.3 i) is only for exceptional circumstances beyond the control of the operator.

 

Percentage of organic ingredients for feed

May livestock be fed organic food waste containing 95% or more organic ingredients? What about food waste stemming from products only containing 70-95% organic ingredients? (372) - 19 Apr 2019
Livestock may be fed organic food waste (≥ 95% organic content) certified in accordance with 32.310 subclause 9.2.1. Food products containing 70-95% organic ingredients and compliant with 32.310 subclause 9.2.2 can only be fed to livestock according to the derogation in 6.4.7. The subject of this Q&A is under review by the 2020 CGSB Technical Committee.

In 2020, “Food waste” was added to Table 5.2 and the annotation specifies that it is allowed to use “organic food for human consumption or by-products from organic food production”. This means that livestock may be fed organic food waste (≥ 95% organic content) certified in accordance with 32.310 - subclause 9.2.1. Food products containing 70-95% organic ingredients and compliant with 32.310 - subclause 9.2.2 can only be fed to livestock according to the derogation in 6.4.7.

 

 

Vegetable matter

Regarding the 'vegetable matter' element in the requirements for poultry and pork (6.4.3 j)  (6.4.3 l) (340) - 29 June 2020

a) is organic vegetable matter required?

Yes. Organic vegetable matter is required.

b) would non-cereal grains (soybean, flax, corn) count as vegetable matter?

No. Vegetable matter is referring to fruit (apples, pears, etc.), vegetables (lettuce, potatoes, squash, etc.) and the associated crop waste and forage (straw, hay).

c) would straw and seed cleanings count?

Yes - for straw. No - for grain-based seed cleanings.

d) would a grassed access area count?

Yes. Organic pasture would qualify as vegetable matter.

e) would alfalfa meal or pellets count?

Yes. Alfalfa in any format satisfies the current requirements.

This vegetable matter fraction can be supplemental to the feed ration or can be included in the feed ration

 

6.5 Transport and handling

References for animal transportation

Clause 6.5 refers to the Code of Practice for Care and Handling of Farm Animals: Transportation. Also, the note in 6.5 refers to the Health of Animals Regulations under the Health of Animal Act (CFIA). If these two sets of rules contradict one another, which one is to be referred to in evaluating compliance? (315.1)
These two references are not in contradiction. Table 4 of the Code of Practice for Care and Handling cites the Health of Animal Regulations. This table shows the maximum times for travel. When these maximums are reached, it requires that the animals be unloaded and given feed, water and 5 hours of rest time.


I have a choice between two slaughterhouses - one is 2 hours away and another 6 hours. Am I at liberty to use the facility 6 hours away? (315.2)
No. 6.5.5 is explicit - “The duration of transportation shall be as short as possible." The recommendations from the Code of Practice for Care and Handling of Farm Animals: Transportation become applicable when the closest facility is more than 5 hours away.

 

6.6 Livestock health care

Hormone treatments

Is the use of therapeutic hormonal treatment, for example prostaglandins to treat metritis, allowed in dairy animals?  If so, what are the restrictions and withdrawal times? (78.1)
Therapeutic use of hormones such as prostaglandin which is not listed on the PSL is permitted when treatments listed in the PSL are unlikely to be effective, and preventive measures have failed. A 14-day withdrawal period must be observed. If the prostaglandin is used in such a manner, as per 6.6.3, the animal is not eligible for use as organic meat, but this event is not counted as one of the dairy animal “treatments” referred to in 6.6.10 e 4) or 6.6.10 e 5), or 6.6.11 e) (6.6.10 c) or 6.6.10 e) ou 6.6.10 f). That "two-treatment" restriction only applies to treatments of antibiotics and parasiticides (as clarified in the 2020 COS).

For all treatments not listed on the PSL, a minimum withdrawal period of 14 days must be observed - see 6.6.10 d).

Can oxytocin be used to treat postpartum complications?  If so what are the withdrawal rules? (78.6)

Yes. 6.6.3 specifies that hormones are acceptable when the use is therapeutic, not preventive. For oxytocin, the animal does not lose status as organic meat. The withdrawal time is double what is stated on the label or 14 days, whichever is longer. See PSL Table 5.3 Oxytocin and 6.6.10 d) - 32.310.

 

Medical treatments – Dairy animals

Do two separate incidents of treatment with antibiotics and parasiticides administered in combination count as one treatment, two treatments, or four? (135)
6.6.10 e 5)  and 6.6.11 e) (6.6.11 h) mean that the maximum allowable is a total of two treatments per year including each incident of a combined treatment. For example, when a combination of two drugs is supplied at the same time, it counts as two treatments. Therefore two separate incidents of a combination dose would count as a total of four treatments.

However, 6.6.10 e)  states that that an animal treated for the same disease for three consecutive years must be removed from the herd (within 9 months of the last treatment). So, if an antibiotic was used one year and parasiticides in two subsequent years, the animal could stay within the herd, but not if, for example, a dairy cow received antibiotics for mastitis three years in a row.

 

In the case of antibiotic use in dairy cows, if the operator provides test results to show that there is no residue in the milk, can the compulsory 30 day withdrawal period be shortened? (125)
No. 6.6.10 e 2) (6.6.10 f) states that the minimum withdrawal period is 30 days after the use of any antibiotics, even topical applications in milking cows. No exceptions are specified.

However, as specified in 6.4.3 d, organic calves can be given the milk after a withholding period of twice the label requirement or 14 days, whichever is longer.

 

Medical treatments (parasiticides) – Slaughter animals

Please clarify the meaning of the standard regarding the use of parasiticides and the loss of organic status or withdrawal periods for meat and milk. (78.2, 24.1)

Parasiticides not listed in the PSL may be used on slaughter animals only if
• preventative measures have failed (6.6.11);
• fecal or tissue samples confirm the correct diagnosis (6.6.11 a));
• written instructions from a veterinarian which specify the product and method of parasite control (6.6.11 b)  have been obtained;
• the required withdrawal time is twice the label requirement or 14 days whichever is longer (6.6.11 c)),
• there can only be one treatment for slaughter animals under a year old and a maximum of two treatments in the life of the animal. (6.6.11 d),
• For dairy animals no more than a total of two treatments a year of antibiotics and, parasiticides in any combination. (6.6.11 e).  Refer to Q&A 135 for further insight on treatment counting.

 

Parasiticides not listed in the PSL may be used on slaughter animals only if:
• preventative measures have failed (6.6.11);
• fecal or tissue samples confirm the correct diagnosis (6.6.11 a);
• the operator provides a written action plan, with a timeline, describing how they will amend their parasite control plan to avoid similar situations in the future (6.6.11 b);
• the group of animals or entire production unit has not been treated two years in a row for the same problem (6.6.11 c),
• the operator has obtained written instructions from a veterinarian that specify the product and method of parasite control and the operator has developed a plan to avoid the development of parasite resistance to the parasiticides (6.6.11 d);
• the required withdrawal times is twice the label requirement or 14 days whichever is longer (6.6.11 d);
• there can only be one treatment for slaughter animals under a year old and a maximum of two treatments in the life of the animal (6.6.11 g);
• for dairy animals, no more than a total of two treatments a year of antibiotics and parasiticides in any combination are permitted (6.6.11 h). (efer to QA 35 for further insight on treatment counting. However, dairy cull animals that receive more than two treatments of parasiticides in their lifespan 2020 or any antibiotics in their lifespan cannot be considered organic in terms of meat.

Note that gestating animals may be given parasiticides during gestation (6.6.11 f).

 

Parasiticide treatment after 12 months

How many parasiticide treatments may be given to meat animals older than 12 months? (406) -19 Apr 2019

A meat animal can receive one parasiticide treatment within its first year. A total of two parasiticide treatments are permitted within a meat animal's lifespan (see 32.310 6.6.11 d) (32.310 6.6.11 g).

 

Veterinary treatment – Withdrawal period

In the case of using a treatment not listed in 32.311, where no withdrawal time is indicated on the label, must organic operators still observe a withdrawal?  (78.4)
6.6.11 c) (6.6.11 d) states that when veterinary drugs not listed on the PSL are used, a withdrawal period of 14 days or twice the label withdrawal shall be observed.  If there is no withdrawal time listed on the label of a pharmaceutical veterinary drug, the 14 day withdrawal period must still be observed. See QA 449.

 

Spray bandage

Is a spray bandage (which is sprayed on wounds, replacing traditional bandages) allowed? (292)
A spray bandage, containing ingredients not listed in 32.311, would fall into the category of "prescribed veterinary drugs" (6.6.10 c). It could be used if the products permitted by the Standard "are ineffective in combatting illness or injury". The withdrawal period specified in 6.6.10 d) applies, as well as the special provision for poultry and breeding stock in 6.6.12.

 

Physical alterations – Anti-inflammatories

Are steroid anti-inflammatory drugs allowed during physical alterations? (78.3)
No – 6.6.4 c 2), by specifically noting “non-steroid” are permitted, implies that steroid anti-inflammatory drugs are prohibited for minimizing pain and stress during physical alteration.

 

Physical alterations – Beak trimming

What justification must be given in order for beak trimming of day-old chicks to be permitted (i.e., compliant with the Standard)? (275)
Since beak trimming is only effective if done before problematic behaviour starts, the operator can point to previous experience or to the shared experience of operators to reasonably predict that problems would emerge to justify day-old beak trimming. The procedure for trimming must be minimal and conducted in a way that minimizes pain, stress and suffering (6.6.4 c) (6.6.4 c 1), 2) 4)). The operator must document the other measures taken to reduce or eliminate behavioural problems in flocks.

Can beak trimming be carried out as a preventive measure or is the allowance for this practice under 6.6.4 c) 4) only relevant after a problem arises? (101)
Yes, the practice of beak trimming is acceptable as a preventive measure to ensure the welfare of poultry if only a very small amount of the beak, the sharp hook, is trimmed or treated (6.6.4 b) 1). In order to remain compliant with the standard, the operator must also document the other measures taken to prevent or control problematic behaviours. Since the standard implies that this is an extraordinary event, it should not become the norm. Operators who employ this technique must review annually with the CB their plans to eliminate the need for beak trimming or treatment.

 

Physical alterations – Dehorning paste

Is de-horning paste allowed? (29)
Yes, all types of dehorning paste are acceptable under  6.6.4 a 4), but operators must abide by applicable industry Codes of Practices and restrictions outlined in 6.6.4 c).

Immunological castration - Pigs

Can immunological castration of pigs during the finishing phase be used to replace castration of young pigs? (218)
No. The substances used would have to be listed on 5.3 of the Permitted Substances Lists in order to be acceptable.

Livestock, vaccines – GE contamination

What would happen if organic livestock are unintentionally contaminated with a GM rabies vaccine? (52)

The note after 8.3.5 addresses the issue of emergency pest or disease treatment. The evaluation of compliance or non-compliance following this theoretical scenario would depend on: the degree of contamination; the precise nature of the contaminant; and the ability of the operator to identify and exclude affected animals. How and why the contamination occurred is not relevant to evaluating compliance. Operators need to inform their certification body when such incidences occur.

GE vaccines for poultry

Can GE vaccines or vaccines grown on GE substrate be used in poultry if the conditions for the use of veterinary drugs (6.6.10) are met? (298)

Vaccines are categorized in the standard as 'veterinary biologics' not 'veterinary drugs'. GE vaccines that are products of genetic engineering, as defined in clause 3.27 of 32.310 cannot be used on two day old birds and older birds. Vaccines grown on GE substrate may be used if no alternative is commercially available and that no traces of the GE substrate exist in the vaccine (32.311 - 5.1.2). Day-old birds and fertilized eggs can be given any type of vaccine (6.2.3.1 b).

Vaccines are categorized in the standard as 'veterinary biologics' not 'veterinary drugs'.  As described in Table 5.3, GE vaccines or vaccines grown on GE substrate can be used if non-GE vaccines are not commercially available. Genetic engineering (GE) is defined in clause 3.31  of 32.310. However, day-old birds and fertilized eggs can be given any type of vaccine (6.2.3.1 b).

GE vaccines for pigs

To prevent livestock losses to deadly diseases (e.g., CircoVirus in pigs), can a genetically engineered vaccine be used, if we consider that it is 'necessary to prevent or treat livestock health problems when other treatments permitted by this standard are not available", as stated in 32.310, 10.3 Criteria for Examination of Particular Substances, Table 9, under Livestock health care? (436) - 19 Apr 2019
No. At present the standard does not allow for the use of GE vaccines. Furthermore, clause 10 describes the process to be used when assessing additions or changes to the Permitted Substances Lists. Clause 10 is not a tool to justify the use of a specific input. The CGSB's Technical Committee on Organic Agriculture is discussing this issue during the current standards review.

A GE vaccine can be used but only if non-GE vaccines are not commercially available or are not efficient (i.e., all vaccines for that particular disease in the marketplace are the product of genetic engineering).

 

Vaccines with preservatives

Are livestock vaccines containing bacteriostatic or fungistatic preservatives permitted? (402)
Yes. But do not overlook that 1) as stated in Table 5.3 of 32.11, “If there are no commercially available sources of non-GE vaccines, or if these are ineffective, GE sources can be used.”; and 2) in the case of poultry, the vaccine is allowed only  given before the chicks are 2 days old.

 

6.7 Livestock living conditions

Poultry housing – Sunlight

Does housing for broilers require windows for sunlight to enter while the birds are confined? (82)

Yes. As per 6.7.1 a) and 6.13.8 (6.13.12), natural light inside the barn is required but windows are not the only mean to satisfy the standard. For example, light permeable fabric is another option.       

 

Level of natural light in poultry barns

Can we have some guidance on how to evaluate the level of natural light in poultry barns? 6.13.8 (6.13.12) requires the ability to read a newspaper but this reference is subjective and variable depending on the person's eyesight and the level of light outside. (316)
The enforceable norm for windows in poultry barns is stated in 6.13.8 (6.13.12): "The total window area shall be no less than 1% of the total ground-floor area..." If this condition is met, there is no need to evaluate light levels. However, if a poultry barn does not meet that minimum, 6.13.8 (6.13.12) also offers alternative means of demonstrating effective natural lighting: "unless it can be demonstrated that natural light levels are sufficient to read a document such as a newspaper anywhere in the barn." In other words, a newspaper that can be read outdoors using natural light must also be legible inside the barn.

 

Bedding for poultry

Is an operator obligated to provide bedding for poultry (as in 6.7.1g), or is it enough to allow litter to “build up” from poultry waste without adding anything? (426) - 19 Apr 2019
As stated in 6.7.1 g), bedding must be provided from the onset of a cycle to "establish and maintain animal living conditions that accommodate the health and natural behaviour of animals". The amount of bedding should be sufficient to keep the birds clean, dry and comfortable. It should also permit the birds to express their behaviour, including scratching and dust bathing. See also 6.13.10 for details on bedding for poultry.

Outdoor access – Turkeys

If an operator arbitrarily confines turkeys inside for one week prior to slaughter, does this constitute non-compliance with the standard? (39)
The standard sets out a number of legitimate reasons for denying outdoor access. Turkeys or other livestock cannot be denied outdoor access for any reason other than those outlined in 6.7.2. Note that “measures taken to reduce the need to restrict outdoor access in the future shall also be documented when circumstances are within the operator's control.”

Outdoor access – Pigs

Can the organic operator choose to keep pigs confined, not allowing outdoor access, when there is no risk to the animal caused by weather or stage of production? (196)
No. Complete confinement of pigs is non-compliant with 6.7.1 a). A key requirement of organic animal husbandry is access to outdoors. 6.7.2 states the specific exceptions to the rule which apply to all livestock. 6.15.2 outlines the outdoor exercise requirement for pigs.

Outdoor access – veterinarian recommendations

Under CAN/CGSB-32.310 Section 6.7.2, can operators limit access to the outdoors to their entire herd / flock (such as goats, sheep, cattle, poultry) for the entire winter if the operator provides a letter from their veterinarian stating that access to the outdoors is detrimental to the health of the particular species of livestock? (354)
No. The standards already provide sufficient flexibility to address the health and welfare of organic livestock with specific guidance and exceptions with regard to outdoor exercise and access to pasture (6.1.3, 6.11.1 & 6.13.1).

Possibly. For example, poultry may be kept indoors in the winter without a letter from a veterinarian. The standards already provide sufficient flexibility to address the health and welfare of organic livestock with specific guidance and exceptions with regard to outdoor exercise and access to pasture (6.1.3, 6.11.1 & 6.13.1). - UNDER REVIEW

 

6.11 Additional requirements for cattle, sheep and goats

Outdoor access – Finishing phase

When herbivores are being confined in the final finishing phase (see 6.11.1)), and are not subject to pasture requirements, must the confinement facility be located on an organic enterprise? (116)
Yes. The areas used for finishing, including all buildings, facilities and outdoor access areas which are used by the organic livestock, must comply with the standard and be verified by the CB.The remainder of the farm is not required to be organic.

Note that even during the finishing phase, the animals “they shall have access to the open air or an outdoor exercise area, weather permitting” as specified in 6.11.1 of the 2020 Standards.

Access to exercise yards

Must young herbivores be given access to exercise yards outside of the pasture grazing season (6.11.1)? (325)
Yes. Outside of the pasture grazing season, young herbivores must have access to exercise yards unless the operator can demonstrate that doing so would jeopardize their health and/or welfare (6.11.1 c) (6.11.1 b). Dairy calves must have access to pasture by 9 months of age (6.12.1.7) (6.12.7).

 

6.12 Addtional requirements for dairy cattle housing

 

Indoor pens for dairy calves

Can dairy calves be raised in indoor pens until such time as they are weaned? (317)
Yes. Note that calves must be given milk until the age of 3 months (6.4.3 c) and that dairy heifers aged 9 months and older must have access to pasture in season (6.12.1.7) (6.12.7).

 

 Electric trainers

Are electric trainers allowed to manage animals in tie stalls? (206) 
Electric trainers are prohibited by the standard in new constructions and renovations and can only be used in existing dairy tie-stall barns, with restrictions when they are part of a management strategy to keep cows clean and prevent disease, in accordance with the requirements of 6.12.1.3. Use will be prohibited 5 years post publication date of 2015 standard - November 25th 2020..

Electric trainers are prohibited as of November 2020.

 

Tie stalls 

Are tie stalls prohibited? (92.1)

Installation of tie stalls is prohibited.6.12.1.1 Existing tie stalls may continue to be used for lactating cows and for one month for heifer training before they join the milking herd, as long as the dairy cows are exercised daily whenever possible, or at least twice a week. 

Tie stalls are being phased out of organic production and will be prohibited by November 2030. Until then, tie stalls are prohibited in new construction and major renovations. Existing tie stalls may continue to be used for lactating cows and for one month for heifer training before they join the milking herd, as long as the dairy cows are exercised preferably daily, or at least twice a week.

 

Is 6.12.1.1 (6.12.1) to be interpreted as a requirement to allow cows housed in tie stalls a period of exercise every day when possible (at least twice a week) or merely a recommendation to do so? (92.2)

Yes, 6.12.1.1 (6.12.1)  is a requirement, not merely a recommendation to exercise animals at least twice a week. 6.12.1.1 (6.12.1) recommends, however, that animals have daily exercise periods. The intent of the standard is to require that cows have regular exercise during the winter months. If an operator fails to provide regular exercise, this would clearly violate the requirement and be considered non-compliance..

 

What if it is not possible to exercise dairy animals daily or at least twice a week? (92.3)

There is a 5-year grace period from the date of publication of the 2015 standard by when operators must have loose housing for heifers and daily exercise for all animals. Within 12 months of publication, there must be a plan for the new construction and either tethered cows are exercised daily or a minimum of twice a week OR no heifers or dry cows are ever tethered.

To remain compliant with the standard, the operator must find a way to exercise animals kept in tie stalls at least twice a week or to provide loose housing. There was a 5-year grace period from November 2015 standard but that finishes in November 2020.

Ratio of cows to stalls

Do the requirements under CAN/CGSB-32.310 section 6.12.2 (ratio of cows to stalls shall not exceed 1:1) apply in a situation where dairy cows have access to the outdoors and an outdoor bedding pack year-round? (452) - 26 Sep 2019
Yes, where a group of animals is housed in a free stall system, the 1:1 animal to stall ratio is required, regardless of outdoor access. This ensures that during periods of weather-induced confinement, each animal can ruminate and rest.

 

6.13 Additional requirements for poultry

 

Length of immunization program

Is it permissible to
a) extend the vaccination schedule of a flock of pullets to 18 weeks even if the program does not need to be extended for any medical reason, simply to avoid the need to let the birds outdoors?
b) eliminate the need for an outdoor run by extending the immunization program to 18 weeks in cases where the program can be shorter than 18 weeks? (412)

The answer is no to both questions. "6.13: Additional requirements for poultry" apply, particularly 6.13.2.

Note that the standard recommends that the pullet rearing facilities closely match the conditions of the layer barn.

 

Space requirements – Poultry

Please clarify the outdoor space requirements for poultry. Can a flock be split so that use of the outdoor area is rotated between groups? If so, does the total area required diminish (i.e, is less space required outside)? (37)
While the standard allows for exceptions to the outdoor access requirements (temporary confinement), the total area available for birds outdoors must allow for the entire flock to be outside at the same time without exceeding the densities set out in 6.13.9 - table 4 - (6.13.13, Table 5) for all poultry.

Does the outdoor space requirement for poultry described in 6.13.9 (6.13.13) refer to the total pasture area available for the year, or to the total area available at any given time? In other words, if an operator is rotating poultry between pastures, is each pasture required to meet the space requirements, or is it calculated from the total pasture that will be available throughout the year? (425) - 19 Apr 2019

6.13.9 (6.13.13, Table 5) refers to the total area available at any given time and does not include the pasture the flock cannot access. Read 6.13.11 (6.13.15) for further insight.

 

Are the poultry densities in Table 4 (Table 5) of 32.310 per flock? Or averaged over a year? (415) - 19 Apr 2019
32.310 6.13.9 Table 4 states maximum densities at any given time. This aspect of the standard is currently under review.

32.310 6.13.13 Table 5 specifies maximum densities at any given time.

 

Floor space in multi-aviary systems

Does a raised floor above the nests in a multi-level aviary count in the overall square footage, as well as for the perch length? (360)

Yes, as described in 6.13.10 (6.13.14), the calculation of total floor footage includes all useful floor levels including perches. See details on perches in 6.13.4 (6.13.5).

 

For multi-level aviary systems for layers (6.13.10) (6.13.4):

If winter gardens are accessible all year round, are they counted as indoor space, or part of the outdoor run/space? (410.1)
Depends where the winter garden is. If inside (e.g., greenhouse) it counts as indoor space. If outside (e.g., protected area on pasture) it counts as outdoor space.

A winter garden or enriched verandah does not count towards the indoor or outdoor space allowance. See 6.13.3 b) 6 and note exceptions in 6.13.3 e) 2.

Does space on ramps or ladders count towards useable floor space? (410.2)
No. Ramps and ladders are not floor space.

Do terraces under which manure collects and is not removed count towards useable floor space? (410.3)
No. As manure collection should take place in all spaces used by animals, areas (such as under terraces) where manure collects and is not cleaned out does not count as useable space.

 

Parallel livestock production

Can organic meat birds be raised on the ground floor with access to the outdoors and non-organic birds raised on the 2nd and 3rd floors of the same barn? (393)
Using the same barn for organic and non-organic poultry production would be very difficult to achieve. For the ground floor of a barn to be considered a "separate production unit," complete separation would need to be ensured and documented. This would include having completely separate watering systems, air flows, pest control, biosecurity, effective equipment systems for dust control, feed and input delivery, storage, and preparation activities. Clear identification and separation of flocks would be required by breed and/or by stage of production.

 

Organic layers confined indoors

Is there a temperature difference between the inside of a poultry barn and the outside environment (for example, a 2-degree C differential) that will allow operators to keep poultry confined indoors? (368)
No. A slight temperature difference in and of itself is not sufficient justification to keep poultry confined indoors, because other factors, such as relative humidity, rainfall, wind velocity, presence of predators, etc., must also be considered (6.1.3, 6.7.2, and 6.13.1).

Is it permitted to raise organic layers confined indoors up to peak production based on 32.310 6.13.1.f) & g)  (6.13.2 a) & b)? (427) - 19 Apr 2019

Yes. This is permitted if the operator can demonstrate that the layers are accessing the outdoors by the time of peak production. However, the rearing facility should closely match the conditions in the layer barn, including having access to an outdoor run (6.13.1 g) (6.13.2 b). It is important to understand it is only permitted to keep the pullets indoors as an exception (i.e., when necessary for the immunization program and to ensure birds are confident in their laying sites).

 

Confinement - Laying period

Can hens be confined for part of each day during the laying period? (226)

Restricting outdoor access of laying hens, during day time hours, may only occur during onset of lay as per 6.13.1 f)  (6.13.2 a) or for reasons outlined in 6.7.2. Further restriction of outdoor access is not permitted.

 

Urgent confinement of organic poultry

Can a regional authority make the decision that organic poultry must be confined (kept indoors) based on an imminent threat to the health of the birds, and would this be sufficient to establish the requirements needed for emergency confinement of all organic poultry in a given region, as per 6.13.1 d) (6.13.1 c)? (440) - 21 June 2019
No. Ultimately each operator must make the decision that an imminent threat to health and welfare exists, and document the reasons and the length of the confinement. A documented 'High Risk' alert from a regional poultry authority may be used as one of the documented reasons for emergency confinement, but the decision to confine must be made by each operation individually.

 

Encouraging birds to go outdoors

How can operators encourage layers to use the range? Would management practices such as running electric wire in front of the openings to the outdoors (to prevent crowding along walls and in corners) or raising openings to the outdoors to above the eye level of hens standing on the floor  (to prevent pests entering the barn) be compliant? (413) - 19 Apr 2019
No. Management practices or structural impediments such as those cited in the question would hinder movement of the birds and thus are prohibited. There are many ways to encourage the birds to use the open range; here are some practices to consider:
- Put in place cover on the range in the form of trees, shrubs or constructed shade to protect the birds from avian predators.
- Provide outdoor access or a covered porch to get the pullets outside and make them comfortable with the range they will have access to as adults.
- Provide separation in barns and runs to create multiple segregated flocks (i.e., 3000 to 5000).

Management practices or structural impediments such as those cited in the question would hinder movement of the birds and thus are prohibited. There are many ways to encourage the birds to use the open-range; here are some practices to consider:
- Provide cover on the range in the form of trees, shrubs or constructed shade to protect the birds from avian predators, as described in 6.13.1 c).
- Provide outdoor access or a covered porch or verandah to get the pullets outside and make them comfortable with the range they will have access to as adults.
- Provide separation in barns and runs to create multiple segregated flocks (i.e., two flocks of 5,000 rather than one flock of 10,000).
- Provide enriched verandahs as described in 6.13.3 for pullets and layers. These create a transitional space between the barn and the outside environment, which can help the birds feel more comfortable going outside.

 

Popholes are mandatory

When organic layers are pasture-raised throughout the grazing season can the flock be housed during the non-grazing season in barns without popholes or other means of accessing the outdoors? (478) - 29 April 2020
No. 6.13.5 states "Poultry barns shall have sufficient exits (popholes) to ensure that all birds have ready access to the outdoors." As per 6.13.1 d), access to outdoors may only be restricted when outdoor access results in an imminent threat to the health and welfare of poultry.

UNDER REVIEW BY THE SIC

 

Laying hens sold for organic meat

In order for spent organic laying hens to be sold at the end of their laying-life for organic meat or organic processing, are they required to meet the requirements in 6.13.1 h) (6.13.6 b) that barn raised meat chickens have daily outdoor access by 25 days of age? (411) - 19 Apr 2019
Pullets with access to outdoors (6.13.1 h) - 2nd sentence)  (6.13.6 a) would easily meet the requirements for organic meat birds. The practice of confining pullets does not meet the intent of the requirements and therefore they cannot be sold as organic meat at the end of their laying lives (6.13.1 h - 1st sentence) (6.13.6 b). Another approach is a comparison of life cycles. As 25 days represents approximately 2/3 of the life of a meat bird raised to an average of 40 days, this means that for approximately 1/3 of its life (15 days), this bird must be able to get outside. Based on that logic, a spent hen slaughtered at 18 months of age (548 days), would have needed to spend 183 days outside to qualify as organic meat, unless weather conditions endanger the health or safety of the birds.

 

6.14 Additional requirements for rabbits

Space requirements for rabbits

Why are the space requirements for rabbits the same for all ages when other livestock in the standard has different space requirements for different ages? (458.2) - 17 February 2020
Due to the short period from kit to slaughter of rabbits, it seems impractical to have an interim stocking rate requirement during this period. When the standard was first written, the only reference standard that had different requirements for different ages was assessed to be a lesser (weaker) standard and so these were not adopted. 

 

 

 

7 Specific production requirements

7.1 Apiculture

Transition

Does the three-year transition period apply to apiaries? (121)

No. The apiary site must comply with 7.1.8.1 which specifies that 12 months of organic hive management is required prior to the harvest of organic honey.

New production sites in apicultural operations

When a certified organic apicultural operator wants to add new production sites, does the application for those new sites need to be received 12 months prior to first harvest of honey on the new sites? (312.1)
No. Organic operators just need to list new production sites (fields, gardens, etc.) on their annual application for certification to be inspected along with the rest of the operation.

Does the CB need to inspect new sites before they are added to an existing organic honey operation? (312.2)
No. The operator must document that the new sites comply with organic standards, and include this documentation in their annual application for certification.

 

Buffer zone

Is a transition period required between the last use of a prohibited substance in the buffer zone and the time when the bees are feeding? (124, 278)
No. There is no set transition period required for the apiary buffer zone. No prohibited substances, other than fertilizers (see 7.1.10), can be present when bees are foraging. As such, consideration must be given to chemically persistent materials previously applied that could still present harm to the bees.  For example, the nectar and pollen of plants grown from seed treated with neonicotinoid pesticides can contain residues of the pesticide.

 

Does any use of a prohibited substance within 3000 metres of an apiary automatically disqualify the honey from achieving compliance with the standard? (115.1)

No - not always. All types of fertilizers are allowed. However, sewage sludge, GE crops and agricultural pesticides that prohibited by the standard, including systemic seed treatments, are not allowed (7.1.5). Other sources of potential contaminants should be assessed as to the level of risk they present. For example, if the risk of contamination is low, products prohibited by the Standard that are used by households within the buffer zone and be tolerated.

 

What potential contaminants are specifically prohibited, and which ones may be assessed according to the risk they pose? (115.2)
Agricultural pesticides, herbicides and systemic seed treatments, sewage sludge, as well as GE crops within the buffer zone always result in non-compliance. Potential contaminants used by neighbouring home owners and other non-agricultural prohibited substances can be assessed as to the risk they pose to the bees and the honey. Low-density rural residences within the  buffer zone may not present a significant  risk if it can be established (e.g., with an affidavit) that there is no use of prohibited pesticides or herbicides on forage plants.

Organic honey production typically cannot take place if the following are found within the buffer zone: high density housing areas such as subdivisions  golf courses, garbage dumps or landfill sites, industrial complexes, very busy roads, or commercial non organic greenhouses/nurseries. There may be extenuating circumstances that must be assessed by certification agencies in each case. If natural features, such as forests, hills or waterways, restrict the likelihood of bee travel and abundant organic forage are present, buffer zones of 3000 m may be reduced.

Version 2020

What potential sources of contaminants within the buffer zone need to be considered? (115.2)
Organic honey production typically cannot take place if the following are found within the buffer zone: high-density housing areas, such as subdivisions; golf courses; garbage dumps or landfill sites; industrial complexes; very busy roads; or commercial non-organic greenhouses/nurseries. There may be extenuating circumstances that must be assessed by certification agencies in each case.
Buffer zones of 3 km may be reduced if natural features restrict bee travel and abundant “compliant forage” is present (7.1.10a). In this context, “compliant forage” means flowering plants that meet the requirements of the standard even if they are not certified organic.

 

Adding a nucleus hive

When adding a nucleus hive to an existing organic apiary, shall it be considered as introduced bees (which are subject to commercial availability) or a replacement colony (which must be produced within operation or another established organic apiary)? (432) - 19 Apr 2019
An added nucleus hive (including both a queen and other bees) would be considered a replacement colony and therefore would be required to be produced within the operation or obtained from another established organic apiary (7.1.9).

 

Wax for foundation and comb foundation

Can plastic foundation that has been dipped in non-organic beeswax be used when organic beeswax dipped plastic foundations are not commercially available? (506.1) - 18 dec 2020
No. The wax covering the plastic foundation must be organic (7.1.13.3).

Can non-organic wax comb foundation be used when organic sources are not commercially available? (506.2) - 18 dec 2020
No. Non-organic comb foundation may not be used. Organic comb foundation from the operation or from another source is required. (7.1.15.3)

 

Treated hives

Reading clause 7.1.15.7, does the term "treated hive" apply to the containers present at the time of the treatment only or does it also apply to any clean or untreated temporary containers, such as honey supers in summer time, and unused frames? (391)
The term "treated hive" applies to the container(s) present at the time of the treatment, and not to supers or frames removed from a hive prior to treatment. However, the wax from any honey super frame or brood frame of the treated hive present or added during the 12-month transition period would need to be replaced with organic wax at the end of the transition period in order to return to organic production.
The bees in the colonies, that is the hives plus bees that were treated must also complete a transition period (7.1.8.1 in 32.310)

 

Non-organic sugar for feeding colony

7.1.11.1 b) (7.1.11.1 a) permits the use of non-organic sugar for colony feeding under certain conditions. Does this exception allow the use of sugar derived from genetically engineered beets? (363)
No. The allowance in 7.1.11.1 b) (7.1.11.1. a) is for non-organic, non-GE sugar to be used as the GE prohibition in 1.4 supersedes.

 

Organic beeswax

Can beeswax be certified as organic? (442)
Yes. Beeswax generated by organic apiculture operations can be certified organic (7.1.1) with two exceptions: 1) when comb foundation was not sourced from organic hives (7.1.15.3); and, 2) when hives have been treated with synthetic allopathic drugs (7.1.15.7).

 

7.2 Maple products

Buffer zone

How close to a certified sugar bush can the use of a prohibited substance be allowed, without compromising the certification of the sugar bush? Are buffer zone needed? (13)
A sugar bush has the same buffer requirement as other crops. A minimum of 8 metres is generally required. However, this can be reduced if there are features that effectively buffer the sugar bush, such as permanent hedge rows, windbreaks, or roads (5.2.2). Also, depending on the circumstances, more than 8 metres may be necessary to prevent contamination.

Magnetization of maple water

In maple production, is it permissible to use an anode that magnetizes maple water in order to keep the minerals in suspension and prevent calcareous deposits in the pan? (304)
No. It is prohibited to use technologies that may alter the intrinsic qualities of the product (7.2.7) and magnetisation has that potential.

Use of filtrate for cleaning

Can the filtrate be used to clean evaporators during the season? (215)
Yes, the filtrate (water that passes through the membrane in the osmosis technique of removing water from sap) may be used to clean the evaporator (7.2.13.2 a 3))

 

Well water through reverse osmosis

Does well water meet the criteria for potable water if it has been run through a reverse osmosis filtering system? (430) 19 Apr 2019
Yes. Water purified by reverse osmosis is considered potable.

 

Rinsing and cleaning of osmosis membrane

Is it necessary to verify the quality of water used for cleaning/rinsing the osmosis membrane in maple equipment? (230)
Yes. If water is used during the production season, for cleaning/rinsing the osmosis membrane, potability needs to be confirmed (i.e.,, it must meet drinking water standards). (7.2.13.2 a 3)

 

Heating option for maple syrup evaporator pans

Can natural gas be used to heat maple syrup evaporator pans? (346)
Yes, heating options, such as wood, heating oil, electricity, propane and natural gas, etc., that do not negatively affect the integrity of the syrup are permitted.

 

Waxed cardboard as fuel

Can waxed cardboard pellets be used as fuel in maple syrup evaporators? (373)
Yes. As long as the operator can demonstrate that this type of fuel does not affect the integrity of the maple syrup.

 

7.3 Mushroom production

Disease control

In the production of organic mushrooms, can table salt be used as a spot control measure for disease on mushrooms? (132)
Yes. Refer to the “salt” listing in PSL Table 4.3 (Table 4.2, column 2).

Substrate

Does the substrate for organic mushrooms need to be a) certified organic, b) composted? Can conventional straw be used as compost feedstock for a composted substrate used to grow organic mushrooms? (4, 178) 

Standard 7.3.2.1 through 7.3.2.3 outlines the requirements.

 MATERIAL TYPE  ORGANIC COMPOSTED
 Wood  No, but must be free of prohibited  materials.  No
 Manure  5.5.1 (32.310) outlines acceptable sources. Organic must be used if available.

 Yes, and:
 1) the compost feedstock requirements  in PSL Table 4.2 apply; and,
 2) Either the ‘compost produced on the farm’ or the ‘compost from off-farm  sources’ criteria in PSL Table 4.2 apply.

 Other agricultural  substances (hay,  straw or grains etc)  Yes if available.

 1) If organic is not available then the  materials must be composted.
 2) If composting the:
 a) the compost feedstock requirements  in PSL Table 4.2 apply; and,
 b) either the ‘compost produced on  farm’ or the ‘compost from off-farm  sources’ criteria in PSL Table 4.2

 

Non-agricultural substances as mushroom substrate

Can non-agricultural substances including peat moss be used as a mushroom substrate/growth medium or as a casing layer on top of a mushroom bed without being composted first? (385)
Peat moss is a substance in Table 4.2 of 32.311 which has no specific use or restriction of usage. Therefore, it can be considered as an applicable entry for mushroom production under 7.3.1 of 32.310. Other non-agricultural substances of Table 4.2 can be considered as well unless their annotations restrict the substance to a specific usage which does not include mushroom production. Composting is only mandatory for substances of conventional agricultural origin in mushroom production (7.3.2.3).

 

Spawn marketed with growing substrate

When marketing mushroom starter materials containing living spawn (e.g., mycelium loose in grain/or sawdust or embedded in a grow block/log/loaf/brick) as organic, are the components other than the mycelium exempt from the calculation of total percent organic ingredients in the final product? (471) - 17 February 2020
Mushroom starter materials in any format do not fall under Clause 9, therefore a calculation of the percentage of organic ingredients is not applicable. Spawn must comply with 7.3.3 and the makeup of the starter material must comply with 7.3.2.

 

Feather meal as mushroom substrate

Can feather meal, compliant with table 4.2, be used as a mushroom substrate without being composted? (344)
Feather meal made from organic poultry could be used as a mushroom substrate without being composted. 32.310 7.3.2.3 requires that other sources of feather meal be composted.

 

Non-organic Potato Dextrose Agar to propagate mycelium

Can non-organic Potato Dextrose Agar (PDA) be used to propagate mycelium (non-fruiting genetic material) to produce organic mushroom spawn? If so, can it include compounds and micronutrients that are not listed? (451) - 26 Sep 2019
Yes. Non-organic PDA is permitted if it can be demonstrated that organic is not commercially available and the non-organic PDA does not contain GE ingredients (see Table 4.2, Agar) or compounds not listed in Table 4.3 (Table 4.2, column 2) of 32.311 (see 32.310 7.3.3).

 

7.4 Sprout, shoots and micro-greens production

Parallel production

Can organic and conventional sprouts be produced in parallel in the same facility if grown in visually distinguishable containers? (211)
No. Growing organic and non-organic sprouts of the same plant variety at the same time is parallel production and is prohibited. Where different varieties of the same species are produced simultaneously, the organic and non-organic crop themselves must be visually distinguishable.

Sprouts or shoots

Please describe the difference between shoots and sprouts. (191) 
Unlike sprouts, which are usually grown in water, shoots tend to be grown in a growth medium, such as a potting mix. Shoots tend to be cut, while sprouts are harvested and consumed with the roots attached. Production for both must comply with all criteria in 7.4 (Sprouts, shoots and microgreens production).

 

Plants sold in pots

Plants harvested within 30 days of planting fall under clause 7.4 and require the use of organic seeds. What if they are sold in pots to a customer who keeps them beyond the 30 days? Would they still need to be grown from organic seeds? (293)

If the plants are not "generally harvested within 30 days of imbibition" they do not fall under 7.4 (shoots and microgreens) and the organic requirements in 5.3 a) apply.

Seed cleaning

Can synthetic acetic acid be used for the cleaning of seeds used for sprouts, as seeds are neither considered as food nor as a plant (PSL Table 7.3)? (210)
No. Only substances listed for seed cleaning in Table 4.3 (Table 4.2, column 2), such as peracetic acid, may be used (see 7.4.1.5 (7.4.7)).

 

Substances for sanitizing seeds for sprouting and sanitizing sprouts, shoots, microgreens

Which substances are compliant for sanitizing seeds for i) sprouting, ii) shoot and microgreen production, and iii) for sanitizing harvested sprouts, shoots or microgreens? (303)
Substances used for these activities are limited to the following substances of Table 4.3 (Table 4.2, column 2): hydrogen peroxide and peracetic acid (peracetic acid listing) and hot water (water listing) (32.310 - 7.4.1.5 (7.4.7)). Chlorination of water shall not exceed maximum levels for safe drinking water. (Table 7.3).

 

Sprout rinsing

Does the requirement for water quality in 7.4.1.2 and 7.4.1.3 apply to all uses associated with sprout production?  Could water for rinsing be exempt from this description? (84)
The provisions apply to all stages of production of sprouts. Water for rinsing is not exempt.

Version 2020

What are the quality requirements for water used to rinse sprouts, shoots and microgreens?

Excluding chlorine concentration restrictions (see Q&A 150) water quality criteria for sprouts, shoots and microgreens rinse water is no longer specified in the 2020 organic standard. The expectation is that sprouts, shoots and microgreens operations will have a water quality program in place to address overall food safety requirements.

 

Is the rinsing of sprouts with chlorinated water allowed? If so, in what concentration? (150)
Chlorinated water may be used to rinse sprouts (7.4.1.2) provided the level of chlorine does not exceed the limit for safe drinking water (see 7.4.3 referring to 8.2, and 8.2.1 connecting to the ‘chlorine compounds’ listing in PSL Table 7.3).

Version 2020

Is the rinsing of sprouts, shoots and microgreens with chlorinated water allowed? If so, in what concentration? (150)
Chlorinated water may be used to rinse sprouts, shoots and microgreens provided the level of chlorine does not exceed the limit for safe drinking water (see 7.4.9 referring to 8.2, and 8.2.1 connecting to the ‘Chlorine compounds’ listing in PSL Table 7.3).

 

Soil volume in microgreen production

Is the soil container volume criteria outlined in 7.5.5 (32.310) applicable to containerized microgreen production (7.4)? (400)
No. 7.5.5 is applicable to containerized, staked crops grown in greenhouses. The same logic would apply to containerized staked crops grown outdoors. But this definitely does not include microgreens. Nonetheless, if a substrate is used for microgreens production, it has to be soil and comply with 7.5.2, 7.5.3 and 7.5.4.

Version 2020

Is the soil container volume criteria outlined in 7.5.2 (32.310) applicable to containerized microgreen production (7.4)? (400)
No. 7.5.2  is not applicable to crops harvested within 30 days of imbibition such as microgreen production.

 

Inert substances and materials as growing media

Can inert substances and materials be used in production of sprouts, microgreens and shoots under 7.4.1 (produced in water)? For shoots and microgreens under 7.4.2 (produced in soil)? What about growing on burlap cloth? On coconut coir/fibre? Can the 'soil' (7.4.2) be sterilized? (299)
For water-based sprout, shoot, and microgreen production systems (7.4.1): inert containers made of stainless steel and food-grade plastic are permitted. No growing medium, such as burlap, coconut coir, coconut fibre (inert or not) are permitted in water-based sprout, shoot, and microgreen production systems. For soil-based shoot and microgreen production systems (7.4.2): the growing medium must meet the definition of soil as defined in 3.62 (32.310): A ‘mixture of minerals, organic matter and living organisms.’ This means the soil cannot be sterilized (which would kill the living organisms). Burlap, coconut coir or coconut fibre could be used as part of the 'soil' or could function as the 'container' in a soil-based shoot or microgreen production system. The operator must confirm that these materials are free from and/or have not been treated with prohibited substances.

Version 2020

Can inert substances and materials be used in production of sprouts, microgreen and shoots produced in water? For shoots and microgreens produced in soil? What about growing on burlap cloth? On coconut coir/fibre? Can the 'soil' be sterilized? (299) (358) 
For both water-based and soil-based systems, inert containers made of stainless steel and food-grade plastic are permitted (7.4.3). Growing media use is restricted to soil-based systems (7.4.6) and
must contain “both a mineral and organic fraction” (7.4.6). Thus sterilizing the ‘soil’ would be counter indicated considering the likely presence of beneficial organisms in the organic fraction required in the growing medium. Burlap, coconut coir or coconut fibre could be used as part of the 'soil' or could function as the 'container' in a soil-based shoot or microgreen production system. The operator must confirm that these materials are free from and/or have not been treated with prohibited substances.

 

Organic bean sprout production

Can bean sprout grown hydroponically be certified organic? (245)
Hydroponics is defined as the "cultivation of plants in aqueous nutrient solutions without the aid of soil" (3.29) (3.34). As nutrient solutions cannot be used in organic sprout production (7.4.1.4) (7.4.5), it is not considered hydroponics. 7.4 addresses the production of sprouts.

 

 

 

7.5 Greenhouse crops 

Version 2020 - 7.5 Crops Grown in Structures or Containers

Soil/soil-less mix

Can a greenhouse operator take soil from outside and move it into the greenhouse? (267)
Yes, providing the soil has not been exposed to substances prohibited by the Standard for 36-months (See ‘soil’ listing Table 4.2 – column 1)..

Does the use of a “peat moss/compost etc. mix” satisfy the requirements of 7.5.4 (7.5.2.1) ( for “soil used in a container system”? (25)

No. 7.5.4 (7.5.2.1) allows for container-grown production with soil. A compost and peat moss mixture is missing the mineral fraction that is required  for a “soil used in a container system.” See 3.62 (3.73), definition of soil. Soil as defined in the standard is not required for plant propagation or for transplant production.

Does the use of a culture medium (which is soil-less, but otherwise comprised of organic matter) during the initial phase of propagation (2 – 3 weeks) preclude this type of production from organic certification as per the requirements of 7.5.4 (7.5.2.1) ? (204)
The use of a culture medium, which does not meet the definition of soil but complies with the standard, is allowed in the case of plant propagation.

 

Use of a prohibited fungicide in greenhouses

If a grower covered the soil in a greenhouse container system and then sprayed a prohibited substance, can the soil be used in containers in subsequent cropping cycles if tests show that it does not contain any residues of the prohibited substance? (477.1) - 29 June 2020
No. Residue testing cannot be used as a substitute for required organic management practices; organic operators must not apply prohibited substances as per 1.4 (1.5).

Could this container soil be used for organic production after 12 months? (477.2)
No. Even though the soil was covered, and testing was done 7 months later showing no residue - 36-months of transition is needed from the fungicide application for a compliant soil (see 'Soil' Table 4.2 of PSL). The 12-month period is only applicable to new operations per 5.1.1. Furthermore, keep in mind it is up to the CB if there was deliberate abuse alternating between organic and non-organic methods in this production unit which may lead to decertification. (See SIC Q&A #6)

 

Composition of growing media

Does a growing medium containing a pinch of sand, 10% compost and the balance peat moss meet the requirement of 7.5.4 (7.5.2.1)? (454.2) - 2 December 2019
No. The intent of this clause was to establish the profile of the required soil structure to ensure sufficient air and water drainage and nutrient holding capacity. 


May coconut coir be part of a growing medium used in container growing systems? (454.3) - 2 December 2019
Yes. Coir may be used. It is covered by the "Plants and plant by-products" listing in Table 4.2


Could a soil media blend of coir, peat moss, perlite and compost be used to grow perennials? (454.4) - 2 December 2019
No. Soil used in containers to grow perennials should also contain a mineral fraction that is not covered by perlite. It should contain sufficient sand, silt or clay to contribute to the physical soil structure.

 

Disposal of greenhouse soil

Under 32.310, clause 7.5.12 (7.5.9), can operators dispose of greenhouse soils in cases where there is a risk of disease or pest propagation? (465) - 17 February 2020

Disposal of greenhouse soil to minimize the spread of a transmissible pest or disease is permitted only when a regulatory directive has been issued requiring such a practice "treatment" (32.310, 4.4.6). In the absence of such a directive, greenhouse soils must be reused as per 7.5.12 (7.5.9).

 

Soil and compost requirement in greenhouse production

Is biochar in a soil mix considered part of the mineral fraction? (424.1) - 19 Apr 2019
No. Biochar is considered organic matter.

Are worm castings and vermicompost considered compost, and could they be used for the 10% requirement in 7.5.5.a (7.5.2.1 d)? (424.2) - 19 Apr 2019
Yes. As they are both "products of carefully managed aerobic processes" (see 'compost' definition 3.15 (3.19)). Please also refer to 32.311 Table 4.2 Worm Castings.

Can the additional compost applications required in 7.5.5 b (7.5.2.4 a) be in the form of compost tea? (424.3) - 19 Apr 2019

No. Compost tea does not contribute to organic content of the soil. Its use is twofold. A source of soluble nutrients and beneficial microorganisms.

 

Mineral fraction of soil in contenants

For container production systems in greenhouses is the mineral fraction requirement (7.5.4) (7.5.2.1 c) met if the "soil" contains either perlite or vermiculite? (408)
No. That was not the intention of the standard. Even though both are heated forms of mineral compounds (perlite/volcanic glass, vermiculite/expanded mica) the requirement is some sand, silt or clay would be included in soil mixes.

 

Forestry by-products as greenhouse compost

Can bark or forestry by-products alone fulfill the 10% compost criteria for greenhouse container growing? (461.2) - 17 February 2020
No. Compost is a product of a carefully managed aerobic process (32.310 3.15 (3.19)).

 

Scope of 7.5.5 (7.5.2.4)

Does 7.5.5 apply to determinate (non-staked) varieties, or only to indeterminate (staked) varieties grown in containers? (342.1)
7.5.5 (7.5.2.4) covers containerized semi-indeterminate and indeterminate varieties grown in greenhouses typically for an extended period (e.g., 7 months or more) and that are supported by a trellis system (e.g., stakes, strings or wires). 7.5.5 (7.5.2.4) is not applicable to non-staked determinate varieties or crops with shorter production cycles (e.g., where harvest is finished within a period of less than 7 months), but the volume of soil needed is commensurate with the length of the crop cycle. See 7.5.2.3.

 

Artificial lighting as a supplement to natural light

Are systems reliant only on artificial lighting allowed under COS? (342.2)
Microgreens and shoot production may use systems reliant only on artificial lighting. For greenhouse crops, however, artificial lighting is permitted only as a supplement to natural light (see 7.5.6 (7.5.4)). Note: The organic greenhouse standards were not developed with growth chamber-like systems in mind. 

 

Parallel production

Does the exemption from the rule prohibiting parallel production allow greenhouses to transition only part of their operation? (109)

Yes, the propagation portion of the operation may practice parallel production per 5.1.4.

Is parallel production prohibited for greenhouse crops? (285)

The Standard prohibits parallel production in annual crops including those grown in greenhouses with exceptions outlined in 5.1.4. However, if visually distinguishable organic and non-organic crops are grown, this is considered to be split production (5.1.3), which is permitted if: greenhouse systems (air, water, etc.) are sufficiently segregated so as to eliminate contamination risk of the organic crop by prohibited substances (1.4) (1.5).

 

7.6 Wild Crops

Wild seaweed

Can wild seaweed meal be certified? (244)
Yes, until January 14, 2021, seaweed meal can be certified under Section 7.6 Wild crops if it is used for food or livestock feed. After this date, seaweed products will need to be certified under the Organic Aquaculture Standard CAN/CGSB-32.312.

 

Buffer zone around wild crops

Can wild harvest sites be located less than one kilometre from potential sources of environmental contamination such as golf courses, etc., if it is demonstrated that the wild crops are completely isolated from contact with prohibited substances by a clearly defined buffer, in accordance with section 7.6.4? (343.1)
No. There is no latitude in 7.6.4 to reduce wild crop buffer zones, where required, to less than 1 km.


In the event that wild harvest cannot be certified (if 1 km requirement cannot be attained), is parallel production prohibited between crop production (plantation) and wild harvest? If so under what circumstances might it be allowed? (343.2)
If the wild harvest cannot be certified, parallel production from an existing organic plantation would be permitted; however, a new organic plantation could not be established. (3.52, 5.1.4 and 5.1.5)

 

Weed control for wild crops
 

Can salt be used for weed control on ground here organic wild harvested crops are stored? (367)  

No. First, the wild harvest area is to be "relatively undisturbed" (7.6.3) so using salt as a 'herbicide' in the area, even on a rock outcrop is prohibited as it is would change the ecosystem. Second, salt is not authorized as an herbicide in Table 4.3.

Version 2020

Can salt be used for weed control on the ground where organic wild harvested crops are stored? Even if that storage area is on a rock outcrop? (367) 
No. First, the wild harvest area is to be "relatively undisturbed" (7.6.3) so using salt as an 'herbicide' in the area, even on a rock outcrop, is prohibited as it would change the ecosystem. Secondly, salt is not authorized as an herbicide in Table 4.

 

.Honey harvested from wild bees

Can honey harvested from wild bees be certified to the "Wild Crop" requirements in Clause 7.6? (382)
No. Wild animal products are not covered by the Canadian Organic Standards.

 

8  Maintaining organic integrity during cleaning, preparation and transportation

Staff training

Are CB's required to verify that staff working in facilities where both organic and conventional foods are processed have the necessary training to result in compliance with the standard? (130)
CB's are required to verify compliance with the standard. If in the course of inspecting a facility, it becomes apparent that the staff responsible for maintaining organic integrity lack the necessary training needed to differentiate between organic and conventional processes, this could be the basis of a report of non-compliance. See 32.310, 4.4 and 8.

Irradiation (X-rays, ultraviolet radiation, microwave)

Is ultraviolet radiation of milk, cheese and fruit juice acceptable under the COS? What about tree sap or packaging? (152, 338, 419)
Near and medium ultraviolet (UV) rays are classified as non-ionizing radiation and can be used to treat milk, cheese and juices. But neither near nor medium ultraviolet rays can be used to boil (7.2.14) or sterilize (7.2.12.2) tree sap, such as maple or birch. Far ultraviolet radiation cannot be used on organic products. All forms of ultraviolet radiation can be used to sterilize packaging before it is filled with a product.

 

Water - Filtration 

Can water that has been processed through an alkaline filtration system be used in the preparation or processing of an organic food product? (185)
The resulting water is acceptable if it falls within Health Canada's Guidelines for Drinking Water; has a pH 6.5 to 8.5; and no prohibited substances have been added to the water or prohibited processes have been used.

 

8.2 Cleaning, disinfecting and sanitizing

Water - Product preparation and vegetable rinsing

What are the requirements for the quality of water used to wash organic vegetables or prepare organic products? (128, 5)
Water must meet the requirements for potability as per local, provincial or federal authorities. When water is in contact with an organic product, the chlorine concentration must not exceed the levels permitted in municipal drinking water systems and rinsing is not required (Table 7.3).

 

Cleaners – Milking equipment

What is the distinction between acceptable cleaning agents for milking equipment on farms vs. those used in processing facilities? (209)
8.2 gives direction for cleaning food contact surfaces which would be appropriate both on dairy farms and in off-farm dairy processing facilities.

Cleaning – Milk trucks

Is it necessary to wash milk trucks at a processing facility under the supervision of a certifying body in order to maintain certification of the milk? (108)
No. There is no requirement to wash bulk milk trucks specifically at a processing facility placed under the supervision of a certifying body. In order to comply with the standard, documentation that substances used in the cleaning process have been removed, must be maintained to demonstrate compliance to 8.2.

 

8.3  Facility pest management and post‐harvest management

Pest control – Bait station location

When a pesticide not listed in the PSL is used in a baited station clamped to the inside wall of a facility preparing or storing organic products, is having it in the bait station sufficient to satisfy 8.3.3 requirement? (38)
No. Only pesticides listed in PSL Table 8.3 may be used in the interior of a facility when organic products or packaging materials are present. This applies even if the pesticide is contained within a bait station and there is no potential contact between the pesticide and the organic products or packaging.

Pest management - indoor/outdoor

Does 8.3.3 apply to pest control substances used inside facilities or to those used on the exterior? (212)
8.3.3 applies to both indoor and exterior pest control for all operations that grow, handle, store and transport organic products. It is essential that pest control around farm buildings and storage areas does not compromise organic product integrity or the surrounding farm environment. 8.3.3 does not apply to exterior pest control at facilities when it is unlikely that organic product integrity will be compromised and unlikely that the surrounding environment will be contaminated (e.g.,, manufacturing facilities in industrial parks).The indoor/outdoor requirement is stated in 8.3.3 of 310 and reiterated in 8.1.1 a) of the PSL.

 

Pest control in food processing facilities

Clause 8.3.2 states that Table 8.2 substances can be used in food processing facilities to control pests. Can substances listed in Table 4.3 (Table 4.2, column 2) (e.g.,, pheromones, sodium tetraborate) also be used? (392)

No. Only substances in the Table 8.2 can be used to control pests in food processing facilities. Substances in Table 4.3 (Table 4.2, column 2) are strictly for crop production. Please refer to CAN/CGSB-32.310 clause 8.3.3 for alternative pest control options for food processing facilities.

 

 

9 Organic product composition

Calculation of organic content – Aloe vera powder
 

Can aloe vera juice or gel made from organic aloe vera powder and water be certified as organic for human consumption? How is the organic content calculated? (301.1)
Yes. A reconstituted  aloe vera juice or gel product can be certified as organic. If the principal display panel (PDP) states that the aloe vera is “reconstituted from concentrate”, the organic content of the juice or gel should be calculated using the amount of single-strength aloe vera made from the concentrate. If the PDP does not mention the reconstitution of aloe vera, the organic content of the juice or gel should be calculated by subtracting the total volume of water from the final product. (9.1.3.b)

When organic aloe vera juice (reconstituted from 200X aloe vera powder and water) is used as an ingredient in a further food product, how is the organic content calculated for the secondary product? (301.2)
Water used to reconstitute the powder should be excluded from the organic content calculation. For example, if 200 L of aloe vera juice (reconstituted from powder at 200X strength) is used as an ingredient in a further juice product, only 10 grams of the original aloe vera powder would be included in the calculation of the secondary product. (9.1.3 c).

 

Gas as ingredient

Are gases (such as carbon dioxide for the carbonation of beverages) added as ingredients (under PSL table 6.3 or 6.4) required to be calculated as non-organic ingredients? (473) - 17 February 2020
No. Gases are not included. Only solids and liquids must be accounted for when calculating organic content (9.1.3 in 32.310).

 

Constituents of ingredients - Calculation

In 9.1.2 of the standard, what does the term "constituent of an ingredient" mean? Are incidental components or carriers considered constituents? (131)
Constituents refer to all the components contained in an ingredient. Every constituent or subpart of every ingredient including carriers or preservatives needs to be included in the calculation of constituents’ percentages and reviewed with regard to compliance with the PSL.

Ingredients – Organic and non-organic

Does the prohibition against using both the organic and non-organic form of an ingredient (9.2.1) apply to different varieties of grapes used in a wine or different flours (e.g.,, barley and wheat) used to bake a single bread? (173)

It depends. Under 9.2.1, ingredients that are recognized as having distinct qualities could be considered as separate ingredients, even when they fall into the same general category of ingredients such as "flour" or "grapes". In the examples given, it would be possible to use one ingredient in its organic form and the other in its non-organic form without violating 9.2.1 provided the following restrictions are met.

For organic products with organic content equal to or >95%, the non-organic content must be less than 5% of the total and commercial unavailability must be confirmed annually for any non-organic agricultural ingredients. For products containing 70-95% organic content, commercial availability does not apply.

In both categories, the organic and the non-organic ingredients must be listed on the label to be compliant with labelling requirements in the SFCR and the guidelines from CFIA.

 

Meal replacement

Is a "meal replacement" certifiable under the COR, given that it contains supplemental minerals and vitamins? (266)
Yes. Meal replacement products may be certified organic if produced in accordance with this Standard and if they meet the nutritional profile set out by Canadian regulation for "meal replacement" products.

 

Fortification of organic food

Can juice formulated with vitamin C, vitamin D, or calcium be certified as organic? (328)
It depends.

The answer is yes, if the calcium compounds and vitamin C (ascorbic acid) are used as acidity regulators, stabilizers, or preservatives as outlined in the individual listings in Table 6.3.

The answer is no, if vitamin C, vitamin D, or calcium is added for nutritional fortification. Juice is categorized as a voluntary fortification option by the Canadian Food & Drug Regulations and the PSL (Table 6.4) states that 'Vitamins and mineral nutrients' "shall be used if legally required". "Legally required" means that fortification is mandatory by government and that is not the case for juices.

Refer to CFIA’s Foods to Which Vitamins, Mineral Nutrients and Amino Acids May or Must be Added [D.03.002, FDR] and to the "Vitamins and Mineral Nutrients" listing in Table 6.4 for details.

 

Processing Aids

Does the standard require that processing aids in the production of non-organic ingredients be listed on Table 6. 5 PSL? (20.1)

No. The processing aids used by manufacturers of  non-organic ingredients are not subject to the scrutiny of Certification Bodies.

 

 

Permitted substances lists - CAN/CGSB-32.311

 

General information

Brand name approval

What is the pathway for approving cleaners, or substances used? (3)
Operators should approach their Certification Body to verify that all inputs and substances including cleaners, comply with the standard before using them.

Formulants

For soil amendments and crop production aids, is it enough that the active ingredients are compliant, or does the certifier need to review the list of inert ingredients and formulating agents? (168)
All substances contained in soil amendments and crops production aids must be disclosed by the supplier for review by the CB. Table 4.3, under the heading "Formulants" provides some guidance in evaluating non-active ingredients (inerts) in crop production aids.

Version 2020

All substances contained in soil amendments and crop production aids must be disclosed by the supplier for review by the CB. Table 4.2 , under the headings "Formulants used in soil amendments" and "Formulants used in crop production aids" provides some guidance in evaluating non-active ingredients (inerts) in crop production aids.

 

Table Cross-Referencing

Does the inclusion of Calcium Phosphate (monobasic, dibasic and tribasic forms) on table 6.3 for use in processing imply that these substances can also be used as soil amendment or Crop Production Aids? (140, 155)
No. An annotation in one table cannot be applied to a listing in another table.  The inclusion of substances on Table 6.3 for preparation does not make them compliant for other uses (Scope 1.1 of 32.311). However, Table 4.2, column 1, does list mined minerals, making the natural form of calcium phosphate (apatite) acceptable as a soil amendment.

Does the process described in Table 4.2, column 1, of the PSL (annotation for amino acids) apply to other microbial products, for example yeast, for use as a soil amendment? (57.2)
No. An annotation for one listing cannot be applied to another listing.

 

About ‘Origin and usage’

If there is nothing showing in the "origin and usage" column of the PSL, does this mean that any form of the substance may be used? In previous versions of the PSL there were restrictions on ascorbic acid regarding its non-synthetic or synthetic nature and this is what gave rise to our question. (423)
Yes. If nothing is written in the "Origin and usage" column, then there are no restrictions as to the origin and/or usage for that substance in accordance with the scope of the PSL table in which it is listed. In the case of ascorbic acid, the annotation was removed after new information indicated that all commercially available ascorbic acid is synthetic, which made the annotation allowing both forms redundant.

Annotations to permitted substances

Clauses 4.1.3 a) & 5.1.2. a) of PSL state that if a listed substance includes substrates or growth media, the substrates or growth media ingredients shall be listed in Tables 4.2 & 4.3 (Table 4.2)  and Livestock Tables 5.2 & 5.3. In this situation do the origin and usage annotations for these substrates or growth media ingredients listed in 4.2, 4.3, 5.2 and 5.3 apply? (389)
Yes. Substance annotations must always be addressed. One exception is pesticide formulants listed on PMRA Lists 4A, 4B and 3. The MAR 2018 amended standard clarifies that pesticide formulants on these three PMRA lists are not subject to 1.4 of CAN/CGSB-32.310. This means 4.1.3 a) is not applicable to pesticides made from microbial products containing some substrate or growth medium as long those compounds used as a substrate or growth medium are listed either on PMRA List 4A, 4B,or 3. However, there is no exemption from the requirements of 4.1.3 a) for microbial products used as fertilizers. In the case of an amino acid preparation fed to livestock produced on a molasses substrate and which contains molasses, the molasses must be organic (see 'Molasses' Table 5.2).

 

 

Permitted substances lists for crop production

4.2 Soil amendments and crop nutrition

Version 2020 - 4.2, Column 1  Soil amendments

 

Amino acids produced by hydrolysis processes

Are amino acids produced by hydrolysis processes using sulphuric and phosphoric acid permitted? (422) - 19 Apr 2019
No. When used in crop production, amino acids cannot be produced by hydrolysis using chemicals such as sulphuric and phosphoric acid. See 32.311 4.2 and 4.3 Amino acids b). See 32.311, Table 4.2 - columns 1 & 2, Amino acids.

 

Testing of ash

Do all sources of ash have to be tested for heavy metals? (448.1) - 21 June 2019
No. Ash from plant and animal sources is permitted without testing if the source is known and not containing  heavy metals. Testing is required when the ash source is unknown or it is known there is a possibility of the ash containing prohibited substances. Testing is to ensure the heavy metal levels are within the limits established in the Guideline for the Beneficial Use of Fertilising Residuals.

 

Activated biochar

Is activated biochar permitted? (377.1)
Yes, if the activation is done with permitted substances. Additional requirements, such as the genetic engineering prohibition (1.4 a in 32.310) and annotation restrictions in the substance listing, would need to be addressed.


Can biochar be used as soil substitute in organic containerized greenhouse production systems? (377.2)
No. Biochar cannot be used as a soil substitute as it does not meet the requirements of a soil/growth medium (see 32.310, 7.5.4 (7.5.2.1) ). It may be used as a soil amendment as listed in Table 4.2 of PSL.

 

Blood meal

In Table 4.2, blood meal is allowed only if sterilized. What does it mean for blood meal to be sterilized? (262)
The Fertilizers Act and Regulations require that fertilizers and supplements not contain any substances likely to be generally detrimental or seriously injurious to domestic animals or public health. Blood meal is defined as "collected blood of slaughtered animals, dried and ground, containing not less than 12% nitrogen". Blood meal is considered to be "sterilized" if it does not 'present a risk of harm to human, animal or plant health or the environment'. Commercial manufacturing of blood meal requires a heating/drying phase to meet the definition of sterilization and the requirements of the Fertilizers Act and Regulations.

 

Calcium chloride

Is calcium chloride made from the purification of naturally occurring brine allowed under the listing of “Calcium” in Table 4.2? (384)
Yes and No. Yes. Calcium chloride that is purified from naturally occurring brine via evaporation is allowed. Such calcium chloride may be used to address nutrient deficiencies and physiological disorders. No. Other purification processes of naturally occurring brine that involve additional processing steps (e.g.,, bromine removal, sulphur oxide addition, use of strong acid precipitation agents or lime, etc.) render the calcium chloride synthetic according to the COS (see "Mined Minerals, unprocessed" in Table 4.2).

Version 2020

Yes. Calcium chloride that is purified from naturally occurring brine via evaporation is allowed. Such calcium chloride may be used to address nutrient deficiencies and physiological disorders.

 

Evaluation of extractants

For substances used in crop production, does the scope of evaluation for extractants require assessment of all materials used or only those that remain in the final product? (443) - 2 December 2019
For substances used in crop production, only extractants that remain in the final product are subject to evaluation, unless extractants are specifically addressed in the substance annotation.

 

Guano - Dried deposits of guano

What is meant by “Shall be decomposed, dried deposits” in the Guano 4.2 PSL listing? Does it mean fresh dry deposits from wild bats or birds cannot be used? Or does it mean that the guano must have been decomposed in situ, not dried elsewhere? (434) - 21 June 2019
Wild bat and seabird guano must decompose at the site of deposits, not be dried elsewhere, and have been in place for a sufficient time to decompose and dry before collection. Collection shall not impact an active colony.

 

Multi-ingredient fertilizer- non-organic oilseed meal
 

When used in a multi-ingredient fertilizer, is the use of non-organic oilseed meal subject to the commercial availability restriction? (387)
Yes. Even when used as a component of a multi-ingredient fertilizer a commercial availability search is required as per the annotation for "Oilseed meals" (Table 4.2). Therefore, an operator wishing to use this fertilizer blend would need to perform a commercial availability search for a fertilizer blend that is fully compliant before using this product.

 

Definition of wastes from crops

Under "Plants and plant by-products" in PSL 4.2, does the restriction “Wastes from crops that have been treated or produced with prohibited substances may be used as composting feedstocks” apply only to wastes from crops or does it apply to all plant materials? What is the definition of “wastes from crops”? (388)
"Wastes from crops" is referring to vegetal matter (plant and plant waste) from any source.

 

Compost feedstocks

With regard to materials other than livestock manure, are all the materials used to make compost required to be free from toxins, or can it be determined that some or all toxins present in the compost feedstock will break down and be purified during the composting process? (76)
The notes in PSL Table 4.2 (32.311) under the headings "Compost from off-farm sources", "Compost produced on the farm" and "Compost Feedstocks" give extensive instruction as to what is required, permitted or prohibited in the production of compost. The underlying assumption is that the composting process is capable of degrading some contaminants that are present in the original material. When materials are used that may contain persistent prohibited substances, it is the responsibility of the operator to document or "prove" the process of degradation. The notation allows for two possible methods; 1) analysis of the final composted material or 2) reference to scientific literature which establishes the common degradation of contaminants during the composting process. In the case of materials obtained from an urban setting, e.g., leaves or yard waste; it should be assumed that persistent chemicals, including pesticides are present and due diligence as outlined above should be practiced. It is the CB's responsibility to assess the risk and require documentation specific to each situation.

What documentation is required to substantiate common degradation of contaminants during the composting process as implied in Table 4.2 "compost feedstocks"? (133)
Acceptable documentation would consist of published academic studies. Claims made by manufacturers must be verified by independent research. Operators also have the option of analysis of the final product to confirm that no contaminants persist.

If GE plants are used in the production of compost, can that compost be used to fertilize organic farms? We are concerned with families who buy conventional food and add the household waste to their compost. (129)
The presence of GE plant material is strongly discouraged, but the possibility of use as compost feedstock is not eliminated. See Table 4.2, 32.311 Plant and Plant by-products:

"Wastes from crops that have been treated or produced with prohibited substances may be used as composting feedstocks".

However compost is subject to the following restrictions under Compost feedstocks: "When evidence indicates that composting feedstocks may contain a substance prohibited by 1.4/1.5 of CAN/CGSB 32.310 known to be persistent in compost, documentation or testing of the final product may be required.”

 

Human waste in compost

Can urine from unmedicated individuals be added into compost which is used in organic certified production? (401)

No. Human waste is not listed as a permitted compost feedstock. See Compost feedstocks, Table 4.2.

 

Biodegradable bags as compost feedstocks

Can residential food waste collected in biodegradable bags be used as a compost feedstock? (302)
Yes, as long as the biodegradable bags and the residential food waste decompose effectively during the composting process.  If applicable, the absence of petrochemical residues may need to be confirmed by testing. See Table 4.2, column 1, Composting feedstocks.

 

Coloured ink in compost feedstock

If tests demonstrate acceptable levels of heavy metals, foreign matter and human pathogens, as specified in Guidelines for Compost Quality, is compost made from Municipal Source Separated Organic (SSO) household waste, which is composed mainly of vegetal and animal origin but could contain some coloured newsprint (added to household containers to absorb moisture and odors), and possibly other prohibited substances, permitted? (470) - 17 February 2020
No. Regardless of whether testing indicates acceptable levels of heavy metals, finished compost must conform to the compost feed stocks annotation, which, for example, prohibits paper with coloured ink other than yard waste bags. See 32.311 table 4.2 Compost feedstocks.

 

Testing of compost used as ingredient

When compost is used as an ingredient in a blended fertilizer product, should the analysis for heavy metals, foreign matter, and pathogens occur on the compost ingredient prior to blending or on the final blended fertilizer? (334)
Compost must meet the required specifications whether it is applied directly to the soil or blended with other ingredients. In the case of a blended product, the compost analysis shall be performed prior to blending with other ingredients.

Forestry by-products as compost feedstocks

Can bark or forestry by-products be used as a compost feedstock? (461.1) - 17 February 2020
Yes. Forestry by-products can be used as compost feedstocks providing it can be demonstrated they do not contain a substance prohibited by 1.4 of CAN/CGSB-32.310 known to be persistent in compost. See Table 4.2 Compost Feedstocks.

 

Heavy metal analysis of off-farm sourced compost

Is a heavy metal analysis required for each individual compost ingredient used in the manufacture of off-farm sourced compost? (353)
"No. It is not necessary to test each ingredient of a compost before the composting process. Heavy metal analysis is required at the end of the composting process, before it is blended with any other substances, such as potting mixes, minerals, other composts, etc. See Compost from off-farm sources,Table 4.2.

Version 2020

No. It is not necessary to test each ingredient of a compost before the composting process. Heavy metal analysis is required at the end of the composting process. See Compost from off-farm sources, Table 4.2, column 1.

 

Expanded perlite

Is expanded perlite permitted under the listing of ‘Clay’ on Table 4.2? (335)
Yes.The physical expansion of perlite during its manufacturing is permitted as the process does not change the molecular structure of the substance.

 

Fish products – Stabilization

The manufacturer of a fish-based soil and plant fertilizer would like to stabilize the product by reducing the pH below 3.5.  Is this allowable? (114)
Yes. As long as the amount used is not in excess of what is needed to stabilize the product. See Fish meal, fish powder, fish wastes, hydrolysate, emulsions and solubles listing in PSL Table 4.2.  See Fish products, Table 4.2, column 1 of PSL.

Fish & kelp products – Preservative

Can potassium sorbate be used as a preservative in kelp and fish products used as fertilizers? (110.1)
Potassium sorbate can be used as a preservative in kelp and fish fertilizers provided it meets the non-synthetic definition in 3.39. The origin and usage annotations for both the “Aquatic plants and aquatic plant products” and the “Fish meal, fish powder, fish wastes, hydrolysate, emulsions and soluble” listings, in PSL Table 4.2, prohibit synthetic preservatives.

Version 2020

Potassium sorbate can be used as a preservative in water-extracted kelp-based fertilizers as potassium sorbate is specifically mentioned in the ‘Aquatic plants and aquatic plant products’ annotation in PSL Table 4.2. But it cannot be used in fish-based fertilizers as it is not listed in ‘Fish products’ annotation.

 

Definition of fish farm waste

What is the definition of “fish farm wastes” used in the listing of “Fish meal, fish powder, fish waste, hydrosylate, emulsions and solubles” (Fish products) in Table 4.2? Does it need to be composted? (333)
Fish farm wastes consist of sludge and mortal remains (fish, bones, scraps, carcasses, etc.) collected at the fish farm. Such wastes cannot be used raw; it must be composted or processed before use. Manufactured fish by-products, such as processed fish meals or liquid fish fertilizers made with farmed fish and/or fish farm wastes, do not have to be composted before use.

 

Lactic acid produced by fermentation and extraction

Is lactic acid produced by fermentation and extraction allowed under the Canadian Organic Standards? Is that lactic acid considered to be synthetic? (331)

UNDER REVIEW BY THE STANDARDS INTERPRETATION COMMITTEE

Lactic acid produced by fermentation and extraction is permitted. Extraction processes must use permitted extractants (See Extractants, Table 4.2 and 4.3 and Extraction solvents, carriers and precipitation aids, Table 6.3). Lactic acid produced by fermentation and extraction is non-synthetic under the Canadian Organic Standards. Requirements with regard to substrates/growth media must be met. Chemical processes used to purify and/or extract substances are permitted as long as they do not create new molecules or involve processes specifically prohibited by the standard. See Synthetic substance, 3.65, 32.310.

 

Gibberellic acid produced by fermentation and extraction

Is gibberellic acid produced by fermentation and extraction allowed under the Canadian Organic Standards? Is that gibberellic acid considered to be synthetic? (332)
Gibberellic acid produced by fermentation and extraction is permitted. Extraction processes must use permitted extractants. See Extractants,Tables 4.2 and 4.3. Gibberellic acid produced by fermentation and extraction is considered to be non-synthetic under the Canadian Organic Standards. Requirements with regard to substrates/growth media must be met. Chemical processes used to purify and/or extract substances are permitted as long as they do not create new molecules or involve processes specifically prohibited by the standard. See synthetic substance, 3.65 (32.310).

Version 2020

Gibberellic acid produced by fermentation and extraction is permitted. Classifying the synthetic / non-synthetic is no longer required as of the 2020 revision of the standard. Confirmation is needed to ensure the gibberellic acid is derived from biological materials.

 

Minerals – Flotation reagents

Does the use of flotation reagents in extraction & purification of mined minerals render the product prohibited? Is a producer required to demonstrate the absence of flotation reagents in the final product? (189)
Minerals which have been extracted using flotation reagents that are not intended to form part of the mineral substance are allowed. Given that flotation reagents are removed and reused by the mining industry, the operator is not required to prove the purity of the final product.

 

About fused minerals

Are fused mineral fertilizers (created by heating and blending minerals) compliant to COR? (464) -17 February 2020
No. Unless specifically listed in the PSL, minerals that have undergone such a change are not permitted.

 

Microbial fertilizers and soil amendments

What are the requirements for substrates used to create microbial fertilizers or microbial soil amendments? (167.2)
The requirements for feedstock used to create microbial soil amendments are distinct for two separate groups of products; i) microbial products containing no residue of the substrate: for these, the feedstock should be non-GE if commercially available. ii) products in which the microbial is delivered along with a remnant of the feedstock: here feedstock materials must be listed on PSL Tables 4.2 or 4.3 and comply with any annotations. (see PSL 4.13)

Version 2020

As of the 2020 standard, microbial fertilizers and microbial soil amendments may not be derived from municipal sewage sludge (see ‘Microorganisms and microbial products’ PSL 4.2). In addition, if the product contains the substrate: the feedstock materials must be listed on PSL Table 4.2 and comply with any annotations (4.1.3 a).  Or, if they do not contain the substrate, the substrate should be non-GE if commercially available (4.1.3 b).

 

Molasses

If a blended, multi-ingredient soil amendment contains non-organic molasses, can it be used in organic production? (188)
No. Organic molasses is required (see Molasses PSL Table 4.2)

 

Non-organic spent brewers' grains as amendment

Can non-organic spent brewers' grains be used as a soil amendment? As a compost feedstock? (323)

To be acceptable for use as a soil amendment, non-organic spent brewers' grains must be non-GE and any non-agricultural substances added during the brewing process must be listed on Table 4.2 of 32.311 and comply with 1.4 a and d  (with 1.4 a and 1.5 a) of 32.310. For example, diammonium phosphate (DAP) added during the brewing process would render spent brewers' grains non-compliant for use as a soil amendment in organic production. Non-organic spent brewers' grains from GE sources are an acceptable composting feedstock, as GE residues do not persist after the thermophilic stage of the composting process. See Compost feedstocks in Table 4.2.

 

Corn steep liquor as an amendment

Is non-organic corn steep liquor allowed as a soil amendment/fertilizer in organic production? (503) - 18 Dec 2020
No. However, organic corn steep liquor would be permitted. Refer to SIC Q&A 60a for further insight.

 

Paper mill sludge

Can paper mill sludge be used on organic farms? (294)
No. Sludge from paper mills is not listed in CAN/CGSB-32.311and is therefore not permitted for use on organic farms (32.310 1.4 d). Any synthetic extractants, solvents or additives used when generating plant by-products are prohibited, except as specified in the annotations of substances listed on Table 4.2.

Version 2020

Sludge from standard paper mills contains substances not listed in CAN/CGSB-32.311 and is therefore not permitted for use on organic farms (32.310 1.5 a). If all extractants, solvents or additives (e.g., glues, preservatives, etc.) used when generating the paper are covered by the ‘Extractants’ or the ‘Plants and plant by-products’ listings in PSL 4.2 – column 1, then the sludge would be permitted.

 

Potassium sulphate

Can potassium sulphate which has not been mined, but manufactured by combining mined potassium chloride, mined sodium sulphate and water, be used as a soil amendment in accordance with the PSL? (166)
Yes. Potassium sulphate produced by combining two mined minerals is permitted (see d, Potassium sulphate, under the Potassium listing - PSL, Table 4.2); however, in general, mined minerals may not be processed or fortified with synthetic chemicals except where specifically permitted in the annotation. Potassium sulphates made using reactants such as sulfuric acid or ammonia are prohibited. (see “Mined Minerals, unprocessed PSL” Table 4.2).

Version 2020

Yes. Potassium sulphate produced from combining mined minerals using ion exchange is permitted (see Potassium d),  PSL, Table 4.2);. Potassium sulphates made using sulphuric acid as a reactant are prohibited.

 

Potassium nitrate not allowed

Can potassium nitrate be an allowed fertilizer in organic production, if the nitrogen was derived from compliant anaerobic digestate? (502) - 18 Dec 2020
No. It no longer is a digestate, and neither is it listed in the Potassium listing in PSL, Table 4.2.

 

Soap in soil amendment

Can a compliant soil amendment contain soap? (397)
No. Soil amendments, such as compost, manure, etc., may not contain soaps as they are restricted to Production aids in PSL, Table 4.3 (Table 4.2, column 2). See Soaps, PSL, 4.2, column 2.

 

Fish products – Fatty acids


If fatty acids are allowed in organic production systems as a pesticide (see soaps, PSL 4.3), are fatty acids allowable in fish and aquatic plant products used as organic fertilizers? (110.1)
Fatty acids from plant and animal sources are allowed in fish and aquatic plant products used as organic fertilizers. They are not allowed if they are from synthetic sources, such as fatty acids extracted using hexane. For a synthetic to be allowed as an ingredient in an organic fertilizer, the substance must be included on the PSL Table 4.2 or 4.3.

Version 2020

If fatty acids are allowed in organic production systems as a pesticide (see Soaps, PSL Table 4.2 - column 2), are fatty acids allowable in fish and aquatic plant products used as organic fertilizers? (110b)
No. Fatty acids, aka soaps, derived from plant and animal sources are not allowed in aquatic plant products or fish products used as fertilizers applied to the soil, as the  Soap listing restricts the use of soap to production aids such as pesticide applications or foliar nutrient sprays. See Soaps, PSL, Table 4.2, column 2 and Aquatic plants and aquatic plant products, PSL, Table 4.2, column 1.

 

Sugar

Is sugar allowed as a soil amendment? (60.1)
Organic sugar only can be used as a soil amendment. An organic substance does not have to be listed on table 4.2, column 1, to be allowed as a soil amendment.


Sulphuric acid

Please outline the application for the use of sulphuric acid for crops (98) (50)
Sulphuric acid cannot be used to manufacture calcium sulphate (gypsum), or potassium sulphate (see individual listings in PSL Table 4.2). Nor can it used as a pH buffer (see “pH buffer” in PSL Table 4.2 & 4.3) except in fish products but only if vinegar, non-synthetic citric acid and phosphoric acid are ineffective. (see “Fish meal, fish powder, fish waste, hydrolysate, emulsions and solubles).

Version 2020

Sulphuric acid cannot be used to manufacture calcium sulphate (gypsum), or potassium sulphate (see individual listings in PSL Table 4.2 - column 1). Sulphuric acid may be used to stabilize fish products but only if vinegar, citric acid, phosphoric acid are ineffective. See Fish products, Table 4.2).

 

Additives in soil amendments

Can fertilizers used as soil amendment in organic production be supplemented with synthetic substances? (167.1)
No. If a compliant soil amendment is enhanced or changed using additional substances, those substances must appear on Table 4.2 in order for the resulting soil amendment to be compliant.

Version 2020

Can soil amendments be supplemented with non-listed non-organic substances? (167.1)
No. If a compliant soil amendment is enhanced or changed using additional non-organic substances, those substances must appear on Table 4.2 - column 1 and comply with any annotation restrictions in the applicable substances' listings.

 

Non-synthetic mineral fertilizers in ion-exchange systems

Does running a non-synthetic mineral fertilizer through an ion-exchange system render the mineral fertilizer synthetic? (365)
Yes. The use of an ion exchange system involves chemical reactions and unless specifically permitted by the PSL (Table 4.2) is prohibited. The word "combining" in PSL table 4.2 for "potassium sulphate" allows potassium sulphate that has gone through an ion-exchange system

Version 2020 This QA will be deleted.

 

Tractor exhaust

Is tractor exhaust, injected into the soil, acceptable under the standard? (32)
Tractor exhaust may be injected into the soil only if all the components of the tractor exhaust comply with the standard and PSL. This means 100% pure biodiesel exhaust would be acceptable while exhaust generated by a petroleum gas engine would not.

 

Limestone from sugar processing

Under Table 4.2, is "limestone from sugar processing" allowed without evaluating the manufacturing process? (306)

Lime from sugar processing and mined calcium carbonate are acceptable sources. Review of the manufacturing process is not required.

Version 2020

Is "lime from sugar processing" in the annotation to Calcium, in table 4.2, column 1, allowed without evaluating the manufacturing process? (306)
Yes. Review of the manufacturing process is not required.

 

Rock phosphate

The listing for rock phosphate in table 4.2 restricts cadmium levels to 90 mg/kg P2O5.  Is that to be calculated on the total P2O5 or the available P2O5? (305)

The amount of P2O5 used in the calculation is the total amount, not the available amount.

 

Wool as mulch

Can conventional wool be used as mulch? (324)
Yes. Even though wool is not specifically mentioned in the mulch listing in Table 4.3, wool from either organic or non-organic operations could be used as a mulch.

 

4.3 Crop Production Aids and Materials

Version 2020

4.2 Column 2 - Crop Production Aids and Materials

 

Acetic acid

Can acetic acid solution be used as a weed control product in organic production? (172)
Yes. Non-synthetic sources of acetic acid may be used for weed control. See Acetic acid, PSL, Table 4.3). 

Version 2020

Yes. Acetic acid not made from petrochemicals may be used for weed control. See Acetic acid, Table 4.2, column 2, PSL.

 

Use of antibiotics in orchards

Is streptomycin allowed in apple production to control fire blight? (311)
No. The amended standard published MAR 2018 clarifies that antibiotics, including streptomycin, are prohibited in crop production. See Biological organisms, 32.311, Table 4.3 (Table 4.2).

 

Citric acid

Can citric acid be used as a pH adjuster during the extraction of Fulvic Acid? (248)
Yes. Citric acid would be acceptable as an extractant. See Humates, humic acid and fulvic acid a), Extractants e) and Citric acid in Table 4.2 of PSL.

 

Combined formulations

Can a pesticide and a fertilizer be combined under the COR? (110.3)
Yes. An operator wishing to use a pesticide in a fertilizer formulation must ensure that the requirements of 32.310 5.6.1 and 5.6.2 are fulfilled. Pest control substances listed on the PSL Table 4.3 can only be used when other cultural approaches fail and require the documented presence of the pest organism. Fertilizer applications must be applied according to the plant's requirements based upon the plant’s growth stage.

Version 2020

Yes. A pesticide listed in the Table 4.2, column 2 of the PSL can be combined with a fertilizer providing the requirements in 5.6.1 and 5.6.2 in 32.310 are fulfilled and the nutrient load does not exceed the limits of the nutrient management plan. See 3.46 in 32.310.

 

Formulants – Soil amendments & crop production aids

Are the restrictions in the formulant listings in Table 4.2 & 4.3 (Table 4.2) only applicable when formulants are specifically mentioned in an annotation? Or do the annotations for formulants apply whenever a substance contains a formulant? Case in point, may repellents contain formulants?(483) - 29 April 2020

The formulant listings apply whenever a substance contains a formulant unless a specific derogation is identified in an annotation. In the case of repellents: PMRA List 4 formulants are allowed in Repellents listed in Table 4.3 (Table 4.2).

 

Non-complying formulants in pesticides

What is the status of a crop on which a pesticide was applied containing an active ingredient listed in Table 4.3 (Table 4.2) of the PSL but also a formulant from List 3 of PMRA? (326.1)
In most cases the crop cannot be certified because (with the exception of List 3 formulants in passive pheromone dispensers) only formulants from Lists 4a and 4b of PMRA may be used in pesticides allowed by Table 4.3 (Table 4.2, column 2). However, if the List 3 formulant is covered by a different substance listing in Table 4.3 (Table 4.2, column 2) (e.g., essential oils and aloe vera gel under Plant extracts, soap under Soaps, etc.) or Table 4.2, column 1, (talc under Mined minerals, etc.), the crop could be certified.

Will a 36-month transition period be required for the land where the pesticide described in 326a was applied? (326.2)
A 36-month transition will not be required if the List 3 formulant is a permitted substance. See Formulants used in crop production aids, Table 4.3 or 4.2. (Table 4.2).

 

Insecticidal soaps

Can insecticidal soaps that contain isopropyl alcohol, in addition to the fatty acids derived from animal or vegetable oils, be used in organic production? (75)
Yes, insecticidal soaps containing isopropyl alcohol can be used since isopropyl alcohol (1-Propanol) is a formulant listed in List of formulants 4B of PMRA. See Formulants used in crop production aids, Table 4.2.

Kaolin clay

Is calcined kaolin clay a permitted substance under Canadian Organic Standards? (223)
Yes. Calcined kaolin clay is allowed, but only if no synthetic chemicals were used or added during the calcination process. (See Kaolin clay PSL Table 4.3)

Version 2020 This QA will be removed as 'calcined' has been added to the annotation relating to Kaolin clay.

Calcination of kaolin 

Is calcined kaolin allowed as a crop production aid (Table 4.3) if synthetic chemicals are added prior to calcination, such as flocculating agents, bleaching agents, and fluxes? (386)
Kaolin clay, per the annotation in 4.3, cannot be processed or fortified with synthetic chemicals unless they are listed in Table 4.2. See Mined Minerals, unprocessed in Table 4.2.

Version 2020  This QA will be removed as 'Shall not be processed' has been added to the annotation relating to Kaolin clay.


Pheromones

Is the delivery of pheromones confined to passive dispensers or is spraying application allowed? (93)
Yes.  The annotation for pheromones limits the delivery to traps or passive dispensers. Spraying applications are prohibited. See Pheromones and other semiochemicals in PSL, Table 4.3.

Version 2020 

Yes. All sources are permitted. For pest control.

 

Hay preservatives with prohibited substances in an organic field

If a hay preservative containing prohibited substances is applied while baling, and the hay is being sold as non-organic, does the field lose its organic status? (445) - 21 June 2019
Yes. The field would lose organic status as there is no means to ensure the field will not become contaminated to some degree. Only hay preservatives approved for organic use or those containing active ingredients listed in 4.2, 4.3 & 5.2 (4.2 & 5.2) are permitted.

 

Acceptable substances in biodegradable mulches

Can biodegradable mulches contain substances listed in PSL 4.2 or 4.3 (PSL 4.2)? (371.1)
Yes.


If yes, does the annotations for those substances listed in Tables 4.2 and 4.3 of the PSL (Table 4.2 of the PSL) have to be addressed? (371.2)

Annotation restrictions apply even if substances are used as components of a biodegradable mulching material. For example, if embedding micronutrients into the material, the annotation for micronutrients must be addressed.

 

Processes in the manufacturing of mulches

Could a biobased film become non-compliant because of the manufacturing process that would disqualify it from being used on organic farms? (284)

No. Biobased biodegradable mulches must meet the requirements listed in Table 4.3 of the PSL and have been evaluated according to the criteria specified in Clause 10.3, Table 8. These criteria give preference to non-synthetic substances and consider the environmental impact of manufacture but do not specify any current restrictions on manufacturing processes.

Version 2020

No. The manufacturing of a biobased biodegradable mulch does not come into scope when a CB reviews a product for use. Biobased biodegradable mulches must meet the requirements listed in Table 4.2 of the PSL.

 

Plastic mulch removal

Are bioplastic mulches, made from corn, accepted as “biodegradable films” that can be left to decompose in the soil? (79, 253)

To be acceptable as biodegradable and left to decompose in the soil, a bioplastic mulch made from corn:
1) cannot be made using GE plant material;
2) cannot contain substances such as biodegradable polymers, Carbon Black from GE or petroleum.
Mulches containing biodegradable polymers and Carbon Black from GE or petroleum sources which were considered to be compliant in 2014 can be used and left in fields without removal as a temporary exemption until January 1, 2017 (see Mulches PSL Table 4.3 in 311 and the definition of biodegradable in 3.10 in 32.310).

Version 2020

To be acceptable as biodegradable and left to decompose in the soil, a bioplastic mulch made from corn:
1) cannot be made using GE plant material;
2) cannot contain substances such as biodegradable polymers, Carbon Black from GE or petroleum.
3) must meet the biodegradable criteria specified in biodegradable definition (3.11 in 32.310).

 

Kraft lignin in biodegradable planting containers

Is Kraft lignin allowed as an ingredient in biodegradable planting containers that are left in the soil to decompose? (352)
Yes. Most papers are produced using the Kraft process. If all other ingredients are listed in Table 4.2, planting containers that contain Kraft lignin can be left to decompose in soil. See Table 4.3 (Table 4.2, column 2) Biodegradable plant containers.

 

Microbial substrates

May a bacteria for use as an organic crop production aid be produced using prohibited materials in the substrate? (141) 

PSL Table 4.3 (4.2) allows the use of "Biological organisms", which includes bacteria, providing they are not genetically engineered.

The requirements for the substrate on or in which they are propagated fall into two distinct categories;

i) microbial products containing no residue of the substrate: for these, the substrate feedstocks should be non-GE if commercially available.

ii) products in which the microbial is delivered along with a remnant of the substrate: here feedstock materials must be listed on PSL Tables 4.2 or 4.3 (Table 4.2, PSL) and comply with any annotations. See PSL 4.1.3.

 

Neem oil

Can neem oil be used to treat powdery mildew in cucumbers? (268)
Registered neem based pesticides can be used as a Crop Production Aid based on the listing in Table 4.3 (Table 4.2, column 2) of the PSL "Botanical Pesticides", with restrictions noted in the "Origin and Usage" column. Formulants included in these pesticides also have to comply with PSL requirements.

 

Magnesium lignosulphate

Is Magnesium lignosulphate allowed under the listing of lignin sulphonates in Table 4.3 of the Permitted Substances List? (289)

Lignin sulphonates, including magnesium lignosulphate, are allowed as chelating agents for micronutrients, formulant ingredients or dust suppressants.

Version 2020

Lignin forms such as lignosulphonic acid, calcium lignosulphonate, magnesium lignosulphonate, sodium lignin and sodium lignosulphonate are permitted.

 

Sulphonates manufactured with non-listed substances

Are lignin sulphonates manufactured with non-listed substances (e.g., calcium bisulphate) permitted? (355)
All lignin sulphonates, except ammonium lignin sulphonates, are allowed, as crop production aids, if used as chelating agents, formulants, or as dust suppressants. See Lignin sulphonates,' Table 4.3, (Table 4.2) and 4.1.1 b) of PSL.

Rotenone

Is Rotenone allowed for use in organic production? (308)
Rotenone is a substance that qualifies as botanical pesticides. However, in countries such as Canada, where rotenone products are no longer registered for agricultural use, they cannot be used for organic production.

 

Seawater

Water is listed as permissible. Can you please confirm if seawater can be used in crop production? (23)
Yes. Table 4.3 (Table 4.2, column 2) of the PSL allows for Water which would include seawater to be used as a crop production aid.

Sprout inhibitor – Ethylene

Is the use of ethylene as a sprout inhibitor for onions and potatoes admissible? (43)
No. The use of ethylene is restricted to tropical fruit ripening and citrus degreening. See PSL Table 8.4.

Version 2020

Yes and no. The use of ethylene is permitted for potato sprout control, but not onions. See Table 8.3 of PSL.

 

Structural PVC tubing

Can PVC tubing be used as structural material to hold insect nets? (136)
Yes. PVC tubing may be used. The prohibition of poly vinyl chloride for mulches and row covers does not apply to the structural material.

 

Transplant containers

If paper containers are placed in the ground as transplant containers and allowed to decompose, what are the requirements for the paper? (187)
The requirements are the same as for mulch (see Q&A 79). No glossy paper or coloured ink. Must be 100% biodegradable derived from bio-based sources to be left to decompose in the ground. 

Weed barriers

Could a woven polypropylene weed barrier cloth be left in place for 3-5 years in an orchard or vineyard? (347.1)

Yes, it can be left in place as long as it doesn't start to degrade.

Can the same thing be done with 100% coconut fibre mats? (347.2)
If the coconut fibre mats do not contain any prohibited materials, they can be used and left to degrade in place.

 

 

 

Permitted substances lists for livestock production

5.2 Feed, feed additives and feed supplements

Acetic acid for acidifying drinking water

Can acetic acid be used for acidifying drinking water for animals? (201) - 26 Sep 2019

Yes. Acetic acid from any source other than GE sources may be used to acidify livestock drinking water. (See 'Acids' Table 5.3).

 

Hydrogen peroxide for drinking water

Can hydrogen peroxide that is used to treat drinking water for humans but is not necessarily rated 'food grade' be used to treat livestock drinking water? The hydrogen peroxide annotation in PSL table 5.3 stipulates "food grade" is required. (486) - 29 June 2020
Yes, Hydrogen peroxide approved to treat drinking water for humans is considered equivalent to food grade for the purpose of treating livestock drinking water.

 

Livestock feeds – Certification

Can livestock feeds which contain non-agricultural ingredients be certified? (65.1)
Livestock feed must meet the organic product requirements in 9.1.3 d), and the labelling and advertising requirements in Safe Food for Canadians Regulations (SFCR).  Livestock feeds may contain necessary feed additives or supplements according to PSL Table 5.2. Refer to 6.4 in 310 for complete details on livestock feed.

Lactoserum for feed

Can non-organic lactoserum be used as feed if it is documented that organic lactoserum is not commercially available? (258)

No. Livestock feed must contain 100% organic agricultural ingredients. (9.1.3 d).

 

Substrate for probiotics

Q: Can probiotics be used as feed supplement if they are manufactured using a non-organic agricultural substance such as whey as the growing medium (252)

It depends. Non-organic agricultural ingredients such as whey can be used as the growth medium or substrate to manufacture probiotics that are used as a feed supplement as long as their use complies with the requirements of 32.311 5.1.2 and 6.2.1, as follows:

a) if the probiotic includes the substrates or growth media, the ingredients of the substrate or growth medium  shall be listed in the appropriate PSL Tables 5.2 (Livestock feed) & 5.3 (Livestock health care), and use of non-organic agricultural substances listed in the PSL must comply with substance listing annotations;

b) if the probiotic does not include the substrates or growth media, it shall be produced on non-genetically engineered substrates or growth media, if commercially available.

This means each substrate needs to be assessed individually for compliance. For example, whey residues are not permitted in a probiotic product because whey is not listed in the required tables. Whey would need to be organic under these circumstances. Probiotic products without whey residues are permitted without a commercially available search because at present there is no milk being produced from genetically engineered animals.

 

Amino Acids – DL methionine and lysine

Is the use of DL methionine from processes involving genetic modification allowed? (54)
No. Table 5.2 of the PSL allows for the use of synthetic DL methionine, as a special exception subject to a review by the CGSB technical committee.  Section 1.4 a) prohibits products from genetic engineering.

Possibly. As clarified in the Amino acid annotation in 2020 PSL Table 5.2,
a) the first choice for providing amino acids in feed shall be organic sources, such as fishmeal, insect meal, brewer’s yeast, etc.
b) If supplementation with these sources does not meet the requirements to produce a balanced feed, the operator can use amino acids “derived from biological sources by biofermentation and extracted, or isolated, by hydrolysis or by physical or other non-chemical means.”
c) As a last resort, and only for monogastrics (such as pigs, rabbits and chickens), “all sources of lysine and methionine,” including GE forms, may be used if there are no commercially available sources of lysine or methionine “derived from biological sources by biofermentation and extracted, or isolated, by hydrolysis or by physical or other non-chemical means.”

 

Cobalt Sulphate

Does the prohibition of sulphates produced with sulphuric acid apply to cobalt sulphate used as a mineral supplement and for medical use? (22.1)

Table 5.2 of the PSL allows synthetic trace elements, such as cobalt sulphate for feed if a non-synthetic form is not commercially available. Table 5.3 allows any source for medical use.

Can cobalt sulphate produced with sulphuric acid be used as a mineral supplement and for medical reasons? (22.1)

The annotation for “Minerals, trace minerals, elements” in Table 5.2 of the PSL allows sulphated forms of minerals provided they do not contain or are produced with EDTA or EDDHA. Table 5.3 allows any source for medical use.

Fish Products

Is the use of fish products as feed supplements allowed? (22.2)
Yes. Fish products are allowed as feed supplements, as operators must supply “a feed ration sufficient to meet the nutritional requirements of the livestock” (6.6.1 b)). Feed supplements must not be fed in amounts above those required for health of the animal at its stage of production as per 6.4.4 c). This limits the volume of the fish supplement that can be fed in the ration. Feed supplements are defined in the standard as ‘feed that is used in conjunction with other feeds to improve the nutrition balance... “ (see 3.21 for Feed supplement definition).

Yes. Organic fish meal can be used and non-organic fish meal is allowed if organic fish meal is not commercially available and if all preservatives and other ingredients are listed in Table 5.2. Fish meal was added to Table 5.2 in 2020.
Operators must supply “a feed ration sufficient to meet the nutritional requirements of the livestock” (6.6.1 b). Feed supplements must not be fed in amounts greater than those required for health of the animal at its stage of production as per 6.4.4 c). This limits the amount of the fish supplement that can be fed in the ration. Feed supplements are defined in the standard as “feed that is used in conjunction with other feed to improve the nutrition balance...” (see “feed supplement” definition in Section 3 of 32.310).

 

Vitamin & Mineral Premixes – Preservatives

If all commercially available vitamin and mineral premixes contain preservatives, how can organic farmers meet the nutritional needs of their animals? (65.1)
The annotations in the listing of Pre-mixes, Vitamins, and Minerals, trace minerals, elements in Table 5.2 (PSL) make it permissible to use pre-mixes that contain preservatives, if no fully compliant product is available. See “3.17, Commercially Available” definition in 32.310.

However, as of 2020, all “vitamin formulants that comply with Canadian regulations are accepted. Vitamins not compliant to 5.1.2 of this standard are permitted.

 

Sprayed substances on dry hay

Can stored organic hay be sprayed with substances listed in 4.3 (4.2 (Column 2)) and/or 5.2 of PSL? (381)
No. Only substances listed under "Hay or silage preservation products" in Table 5.2 of 32.311 can be used with dry hay. “Preference should be given to bacterial or enzymatic additives derived from bacteria, fungi and plants and food by-products (such as molasses and whey).The following acids may be used: lactic, propionic and formic.” Although salt is not specifically mentioned in this annotation, it would be allowed for hay treatment, as salt is permitted as part of livestock feed.

 

 

 

Propionic acid containing ammonium hydroxide

Is propionic acid containing ammonium hydroxide permitted as hay or silage preservation product under CAN/CGSB-32.311 Table 5.2? (356)
No. The allowance in the PSL 5.2 listing 'Hay or silage preservation products' is for propionic acid, not for propionic products containing prohibited compounds such as ammonium hydroxide. 1.4 f) prohibits the use of "synthetic crop production aids and materials", except as specified in CAN/CGSB-32.311.

No. The allowance in the PSL 5.2 listing “Hay or silage preservation products” is for propionic acid, not for propionic products containing prohibited compounds such as ammonium hydroxide. 1.5 b) prohibits the use of crop production aids and materials that are not listed in CAN/CGSB-32.311.

Yeast Derived Protein

Does the definition of “Micro-organisms and yeasts” in Table 5.2 of the PSL include yeast-derived protein? (120)
A yeast-derived protein is not a yeast; it is a protein. Protein for use in organic livestock rations must be organic (see “Protein feeds” PSL Table 5.2), and in compliance with 6.4.4 (32.310). Protein derived from organic yeast could be permitted depending on the method of fractionation.

Yeasts are listed on Table 5.2. Are the derivatives of yeast, namely the yeast cell wall products, also allowed? (238)
Yes. Yeast and yeast cell wall products are allowed as feed supplements. Non-organic sources, inluding autolysate, can be used if organic sources are not commercially available.

 

5.3 Health care products and production aids

Colloidal silver

Is colloidal silver allowed for use in livestock health care? (273)

It depends. Colloidal silver falls under the "Minerals, trace minerals, elements" listing in PSL Table 5.3.  But due diligence is required to make sure the form of colloidal silver is acceptable. Colloidal silver produced using electrolysis is allowed. Also, colloidal silver produced by a biofermentation process is allowed as long as the genetically engineered restrictions specified in 1.4 a (32.310) are met. Colloidal silver is basically nano-sized clusters of silver atoms in an aqueous solution. Although products of nanotechnology are generally prohibited, the two forms listed above are allowed as they fall under the exception pertaining to nanotechnology provided in 1.4 b) 2) of 32.310.

 

Garlic

Can uncertified garlic be used as a de-wormer in organic livestock operations? (7)

This standard permits the use of uncertified garlic as a de-wormer treatment under Table 5.3 of the PSL, Botanical compounds.

 

Magnesium carbonate as anti-caking agent

Can magnesium carbonate be used as an anti-caking agent in salt when used for livestock? (467.2) - 17 February 2020
Yes. As magnesium carbonate may be included in feed as a source of nutrition. See Minerals, trace mineral, elements, PSL, Table 5.3.

 

Ketoprofen

If ketoprofen is used therapeutically, is there a withdrawal period? (449) - 26 Sep 2019
No. Non-steroid anti-inflammatories such as ketoprofen are included in Table 5.3 of the PSL. Products listed in the PSL do not require any withdrawal times unless specified in the annotation or on the product label.

 

Lanolin

Is Lanolin allowed for use on dairy cows' teats? (55)
Yes. Lanolin may be used. The SIC is aware that lanolin or similar preventative balms are not listed in PSL Table 5.3; but simultaneously they are neither prohibited by 6.6.2 of 32.310.

Yes. In 2020, lanolin was added to Table 5.3 “for external use only, such as udder balm (ointment).”

 

Medical Treatment – Fish Products

Is the use of fish oil as medical treatment (to treat bloat) prohibited? Are fish-based animal health tonics prohibited? (22.3)
Fish oil and fish-based health products are allowed as veterinary medicinal substances under 6.6.10 c. (32.310)

Vitamin B

Is it acceptable to inject meat animals with vitamin B for the purpose of improving meat colour? (33)
No.  Table 5.2 lists vitamins for “enrichment or fortification.”  Injection to improve the colour of meat is for cosmetic purposes, not enrichment of fortification.

Vitamins – Preservatives

Can a vitamin that contains a synthetic preservative be used in livestock feed? (81)
Yes. Vitamins, with no restrictions, are permitted for feed enrichment or fortification. See Vitamins, PSL, Table 5.2.

Eggs – Ink Labels

Can ink be used to label organic eggs? (46)
Yes. Ink that does not contain prohibited substances may be used to label eggshells.

Barn Sanitizers

Is citrus extract allowed as a cleaner or disinfectant in buildings for animal production? (68.1)
Yes. Citrus extract included under Botanical compounds in Table 5.3 (32.311) could be used as a cleaner in livestock houses. See 6.7.4 in 32.310.

What is the status of Tables 7.3 and 7.4 regarding livestock production? (68.2)
Substances on Tables 7.3 and 7.4 can be used in livestock facilities as can substances in Table 5.3, but cleaning or disinfection of livestock facilities is not confined to these lists. Any effective disinfectant can be used to clean livestock facilities in the event of a reportable disease. See 6.7.4 - 32.310.

Zinc oxide

Is zinc oxide allowed as a health remedy in organic livestock production? (279)
Yes.  Table 5.3 "Health Care Products and Production Aids" lists "Minerals, Trace Minerals, Elements" and specifies that "minerals of any source are allowed for medical use". Zinc oxide would fall under this listing.

Zinc sulphate

Can zinc sulphate be used as a treatment in foot baths for livestock? (270)
Yes, as it is considered a mineral under the listing in Table 5.3 - Minerals, Trace Minerals and Elements which specifies that “minerals of any source are allowed for medical use.”

 

Phytase - Enzymes from genetically engineered bacteria

Can enzymes such as phytase be compliant to the standard even if the enzyme is produced by genetically engineered bacteria? (380)
No. Clauses 1.1 and 5.1 in 32.311 and 1.4 a in 32.310 apply to enzymes in Tables 5.2 & 5.3 in 32.311.

Yes. An exception was made for phytase in 2020 and GE forms can be used.

 

 

Thymol - Synthetic thyme oil

Can synthetic thymol (thyme oil) be used to prevent and treat hoof problems? (379)
Yes. Synthetic thyme oil (thymol) is permitted as it is included in Miscellaneous section of the "Animal Health Care Products and Production Aids" listings approved for use in livestock husbandry.

Yes. Thymol was added to Table 5.3 in 2020. If it is derived from botanical sources, the annotation in Table 5.3 “Botanical compounds” applies. If it synthetic (i.e., not derived from botanical sources), thymol may only be used in foot baths.

Bloat treatment

Is the use of poloxalene allowed as a bloat treatment for dairy animals? (492) - 18 August 2020

No. Poloxalene cannot be used  unless the requirements of 6.6.10 of CAN/CGSB-32.310 are met.This means that alternative solutions must be explored first. If these are ineffective, a veterinary pharmaceutical such as poloxalene can be used under the written authorization of a vet, but the withdrawal period for milk and meat must be 14 days or double the label requirement, whichever is longer. Note also that repeated use of poloxalene may result in an animal losing organic status for the rest of its life (see details in 6.6.10 e).

 

Propolis for health care

Can non-organic propolis and other bee products, except honey, be used as a livestock health care product? (496) - 18 August 2020

Yes. Non-organic propolis, pollen, royal jelly, beeswax and bee venom may be used as livestock health care products (Homeopathy and biotherapies, CAN/CGSB-32.311 Table 5.3). Honey though, if used for livestock health care, would have to be organic (Honey, CAN/CGSB-32.311 Table 5.3).

 

Permitted substances lists for preparation

Anti-caking agents for grated cheese

What anti-caking agents are listed in the PSL that can be used in grated organic cheese? (435, 235) - 19 Apr 2019
Currently none.


Magnesium carbonate as anti-caking agent

Can magnesium carbonate be used as an anti-caking agent in salt when used for food? (467.1) - 17 February 2020)
No. Magnesium carbonate may only be used as an anti-caking agent in non-standardized dry mixes (e.g., seasonings) used in meat products with 70-95% organic content. See Magnesium carbonate, PSL, Table 6.3.

Bone Char

Is the use of bone char allowed in the processing of organic sugar? (192)
No. Although bone char is a form of Activated charcoal, it is not allowed because it is not from plant sources as required in Table 6.5 of the PSL.

Cheese Wax

Can a coloured wax containing paraffin waxes (hydrocarbon or microcrystalline wax) and a colouring agent be used to coat organic cheese? (154)
Paraffin wax may be used to coat cheese if organic waxes, e.g., organic carnauba or organic beeswax, are not commercially available and the coating is non-edible and completely peelable. See Waxes, PSL Table 6.5. The paraffin cannot contain synthetic colours, preservatives, bactericides or fungicides. Microcrystalline wax is prohibited.

Fermentation-produced chymosin

If a cheese producer makes cheese made with fermentation-produced chymosin FPC, can it still be labelled certified organic? (280)
No. FPC is produced by fermentation processes using bacteria, fungi or yeast that have had bovine rennet-producing genes inserted into them. This means FPC is a product of genetic engineering, which is prohibited for use in organic production (1.4 a) and 3.27 of 32.310.

 

Chymosin

For cheese production, can we use non-GE chymosin containing sodium benzoate ? (151)
Chymosin derived from genetically engineered micro-organisms is prohibited as per 1.4 a). Chymosin extracted from calf stomach linings is permitted and should be from an organic source when commercially available (refer to Enzymes, PSL, Tables 6.3 and 6.5).  As sodium benzoate is not listed on the PSL, allowed chymosin products may not be preserved with sodium benzoate. Additional requirements outlined in PSL 6.2.1 must be addressed if the production of allowed chymosin products involves the use of substrates or growth media.

Version 2020

Non-GE chymosin extracted from conventional calf stomach linings is permitted, providing an organic source is not commercially available. See Enzymes, PSL, Tables 6.3 and 6.5. Additional requirements outlined in 6.2.1 of PSL must be addressed if the production of allowed chymosin products involves the use of substrates or growth media. When the sodium benzoate acts as a preservative for the chymosin, it is classified as a non-agricultural subpart having a functional effect on the ingredient but not on the final product, nor is it declared on the product label, it is permitted (9.1.2 of 310) as of the 2020 revision of the standard.

 

Use of desiccants

Are silica gel pouches in containers of organic spices permitted? (439) - 19 Apr 2019

Yes. Silica desiccants, which includes silica gel pouches, may be used as silica, that is silicon dioxide, is listed in 6.5 with no restriction (except for maple products). Because the silica gel packs will be in direct contact with food, they are expected to be food grade as are packaging (8.1.6, 32.310) and other food-contact surfaces (8.1.1, 32.310)

 

Dextrose

Can Dextrose be used as a flavouring agent in organic products? (236)
Yes. Organic dextrose may be used as a flavouring agent in organic production.

 

Carriers

Can permitted substances contain carriers? (376)
Yes, carriers present in permitted substances are subject to the requirements of "Extraction solvents, carriers and precipitation aids" unless they are organic ingredients.

Version 2020

As of the 2020 version of the standard, there is a separate “Carrier” listing with detailed restrictions as follows: “Carriers of non-agricultural origin may be used if listed on Tables 6.3, 6.4 or 6.5. Non-organic carriers of agricultural origin (such as wheat starch) may be used if ingredients or processing aids containing organic carriers are not commercially available". See Carriers, Table 6.3, PSL.

 

Gelatin – Alternatives

Are there acceptable alternatives to gelatin, such as seaweed and plant derived hypromellose? (118)
Plant substances such as seaweed extracts are acceptable alternatives to animal-derived gelatine. Hypromellose is a non-agricultural substance and therefore cannot be used because it is not specifically included in the PSL.

Indirect Processing Aids

Can products not listed on the PSL be used as “indirect processing aids”?  (e.g., – mineral oil on cutter/slicer blades) (61)
Indirect processing aids aka “incidental additives” cannot compromise organic integrity. In short, agricultural products not on the PSL can only be used as processing aids if they are organic. Non-agricultural products must be on the PSL. See Incidental additives, 3.30 (3.35), “” and 8.1.2 in 32.310.

Mineral Salts of Ascorbic Acid

Can the mineral salts of ascorbic acid (calcium ascorbate and sodium ascorbate) be used as food additives (Table 6.3)? (163)
No. Ascorbates are not the same substance as ascorbic acid, and therefore cannot be used.

Nitrates

Are nitrates forbidden in all processed foods? Is it possible to produce organic bacon with culture celery powder? (56, 153)
Nitrates such as those found in celery or chard extracts, juices or cultured powders may be used. Organic supplies must be used if commercially available. See Meat Curing Agents, Table 6.3, PSL.

 

Sodium citrate

If non-synthetic sodium citrate is not commercially available (or not available at all), can synthetic sodium citrate be used as a processing aid (table 6.3)? (405.1)
No. The annotation for sodium citrate in Table 6.3 does not include a commercial availability clause and clearly restricts the use to the non-synthetic form.


What type of manufacturing process would enable sodium citrate to be considered “non-synthetic” (and thus be compliant with PSL table 6.3)? (405.2)
Non-synthetic sodium citrates can be derived by biofermentation of some type of sugar, followed by filtration (physical) and separation by a non-chemical driven precipitation step. Sodium citrate could become prohibited if precipitated by a chemical agent even if the sugar and biofermenting agent are non-GE. The synthetic / non-synthetic status of various substances is planned for review during the 2020 revision of the COS.
Note: the SIC answered this question from the perspective of sodium citrate being listed in Table 6.3 which is titled "Ingredients Classified as Food Additives". Sodium citrate would need to be listed in Table 6.5 to be used as a processing aid.

Version 2020

There are no restrictions for the use of Sodium citrate in the 2020 version. So, QAs 405a and 405b will be deleted.

 

Stevia

Can stevia be used as a sweetener in organic products? Is non-organic stevia admissible under the 5% non-organic ingredients rule? (171)
Stevia is a plant product which can be used in the manufacture of organic products. As stevia is commercially available in organic form, this form must be used.

 

Starch

Beyond non-organic rice or waxy maize starches, which are listed as permitted by the 'Starch' listing in Table 6.4, would starches made from other sources (i.e., tapioca, potatoes, arrowroot, cassava, etc.) have to be certified as organic? (433) - 19 Apr 2019
Yes. Unless the specific starch is listed in the PSL then certified organic varieties are required.

 

Vitamin D

Is the use of vitamin D allowed for fluid milk products if it contains a preservative not listed on the PSL? (137)
Yes. Vitamin D sources containing non-listed preservatives are allowed in organic fluid milk products as the addition of Vitamin D to milk is required by law. Keep in mind that GE rules regarding the inclusion of substrates as outlined in 6.2.1 (32.311) do have to be addressed.

 

Vitamins and minerals added to organic products

Can vitamins and minerals be used to fortify organic products if not legally required? (500.1) - 18 Dec 2020
No. Organic products may not be voluntarily fortified with vitamins and minerals even if legally permitted. The only exceptions permitting voluntary fortification of organic products are a) dairy substitutes that are plant based, and b) fortification with ferrous sulphate when legally required or voluntarily if legally permitted. See Vitamins and mineral nutrients, PSL 6.4.

Do vitamins and minerals have to be certified organic to be used in organic products with 95% or above organic content? If yes, are commercial availability searches required? (500.2) - 18 Dec 2020
No. Vitamins and minerals are not agricultural products and hence are not certifiable to organic standards. Vitamins and Minerals used in organic products are ingredients classified as food additives and are listed in PSL 6.4. Per 9.2.1 a, ingredients classified as food additives are subject to substance listing annotations and restrictions specified in 6.2 of CAN/CGSB-32.311. As there are no organic commercial availability requirements listed in the annotation for Vitamins and Minerals in PSL 6.4, commercial availability is not applicable. However, there are restrictions in the listing annotations on when they may be used.See Vitamins and mineral nutrients, PSL 6.4.

 

Substrate for probiotics

Can a non-organic agricultural substance such as whey be used as the growing medium to manufacture probiotics used as an ingredient for food? (375.2)
Probiotics are covered by “Micro-organisms” in Table 6.4 and may contain residues of agricultural and biological substances as long as they are from non-genetically engineered sources (1.4 a). Probiotics may also contain non-agricultural subparts, such as carriers, or stabilizers that have a functional effect on the ingredient (the probiotic) but not on the final product in which the probiotic is being added (9.1.2 in 32.310).

 

Use of calcium chloride in beer making

May calcium chloride be used as an ingredient in beer making? (482)  - 29 April 2020
No. Calcium chloride as an ingredient is restricted to milk, fat, soybeans and fruit and vegetable products. See Table 6.3, Calcium chloride. However, water as an ingredient is outside the scope of the standard, if calcium chloride is used as a water treatment - before the water enters the production stream, it would be permitted.

 

Amidated, low-methoxyl pectin

Do food products containing amidated, low-methoxyl pectin qualify for use in products with ≥95% or 70-95% organic content? (357)
Yes, amidated versions are permitted as there are no constraints in the annotation for pectin in Table 6.3.

 

Cleaners, disinfectants and sanitizer

Conformity of a cleaning product

Manufacturers of concentrated sanitation products may provide Safety Data Sheets (SDSs) showing the ingredients of both the concentrated form and the diluted form (as used) on the same document, or they may provide two distinct SDSs - one specific to the concentrated form and another specific to the diluted (as used) form. Which SDS should be used to evaluate the conformity of a cleaning product to the PSL if the ingredient listings are different? (437) - 19 Apr 2019
If the operation is using a diluted version, either purchased or diluted on the site, the SDS for the diluted product is used for the evaluation compliance process.

 

Chlorine to disinfect poultry carcasses

Can chlorine be used to disinfect livestock carcasses? Are there alternative substances or processes? (254, 476) - 18 August 2020 - Revised 18 Dec 2020
Peracetic acid may be used in wash or rinse water in direct contact with plant and food including livestock and poultry carcasses (Table 7.3). Chlorinated water may also be used if chlorine level does not exceed maximum limits for safe drinking water (See Table 7.3 - Chlorine compounds). Alternative physical processes for disinfection such as steam, hot water or High-Pressure Processing (HPP) are allowed.

 

Assessment of detergent biodegradability

Does each component (e.g., surfactant, chelating agent, enzyme, and dispersant) of a detergent need to be assessed individually for its biodegradability? (444) - 21 June 2019
No. The purchased "detergent" product must be rated as biodegradable.

 

Substances for egg cleaning

Can substances listed in Table 7.4, with a removal event, be used to clean eggs? Is potable water required to wash eggs? (351)
Only substances listed in Table 7.3 as permitted for direct contact with organic products may be used to clean eggs. Water used for egg washing must be potable. See CFIA 'Shell Egg Manual' requirements. Take note, however, that organic vegetable oils, or other appropriate non-organic processing aids in PSL Tables 6.5 such as, e.g., silicon dioxide, could be used as defoaming agents during egg washing.

 

Non-food Contact Surface Cleaning

Do clauses 7.3 and 7.4 apply to the cleaning of: dedicated and non-dedicated spraying equipment; of irrigation systems; and non-food contact surfaces such as floors, windows, staff toilets etc.? (21.1, 10)
Tables 7.3 and 7.4 of the Permitted Substances Lists generally apply to products (7.3) and product contact surfaces (7.3 and 7.4). While the cleaners listed in these tables may be used in other applications, and are preferred, cleaning of non-product contact surfaces is not restricted to these cleaners. In the case of the use of substances not listed in 7.3 & 7.4, the operator is responsible for ensuring that no residual contamination occurs on land and crops.

Substances used as cleaners

Can substances listed as food additives (PSL 6.3) or processing aids (PSL 6.5), such as tartaric acid, be used as cleaners in facilities where organic product preparation takes place? (319)
If substances listed in 32.311 7.3 & 7.4 have been shown to be ineffective, substances listed in Tables 6.3 and 6.5, such as tartaric acid, or any other non-listed substance, can be used to clean organic product contact surfaces in facilities where organic product preparation occurs, as per criteria stated in 310 8.2.3.

 

Botanical compounds as cleaners

Can botanical compounds, such as essential oils, be used to clean organic products or organic product contact surfaces? (366)
Botanical compounds such as essential oils cannot be used to clean organic products because they are not listed in 32.311 Table 7.3. Botanical compounds such as essential oils may be used to clean organic product contact surfaces in accordance with 32.310 8.2.3, or if used as wetting agents (see 32.311 Table 7.4 Wetting agents).

Version 2020

Can essential oils be used to clean organic products or organic product contact surfaces? (366) 
Essential oils compliant to the restrictions described in the new Essential oils listing in Table 7.4 may be used to clean surfaces in contact with organic products. But they cannot be used to clean organic products as they are not listed in Table 7.3.

 

Annotation for surfactants and wetting agents

Can you clarify whether the annotation in "surfactants' and 'wetting agents" means that the user needs to document that the substance complies with the Detergents listing in 7.4 AND the Soaps listing in 7.4, or simply either one of them? (345)
The annotation 'See Table 7.4 Detergents; Soaps.' should be read with an "or" (soaps OR detergents). The nature of the product in which the surfactant or the wetting agent is an ingredient will determine which listing to use.

Version 2020

This QA will be deleted. Annotations relating to Surfactants and Wetting agents in Table 7.4 have been revised.

 

Surfactant, spreaders, stabilizers, foaming agents

Must formulants, such as surfactant, spreaders, stabilizers, foaming agents, contained in commercial cleaning products be listed on 7.3 and 7.4, or only the active ingredients?? (453) - 26 Sept 2019
When commercial cleaning products are used without a removal event on direct contact or on contact surfaces with organic products, all the ingredients listed on the Safety Data Sheets (SDS) and the cleaning product label, including any formulants, must be listed in PSL Table 7.3 or be chemicals used to treat drinking water, or serve as product stabilizers. When used on product contact surfaces followed by a removal event, only the ingredients on the SDS, including formulants, must be listed in Table 7.3 and/or 7.4.

 

Cleaning of dairy equipment

Is sodium phosphate tribasic dodecahydrate permitted for use as a cleaner, disinfectant and sanitizer on dairy equipment as a derivative of phosphoric acid? (493) - 18 August 2020
No. Cleaning substances, including derivatives, must be listed in Tables 7.3 or 7.4. (7.1.3 in CAN/CGSB-32.311, SIC Final Questions and answers -Q&A 453) unless the derogation in 8.2.3 of CAN/CGSB-32.310 is pertinent.

 

Colloidal silver

Can colloidal silver be used as a cleaning product for food contact surfaces? (274)
Use of colloidal silver as a cleaning product must comply with 8.2.3 and 1.4 of 32.310.

 

Neem oil and diatomaceous earth

Can neem oil (listed in Table 8.2) be permitted in direct contact with organic food products? (310)
Yes. While the title of 8.2 is "Facility pest management substances", there is no restriction on the use of diatomaceous earth, carbon dioxide or neem oil in relation to food contact post-harvest.

 

Peracetic Acid

Peracetic Acid (peroxyacetic acid) is listed on table 7.3 PSL. Are all forms of this substance allowed, regardless of method of production? (221)
Yes. There are no restrictions on the method of production in the annotation for peracetic acid

 

Peracetic acid containing synthetic (synthetic) acetic acid

Is peracetic acid that contains synthetic (synthetic) acetic acid permitted? (390)
Yes. Commercially, peracetic acid is produced by reacting synthetic (synthetic) acetic acid and hydrogen peroxide and residues of both reactants will more than likely be present. As there is no restriction in the peracetic annotation in PSL Table 7.3, peracetic acid products containing residual amounts of hydrogen peroxide and acetic acid are permitted for use in direct contact with organic products without a removal event.

 

Electrolysed water

Is electrolysed water allowed by the Canada Organic Standards? (290, 491) - 18 August 2020

Electrolysed water (which may contain hypochlorous acid as a byproduct of either electrolysis or from the dissolution of chlorine compounds in water) is permitted for all production types except maple syrup. For maple syrup refer to 7.2 of CAN/CGSB-32.310.

Version 2020

Electrolyzed water is now mentioned under Chlorine compounds, Tables 7.3, 7.4, PSL: 'c) hypochlorous acid generated via electrolyzed water'.

 

Use of detergents to wash clothing of employees

Must laundry detergents used to wash clothing of employees comply with the Canadian Organic Standards when they work in an operation manufacturing organic products? (489) 18 August 2020
When clothing is in direct contact with organic food intentionally (i.e., fabric gloves), laundry detergents must comply with clause 8.2 of CAN/CGSB-32.310. Otherwise, the clothing is not considered a food contact surface, and is outside the scope of the standard.

 

Use of piperonyl butoxide

Are pyrethrin products containing piperonyl butoxide as a synergist permitted for use in organic facility pest management programs? The annotation in 8.2 of CAN/CGSB-32.311 specifically prohibits piperonyl butoxide as a carrier. (490) - 18 August 2020
No. The annotation for pyrethrin is to prohibit its use if it contains piperonyl butoxide. When used as a synergist, piperonyl butoxide is considered an active ingredient under the Pest Management Regulatory Agency and would need to be listed in CAN/CGSB-32.311 to be acceptable in organic production.

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