Comments and Recommendations on the Safe Foods for Canadians Regulations

Transcription

1 Comments and Recommendations on the Safe Foods for Canadians Regulations Submitted on behalf of: Atlantic Canadian Organic Regional Network Certified Organic Associations of BC Canadian Organic Growers Growers of Organic Food Yukon Manitoba Organic Alliance Organic Federation of Canada Organic Alberta PEI Certified Organic Producers Co- Operative SaskOrganics To: The Canadian Food Inspection Agency April 21, 2017

2 Table of Contents About the Organic Federation of Canada and Canadian Organic Growers 3 1. The Organic Products Regulations and the Safe Food for Canadians Regulations 3 2. Traceability 6 3. Licensing and the Preventive Control Plans 7 4. Clarity of Definitions 9 5. Certification of Conveyance and Storage Certification of Slaughtering Activities Time of Initial Application Expiry of the Organic Certificate Percentage of Organic Ingredients listed on the Organic Certificate The Small Operator Certification Issue Improvements to the Canada Organic Regime Further Consultation and Implementation Period 19 Page 2 of 20

3 About the Organic Federation of Canada The Organic Federation of Canada (OFC) was created in It is a national association composed of 10 provincial/territorial associations: Certified Organic Associations of British Columbia (COABC), Organic Alberta, SaskOrganics, Manitoba Organic Alliance, Organic Council of Ontario, Union des producteurs agricoles, Atlantic Canadian Organic Regional Network (ACORN) and their Nova Scotia and New Brunswick Working Groups, Prince-Edward-Island Certified Organic Producers Co-operative, Growers of Organic Food in the Yukon (GOOFY). Members support the operations and mandate of the Organic Federation of Canada, which include: Maintenance of the Canadian Organic Standards under the supervision of the Canadian General Standards Board (CGSB); Management of the Canadian Standards Interpretation Committee (SIC); Management of the Organic Science Cluster (OSC), an industry-supported research and development endeavor in cooperation with the Organic Agriculture Centre of Canada at Dalhousie University; Communication in both official languages: the OFC is a bilingual association that has developed a communications program to inform organic operators across the country about research, organic standards and other organic issues. About Canadian Organic Growers Canadian Organic Growers (COG) is a registered national charity working to create a sustainable farming system across the country and has been in existence since We are an experienced leader in organic education, policy work and sector development at the local and national level. Our educational services help farmers and gardeners produce fresh, nutritious food using the organic approach which is environmentally sound and commercially viable. Together with our partners in the farming, nonprofit and business communities, we promote the values, methods and integrity of organic production and help ensure the future of organic farming. Our members and supporters are farmers, gardeners, processors, retailers, researchers, certifiers and consumers who share a vision of a sustainable bioregionally-based organic food system. Our mission is to lead local and national communities towards sustainable organic stewardship of land, food and fibre while respecting nature, upholding social justice and protecting natural resources. Page 3 of 20

4 1. The Organic Products Regulations and the Safe Food for Canadians Regulations The Organic Products Regulations was established in 2009 through an industry-government partnership, which resulted in a robust regulatory framework upon which Canada s Organic Sector could succeed. The Canada Organic Office (COO) at the Canadian Food Inspection Agency (CFIA) enforced the Organic Products Regulations and worked closely with the organic industry to implement the Canada Organic Regime of organic standards CAN/CGSB & While at first a productive partnership, the organic sector s relationship with the CFIA has deteriorated in recent years as a result of administrative changes at the CFIA. The Canada Organic Office has been disbanded and monthly calls between the Certification Body Working Group and the CFIA have been cancelled indefinitely, leading to strained relationships and poor communication with organic stakeholders. Compounding this tension is the migration of the Organic Products Regulations as Part 14 of the Safe Food for Canadians Regulation. The Organic Products Regulations is not a food safety regulation and does not belong in the Safe Food for Canadians Regulations. Furthermore, in completing this migration, regulators have made substantial changes to organic regulations, some of which, if left unchanged, will undo the entire Canadian organic supply chain. How can an industry with so many benefits to Canada s environment, economy, and trade continue to thrive when it is being ignored and left to fall through regulatory cracks? Conversely, while relationships with the CFIA eroded, the organic industry has built strong ties with various groups at Agriculture and Agri-Food Canada (AAFC). This new relationship is as a result of strong governmental interest and participation on the Organic Value Chain Roundtable. Communication with AAFC has never been better and there is obvious and widespread departmental support for the development of Canada s organic sector; the fastest growing segment of Canada s Agricultural Sector. Since publishing the Safe Food for Canadians Regulations in the Canada Gazette, organic stakeholders have mobilized in a cross-canadian review of its impacts to the organic industry, with discussion of solutions to our challenges with both the SFCR and the CFIA. There is a strong belief within the organic sector that our once productive partnership with CFIA can be reconciled, but there needs to be equal interest from the CFIA for this to occur. Organic stakeholders recognize and appreciate the role of the CFIA as the central agency maintaining organic integrity and public trust through their enforcement of the Organic Products Regulations. However, Page 4 of 20

5 there is a firm view that the Organic Products Regulations is not a good fit for the Safe Food for Canadians Regulations in part because this integration limits market access by restricting the scope of organic certification to food, aquaculture, livestock feed, and seed. There is enormous market opportunity for organic certification of other agricultural products such as; textiles, Natural Health Products, pet food, personal care products, and marijuana; but these markets cannot be developed as long as the Organic Products Regulations is constrained by the Safe Food for Canadians Regulations. Furthermore, as long as market access is limited, other international organic programs such as the USDA National Organic Program, the EU Organic program, and the Global Organic Textile Standard will continue to benefit from our limitations by certifying and selling these additional types of organic commodities, bearing their organic logo, to Canadian consumers. Furthermore, as long as the term organic remains unregulated for these additional types of commodities in Canada, we open the door to fraudulent claims which harm public trust in organics. To stay globally competitive and realize the full potential of the Canadian organic opportunity, we urge the Government of Canada to work with organic stakeholders to overcome these departmental and regulatory hurdles in order to improve market access for Canadian Organics. On the Organic Products Regulations and the Safe Food for Canadians Regulations, we recommend: 1.1 Maintaining the Organic Products Regulations outside of the Safe Food for Canadians Regulations and migrating it to an appropriate act within the Department of Agriculture and Agri-Food Canada. 1.2 Working with organic stakeholders to codify a Canadian Organic Act within the Department of Agriculture and Agri-Food Canada, within which the Organic Products Regulations can be held and further expanded to include the certification of additional commodities such as; textiles, Natural Health Products, pet food, personal care products, and marijuana. 1.3 Re-establishing the Canadian Organic Office at the Canadian Food Inspection Agency. 1.4 Repairing relationships with organic stakeholders through greater participation of the Canadian Food Inspection Agency on the Organic Value Chain Roundtable and at other organic industry gatherings. Page 5 of 20

6 2. Traceability Certified organic operators are pioneers in food traceability. The Canada Organic Regime, implemented in 2009, already ensures the traceability of the products that are certified under a third party verification system. All food products bearing the organic label in Canada have to be sold with the organic certificate that describes where they have been grown or prepared, validating that the cultivation/preparation processes are compliant with the Canadian Organic Standards (CAN CGSB and ). The Canadian Organic Standards enforce traceability through strict record keeping (clauses 4.4.2, b) and of CAN/CGSB ). Organic certificates have to accompany all organic ingredients used in the preparation of multi-ingredient food. Traceability is also ensured under the Canadian Organic Standards as operators have to prevent commingling and exposure of organic products to prohibited substances. However, more can be done to enhance traceability and increase transparency, such as the creation of a public database of organic operators. On traceability, we recommend that: 2.1 The Canadian government reinforces traceability of organic foods by creating and maintaining a public database of certified operators under the Canada Organic Regime. Page 6 of 20

7 3. Licensing and the Preventive Control Plans Producing safe food for Canadians is a priority for all organic operators across the country. Organics is one of the most heavily regulated industries in Canada and at every step along the way, food safety is of utmost importance. While the Safe Food for Canadians Regulations has good intentions, the imposition of additional, and seemingly overwhelming regulations will hinder the profitability of numerous small and emerging farm businesses, organic or otherwise. Those least prepared for these regulations will be small, low-risk, fruit and vegetable producers who sell domestically across provincial borders. Implementation of the SFCR will mean that farm businesses selling inter-provincially and grossing at a minimum $30,000 in annual sales will be required to develop and maintain a food safety preventative control plan (PCP). The estimated average budget for this annual PCP as stated by the CFIA is $6,370 which could mean that some producers are spending upwards of 1/5 th of their gross revenue on a PCP every year. The math on this makes no sense and the imposition of this expense will have catastrophic financial impacts on producers and will create another barrier to farming. The majority of farmers who operate at this smaller scale of gross revenue are primarily direct marketers; selling to consumers at markets, through community supported agriculture programs and at road stands and so traceability is inherent to their operations. Should a food safety issue arise with the fruit or vegetable purchased, consumers would know from which farm they were produced because they were a direct purchase. Safe Food for Canadians Regulations - Extracts 84 (1) A licence holder must prepare, keep and maintain a written preventive control plan that meets the requirements of section 87 for any activity that they conduct in respect of a food or food animal that is identified in their licence. So, what is the food safety justification for this regulatory and financial burden? Our internal review of all the food safety recalls on the CFIA website indicated that there were 840 food recalls (sometimes multiple recalls pertaining to one issue) from January 2013 to Feb Out of this total of food safety recalls, only 22 are for fresh fruit and vegetable, and 21 of these cases are either clearly imported or international in scope. Only 1 recall was clearly from Canadian farms and this was the needle issue in potatoes from PEI. There were no injuries or deaths as a result. Fresh fruit and vegetable imports into Canada have doubled from 2006 to 2015 demonstrating that Canadian domestic producers are already facing competitive challenges. The Safe Food for Canadians Page 7 of 20

8 Regulations is punitive towards fruit and vegetable producers and will further their competitive disadvantage among the imported foods that are the bulk cause of Canada s food safety problems. On licensing and preventative control plans, we recommend that: 3.1 Exploring the cost-effectiveness of the organic certification processing also including an audit of the preventive control plan (PCP) for certified organic operators who need to implement a PCP (for interprovincial trade or import/export); the PCP would be incorporated in their organic plan. This will reduce the cost and level of bureaucracy. 3.2 Exempting fruit and vegetable Direct Marketers (defined as farmers selling directly to consumers) from the licensing and preventive control plan requirements of the Safe Food for Canadians Regulations regardless of their gross revenue. 3.3 Raising the gross revenue threshold level for licensing and preventive control plan requirements to a minimum of $1,000,000 for operators who only sell within Canada. Page 8 of 20

9 4. Clarity of Definitions Part 14 of the Safe Food for Canadians Regulations has a lack of clear definitions of the various activities requiring certification. In this version of the gazetted SFCR text, the term preparation no longer aligns with the definition found in the Canadian Organic Standards (clause 3 of CAN/CGSB ) and which is a term used to align handling and processing standards. There is a confusing disconnect in definitions found between the current version of the Safe Food for Canadians Regulations and the Canadian Organic Standards that needs to be resolved. Safe Food for Canadians Regulations Extracts Definitions 338 The following definitions apply in this Part. various activities means manufacturing, processing, treating, handling, slaughtering, producing, storing, packaging, labelling and conveying. With the inclusion of the organic aquaculture standard (CAN/CGSB ) in Part 14 of the SFCR, it is important to clarify that fruits and vegetables will continue to be excluded from the definition of aquatic plants. Soil is a foundational element of organic farming and fruit and vegetables grown without soil cannot be labeled as organic or certified to any Canadian Organic Standard. On the clarity of definitions, we recommend that: 4.1 The definitions of the specific various activities in clause 338 be added to the Safe Food for Canadians Regulations. 4.2 The term preparation be referenced in Part 14, section 338 of the Safe Food for Canadians Regulations with a definition that aligns with Canadian Organic Standards, clause 3 of CAN/CGSB Where there is overlap in terminology between Part 14 of the Safe Foods for Canadians Regulations and the Canadian Organic Standards (CAN/CGSB ), definitions in the Safe Food for Canadians Regulations should reference definitions found in the Canadian Organic Standards (CAN/CGSB Clause 3) 4.4 Maintain the exclusion of fruits and vegetables from the definition of aquatic plants. Page 9 of 20

10 5. Certification of Conveyance and Storage In migrating the Organic Products Regulations into Part 14 of the Safe Food for Canadians Regulations, storing and conveying have been added to the various activities that require service providers to hold an organic certification. Safe Food for Canadians Regulations Extracts Definitions 338 The following definitions apply in this Part. various activities means manufacturing, processing, treating, handling, slaughtering, producing, storing, packaging, labelling and conveying. Conduct of activities 340 The various activities may only be conducted in respect of an organic product by a person who holds a certification that is granted under section 342 or 345 in respect of the activities and must be conducted in accordance with (a) in the case of a food commodity other than a seaweed, aquatic plant or aquaculture animal, CAN/CGSB ; and (b) in the case of a seaweed, aquatic plant or aquaculture animal, CAN/CGSB Application 344 (1) A person who wishes to conduct an activity, among the various activities, in respect of an organic product and who does not hold a certification that is granted under section 342 must apply to a certification body for certification of the activity. The addition of these activities requiring certification would have significant negative impacts for the Canadian organic sector. Canadian warehouses and transportation companies handle a large variety of products (organic and otherwise) and there are not sufficient market incentives to force a specialized certification for storing and transporting a single type of product such as organics. This requirement for certification will create unnecessary logistical burdens for the organic value chain, increase the price of organic products, constrain market development and further the competitive Page 10 of 20

11 disadvantage of Canadian organic operators. Organic products packed and labeled by a certified operation are at a low risk of having their organic integrity compromised during storage and transportation. Storage companies must submit an attestation of compliance to the organic operation that neither their pest management nor their sanitation practices will compromise the organic integrity of the packed goods and that facility pest management practices meet the requirements of 8.3 of CAN/CGSB Similarly, transportation companies submit an attestation of compliance with 8.4 of CAN/CGSB when moving packed organic products from one certified organic operator to the next. On storage and conveyance in Part 14, we recommend: 5.1 Storage and conveyance of packaged organic products be removed from certification requirement in the Safe Food for Canadians Regulations as it would penalize Canadian operators and create enormous financial and logistical burdens for the Canadian organic industry. 5.2 Storage and conveyance of unpackaged organic products should be conducted in compliance with the Canadian Organic Standards. Attestations of compliance by these service providers are integrated into the organic plan of the operator that holds the organic certificate. Integrity of the organic product is ensured by the procedures established in the organic plan of the holder of the certificate. Reference CAN/CGSB clauses 5, 6, 7, and 8. Page 11 of 20

12 6. Certification of Slaughtering Activities Slaughtering has also been added to the various activities that need to be conducted by an operator or a third party that holds a certification for that activity in the Safe Food for Canadians Regulations, clause 340. Safe Food for Canadians Regulations Extracts Definitions 338 The following definitions apply in this Part. various activities means manufacturing, processing, treating, handling, slaughtering, producing, storing, packaging, labelling and conveying. Conduct of activities 340 The various activities may only be conducted in respect of an organic product by a person who holds a certification that is granted under section 342 or 345 in respect of the activities and must be conducted in accordance with (b) in the case of a food commodity other than a seaweed, aquatic plant or aquaculture animal, CAN/CGSB ; and (b) in the case of a seaweed, aquatic plant or aquaculture animal, CAN/CGSB Application 344 (1) A person who wishes to conduct an activity, among the various activities, in respect of an organic product and who does not hold a certification that is granted under section 342 must apply to a certification body for certification of the activity. Imposing the certification of slaughterhouses will have a disastrous impact on the organic livestock industry and supply chain. There is already a shortage of slaughtering facilities and adding the requirement of certification will compound this supply issue and lead to an increase in the price of organic meat products. Many slaughterhouses only process organic meat a few days out of a year, so there is not sufficient demand for organic processing to incent slaughterhouses to seek organic certification. There has already been a failed attempt to require the certification of slaughtering Page 12 of 20

13 facilities in Canada; during that time, due to a lack of incentives, many facilities made no attempt to certify unless the cost of doing so was paid for by a third party, such as an organic meat marketer. The organic integrity of slaughter stock and livestock products should continue to be maintained in accordance with the requirements set out in clauses 6, 8 & 9 of CAN/CGSB Attestations are currently being used by slaughterhouses and submitted to organic operators to confirm that they are meeting the requirements of the standards. Should the CFIA want to increase the legal accountability of slaughterhouses, they need only go so far as requiring an affidavit of compliance with the organic standards to replace the current system of attestations. Affidavits bear more legal weight than an attestation and are made under oath in the presence of a court official. On the activity of slaughtering in Part 14, we recommend: 6.1 Maintaining clause 19 of the Organic Products Regulations which ensures that slaughtering shall be conducted in accordance with the requirements set out in CAN/CGSB clauses 6, 8 and 9, in order to ensure the organic integrity of the livestock or product. 6.2 Replacing the requirement of attestations for slaughterhouses with affidavits of compliance with clauses 6, 8 and 9 of CAN/CGSB Should slaughterhouses be maintained as an activity requiring certification (against the recommendations of our organization) there should be extensive consultation with the slaughterhouses and organic stakeholders to determine an appropriate implementation period of this requirement. Page 13 of 20

14 7. Time of Initial Application The notion of a 15-month pre-application or waiting period between initial applications and initial marketing for certain products (see SFCR extract below) creates confusion, delays the transition period and limits market access. A 12-month application period provides sufficient time to validate that the operator complies with the Canadian Organic Standards (CAN/CGSB and ). Safe Food for Canadians Regulations Extracts Part (3) Time of Initial Application In the case of an initial application for the organic certification of a food commodity, the application must be filed within 12 months before the day on which the food commodity is expected to be sold or, in the case of the following food commodities, at least 15 months before that day: (a) maple products; b) field crops or crops that are grown in greenhouses with an in-ground permanent soil system; (c) uncultivated seaweeds and aquatic plants; and (d) aquaculture products with a production cycle of more than 12 months. On the time of initial application, we recommend: 7.1 The requirement of a 15-month pre-application or waiting period between initial applications and marketing products should be replaced with a 12 month pre-application period. Page 14 of 20

15 8. Expiry of the Organic Certificate Clause 342 of the Safe Food for Canadians Regulations, will institute a 12-month expiry date on organic certificates even if the activity and product remains compliant with the Canadian Organic Standards (CAN/CGSB & ). The proposed expiry date applies even if the operator is in the process of renewing their certificate, which they are required to do on an annual basis. The introduction of an expiry date on organic certificates will create a frustrating administrative burden for certification bodies and organic operators and will do nothing to serve the organic industry. It will also create confusion because products bearing an organic claim will remain in the market place beyond the expiry of their certificates. Safe Foods for Canadians Regulations - Extract 342 Period of validity (3) The organic certification of a food commodity is valid for 12 months beginning on the day on which it is granted under subsection (1). On the expiry of the organic certificate, we recommend that: 8.1 The organic certificate, once issued, shall remain valid, unless suspended or revoked by the certification body or surrendered by the operation. To remain valid, the holder of the certification must apply annually to the certification body for continued certification. The product and activity listings will need to be updated by the certification body on an annual basis. The certification body may suspend or revoke the certificate if the application is not submitted within the specified time frame. Page 15 of 20

16 9. Percentage of Organic Ingredients listed on the Organic Certificate Clause 2, Section 342 of the Safe Food for Canadians Regulations, requires that the organic certificate declare the exact percentage of organic content in multi-ingredient products on the organic certificate. Safe Food for Canadians Regulations - Extracts Clause 342 Certificate (2) The certification body must provide the applicant with a certificate that confirms the organic certification of the food commodity and that indicates whether CAN/CGSB or CAN/CGSB is applicable, the period of validity referred to in subsection (3) and, in the case of a multi-ingredient food commodity, the percentage of its contents that are organic products. The requirement to list the exact percentage of contents that are organic products in a multiingredient organic food commodity is inconsistent with current practices in Canada and among our current and potential trading partners. Currently, organic certificates issued in Canada need only indicate whether the multi-ingredient commodity falls in one of the two categories as outlined in the Canadian Organic Standards (CAN/CGSB ) organic (95% or more) or 70-95% organic content. This requirement works because there are instances where, depending on the availability of organic ingredients, a multi-ingredient product may vary in its organic content from one batch to the next. Because of the potential for organic ingredient percentages to vary at the time of processing, it is necessary to maintain the status quo, which allows more flexibility in reporting the percentage of organic ingredients and reflects the reality of sourcing scarce organic ingredients. On the percentage of organic ingredients listed on the organic certificate, we recommend that: 9.1 The status quo be maintained, which requires the organic certificate to list which category the multi-ingredient organic food commodity belongs - organic (95% or more) or 70-95% organic content. Page 16 of 20

17 10. The Small Operator Certification Issue The percentage of gross revenue spent on organic certification is greater for small operators than it is for large operators due to the overall complexity of smaller operations and the often diverse and numerous commodities being produced. Certification applications from small operators are sometimes denied by certification bodies because of their reluctance to certify small yet complex operations. It is obvious that the Canadian Organic Regime, as it is currently constituted, is not compatible with small organic farm operator certification. The net impact of imposing a certification system designed for large and often sophisticated operators, on small farms will force them out of the organic sector and discourages new farmers from entering the organic marketplace. On small operator certification, the we recommend that: 10.1 The Canada Organic Regime reflect the cost and the complexity of small-scale organic operations and develop a risk-based certification that lessens the financial impact of certification This program would include inspections that occur every third year as opposed to annual on-site verification. This will effectively reduce the annual cost of certification by an estimated 40%, without a significant risk to organic integrity The Canadian government establish a National Canadian organic certification cost share program to offset part of the cost for certification. The USDA National Organic Program can be looked to as an example. Page 17 of 20

18 11. Improvements to the Canada Organic Regime Under the Canada Organic Regime, the certification body holds the ultimate authority: the certification body inspects the operation, verifies compliance with the Canadian Organic Standards (CAN/CGSB & ) and delivers the organic certificate to the applicant. There are currently 19 certification bodies operating in Canada according to the CFIA website. There are accounts from the organic industry of serious discrepancies in the interpretation of the Canada Organic Regime by the various certification bodies and in the variance of oversight of operators. Examples include, producers who are issued a non-compliance for a practice by their certification body, while a producer certified by a different certification body is not issued a noncompliance for the same practice. This lack of uniformity in the application of the Canada Organic Regime erodes operator confidence in our national framework and the integrity of the Canada Organic Logo. What is also missing from the Canada Organic Regime is a firm cancellation period, whereby an operator with a serious non-compliance constituting food fraud, is prevented from re-applying for organic certification with another certification body. A necessary complement to this fraud policy would be a clear appeal process for operators who feel they have been unjustly issued a noncompliance and/or accused of food fraud. On improvements to the Canada Organic Regime, we recommend: 11.1 Mandatory annual trainings for certification bodies and their verification officers provided by the Canadian Food Inspection Agency and the Standards Interpretation Committee with a focus on interpretation of governing regulations and the Canadian Organic Standards Re-establishing the monthly meeting between the Canadian Food Inspection Agency and the Certification Body Working Group Imposition of a cancellation period of 5 years for fraudulent operators and application of fines and penalties proposed by the Safe Food for Canadians Regulations Developing and implementing an appeal process that would involve a special committee composed of certification bodies, organic operators, certification verification bodies and the Canadian Food Inspection Agency. Page 18 of 20

19 12. Further Consultation and Implementation Period Covered in this submission, are substantial recommendations for revisions to the Safe Food for Canadians Regulations. The impact of this regulation will be monumental for the Canadian Agricultural and Agri-food sector and we urge the CFIA to allow a second gazette and stakeholder consultation period before it is implemented. Furthermore, should any of the newly added activities requiring organic certification (conveyance, storage, slaughtering) stay in the regulation (clause 340), despite the strong opposition of organic stakeholders; it is prudent that the CFIA consult with the organic value chain stakeholders to determine an appropriate length of time to implement this requirement for certification likely a minimum of five years. On further consultation, we recommend: 1. A second gazette and stakeholder consultation period before full implementation of the Safe Food for Canadians Regulations. 2. Should any of the newly added activities requiring organic certification (conveyance, storage or slaughtering) stay in the regulation, regardless of the strong opposition of organic stakeholders, the CFIA must consult with the organic value chain stakeholders to determine an appropriate length of time to implement this requirement for certification likely a minimum of five years. Prepared and Submitted by: Ashley St Hilaire Nicole Boudreau Canadian Organic Growers Organic Federation of Canada Gloucester Ave , Grand boulevard Ottawa, ON K1C 0A4 Montreal, QC H4B 2X ashley@cog.ca info@organicfederation.ca Page 19 of 20

20 In Consultation with: Certified Organic Associations of British Columbia Organic Alberta SaskOrganics Manitoba Organic Alliance Organic Council of Ontario Union des producteurs agricoles Atlantic Canadian Organic Regional Network (ACORN) New-Brunswick Working Group/ACORN Prince-Edward-Island Certified Organic Producers Co-operative/ACORN Nova Scotia Working Group/ACORN Growers of Organic Food in the Yukon (GOOFY) Page 20 of 20