CERES Policy

Sampling Frequency for Pesticide Testing

No	Issue	Text
1	Aims	Establish clear rules for pesticide testing of organic food and crops, to safeguard equal treatment of all operators and increase consumer trust in organic products.
2	Background	Frequent pesticide testing by certification bodies is, on the one hand, expected by state authorities, handlers, retailers, and consumers. On the other hand, it may be a disadvantage for the respective certifier, because it causes considerable costs.
3	Normative framework	EU-regulation Annex III.5: … The inspection body or authority may take samples for testing of products not authorised under this Regulation or for checking production techniques not in conformity with this Regulation. Samples may also be taken and analysed for detecting possible contamination by unauthorised products. However, such analysis must be carried out where the use of unauthorised products is suspected. Annex III.10: When requested by the inspection body or authority, the operator shall submit the results of its own voluntary inspection and sampling programmes. NOP § 205.403 (c) The on-site inspection of an operation must verify: (3) That prohibited substances have not been and are not being applied to the operation through means which, at the discretion of the certifying agent, may include the collection and testing of soil; water; waste; seeds; plant tissue; and plant, animal, and processed products samples. § 205.504 A private or State entity seeking accreditation as a certifying agent must submit … (6) A copy of the procedures to be used for sampling and residue testing pursuant to § 205.670.
4	Terms, clarifications, ab­breviations	Pesticides: all plant protection products not listed in Annex II (EU-regulation), the National List (NOP) or Notification 59 (JAS).
5	Policy
5.1	General determination Contrary to some media or consumers, we do not consider pesticide testing the most important tool for controlling organic operations. Nevertheless, in order to establish a high quality level, we will do sampling for pesticide testing with a relatively high frequency. Even more than helping to detect real infringements, this policy will help to avoid fraud by operators.
5.2	Normal situation In all cases except those mentioned in 5.3, samples for pesticide testing will be taken only in case of suspicion.
5.3	Sampling frequency for special crops, according to risk The following figures stand for percentages of growers or fields in a country or region, where sam­ples should been taken within one growing season.
Crop			Sampling of leaves or other adequate plant material		Sampling of harvested product
			> 40 %	> 20 %	> 40 %	> 20 %
High risk crops - where in the final product residues are often not detectable (e.g. Bananas; Cotton)			x
Fruits and vegetables in gen­eral (with the exception of tra­ditional low input "Streuobst" fruit orchards)				x
Fruits and vegetables from ar­eas where intensive pesticide spraying is common				x		x
Greenhouse cucumbers			x			x
Potatoes				x
Products from regions with very high pesticide drift risk, but low risk of application by organic farmers					x
Tomatoes			x			x
5.4	Adaptation to real situation: In case that considerable residues are found with high frequency, the above-mentioned percent­ages shall be increased. If no or only very low residues are found, percentages can be decreased, at least during a certain period.
5.5	Sampling by the operator In case of operators with a good and reliable quality management, where the operator takes a suffi­cient number of samples, using reliable procedures, CERES needs not do any sampling on its own. The operator must give CERES access to sampling protocols and testing results. CERES will ac­cept these results only in case of testing by an accredited or otherwise reliable laboratory.
5.6	Payment Under EU-regulation and JAS, the operator has to pay for sampling and testing. To avoid inade­quately high costs for particular operators, CERES will take care that at similar operations with similar risks, the same number of samples is taken throughout the years. Under NOP, CERES will carry the cost for sampling and testing. To cover these costs, the overall flat fee for NOP certification has to be somewhat higher than for EU or JAS certification.
5.7	Release of the test results The test results are evaluated by the responsible technical staff who will take appropriate action in case of necessity. A copy of the test results is always forwarded to the operator. The test results are filed in a separate section of the operators folder at the CERES office.
6	Related documents	•     CERES Policy on Pesticide Residue Interpretation •     Sampling and Laboratories (Introduction) •     Procedure for Field Sampling (Work Instruction) •     Procedure for Post Harvest Sampling (Work Instruction) •     Sampling Protocol (Form)