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Keatings Draft – Proposed Amendments to the Guidelines for the Production, Processing, Labeling, and Marketing of Organically Produced Foods

Proposed amendments to the GUIDELINES FOR THE PRODUCTION, PROCESSING, LABELLING AND MARKETING OF ORGANICALLY PRODUCED FOODS (LIVESTOCK and LIVESTOCK PRODUCTS) (At Step 68 of the Procedure)

ANNEX 1, B: Livestock and livestock products
Species Specific Requirements

Beekeeping and bee products

General Principles

54. Bee keeping is an important activity that contributes to the enhancement of the environment, agriculture and forestry production through the pollination action of bees.
55. The treatment and management of hives should respect the principles of organic farming.
56. Collection areas must be large enough to provide adequate and sufficient nutrition and access to water.

57.
The sources of natural nectar, honeydew and pollen shall consist essentially of organically produced plants and/or spontaneous (wild) vegetation.

58.
The health of bees should be based on prevention such as adequate selection of breeds, favourable environment, balanced diet and appropriate husbandry practices.

59.
The hives shall consist basically of natural materials presenting no risk of contamination to the environment or the bee products.

60.
When bees are placed in wild areas, consideration should be given to the indigenous insect population.

Siting of hives

61.
Hives for beekeeping shall be placed in areas where cultivated and/or spontaneous vegetation comply with the rules of production as set out in Section 4 of these Guidelines.

62.
The official certification body or authority shall approve the areas which ensure appropriate sources of honeydew, nectar and pollen based on information provided by the operators and/or through the process of inspection.

The official certification body or authority may designate a specific radius from the hive in which the bees may access adequate and sufficient nutrition that meets the requirements of these Guidelines.
63. The certification body or authority must identify zones where hives, that meet these requirements, should not be placed due to potential sources of contamination with prohibited substances, genetically modified organisms or environmental contaminants.

Feed

64. At the end of the production season hives must be left with reserves of honey and pollen sufficiently abundant for the colony to survive the dormancy period.
65. The feeding of colonies can be undertaken to overcome temporary feed shortages due to climatic or other exceptional circumstances. In such cases, organic sugar should be used if available. However the certification body or authority may permit the use of non-organic sugar. Time-limits should be set for such derogations. Feeding should be carried out only between the last honey harvest and the start of the next nectar or honeydew flow period.

Conversion Period

66.
Bee products can be sold as organically produced when these Guidelines have been complied with for at least one year. During the conversion period the wax must be replaced by organically produced wax. In cases where all the wax connot be replaced during a one-year period, the conversion period may be extended with the approval of the certification body or authority. By way of derogation:

When organically produced beeswax is not available, wax from sources not complying with these Guidelines may be authorized by the certification body or authority, provided it comes from the cap or from areas where no prohibited materials have been used.
67. Where no prohibited products have been previously used in the hive, replacement of wax is not necessary.

Origin of bees

68. Bee colonies can be converted to organic production. Introduced bees should come from organic production units when available.
69. In the chhoice of breeds, account must be taken of the capacity of bees to adapt to local conditions, their vitality and their resistance to disease.

Health of the bees

70.
The health of bee colonies should be maintained by good agricultural practice, with emphasis on disease prevention through breed selection and hive management. This includes:
i) the use of hardy breeds that adapt well to the local conditions;
ii) renewal of queen bees if necessary;
iii) regular cleaning and disinfecting of equipment;
iv) regular renewal of beeswax;
v) availability in hives of sufficient pollen and honey;
vi) systematic inspection of hives to detect any anomalies;
vii) systematic control of male broods in the hive;
viii) moving diseased hives to isolated areas, if necessary; or
ix) destruction of contaminated hives and materials.
71. For pest and disease control the following are allowed:
- lactic, oxalic, acetic acid
- formic acid
- sulphur
- natural etheric oils (e.g. menthol, eucalyptol, camphor)
- Bacillus thuringlensis
- steam and direct flame.
72. Where preventative measures fail, veterinary medicinal products may be used provided that:
- preference is given to phytotherapeutic and homeopathic treatment, and
- if allopathic chemically synthesised medicinal products are used, the bee products must not be sold as organic. Treated hives must be placed in isolation and undergo a conversion period of one year. All the wax must be replaced with wax which is in accordance with these Guidelines, and
- every veterinary treatment must be clearly documented.
73. The practice of destroying the male brood is permitted only to contain infestation with Varroa jacobsoni.

Management

74. The foundation comb shall be made from organically produced wax.
75. The destruction of bees in the combs as a method of harvesting of bee products is prohibited.
76. Mutilations, such as clipping of the wings of queen bees, are prohibited.

77.
The use of chemical synthetic repellants is prohibited during honey extraction operations.

78.
Smoking should be kept to a minimum. Acceptable smoking materials should be natural or from materials that meet the requirements of these Guidelines.

79.
It is recommended that temperatures are maintained as low as possible during the extraction and processing of products derived from beekeeping.

Record Keeping

80. The operator should maintain detailed and up-to-date records as set out in Annex 3, paragraph 7. Maps should be maintained depicting the location of all hives.

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Consequential amendments to: ANNEX 3 at Step 8 (ALINORM 01/22 Attachment IV refers) MINIMUM INSPECTION REQUIREMENTS AND PRECAUTIONARY MEASURES UNDER THE INSPECTION OR CERTIFICATION SYSTEM

5. Each year, before the date indicated by the inspection body, the operator should notify the official or officially recognized inspection/certification body of its schedule of production of crop products and livestock, giving a breakdown by land parcel/herd, flock or hive.
7. All livestock should be identified individually or, in the case of small mammals or poultry, by herd, flock, or in the case of bees, by hive. Written and/or documentary accounts should be kept to enable tracking of livestock and bee colonies within the system at all times and to provide adequate traceback for audit purpose. The operator should maintain detailed and up-to-date records of:
i) breeding and/or origins of livestock;
ii registration of any purchases;
iii) the health plan to be used in the prevention and management of disease, injury and reproductive problems;
iv) all treatments and medicines administered for any purpose, including quarantine periods and identification of treated animals or hives;
v) feed provided and the source of the feedstuffs;
vi) stock movements within the unit and hive movements within designated forage areas as identified on maps;
vii) transportation, slaughter and/or sales;
viii) extraction processing and storing of all bee products.

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Dear Colleague,

It has been some time since the first mailing and you are all probably wondering about the status for organic standards for honey and beekeeping.

Since petitoning the National Organics Standards Board (NOSB) for task force status last March, I recently found out our request has been ignored. Another Board meeting is scheduled next week in LaCrosse, Wisconsin, but I see no reason to have someone attend these hearngs if our requests fall on deaf ears.

Checking on the National Organics Program (NOP) website, I saw nothing relevant about beekeeping in the Livestock Committee minutes. So I called Mark Keating, NOP staff liason to Livestock.

Keating has told me last February that he was working on organic standards for beekeeping for the Livestock Committee. They were to have a preliminary draft ready in April.

In fact, Keating has written an organic standard for beekeeping. It is based on Arthur Harvey’s compilation of organic standards sent to you previously.

Keating said in the interest of time, and since the Livestock Committee was too busy, he had written a proposal and had already turned it in to his superior. It will not be available for comment until publication in the Federal Register, probably sometime in the fall.

Keating said there was no time to assemble an industry task force, and he said that although he has very limited knowleage of beekeeping, Harvey’s work was his guide in the process.

The proposed standard has no post-harvest guidelines – extracting, heat treatments, settling, filtration, straining, etc. Keating said he would appreciate receiving comments in these areas. I reminded him that if there were no specifications for post-harvest rather than general organic food processing principles, there would be a wide interpretation of such things as filtrations and heat application that were critical to the quality of organic honey.

I would call your attention to the enclosed Livestock Committee’s suggestions for post-harest handling in 1998. You can see an example here of work done with no industry input.

I’ve also compiled post-harvest guidelines from the standards previously sent, plus a new copy from the latest Codex committee meeting working on organics. I would like each one of you to let me know what you believe is important for a post-harvest standard. I’ve enclosed my own comments. If you can get these comments back to me promptly, I’ll put them together and send them to Keating.

Meanwhile, where do we go from here? It looks like once again a standard is being proposed without practical industry input. Another of my contacts at NOP, Richard Mathews has told me there has been quite a shake-up at NOP recently. He told me he would like to receive industry comments. I infer that he has concerns about the handling of beekeeping standards by NOSB and Livestock.

Please send me your input. Should we wait until the new proposal is published for official commentary?

The National Honey Board has offered help in compilation of comments and drafting proposals. Although NHB is prevented from directly commenting on qualty issues, they can help us coordinate and refine our comments and assist in industry communications. This will be brought up at the next NHB meeting, and if the Board approves, this could really help our efforts to keep our message flowing to the NOP staff.

Keating mentioned he has liberalized the forage requirement in his proposal. This is definitely a concern that we should concentrate on next.

Also, I would suggest you check the NOP website, www.ams.usda.gov/nop. There is a list here of NOSB members that some of you may wish to contact.

Please send in your post-harvest comments as soon as possible. And let me know if you wish to continue receiving reports and be in on this process. Best regards, xxx