. Copies, submitted to USDA, of notices issued involving denials of
certification, noncompliance, and suspension or revocation of certification.
This requirement will be fulfilled simultaneously with sending notices to
applicants or clients.
who pays for that. I know don't tell me let me guess the organic farmer.
. Retention of records created by the certifying agent regarding applicants
and certified operations for not less than 10 years, retention of records
obtained from applicants and certified operations for not less than 5 years,
and retention of other records created or received for USDA accreditation
for not less than 5 years. This activity requires records and database
management capabilities and resources (storage space, file cabinets,
electronic storage, etc.). In an informal inquiry, AMS found that most
existing certifying agents currently retain records for at least 10 years
and use both electronic and paper storage. We believe that this requirement
will not pose an additional burden on existing certifying agents.
don't worry the organic farmer picks up that storage bill. buy every one a
big new building just to hold the info.
Providing program information to certification applicants. To comply with
this requirement, certifying agents may need to modify existing standards
and practices. The criteria for qualified personnel in the proposed rule may
likely result in an increase in labor costs for some existing certifying
agents and, initially, an increase in training costs. The amount of
additional costs to these certifying agents would depend on the level of
expertise among current certification agency staff, the extent to which
certifying agents currently rely on volunteers, and the current costs of
training certification staff.
hey put the load right on me the farmer will pay for that
The regulation will impose administrative costs on producers and handlers
for reporting and recordkeeping
Although producers and handlers are generally aware of the goals of organic
plans, current practice may fall short of the rigor that will be required by
the national program. New producers and handlers will have higher costs
because they will have to prepare a plan from scratch.
no problem the check is in the mail
Notify the certifying agent as required, e.g., when drift of a prohibited
substance may have occurred, and complete a statement of compliance with the
provisions of the NOP
hey my time is your time no problem I will galdly take the time for that
The total recordkeeping burden is the amount of time needed to store and
maintain records
The annual burden on certified producers is estimated at 10 hours and $229.
Certified handlers have an estimated burden of 50 hours valued at $1,189.
Certifying agencies have an estimated burden of 700 hours valued at roughly
$18,900
ok put that on my bill organic farmers pay for all that too
Based on the projected number of producers (17,150) and handlers (2,150),
the total reporting and recordkeeping cost, which captures much of the
compliance costs of the rule for this group, is $5,200,721.
thats nothing organic farmers can just raise their price a little more.
The imposition of the national standards may change the composition of the
organic industry. Even with the small business exemptions, some small
organic operations may choose to exit the industry and small organic
operations may also be discouraged from entering the industry, resulting in
a higher concentration of larger firms.
nothing new here get big or get out.
The costs of the proposed regulation are the direct costs for accreditation
and the costs of complying with the specific standards in the proposal
including the reporting and recordkeeping requirements. Other than
accreditation fees, recordkeeping and reporting costs, we did not quantify
the magnitude of the compliance costs or the costs of adhering to other
provisions of this regulation.
sure do't worry about those other cost the organic farmer pays it.
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) (Act) requires
agencies to consider the economic impact of each proposed rule on small
entities and evaluate alternatives that would accomplish the objectives of
the rule without unduly burdening small entities or erecting barriers that
would restrict their ability to compete in the market.
I don't think they did that here.
Small businesses in the agricultural services sector, such as certifying
agents, include firms with average annual revenues of less than $5 million
(SIC Division A Major Group 7). Producers with crop production (SIC Division
A Major Group 1) and annual average revenues under $500,000 are small
businesses. Producers with livestock or animal specialities are also
considered small if annual average revenues are under $500,000 (SIC Division
A Major Group 2), with the exception of custom beef cattle feedlots and
chicken eggs, which are considered small if annual average revenues are
under $1,500,000. In handling operations, a small business has fewer than
500 employees (SIC Division D Major Group 20).Based on SBA's small business
size standards for the agricultural services sector, it is not likely that
many, if any, of the 49 domestic certifying agents have annual revenue
greater than $5 million. Based on anecdotal information, only a few private,
for-profit, certifying agents might be categorized as a large business. All
private, non profit, and State certifying agents would be considered small
by SBA's standards. Even if State certifying agents do not exceed the
revenue threshold, they would not be considered to be small entities under
the Act if the agents are an arm of state government. Based on SBA's small
business size standards for producers, it is likely that almost all organic
producers would be considered small.
The Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3506 and 3507) is
designed to minimize the burden of reporting and recordkeeping (information
collection requirements) required by Federal regulations on individuals,
businesses, other private institutions, and State and local governments. The
burden is an estimate of the amount of time and the cost required of program
participants to fulfill the information collection requirements
hehe what a joke there is no paper reduction here we get more paper work
duplication and triplication.
check out an organic farmers homepage
http://www.rain.org/~sals/my.html
sals@rain.,org
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