To submit suggestions for revisions to Protected Harvest Standards:
Revisions must be in writing (electronic mail is encouraged) and may be submitted electronically or by mail or by fax to the program manager:
Cliff Ohmart, PhD.
Protected Harvest Program Manager
1528 Olympic Drive:
Davis, CA 95616
- The person submitting proposed revisions must be identified by name. No anonymous proposals will be accepted. If submitted on behalf of an organization or company, the name of the organization or company, address, phone number, number of members, and name and title of person submitting proposed revisions must be included.
- List the standard, section number, question number, and actual text you propose to change.
- Provide the replacement language you would like to propose. New text should be in underline format, and deleted text should be indicated by strike out format.
- Provide a rationale, including the need for and intended effect of your proposed change. Supply any supporting documents or research information, including historical use.
- Include a summary of your position in 100 words or less.
Protected Harvest Process for Consideration of Revisions:
The first factor that must be clarified is the difference between a revision and a technical correction. Revisions represent substantive changes or additions to the standards that may affect the ability of an operation to comply. These can include additional requirements, changes to the allowance of practices, or any adjustments to the scoring of a certification audit. Technical corrections are changes that do not affect the intent of the standard. These include grammar and spelling corrections or terminology adjustments.
Technical corrections can be made by Protected Harvest staff at any time to improve the certification documents. As these do not affect the intent of the standard, no notice or phase in period is required.
Revisions require a fully transparent procedure that allows for comment from all stakeholders. It is expected that three distinct facets of industry will provide request for revisions. They are:
- Growers and program participants
- Industry groups and consumers
- Protected Harvest board and staff
The procedure will be equivalent no matter who submits the request. The following is a step by step method for revision:
- Written request for revision submitted to the Protected Harvest Certification Department. Requests must be submitted at least 6 months prior to the application month. Commodities that have year round production will be assigned an application month.
- Within 30 days, Protected Harvest Certification and Technical / Science Departments will create a recommendation based on the request information. This recommendation will be forwarded to the rest of the Protected Harvest staff and appropriate board members.
- The staff and board will have 30 days to provide comments. Afterward, comments will be used to create a revised recommendation by the Certification and Technical / Science Departments.
- The revised recommendation is posted for comment on the Protected Harvest website for 30 days. Simultaneously, the industry group is advised of the recommendation.
- After the posting, within 30 days the recommendation is revised once again by the Certification and Technical / Science Departments to encompass comments and submitted to the staff and board of Protected Harvest for approval.
- Once approved, the recommendation is posted on the website as a notice of change. Included is a date of implementation. The date of implementation is the date in which growers will be required to meet the new standard requirement. The Certification Department prior to the implementation date must adjust all documentation effected by the change. In the case of extreme changes, the implementation date may be held off until the following season with an exploratory period in the present season. Simultaneously, the industry will be alerted to the eminent change.