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					Hi Daniel, Great questions – see below for some answers. I’ll look forward to continuing the conversation next week. Thanks, Joe How does plastic packaging affect organics, if at all? Are there any standards for the packaging of organic products? The National Organic Standards do not deal with packaging at all; organic products are allowed to be packaged using any material approved by the FDA as a food contact surface/substance, which includes most plastic packaging materials. What actions, if any, are taken by QAI when a WFM store is not compliant with organic standards? Following an inspection, the inspector sends his or her finding to a technical reviewer at QAI. That reviewer than looks at each non compliance and assesses it’s severity. QAI then sends me a letter asking me to address each noncompliance within a specified period of time, and also address company wide anything they see as national trends (eg sanitation, pest control). See the attached letter (my response to QAI’s 2006 letter) as an example. In general, they require us to convince them that we’ve taken steps to correct any noncompliance and prevent them from occurring in the future. However, for particularly severe noncompliances, QAI’s action could be to suspend or revoke our certification. A bad enough noncompliance at the store level could result in the suspension or revocation of our national certification. Can TMs receive a copy of the USDA Organic Can Use/Cannot Use list? This list is mentioned in several of our training materials, but I've never actually seen it and don't know where it is located. For example, our materials mention that 5% non-organic ingredients of 95% organic products must be allowed by the USDA ingredient list. Also, what is the official title of this list? I've only seen descriptions of the list and the lists purpose, I'm not sure what the list is actually referred to as. The “National List” of allowed prohibited substances is actually three lists: one for crops, one for livestock, and one for processing foods. For each category there is a list of synthetics allowed (to use a synthetic material it must be specifically approved by the National Organic Standards Board) and natural substances prohibited (harmful natural substances such as arsenic and strychnine). I’ve attached that section of the list – you’ll find crops in 205.601 and 602, livestock in 603 and 604, and processing in 605 and 606. Is QAI a non-profit? Also, do farmers and production facilities pay QAI to audit them? I'm assuming yes - the other question is - do farmers and facilities pay the travel expenses of QAI? We're wondering because TMs were curious about what happens when a location is very remote. Yes. QAI is a subsidiary of the non-profit NSF international. Farmers and production facilities pay QAI for auditing services, including travel expenses for the inspectors. As far as remote facilities, QAI uses a network of inspectors based in various parts of the country, and other certifiers use similar networks, so there’s almost always an inspector within a few hours drive of a facility. When discussing the labeling of organic products, our Grocery team told me that they don't see very many labels with 100% organic. I walked through our aisles, and I noticed that seemed

true. Do you know if this is just because there aren't many 100% organic products on the market, or because companies deliberately choose not to use the label "100% Organic," and choose instead to just use "Organic"?

There are very few 100% Organic products on the market because it’s extremely difficult to make a processed product that only contains organic agricultural ingredients. Products labeled 100% organic can only contain organic agricultural ingredients – crops grown organically – and nothing else. They also cannot use any processing aids (materials used in trace amounts in production, such as line lubricants and sanitizers), which is prohibitive for most manufacturers.
What does WFM do when a store fails an organic audit or receives a poor score? I work with the store and regional leadership to help understand the noncompliance, retrain whomever might be responsible for it and develop an action plan to prevent it’s recurrence. We then monitor to ensure the store stays in compliance. Because this is a regulatory program related to compliance with a federal law, we treat it like any other food safety, safety or regulatory compliance issue. What does it mean when we say that organic life stock must be allowed to "fulfill natural behaviors"? Some of the tenets regarding organic husbandry seem ambiguous. Is there more specific information that I can share with our TMs?

This section of the standard is admittedly ambiguous. The point was to make it adaptable to the needs of different species of animal, who have different needs in terms of diet, space per animal, access to the outdoors, etc. Each certifier looks at each operation uniquely, assessing it’s compliance with the spirit of the standard. Keep in mind that organic animals are only fed organic food, never given antibiotics or hormones, and restricted to veterinary drugs and supplements on the national list. WFM, and a number of other industry members feel that the standards need to more clearly articulate certain livestock requirements, including access to pasture for dairy animals. Following our testimony to the USDA last year, the agency is developing a tighter regulation in this area.
Are organic audits announced to stores before hand, or are they surprise visits? Our annual audits from QAI are announced ahead of time, but QAI, the USDA and the RI Dept of Agriculture have the right to enter our stores at any time and enforce the national organic standards.

Joe Dickson Quality Standards & Organic Programs Coordinator Whole Foods Market ◊ 550 Bowie Street ◊ Austin, TX 78703 O: 512 542 0388 ◊ F: 512 482 7388
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From: Daniel Kauwe (NA PRO) Sent: Sunday, April 08, 2007 9:31 AM To: Joe Dickson (CE CEN) Subject: Organics Questions Hi Joe, Our store recently did a store-wide Good Organics training. During the sessions, TMs had a number of questions that I couldn't answer, and I thought you'd be the right person to ask. On a side, but related note, I understand that you'll be here in Providence on Friday, and I'm planning on attending your training session on Friday 4/13 - so if it's more convenient to answer these questions in person, please let me know. === Questions === How does plastic packaging affect organics, if at all? Are there any standards for the packaging of organic products? What actions, if any, are taken by QAI when a WFM store is not compliant with organic standards? Can TMs receive a copy of the USDA Organic Can Use/Cannot Use list? This list is mentioned in several of our training materials, but I've never actually seen it and don't know where it is located. For example, our materials mention that 5% non-organic ingredients of 95% organic products must be allowed by the USDA ingredient list. Also, what is the official title of this list? I've only seen descriptions of the list and the lists purpose, I'm not sure what the list is actually referred to as. Is QAI a non-profit? Also, do farmers and production facilities pay QAI to audit them? I'm assuming yes - the other question is - do farmers and facilities pay the travel expenses of QAI? We're wondering because TMs were curious about what happens when a location is very remote. When discussing the labeling of organic products, our Grocery team told me that they don't see very many labels with 100% organic. I walked through our aisles, and I noticed that seemed true. Do you know if this is just because there aren't many 100% organic products on the market, or because companies deliberately choose not to use the label "100% Organic," and choose instead to just use "Organic"? What does WFM do when a store fails an organic audit or receives a poor score? What does it mean when we say that organic life stock must be allowed to "fulfill natural behaviors"? Some of the tenets regarding organic husbandry seem ambiguous. Is there more specific information that I can share with our TMs?

Are organic audits announced to stores before hand, or are they surprise visits?

Thanks, Daniel Kauwe In Store Educator - Providence 261 Waterman St Providence, RI 02906 401-272-1690 401-272-0280 Fax


				
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