IFOAM EU SGOP proposal for a common EU residue

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IFOAM EU SGOP proposal for a common EU residue approach for
organic
Version: 09-11-10
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Proposals AB 31.5.2010
Discussed on SGOP meeting 5/6-10-10 and suggestions implemented
Comments by BNN implemented 11-10-10
Comments by BIOKAP partly implemented 15-10-10
Comments by EM – Synabio implemented 09-11-10
Comments by BIOKAP implemented 09-11-10
Strategy for this paper
IFOAM EU Sector Group Organic Processing (SGOP) discussed half a year this residue paper. At
the last meeting of 5-6 October it was decided to finalize the paper with the following purposes:
1. Discuss the paper in IFOAM EU E-board and the IFOAM EU board meeting of 18/19
November
2. Discuss the paper with EOCC boardmeeting (17 November), who decided in June 2010 to
bring forward their own EOCC residue policy paper .
3. After agreement within IFOAM Board, send the paper to the Commission (and spread to
national representatives of the SCOF).
4. Further discussion with Commission about the responsibility of the costs for analyzing
schemes (private/certification bodies) and costs for decertification in case of
contaminations where farmer/processor are not responsible.
5. Further discussions with EOCC (and Commission) to establish risk based inspections in
regard to residue contaminations, based on the internal /private quality procedures
‘based on systematic identification of critical processing steps’ (art 26.2 of ECC Reg
889/2008).
Introduction/Background
Organic farming is a production system where, instead of using chemical inputs, the farmer relies
on a broad range of activities which prevent problems from occurring. It is a system with an
absence of pesticides. However, the organic products are produced in a world where pesticides
are commonly used. Hence the risk of contamination with pesticides is always there, in the field,
during processing and during transport. As well as any sector, the organic sector is vulnerable for
fraud. So, beside the risk of contaminations, residues in organic certified crops might also be an
indication of fraud.
To secure the integrity and quality of organic certified agriculture, crops, ingredients and
processed food, residue-analyses has become the past 10 years more and more part of the
quality assurance of more and more private companies and certification and inspection bodies in
organic agriculture, trade and food-processing. Different monitoring programs, like the Okomonitoring from Baden-Würtemberg, BNN residumonitoring by BNN in Germany and BIOKAP
residue-monitoring by VBP in The Netherlands show the relevance of residu-monitoring: about
20% of organic crops show traces of residues, mostly below the action level of 10 ppb.Also in
Belgium, Italy and France more intensive residue-monitoring has been started by authorities
and/or private sector. More and more private companies in EU countries set their own private
standards, including very variable levels from on system to another. Since two years an unofficial
Task Force within the SCOF is formed to discuss individual residue-cases. It seems time to really
discuss the residue topic on EU-level with all stakeholders and come to a common approach.
With the rising of the daily practice of residue-analysis the organic sector in the EU faces new
fundamental questions in regard to the residue topic. Before the issues are mentioned it is
essential to keep in mind that organic legislation was originally mentioned as legislation for a
process based agriculture and food-processing system and mainly still is. In the discussion about
the need for harmonization in the residue-topic, we might make the mistake to transform a more
or less private developed action-level into a strict decertification level into the EU legislation. The
negative effects of this simple solution might be even worse than the dissatisfying disharmonized
situation of this moment. When the action-level would be transformed to decertification level, it
can easily happen that the residue-level replaces all other important aspects of organic
agriculture. Organic agriculture is a method, which cannot be replaced by the absence or
presence of residues under or above a certain level. On the other hand, a good harmonized
policy in the EU towards residue contaminations can help the organic sector to assure and
develop organic quality where ignorance is in stake, and prevent the downfall of organic integrity
where fraud is the case.
Aim of this paper
The aim of this paper is to show the need for a common residue-approach within the EU, which
is based on monitoring, research and exchange of information between stake-holders. The paper
is providing practical solutions for authorities, certification bodies and private sector to
implement the given EU Regulation in regard to ‘critical processing steps’, ‘organic integrity’ and
‘risk of contamination by unauthorised substances or products’.
The implementation of a common residue approach in all EU countries should furthermore lead
to the following benefits:
1. To prevent contaminations in general.
2. To prevent economical damage for all organic stake-holders in general.
3. To take decisions based on research knowledge and clear understanding.
4. To improve the communication and cooperation between private companies,
certification bodies and authorities of all EU memberstates about residue contaminations
and risk assessment.
5. Establish common understanding about the meaning of residue contaminations.
6. To further evaluate and specify the action-level based on monitoring and researchn
7. To structure both general communication about the organic approach towards residue
contaminations in general and crisis-management in case of calamities
EU legislation about residue contaminations
In accordance to article 26 2. of ECC reg. 889/2008 operators have to “..establish and update
appropriate procedures based on systematic identification of critical processing steps”. The aim
is to facilitate the organic integrity of the products (article 27 3.). In article 26 4. it is specified
that in regard to the above mentioned procedure the operator shall; “(a) take precautionary
measures to avoid the risk of contamination by unauthorised substances or products.”
The operators are obliged to have a strategy in place how to handle contaminates.
Further on the obligations given in article 91 1. of ECC reg. 889/2008 the operator has to take
actions if he “considers or suspects that a product is … not in compliance with organic production
roles,..”.
In order to fulfil this requirement a knowledge based action level for residues is an important
tool. Such an action level for residues is to establish on company level or in a shared quality
assurance system (obligation in article 26 2.-4.) as a strategy how to handle contamination with
pesticides. Above the action level a residue finding is a “suspicion” in accordance to article 91 1.
first line.
Issues
 There is no common accepted residue-approach for organic within the EU. Not between
the EU countries, not between the certifying bodies and not between the private sector.
 There is no common understanding within the EU about a common accepted action level.
BNN established 10 years ago the so called BNN action value of 10 ppb (with an
uncertainty factor of 50%, with recounting tot fresh products in case of dried or
concentrated products and some examples). The private BNN approach has been taken
over by the private BIOKAP monitoringsystem of VBP in the Netherlands. In France the
actions-levels are slightly different. Belgium is the only EU-country with a decertificationlevel: 1,5 x LOQ of MRL-values in EU directive for substances ( Directive 396/2005).
 Between EU-authorities there is no common approach in case of positive results above
the action-value. There is even no common approach towards the action-level itself (see
above). This results in market-disturbing situations for many organic companies who take
residue-monitoring.
 There seems to be a tendency the past years, starting in the private sector, taken over by
some certification bodies and even taken over by a special Task Force of the SCOF in
residue cases, to work with the action-level , which is established by BNN-Germany, and
adapted by BIOKAP-Netherlands.
 The operators establish their one internal concepts and strategies. The problem of
harmonization is still valid.
 Between the private labs there is no common residue-norm and some of them take the
freedom to disqualify ingredients as organic when a residue is found (under the actionlevel of BNN-BIOKAP).
 Between the customers of the private organic companies there is no common accepted
residue-norm: it varies from zero tolerance to absolute ignorance about the topic (and in
the last case when something is found to panic).
 Zero tolerance is not the way forward, as it leaves no openings for accidental
contaminations as well as huge risks for importers of organic produce in case of positive
findings.
 On the one hand the organic suppliers face customers that demand zero-tolerance on
residues while on the other they face certifiers that do not act when serious doubt has
risen.
 On the one hand the organic suppliers face national EU-authorities that stop importauthorizations and on the other hand national authorities that take no action at all.
 There is no common knowledge about the status of contamination with pesticides and of
metabolites as proof of active use, not even between respected labs and respected
scientific institutes and advisors related to the organic sector.
 At last, but certainly not at least there is the issue of economical damage that can occur
by findings of residue-contaminations above the action-level and (after research
perhaps) decertification of ingredients. Three important remarks has to be placed here:
1. the organic farmer is not well protected in case of decertification; 2. the importer is
not well protected, especially in case of import from third countries when goods are paid
already, and there is no agreement between certifiers in different countries; 3. In legal
sense decisions made by certification bodies and authorities must be ‘proportional’, that
means: must be reasonable in regard to the findings. In some cases it can be clear shown
that the last has not always been the case. Certification bodies and authorities must be
aware of the economical consequences of their measures and this is not always the case.
 The above mentioned examples show the lack of common approach and understanding
and leads to serious uncertainty and damage for private companies who really try to take
responsibility. Therefore it is necessary that a common approach for all EU-countries will
be established soon.
The common EU residue approach for organic
 An EU-wide harmonized residue approach is needed which is carried by the organic
sector itself, the certifiers and both local and EU authorities. It should be a case by case
approach and it is essential to have supervision and solve bottlenecks.
 The approach should be in a first step based on the BNN-BIOKAP approach:
- 0,01 mg/kg as action level (correction with 50% uncertainty, recounting for
concentrated/dried fruit products to fresh product and some exemptions, like
bromide).*
- In a second step the action levels must be further differentiated in accordance to
the findings and results of residue monitoring activities and scientific evidence.
The monitoring databases has to deliver new action levels for specific substances.
This differentiation should be dynamic and knowledge based. For harmonization
purposes new differentiated action-levels for individual substances should be
agreed on international level (both by private sector and certification bodies).
- When the action level is exceeded then the product is blocked (ECC Reg.
889/2008 article 91 1,) at the current part of the chain, and the procedure of
contra-analyses starts. When the contra-analyses is also positive, then the
procedure of research starts. This means that the certification body who certified
the crop has to do research about the background and cause of the
contamination. When the background of the contamination can be clarified
(scientifically) and the company/farmer who is responsible for the crop is not to
blame, the crop can be sold as organic and will not be decertified. When the
certifier is not able to proof satisfactory the background and cause of the
contamination, then the certifier in the EU country of import decertify the crop
and this decision should be taken over by a. the certification body in the country
of origin and b. all other EU-countries.
- The certification bodies of a. the country where the contamination is found (and
consumed) and b. the country of import in EU are in principle competent to judge
together whether the answers of the certification body who certified the crop is
consistent and trustworthy or not. If both EU-certifications bodies disagree, than
the below mentioned ‘commission of advice’ must decide.
- For all parties involved there should be an international EU-helpdesk of scientific
experts which is qualified to judge about a case, when there is no consensus
between stakeholders involved.
 Furthermore repeatedly findings (more then 3 times) of the same residue(s) in a product
from the same origin (organic project of supplier) but with levels below the action level
should also trigger doubt about the organic quality and lead to a serious investigation
into the cause of the repeatedly findings of the same residue from the same origin.
 A commission of advice should be part of the common residue appraoch. This
commission should consist of members of the sector (farming, trade, production),
certifiers and independent experts. This commission should advise on bigger cases (to
prevent both over and under reaction by authorities) as well as the direction of the
common policy.
* = The proposal to start with the BNN-BIOKAP approach, which is based on the EU Directive for
Baby Food <91/321/EEG>, is not based on scientific evidence. It is proposed for practical reasons,
because: 1. It is adapted by most initiatives from private sector, 2. it is dapated by several
certification bodies and 3. it is adapted/accepted by several national authorities. As a matter of
principle it is impossible to find a scientific proven level that distinguishes between
application and unintentional contamination. Pesticide residues have to be interpreted
individually because the degradation of pesticides depends on various factors. So an
action level cannot tell about the cause of the residue.
It can only give a hint as it is based on experience. The BNN orientation value is an
experience value. A decisive proof can only be found by investigation, this underlines the
importance of process control as a definition of organic.
Further investigation is needed
 Norms for findings of multi-residue contamination in one crop below the action-level.
 Seeds and sowing material needs further investigation in terms of the appropriate
action-level; this investigation has started at the Wageningen University in The
Netherlands.
 Further investigation is needed for the recounting factor for other dried products than
fruits.
 Further investigation is needed about the position of different metabolites in different
crops as accepted indication of the active use of active chemicals (see Annex A-3).
 Further specifications are needed for tolerance of residues of substances which are
allowed in organic agriculture.
Concerns
 A MRL policy within the organic legislation may not become fuel for the anti-organic
lobby: it can give the impression that organic sector starts to allow a certain level of
residues while the consumer who thinks he’s buying residue free; hence he gets
disappointed. The consumer who expects organic to be free from residues should hence
be educated or otherwise there is the risk of losing his interest as buyer.
 The implementation of the residue approach for organic should not reduce the control
by certifiers to lab testing. Organic may never be reduced to ‘free from residues’.
Conclusions
The need for a common EU residue approach is urgent for further harmonized development of
organic in EU. Maintaining integrity of organic, preventing contaminations, reduce economical
risks, implementation of risk based approach by certification bodies based on internal quality
systems by private companies, setting international standards for action-values and further
differentiation based on monitoring data and research, and off course meting consumer
expectations towards organic integrity and quality are the main objectifs to be realized. The
common approach proposed in this paper is based on what is actually happening in different
countries like Germany, The Netherlands, France and Italy. Only the approach in Belgium is quite
different at this moment.
We strongly underline that the proposed common approach is based on a case-by-case
approach. An international expert-group might be necessary to take decisions in difficult and/or
conflicting cases, or for further development and differentiation of the action-value for specific
substances.
Some points for further investigation and some concers has to be taken in account by the
implementation of this common EU approach.
ANNEX A-1: BIOKAP Residue Norms & Procedures
BIOKAP Norms and Procedures
Since November 2008 the Dutch Processing and Trading Association VBP, started the monitoring
program BIOKAP, in order to have better supervision and solve bottlenecks. Etc. etc
As VBP we established with Skal certification-body a residue-approach that is based on the BNN
approach: a norm of 10 ppb ( 0,01 mg/kg) as action level for investigation, after correction with
50% uncertainty and recounting for concentrated/dried fruit products to fresh product.
When the action value of 10 ppb is exceeded the company has to set the product on hold. A
second analysis can be done. In case the result of this second analysis is negative (below 10 ppb)
further investigation has to be done. The first positive value will not be published in the BIOKAP
database. In case the result of the second analysis is positive the company will inform the VBP
and Skal. VBP will inform the certifier and supplier and ask for a explanation. the target for this
procedure is two weeks. In the case of a positive value Skal will take action conform her statues
and procedures. This will lead to possible decertification of the product. VBP will inform the
BIOKAP members during this procedure. The target to come to a conclusion is a period of 6
weeks.
Examples
1) Dodine, found in dried apricots in several analysis harvest 2008 between 0 to 0,02
mg/kg (after correction)
• Investigations and consultancy advice
• Consultancy: might be caused by fraud, but not certain (could also be caused in the fields
or in contaminated water for cleaning)
• Decision: decertification of lots above 0,01
• Practice: only import of analyzed lots and extra attention harvest 2009
2)
•
•
•
•
•
Chloorprofam in potatoes, several analyses 2008 between 0 to 0,05 mg/kg
Start investigation in whole chain
Problem traced in pack-stations (where conventional and organic are combined)
Contamination on the packaging lines
Actions taken by pack-stations to prevent contamination
Conclusion: cross-contamination where conventional and organic are combined. No fraud
3) Metabolite found in cumon seed, april 2009
• Investigation: period of 6 months
• Two of three labs don’t consider this metabolite as proof of use of residue. One does.
• Conclusion external advice: might be proof of use
• Decision: decertification of the lot(s) and stop of import-authorization by Dutch
government
• Further developments:
 practical all cumin seed of different countries show the same contamination,
specially India
 Germany, France, Denmark and UK follow the decertification at BioFach
 After new information Dutch government stops all import-authorizations for
company involved; not followed by other countries
• Market consequence: distinction between private companies and authorities who accept
cumin-seed with-without this metabolite (and other products from same supplier) =
market disturbance
• Juridical complaint by BIOKAP members to Dutch authority
Annex A-2: Press release BIOKAP February 2010
PRESS-RELEASE
Nürnberg, 17 February 2010
Results BIOKAP residue-monitoring 2009:
Harmonization residue-approach on EU-level needed
The results of the Dutch quality and residue-monitoring system BIOKAP in 2009 show that
residue-contamination is a serious harmonization topic for the organic sector in- and outside
the EU. The good news is that 81,2% of all analyses are absolutely free of residuecontaminations. This means 18,8% show values above the detection-limit. Of the total
amount of 901 analyses 2,9% contains residues above the action-value. This is more or less
in line with the Öko-monitoring of the Baden-Würtemberg.
The most striking conclusion is in the field of follow-up decisions by boarder-crossing cases.
Between EU-authorities there is no common approach in case of positive results above the actionvalue. There is even no common approach towards the action-level itself. This results in marketdisturbing situations for many organic companies who take residue-monitoring seriously.
The Dutch Processing and Trading Association VBP, founder of the BIOKAP quality system, is
after one year experience very positive about BIOKAP. Director Bavo van den Idsert: ‘To meet
the consumer expectations and to maintain high quality of organic it is really necessary to pay
attention to the residue-contamination issue by organic companies themselves and cooperate with
the certifying bodies and authorities. Many contamination cases can be easily avoided, for
instance by good separation between organic and conventional food-streams from the field to the
shop. And in difficult cases it is important to do good research, as happened several times the past
year in the BIOKAP program.”
But the first year BIOKAP shows also the weakness of the absence of common understanding and
harmonization in the EU towards the residue-topic. Bavo van den Idsert: “There is no common
accepted residue-approach for organic. Not between the EU countries, not between the certifying
bodies and not between the private sector. As VBP we established with Skal certification-body a
residue-approach that is based on the BNN approach: 10 ppb (after correction with 50%
uncertainty and recounting for concentrated products to fresh product) as action-level for
investigation. On the one hand we face labs (and probably their customers) that demand zerotolerance and on the other hand we face certifiers that do not act when serious doubt has risen. On
the one hand we face national EU-authorities that stop import-authorizations and on the other hand
national authorities that take no action. These examples show the lack of common approach and
understanding and leads to serious uncertainty and damage for private companies who really try to
take responsibility. Therefore it is necessary that a common approach for all EU-countries will be
established soon.”
VBP – BIOKAP, www.biokap.com, email: renske@biokap.com
Annex Press release with background BIOKAP
Back-ground BIOKAP
- Project of Dutch Organic trade and processing association
- Common monitoring database for participants
- Started in November 2008
- Cooperation with Wageningen University – RIVM and Louis Bolk Institute
- Cooperation with Skal certification body
- Supported by Dutch authorities (ministry of agriculture, nature and food-quality)
- Aim: international cooperation with other organic associations
Targets
- Annual 1000 – 1500 analyses
- Knowledge based approach to find and eliminate causes for contaminations
- Common approach by private sector, certifying bodies and governments
- Active approach by private sector for sparring with certifying bodies and governments
- Realize pressure on companies (and their certification bodies and governments) where residues
are found
- Communication-tool to customers of participants (business-to-business)
- Harmonization residue-approach on EU-level
Database product-groups
• Grains, rice, maize
•
Vegetables and potatoes
•
Fruits
•
Beans, peas, seeds, nuts
•
Coffee, tea, cacao, cichorei, carob
•
sweetening products
•
Oil and fats
•
Dairy products and eggs
•
Herbs and spices
Action value (based on BNN approach) for start investigation
– > 0,01 mg/kg = 10 pbb
– 50% incertainty
– Dried and concentrated fruit factors applied for recount to fresh product
Participants
- AgroBioConnection
- Ariza
- Biofresh
- Bakery Van der Westen
- Doens Food
- Do it
- Eosta
- Horizon
- Machandel
- Natudis/Wessanen
- Naturelle
- Organic Flavour Company
- Simon Levelt
- Stichting Skal
- Tradin
- Udea
- Vitalis
- Yarrah
Annex A-3: Metabolites
Need for fraud prevention is rising; unclear status of metabolites must be solved
The international oriented organic trade and processing companies face more and more
problems about the uncertainty with the integrity of organic ingredients that are offered on the
international market. There are two main reasons:
1. The growth of organic sales during the last years.
2. The participation of retail with very strong demands about residue-free products
The time that purchasing companies could trust on organic certificates only is already far behind
us. In reaction on this situation the quality assurance measures by organic trade and processing
companies is rising fast. Besides the implementation of quality systems, like BRC, the daily
routine of residu-analyses and other analysis become more and more implemented in the
organic sector. Several trade organizations established their own residue-norms and procedures,
like BNN in Germany and VBP-BIOKAP in the Netherlands. Also the certifiers organized in EOCC
are working in the direction in establishing norm and procedures.
The fast growth and importance of the analysis to fight against fraud and secure the integrity of
organic quality face the organic sector with new challenges in an area which is knowledge driven
and for companies very sensitive (in the way it is interpreted). This can best be illustrated by the
recent case of Cumin seed from Turkey (and India). In this recent case several residuecompounds were found and one metabolite called 4-IPA. In this case a technical discussion
appeared whether the metabolite 4-IPA was a proof of active use of the substance Linuron or
not. Besides that several labs which are fully established in organic sector as trustworthy labs for
organic products, appeared not to be able to analyze on this substance. It took about 7 months
of investigation to get a clear decision by the authorities.
From the perspective of the good-willing and more and more analyzing organic trading and
processing industry it is necessary to learn much more about the legal and practical implications
of the presence of metabolites in organic products. Which metabolites (on which crops) are
accepted as clear evidence for active use of the original substance and which are not? For
organic industry this would set clear and practical international standards to fight fraud and
ensure integrity of organic ingredients.
Bavo van den Idsert
VBP-BIOKAP
www.biokap.com
ANNEX B-1
Contaminants analysis results data-base and monitoring
program for French organic sector
To ensure organic sector integrity by contaminants ‘management and
associated risks’ prevention
Current situation in France and discussion status at national level
Until now, there is no harmonization of residue interpretation and policy in France. Authorities and each
certification bodies have its own system and sanctions procedures.
Discussion started in February 2010 at national level within French national organic regulation committee of
INAO (National Institute of origin and quality sign) in order to define a common national residue policy with
harmonized residue limits. The global objective of the work is to define national guidelines in terms of
actions and sanctions in case of pesticides contamination detection in organic products, taking into account
risk analysis and pesticides contamination level.
To meet this objective, three task forces were set up to work on following topics in year 2010:
(1) Definition of normalized sampling methodology
(2) Definition of national guidelines for pesticides analysis risk criteria in order to define what is an
“adventitious and technically unavoidable presence” of pesticides
(3) Harmonization and definition of residue certification limits
SECURBIO data base project will contribute to the development of task forces (2) and (3) works.
Context and SYNABIO’s previous works
Between 1997 and 2008, SYNABIO (French organic trade association) studied residues analyses reports
collected from its members and from French certification bodies on 1993-1997 period for the first study
made in 1997 and on 2005-2007 period for the most two recent studies made in 2007 and 2008 especially
on organic crops, fruits and vegetables. In 2007, 1988 analysis results were collected on organic crops
products. In 2008, 2614 analysis were collected on organic fruits and vegetables.
SYNABIO’s objective is to improve internal analysis control plans set up by organic processors and to give
a picture of current status of organic products contaminations by pesticides in France. These inventories
proved out that further actions could be carried out in order to support effectively organic sector in the step
of permanent improvement of organic products quality.
In 2010, it was decided that ITAB (French organic farming research institute) took over the pesticides
contaminations monitoring project as it appeared clearly that challenges and interests of this project on
contaminants were oriented towards whole organic sector.
Since the beginning of 2010 and based on SYNABIO’s previous experiments, ITAB started to development
a data-processing tool in order to perpetuate the data collection and treatment work which has beeen
achieved by SYNABIO until then.
General presentation of SECURBIO program
The SECURBIO project has the objective to develop methodology and tools in order to improve
understanding and management of pesticides and GMO contaminations in organic crops products.
The SECURBIO project should lead to following opportunities and benefits:
- to prevent contaminations and downgrading of organic products.
Indeed, today when an organic product is contaminated by pesticides and a fortiori by GMO, it is generally
downgraded, which means that it cannot be certified as organic and is sold on the conventional market with
the associated economic loss for producer or processors
- to define collectively harmonized limits and relevant thresholds linked to product/ substance couples for
the interpretation of the results of analyses and the adoption of relevant corrective actions and/or sanctions
to be undertaken in case of contamination.
- to improve the relevance of investigations by development of contamination follow-up procedures in order
to secure information flow related to contamination cases and to optimize management of the analyses
carried out by the companies but also certification bodies
- to anticipate and structure crisis management by building relevant procedures (relevant documentary
filing, localization of documents resources, lists of the members of the crisis cell, etc),
- to disseminate recommendations aiming to avoid or at least to limit the adventitious contaminations.
These recommendations will also detail specific molecules that should be researched regarding the risks
for each type of products and sector
The consequence and benefit awaited are the integrity of organic plant products and the release on the
market of organic products free from residues in conformity with consumer’s expectations.
Objective of SECURBIO program in 2010
The objective of the first year is to make of a computer tool prototype for the collection and the monitoring
contaminants analysis results. This tool is exclusively dedicated to organic products.
ITAB (French organic research institute) and SYNABIO (French organic trade association) are responsible
of this part. The first year of the project was co-financed by Agence Bio (French organic umbrella).
Results and deliverables of SECURBIO program expected for 2010
1.
2.
3.
4.
Document mentioning precise specifications of the computer tool
Procedures to use of this tool
The tool prototype
Tool testing and assessment by capturing and processing existing analyses already collected
before
5. Tool testing by partners sources of analysis reports
6. Definition of complement modules in a view to improve the tool thereafter
Future of SECURBIO program on 2011-2013 period
SECURBIO project development will carry on below 2010.
Indeed, SECURBIO project will be co-financed for 3 years by French authorities from 2011 to 2013.
In order to consolidate and develop further on the SECURBIO data base project, many partners are
involved at national level (authorities, technical institutes, organic professional associations...).
ANNEX C-1
BNN paper???
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