Skip to content


February 16, 2010

Are you in favor of parallel production?

Parallel production is not allowed in Canada but it is allowed in the US, and the EU prohibits it with exceptions. The issue is under debate at the level of the CGSB Committee on Organic Agriculture and a proposal for amendment will be submitted for balloting.

Should Canada be more flexible on the issue of parallel production? If it were allowed, could parallel production be managed without compromising organic integrity? Can consumers trust the organic quality of produce grown on a unit where organic and non-organic crops are produced? What is your opinion? To leave a comment, please click on “comment” and then on “reply” at the bottom of the list of comments that will pop up!

Êtes-vous en faveur de la production parallèle en agriculture biologique?

Au Canada, la production parallèle n’est pas permise; cette pratique est acceptée aux ÉU et interdite dans l’UE bien que certaines exceptions soient admises.  Cette pratique fait actuellement l’objet d’un débat au sein du Comité sur l’agrculture biologique de l’ONGC et une proposition d’amendement sera soumise au scrutin.

Le Canada devrait-il être plus flexible sur la pratique de la production parallèle? Si la production parallèle était permise, pourrait-on la gérer sans compromettre  l’intégrité de la production biologique?  Les consommateurs peuvent-ils se fier à la qualité biologique d’un produit cultivé dans une unité de production où des cultures biologiques et non biologiques sont produites?  Qu’en pensez-vous?  Cliquez sur “Comment” pour accéder à la section des commentaires et émettez votre opinion en cliquant sur “Reply” en bas de la page de commentaires.


70 Comments leave one →
  1. Ted Zettel permalink
    February 19, 2010 3:32 pm

    Parallel Production: Argumentation

    The Canadian Organic Standard defines parallel production as “The simultaneous production, preparation or handling of organic and non organic crops, livestock and other organic products of the same or similar visually indistinguishable varieties.” (3.1)

    Section 5.1.2 allows for production of organic and non-organic products during the transition phase only (split operation) but specifies that eventually the whole enterprise must be included in the transition, effectively prohibiting parallel production with no exceptions.

    At the 11th meeting of the Organic Technical Committee in Cornwall (Jan 2010) a resolution was discussed and sent to ballot, that would amend 5.1.2 as follows;

    Option B/C – proposal – Modify par 5.1.2 to read as follows;

    The enterprise shall aim at a complete transition of its production. During the transition period, the enterprise can maintain, in addition to the production in transition, a non-organic system of production (split operation) that shall be entirely separate and identified separately, pending its incorporation into the overall transition process. The enterprise can be converted one unit at a time, and each converted unit shall respect the requirements of this standard. The exception to this norm, indefinite parallel production, is not only allowed in the following cases: perennial crops (already planted), agricultural research facilities, production of seed, vegetative propagating materials, transplants. The following special conditions must be observed for parallel production;

    This amendment, if it passes through the balloting process and becomes part of the standard, would allow limited instances of production of organic and non organic products on the same operation (perennial crops, seed, research etc.)

    What is the status quo?

    At present, it is recognized that the prohibition on parallel production is problematic in some instances, and there are valid criticisms of the rules ;

    – orchardists, perennial fruit producers who choose not to convert their entire production for legitimate reasons. (risk, limitation of demand, scale of operation not suited to the market etc.)

    – seed companies who would not have a viable business dealing exclusively in organics

    – the system allows operators to have side by side organic and non-organic in every other area except on farm crops; processing, distribution, retail – all these handle both and rely on documentation to ensure the integrity of the organic audit trail. Farmers are the only ones that the organic rules deem incapable of segregating the two.

    – Operators who want to get around the prohibition do so by putting the organic part of the operation under a separate legal ownership. Technically this makes them legal. In fact, it probably increases the risk of fraud, because now the certifier has no ability to gather information on the non organic side of the business.

    – Neither of our major trading partners (EU or US) have a prohibition, but this has not been raised as a critical variance in the EQ agreements

    Why did we prohibit it in the beginning? (these are only my suppositions!)

    – fear that the task of keeping crops separate was overwhelming – that documenting handling and storage to instill confidence in the final product would be beyond the capability of the operator

    – fear of corruption – that it would be too easy to cheat, borrowing some product from the conventional side and selling it at higher organic prices

    – the belief that those who continue to produce some of each do not belong within the organic community, that they have not sufficiently assimilated the organic principles and represent a risk to the credibility of the organic claim

    – the ideal of “the farm organism” – a completely self-sufficient, enclosed production unit which relies only on internal resources and is indefinitely sustainable, as opposed to “production units” modeled more on the industrial system, but using organic inputs


    – the first two points around record keeping and fraud are in essence the justification for a rigorous mandatory certification system. If that system works it should be able to sufficiently ensure organic integrity. If it doesn’t, even operators who don’t practice parallel production will be able to take advantage of its inadequacy

    – the last two points speak to the original ideal of organics as a completely new and alternative food system that requires its adherents to adopt a new mindset. The argument could be made that if we want the certification system to enforce this ideal, we will have to go much further and eliminate co-handling of organic and non-organic all the way up the food chain, even prohibiting branding of organic by companies that sell non-organic versions of the same product. We should also enact provisions to discourage livestock facilities that are not self sufficient in feed

    • Nathalie Couturier permalink
      April 15, 2010 3:31 pm

      Je ne suis pas pour le parallele car oui pour le consommateur, cela vient difficile d’etre certain du bio, et meme nous comme producteur on se pose la question parfois sur ceux qui sont encore bio et conventionnel.

    • richard birley permalink
      May 4, 2010 1:15 pm

      no parallel production we must keep our standards strong, the consumer needs to know that we are what we are . Don’t allow the convention industry to question our integrity , we have much to lose and zero to gain!

    • keith everts permalink
      April 6, 2011 3:51 pm

      we need parallel production in the livestock industry. Producers that have forestry permits are not 100% in control of that land base as it has other users. The producers in our group run their first time calvers on that land base and sell the calfs off as conventional. The producers that are in Organic Agriculture, as a living, are not going to cheat. It would be harder to cheat than be honest. Lets not sell are souls to a few who beleive that we do not have integrity. If we are trying to create a clean enviroment, lets not make it undoable for the ones that have been supporting organics for ever.

  2. February 23, 2010 11:38 am

    I feel that parallel production could be monitored the same way the Organic Associations now monitor fraud and misuse of any other part of the program….i.e. pesticides etc.

    In my operation, I produce honey products which will never be able to be classified as organic as I am not further than 3000m away from neighbours who spray their orchard with chemical sprays.

    I would not have to be forced to stop producing honey and selling it as a non organic product because of this rule.

    Marlys Wolfe
    Falcon Ridge Farms

  3. February 23, 2010 5:34 pm

    De facto parallel production already exists on many farms who have had to establish buffer zones within their crop areas. Operators, Verification Officers and Certification Committee members have established segregated handling, storage, sales and recordkeeping protocols and processes to successfully manage the issue along with the knowledge and capability to deal with non-compliance.
    Given the successes of this limited practice, it is illogical to suggest that it could not be managed on a larger scale with more rigorous controls.
    I support an allowance for parallel production as a means of moving existing perennial crops into transition and finally into certification.
    Donna Sawkins

    • Guy Villecourt permalink
      February 24, 2010 10:54 am

      split production goes againts the fondamental principle of organic growing as to provide sustainable pratices of growing foods …
      and too many ways that could go wrong with split production …
      much safer for the consumer to avoid completely split production…
      consider what is happening in california right at this moment , with ‘whole foods ‘ importing from china “california certified organic foods”

      much easyer to trust in whole farm organic production…
      therefore lets not allow split production at all …

    • Michelle Strebchuk permalink
      March 24, 2011 12:48 am

      I agree. However, as certified organic producers that would like to transition more land into organic production our hands are tied by the current standard. We currently grow legumes, rye, oats, wheat, barley, alfalfa and mixced hay organically. As the standard presently reads, we would be unable to grow any of these “indistinguishable” crops as a transition crop – despite the fact that the land we would like to transition is over 20 k.m. away and has separate storage facilities, and that we maintain accurate and exceptional organic paperwork, and successful traceability methods verified by thoroughal inspections and audits. We would be willing to supply taxation records, complete chemical residue testing, and take additional measures to document our processes (ie. photo or video), to allow for parallel production in cases such as ours.
      We would never prohibit a grocery store from carrying non-organic granola and organic granola in the same aisle (virtually indistinguishable), and there is nothing stopping retailers from labelling non-organic products such as these with an organic label (no other verification or tracability on each respective bin). It comes down to trust and integrity – there are organic producers and processors who do not have this, but let’s not penalize the entire industry for the lack of ethics in a few.
      Michelle Strebchuk
      Strebchuk Farms, High Prairie, Alberta

  4. February 23, 2010 5:37 pm

    Parallel production should ideally be avoided for it offers the perfect ground to mix organic and non organic products. The organic food chain should be totally separated from the non organic one in order to maintain near perfect integrity of organic foodstuff and ease monitoring procedures.

    However, economically speaking parallel production may be the best avenue for some producers and/or processors. The issue should be adressed by taking each specific case into account.

    Thierry Boyer
    Marketing & Communication Consultant

    • kris permalink
      February 23, 2010 6:28 pm

      There are two conflicting considerations:
      1. Increase Canadian supply of organic products;
      2. Preserve the integrity of “organic Regime Standards” and the label “organic”.

      I believe parallel production should only be permitted on a case by case basis with increased monitoring in order to preserve the the “integrity” of Organic label.

  5. February 23, 2010 7:13 pm

    Right now, processors can process both organic and non-organic products that are not visually distinguishable. I think our current policy is an obstacle for some growers who would like to be able to try organic production but are afraid to convert the whole operation at onece. They do not know what they are getting into. I think rigorous protocols can be established to prevent fraud, and help newcomers initiate organic production just like is done currently with processors. Imagine what our situation would be if we did not allow parallel processing? We would have no organic processing operations.
    Dwight Brown

    • Rebecca Kneen permalink
      November 4, 2010 11:09 am

      Actually, processors can be fully certified organic. We are, and have been for 10 years. So there are options, and organic processing operations, it just depends on the industry.

      The biggest gap in processing in BC is in slaughterhouses, where we have only a couple of certified organic facilities, and the one near us has to do parallel production – they can’t run otherwise.

      Case-by-case seems to make the most sense, with encouragement for producers and processors to move to full organic production.

  6. C Ens permalink
    February 23, 2010 8:55 pm

    I think there needs to be an element of trust in regards to parallel production. If you don’t trust us as producers to comply with and keep records of parallel production why would you trust large food/ingredient producers to do so? I have certified with a certifiying body where there was no trust evident on the part of the certifier and when you are constantly treated like a criminal, eventually you quit organic production or you go to a certifier who is more realistic and understands business. Should parallel production be allowed? Yes if you want to grow the organic business, No if you want to stifle it.

  7. Eva Johansson permalink
    February 23, 2010 10:01 pm

    Being able to say to consumers that there is no risk of confusion/corruption are important reasons not to allow parallel production. All it will take is one well publicized, cheating operation and consumer confidence in the organic sector will plummet. Not allowing parallel production at least minimizes the risk.

    • Derek Campbell permalink
      March 1, 2010 7:40 am

      But processors are allowed to do parallel production.

  8. Dieter Eisenhawer permalink
    February 23, 2010 10:36 pm

    Would your customers believe or trust you, if you told them you also grow conventional produce?

    Dieter Eisenhawer

    • Derek Campbell permalink
      March 1, 2010 7:46 am

      Yes. Basically if your customers know you they trust that you do what you say you are doing (of course if they don’t trust you they won’t be your customers very long).

      In most cases your product goes through third parties (processors, packers, retailers etc.) and then the consumers is putting his/her faith in the process (organic certification). If that process can’t be trusted to separate organic and conventional products on the farm can it really be trusted at the processor or can it be trusted at all?

  9. Garry & Wendy Lowe permalink
    February 23, 2010 11:23 pm

    Our concern is related to fair representation of what organic farmers, processors and consumers desire – rather than academics, bureaucrats and lobby groups. As PACS members in British Columbia, those who responded to the invitation to share their positions, it is ironic that 61 members said no parallel production and only 4 said yes – yet somehow the direction of the vast majority of our members seems ignored. It is our understanding that only 14 of the 44 Technical Committee voting members are producers or processors, which further highlights the concern for the direction of organics standards in Canada.

    The lobby influence in FDA by Monsanto and other industrial conglomerates is well documented – and their impact on US and World agriculture. We trust that as Canadians, we will make decisions that are not rationalized only by economics, or the desire to follow US and EU decisions, but rather the principles which led each of us farmers to commit 100% of our efforts toward sustainable, healthy and strict organic principles and standards.

    We have two suggestions; have a referendum open to all organic farmers and processors in Canada as to their decisions on this point, and secondly, to conduct a similar professional poll of Canadian consumers as to whether they would prefer to buy organics from parallel production farms or those committed to organic principles. If the results of this research is that the Canadian consumer prefers food grown on farms where parallel production is not allowed, it would seem only suicidal to ignore such data. If parallel production is allowed, it would seem only consistent with other “labeling” initiatives that their Organic Certification also include a designation that identifies that farmer or producer as a “parallel producer/processor”. There will always be a method of avoiding the rules, but one only exposes their lack of commitment to organic principles if they engage in dual legal entities, fraud or other tactics, to attempt to play within both conventional and organic agricultural methods.

    If Canada compromises on parallel production, it will not be more than a decade or two until Monsanto, WalMart and other conglomerates control organics no different than any of the other industries they have decided to control through industrialization and commercialization. If we lose the confidence of the Canadian consumer, our industry as we know it today, will be permanently damaged.

    Garry & Wendy Lowe
    Twin Meadows Organics

    • Derek Campbell permalink
      March 1, 2010 7:50 am

      We already have the “compromise” on parallel production for the processor.

  10. James Freeman permalink
    February 23, 2010 11:41 pm

    With proper record-keeping on a certified organic beef operation, parallel production can properly protect organic consumers’ interests. We have two government summer grazing permits where the cows graze on large acreages, but there are also occassional Shell facilities and some of those have weed issues that Shell is actively dealing with.
    We thus carefully sort and document the cows and calves that go to each pasture each summer. That way, based on that documentation and our double tagging system and database, we know which animals have been on which pasture, and they are then sorted well in advance of sale into the organic system. This system is easy to audit from calving to sale.
    We would urge that the COR include parallel production in the regulations- with proper documentation.

    • Derek Campbell permalink
      March 1, 2010 7:53 am

      Parallel production is allowed on a beef operation of the organic animals are tagged with tags distinctive from the conventional animals and the animals are kept separated. e.g. organic animals have green tags and are in a separate field from the conventional animals with the yellow tags.

      • Derek Campbell permalink
        March 1, 2010 9:23 am

        Oops, that’s not parallel. It’s a split operation. The organic and non-organic products (tagged cattle) are visually distinguishable.

      • Michelle Strebchuk permalink
        March 24, 2011 12:55 am

        These would only be “virtually distinguishable” provided that no animal in either pen ever 1) escaped the pen, 2) lost an ear tag. Branding, ear notching or other permanent methods of identification would be the only way to maintain the distinction.

  11. Mike Stohler permalink
    February 24, 2010 12:28 am

    my two cents:

    If we are to build consumer confidence around Organic products in Canada and maintain the integrity of this certification branding in the market place, I cannot see how any sort of regulation, no matter how rigorous, would allow an operation to offer pallel production services and still maintain consumer confidence around our certification process. In my opinion there are far too many organizations already attempting to blur the lines and ‘hitch’ their wagons to the organic movement with green-washing statements such as “we use environmentally practices”;and I call BS. Get on board or get out. The proposed transition ammendments allowing an operation to produce both organic and non-organic products simultanesouly are particularly problematic and in my opinion only delays an invitable mindset and comprehensive farming and processing change on the part of the business that is required. Furthermore, a business that offers only a part of it’s products as Organic still enjoys the full benefit of calling themselves and their business 100% Certified Organic without a real commitment and with only a limited offering of organic products at their place of business. The consumer is still attracted to their location on the pretense of the organic branding on the larger business, only now to find it’s back to them to research each of products individually as to whether they are organic or not. I think that we would be selling ourselves short and the consumers would be disenfranchised with us if we try to bend the rules too far to allow a few outlying organizations into the organic club who are very likely not suited to organic operations in the first place and quite possible not convinced about the change; instead looking only to capitalize on a growing marketshare which is demanding organic products.

    Mike Stohler
    SummerGate Vineyard & Winery

  12. Derek Campbell permalink
    February 24, 2010 7:04 am

    Anyone concerned about “cheating” should also consider all one needs to do is create another company (farm) to produce the organic product. Land ownership doesn’t need to change (organic farm leases land from conventional farm), you still use the same equipment (following proper cleaning procedures), nothing changes except that the organic inspector can only look at the records of the organic farm. This creates a much more favourable environment for “cheating”.

    It very upsetting that our organic standards basically state the processors are trustworthy but the farmers aren’t (processors can do parallel production).

    Also upsetting is that this rule makes it more difficult for conventional growers to convert to organic. And telling the wheat grower to grow something else until his whole farm is converted is a very tough sell. I have also heard some say there is no reason to convert only a small portion of the farm at a time. I find that strange since one consistent piece of advice I have heard for years was to convert a small portion at first and work out the kinks before you convert the rest of the farm.

    • Michelle Strebchuk permalink
      March 24, 2011 1:05 am

      I agree completely. Either you have ethics and integrity or you do not. It doesn’t matter how “strict” our standard is, those who want to find a way around it will.
      We had a flub on our farm a few years ago and 160 acre parcel was inadvertently seeded with contaminated alfalfa seed (prohibited substance). We could have simply removed the fungicide tag and carried on. Instead, we chose to remove this field from organic production for three years, and in fact, provided our certifier with all the information (including MSDS sheets) regarding our mistake. It hurt our farm financially to be honest, but our integrity is worth more than lost rent, lost production, and lost sleep.

  13. Gerard Wiebe permalink
    February 24, 2010 9:58 am

    The reality of converting large farms to organic production is that it is very difficult to covert a complete farm to 100% organic production at one point in time.

    Typically this conversion needs to take place over a several seasons.

    As a result parallel production should be allowed during the transition or conversion period.

    With a well defined plan to keep parallel production segregated during this transition period, and a demonstration of adherence to the plan, there is no reason why the integrity of organic certification need be compromised.


    Gerald Wiebe

  14. February 24, 2010 6:12 pm

    I see organic production standards being compromised if there is no differentiation possible between the crops being grown, as we all know it is so easy to intermingle crops without trying to do so by scrupulous growers, the question of less than scrupulous growers is obvious. So parallel production only if there is differentiation by crop by identification type or by time grown and handled. I would tend to follow the european rules

    I see organic production standards being compromised if there is no differentiation possible between the crops being grown, as we all know it is so easy to intermingle crops without trying to do so by scrupulous growers, the question of less than scrupulous growers is obvious. So parallel production only if there is differentiation by crop by identification type or by time grown and handled. I would tend to follow the european rules
    Robert Hettler

    • Derek Campbell permalink
      March 1, 2010 8:04 am

      How can you easily intermingle your crops by accident? You harvest separately, store separately and label everything differently. The only place I can see accidental intermingling is when equipment used on conventional farms wasn’t properly cleaned out and not allowing parallel production doesn’t change this.

      • Michelle Strebchuk permalink
        March 24, 2011 1:06 am

        Agree with Derek.

  15. February 24, 2010 8:16 pm

    As a a certified organic and conventional crop producer, I see risk involved in allowing parallel production, but we wouldn’t be farmers if we couldn’t take a calculated risk, right? We have been slowly converting over the past five years, and I see merit in allowing parallel and at the very least, split production.

    As a small to mid-sized family farm, the conventional portion financially supports our farm so that we have the choice to grow some crops organically. The transition of an operation from conventional to organic is NOT possible without a significant transition period when producing parallel crops allows the farmer to combine knowledge of the crop with increasing the knowledge to grow that same crop organically.

    Yes, integrity must be maintained. It takes more time and effort, but it can be done. The consumer is trusting that the organic crop is organic whether there is parallel production in the system or not. Allowing parallel production won’t cause consumers to lose confidence because if health is your main concern, you will choose to trust organic over conventional everytime.

    If the CGSB does not allow parallel (or split) production, you may lose this family farm, and the organic production with it.

    • Rupert Jannasch permalink
      February 25, 2010 7:00 am

      Although I understand the intent of the regulation concerning split and parallel production, it is not without flaws. I grow organic fruit and vegetables and am one of the few organic farmers who keep cattle. My own cattle (between 6-10) I keep solely as a manure source. Those that I custom graze (about 25) are used for weed control. There is no profit in beef cattle. I have no intention to have my animals certified and would be unable to have my neighbour’s cattle certified in any case. Under the new regulation I stand to lose my certified status, depending on its interpretation. Then I will have no choice but to sell my products as biological or some other label which would only undermine the local organic market. I won’t get rid of the beef cattle. Ironically, I am free to import manure from conventional poultry farms. I would prefer to stay certified but wouldn’t be that upset if it meant avoiding the increasing fees and bureaucracy involved with organic agriculture.

      • Derek Campbell permalink
        March 1, 2010 8:11 am

        Sorry Rupert but I am confused by your comments. How would you lose your organic status? You are allowed to have non organic cattle with organic fruit. are they looking at eliminating split production as well?

  16. Reta Chapman permalink
    February 25, 2010 1:03 am

    Weighing in with my two sense:: When asking ourselves about issues like consumer confidence, agricultural transparentcy and organic, what is the heart of the matter? Consumers are scared and are casting about looking for something to give them a sense of security in the food they buy and consume. If we suppose that farmers, in order to stay financially viable, take five years to convert, is there some way to educate people about local, transitional organic? Is someone who is running parellel production likely going to use chemicals as needed, opposed to prophalactic (daily) use?
    Animal husbandry seems an ideal place to run two operations. SHould an animal become ill, requiring antibiotics; they could be transitioned and treated in the conventional herd.
    Ultimately – the food system in North America is broken and we are searching for ways to fix it. Regulating and harrasing the food producers who are actively trying to change things for the better seems like a bone headed move.

  17. February 25, 2010 6:13 am

    I believe parallel production should be accepted on a farm by farm basis. Some crops, like fruit tree crops, are very well defined lots of land and do not tend to have issues with mixing of seeds etc…

    In Atlantic Canada many farms are smaller and in order to survive they do both conventional and organic farming, while it may be their final goal, at this point they would not be sustainable in solely farming organic.

  18. February 25, 2010 7:21 am

    Why would this be an issue? If a organization wants to grow organic and use what is best for the consumer and not the market or pocket book it seems only reasonable to operate both organic and not organic as long as it is clearly understood by the grower and consumer what conditions exist. Perhaps a organic rating or scale that outlines what practices are followed.

    This grants the grower the right to grow and to consumer the right to know. As long as there are outlines for each classification.

    Class O1 may state that this organic product follows the strictest measures to ensure good wholesome products true to organics

    Class V1 may be vegan may have yet another, yet similar stringent set of guidelines

    the idea is you get what you pay for and you deserve to get it if you pay the price.

    I could go on, but I think I’ve said enough.

    Why would this be an issue? If a organization wants to grow organic and use what is best for the consumer and not the market or pocket book it seems only reasonable to operate both organic and not organic as long as it is clearly understood by the grower and consumer what conditions exist. Perhaps a organic rating or scale that outlines what practices are followed.

    This grants the grower the right to grow and to consumer the right to know. As long as there are outlines for each classification.

    Class O1 may state that this organic product follows the strictest measures to ensure good wholesome products true to organics

    Class V1 may be vegan may have yet another, yet similar stringent set of guidelines

    the idea is you get what you pay for and you deserve to get it if you pay the price.

    I could go on, but I think I’ve said enough.
    C W E

  19. February 25, 2010 7:24 am

    Where are we really trying to go…… trying to answer these questions. If we are so hooked up upon trying to push parallel production in the same fields farmers should rather stay inorganic — make their money and leave the ethically organic farmers alone.


  20. Sam Godwin permalink
    February 25, 2010 10:37 am

    I’m an organic farmer, mixed cattle and grains. In most opinions you will likely find that parallel production is the only way beef can be raised organicly for at least the first few years. The rational of that is the fact you have the need to treat animals to save lives hence making them non organic parellel product.
    In the case of fruit trees being transitioned to organic over a longer period of time , there is bound to be some point of parellel production, this is understandable because of the longevity of the tree lifespan, again a issue that can be argued but do we want to discourage organic production or do we count on people being devoted to the organic production concept. In my personel opinion we need to allow these cases to play their role and hope that the independent inspectors do an extensive inspection paying particular attention to volumes of product being sold, this is the only way we can incourage producers to transition to organics totally rather than have them hid their operations under different names, which by the way we then have no moniter on the real amount of total farm productin.
    So far as cereal grain production i feel there should be no parellel production after the allowed split production, we at this time are trying to incourage the use of certified organic seed, if we allow parellel production in seed production how does that encourage the use of organic seed. As for the production of cereals for human consumption, i would suggest we do not allow any parellel production.
    So with all that taken in to consideration there is a definite need for parellel production in special cases as would need to be clearly outlined so there is no confusion as to who could or could not use the parellel production. This i know will be a bit tricky because we all prefer to see things from a self-serving aspect. If we are only doing the organic thing for money then we need to re-evaluate our position as producers.
    I hope honesty and honor prevail as it has so far.
    Have a good day
    Sam Godwin

    • Derek Campbell permalink
      March 1, 2010 8:14 am

      You can run a split beef operation. Different ear tags and separate the animals.

  21. keith everts permalink
    February 25, 2010 5:11 pm

    The questions keep coming up of where are the markets, where are the processing facilities, where are the retailors. As a group of producers we need to be careful for what we ask. With the COR regulation most of the processing and value adding can be part of your own OSP and alot of this could be part of parallel production. Retailors have alreadey stated that we need to be carefull on suggesting more exspenses when we are already asking a premium for our product. If we can work with conventional farming neighbours and they slowly bring there farms into organic we are starting to make a cleaner system for all of us. Most of the inpectors ask for estimated production run, it is not so easy to cheat as one might think. We need to have parellel production, to ease producers and processors into the organic systems. Other wise we will continue a price war with Natural products that are taking over the market share at reduce pricing.

  22. james permalink
    February 25, 2010 5:37 pm

    If Europe is not in favor of parallel production the niether am I. Why is it that the American influanced the Canadian Organic Standard? Do you want producers and manufacturers sitting on the fence with out a total commitment to the organic industry. The integrity of word organic would totally be compromised.

  23. February 26, 2010 2:25 pm

    While QAI does not want to advocate either for/against parallel production, we have had issues in dealing with this subject in the past for client compliance against the EU regulations. Here’s a suggestion for clarification in the standard, based on our past experiences with categorizing/determining parallel production.

    To help ensure enforcement of the regulation against parallel production is consistent among certifiers, it is important to define a production unit due to the wide variety of business and organizational structures that are routinely encountered in agriculture production. One suggested method is:

    Parallel production requires that the operator maintain physical, financial and operational separation between the organic and conventional products:

    · Physical separation includes clearly marked segregated storage separating organic from non-organic product lots. Organic areas shall be clearly marked.

    · Financial separation includes a clear separation of inputs, and separate or detailed invoicing.

    · Operational separation includes demonstrating that the organic production unit runs separately from other production units under the same holding. This may include separate staff and machinery if there is a concern for commingling.

    • Derek Campbell permalink
      March 1, 2010 8:22 am

      Kasey that is probably the most reasonable description I’ve heard on how we could have a parallel operation but maintain integrity of the standards. It takes the good points of creating a new company to hold the organic operation but still keeps everything under the one operation which simplifies the life of the owner and allows the inspector and certifying body to inspect the whole operation.

      I would also propose that the same rules apply to the growers and processors.

  24. Derek Campbell permalink
    March 1, 2010 9:19 am

    The whole system of organic certification is based on the trust, integrity, and abilities of the operator. Suggesting a grower in parallel production (organic and conventional of non-visually distinguishable products) is not trustworthy, has less integrity or less ability compared to someone of a non-parallel production operation is foolish.

    Let’s eliminate the whole argument about trustworthiness and integrity. If you want to cheat you will cheat. Running a parallel operation doesn’t change that and it makes it only a small amount easier to cheat. If you were cheating in a parallel production operation you wouldn’t have to hide the prohibited substance but you would have to make sure your records indicate you are using the full amount on the conventional products. Currently, if you want to do parallel production you just start a new company that leases the organic land from the conventional operation and contract it to do all the work. This setup is easy to do and is being done now. This setup also makes it easier to cheat because now the inspector / certifier has no right to look at the records of the conventional operation.
    So you can be as trustworthy and have as much integrity as you want. The no parallel production rule doesn’t change that.

    Let’s look at abilities of the operator. Is someone likely to put their conventional wheat and organic wheat in the same grain tank? Not likely but certainly possible. Are they likely to do that and never notice? I find that highly unlikely. Are they likely to make that mistake and lie about it so they can still get their organic market? I believe that argument is invalid as (like I said before) the whole system of organic certification is based on the trusting the operator.
    Another situation is a split production (organic and non-organic but visually distinguishable). Let’s say non-organic corn and organic sunflowers. You (or an employee) could accidentally treat the organic sunflowers with a prohibited substance (e.g. spray glyphosate before planting) on both fields. The system assumes the operator will catch that and take that organic field out of organic production for the next three years. How does this differ from growing organic corn in one field and non-organic in the other?
    Another situation is some non-organic corn was accidentally put into the same bin as the organic sunflower seeds. The sunflower seeds are now contaminated and (please correct me if I’m wrong) and will have to go into a non-organic system. There may be room to prove you removed all sunflower seeds that may have been contaminated and sell the rest as organic, I’m not sure.

    All these situations are quite possible in both parallel and split operations but for some reason we allow split operation but not parallel.

    I’m not necessarily against the no parallel production rule, I just haven’t seen a valid argument for it in our current system.

  25. March 2, 2010 4:08 pm

    We have a rather large and diversified operation.

    I am definitely not in favor of a complete prohibition on parallel production the way it has been in the recent Canadian Standard. Even Europe does not have a complete ban on parallel production – Canada should not either.

    I am very definite that there must be some allowance for parallel production in specific areas similar to the European standard. These include but may not be limited to perennial crops (apples, wild blueberries, etc.) research plots, greenhouse transplants, seed companies, and maybe some livestock operations and/or grazing fields.

    I understand the comments by those who say there is risk with parallel production and that it should be discouraged, but if parallel is not allowed at all, then organic production becomes unattainable for many. I am not interested in setting up a separate company just to get through a legal loophole.

    For some crops (especially perennial crops) there is a huge amount of risk in going fully certified organic with the whole operation. There are apples for example that are scab susceptible and it can take many years to change varieties to avoid parallel production. Wild blueberries are another case of a challenging crop to grow organically. Parallel production helps a grower learn what he needs to know without being ruined financially.

    We will have to give up organic certification if there are not some exceptions made for legitimate parallel production. The purists may be happy to see fewer organic operations, but in the long run the organic movement will suffer.

    I don’t see a need to have all parallel production allowed, as it is in the US. We can still maintain customer confidence and an ethical system that includes as many as possible by going with a system like Europe.

  26. Dr. Iris Thorogood permalink
    March 3, 2010 7:37 pm

    Parallel production? NO. I do not believe that is truly possible…there is bound to be some cross contamination…..Iris Edna Thorogood, M.D.,C.M.

    • Derek Campbell permalink
      March 5, 2010 6:36 pm

      But is this cross contamination less “bound” to happen if I create a new company to handle the paper work for the organic land and crops?

      Are you suggesting parallel production should be banned for processors as well?

  27. stefan permalink
    March 4, 2010 4:37 pm

    Well I run my own body with parallel production. I eat organic produce almost all the time at home. But when I go out to a restaurant I am surely eating conventional and genetically engineered foods. And what about visiting friends to share a meal?

    Should I be expecting a farmer to not be able to do the same? And why have a standard that a farmer needs to uphold but a processor doesnt? Why not pull the ability of processors to run parallel production facilities?

    Philosophically I would rather just see a ban on non-organic production so I dont have to make the choice on whether to eat pesticides and herbicides or not. Sure people will say that we would never be able to feed the planet if that happened, but people are still going hungry today regardless. It would all balance out as folks turn golf courses into community gardens. I also know that transnational-corporations and the lackeys that serve them in the governments would never allow such a thing to occur anyhow. Call me cynical, but I think that creating national standards and then modifying them to be in sync with other nations is trying to create the illusion of trust and integrity. That way no one has to really know where their food comes from and we can just “trust” that the little stamp on the box or package tells us that everything is OK.

  28. Brent Harris permalink
    March 7, 2010 6:42 pm

    Many of the comments listed seem to understand the complexities involved in commercial sized organic farms and parallel production. In a perfect world all agricultural production would be organic but until we reach that critical mass we have to evolve to that point. I believe allowing parallel production with the oversight of the certification process is one step that will help us to grow forward and reach that goal. Disallowing parallel production will hinder the growth of the organic industry in Canada. The following is an example of why parallel production is critical in our farming operation.
    We are a 5th generation family farm and since 1993 we have brought on 824 acres into organic production. We also work with another grower to manage an additional 660 acres of organic production. If our operations were not able to maintain parallel production we would not have been successful in transitioning this much land into organic production. We feel that the Canadian Standard should be the same as the US National Organic Program which allows parallel production if it is undertaken in a way that allows clear separation of crops and records.

    In our situation we farm in an area just outside of Vancouver. Land values are between $50,000 and $100,000 per acre. Buying land at these prices is not an option so most of our production is on leased land. Most of these leases are year to year. Under these circumstances transitioning land to organic production can be a challenge. Having a viable conventional branch in our operation has allowed us to rent and maintain land that we can steadily bring into organic production when the circumstances are right. These circumstances could be market, labour, equipment, management skills, viable transitional crops and suitable land. In some cases land is not suitable to switch to organic production. Some leases are rotational leases that have us growing peas or beans in rotation with a conventional dairy farmer growing corn or grass and then a conventional potato farmer growing potatoes. Working with these growers to achieve crop rotation is a very sustainable farming system that employs many organic farming principles but obviously can’t fit into certifying the land for organic production. Other land can not be certified because of restrictions that the owner places on the land. Some of our land is next to a hotel which restricts us from using manure , another piece of land is next to a greenhouse which does not allow potatoes to be grown so that no pests from the potatoes can affect their tomato production and that limits us on our rotation so that piece is not a viable option for organic production. Some land is adjacent to activities that limit its suitability for organic production. We do not want to give up these leases because we feel that in time circumstances may change and at some point we may be able to transition them to organic. I don’t think it is fair to punish our family and not allow us to farm land that has not been put into organic production yet due to circumstances out of our control. We believe strongly in the benefits of developing an organic system as we have proven that by the amount of land that we have brought into organic production. Many of the techniques that we use successfully on our organic land are also used on our conventional land such as cover crops, manure, maintaining hedgerows, cultivation for weeds, rotation etc. So even though we farm land that isn’t certified it is still benefitting from our organic practices. Many conventional farmers in the area are also learning these sustainable practices and applying them to their operations as well.
    Having conventional production gives us benefits other than keeping land available to someday transition to organic. Our research team can trial products that have not been approved for organic production yet. They can work with different organic techniques on crops that we aren’t comfortable growing organically yet but hope to in the future. Having a conventional market can be useful in absorbing transitional or excess organic crop. One of our most successful crops is organic beans grown for processing. Organic beans need to be planted in the mid to late season production window. Early season beans are unsuccessful because it is too cold and wet and untreated seed will rot, the beans are too slow to grow and weeds overcome the crop. The canneries need to allocate production fairly to their growers and giving the best window to just organic production isn’t fair. We use the early window to grow conventional beans so that we can concentrate our organic beans in the prime growing window . This year we plan to trial organic processing peas, peas are a crop my family has grown for generations and is an important part of our livelihood. We tried organically growing this crop unsuccessfully in the past, but with experience we’ve gained over the years, we believe it’s worth another shot. We plan to start small and see where we get. In a scenario where we were not allowed parallel production, we would never attempt this .
    Every year we grow over 10,000 tons of fresh market organic produce and organic livestock feed. None of these crops are under parallel production. Over and above these crops is our organic and non-organic processing bean program. No parallel production crop is grown in the same field. The processor has control over what variety is planted and the processor who is also certified as an organic processor harvests and hauls the beans to their facility. There is zero chance of comingling by the grower. Each field is individually contracted to the processor and exact records are kept for each field by the grower and the processor.
    Having said all of this there are some basic things that must be kept in mind. It would be very difficult for a conventional farmer to go through the learning curve of transitioning to organic and finding a market for their organic products without being able to support themselves in the meantime by growing what they know. Farming is not a career that many jump into or start from scratch. It takes a huge amount of capitol that is built over time. It is unrealistic to think that all of these assets can be put on hold while a grower waits for his operation to be transitioned to organic. If organic systems are going to be viable and the end game is to get more producers growing organically then a verifiable system needs to be in place that insures organic integrity if parallel production is part of that farm system for whatever reason. I hope that I have given you a few reasons why parallel production can be part of a successful farm plan. If parallel production is not allowed because a few may try to cheat the system then they will find other ways. If growers must be transparent with their entire operation the organic system will keep its integrity.

    Brent Harris

    • Gail Mowatt permalink
      March 8, 2010 6:10 pm

      We are at that pivotal point in organics. Most of the small operations that are organic minded are already in the program. How are we to encourage large scale operations to become organic, if we don’t allow them an opportunity to come on board gradually? They have too much at risk to bring their whole operation into the program in one swooping action. If you put in the measures that the EU has, you are building a possibility for change. At some point we have to trust that the system can work. As the parallel production currently stands, you are not giving them an opportunity to even try to make the change. This current approach is exclusive and continues to keep the “other” out of organics. I would like to think that this could be an educational opportunity to include others in the dialogue. Shouldn’t we be applauding large organizations who wish to come on board? If a conventional operation wants to try and see if organics is for them, why would you want to discourage such a positive initiative?

  29. Marvin Dyck permalink
    March 8, 2010 6:38 pm

    The majority of our organic fruits and vegetables consumed in Canada come from the US where parallel production is allowed. Apparently the Canadian organic consumer has already voted in favor of parallel production.

    Organic farming is all about the soil. How is it that a processor is deemed to be more reliable in following organic principles than a farmer?

    Organic farming is about trust. I am in favor of parallel production since I know the organic integrity of the product can be maintained. No matter what type of system you favor, you can cheat. Let’s have a certification process in place that lets a producer show they are capable.

  30. Yvonna and Roger Breed of Marlinspike Gardens permalink
    March 14, 2010 6:37 pm

    Roger and I would agree to A or B but not to C. CC members would have to be on the farm every day to avoid mishaps. We would have serious concerns about organic production if C were allowed. I personally question the integrity of any farmers who pushed for C, Yvonna and Roger Breed of Marlinspike Gardens

  31. Daniel Terry permalink
    March 15, 2010 2:41 pm

    I am opposed to parallel production. In fact I would much prefer it if it weren’t allowed for processors, as well as growers. Inclusion of parallel production allows too much scope for abuse by unscrupulous businesses who see a partial venture into the organic sector as a quick way to increase market share and make some easy money.

  32. Gabriele Wesle permalink
    March 17, 2010 10:19 am

    Parallel production should ideally be avoided for it offers the perfect ground to mix organic and non organic products. The organic food chain should be totally separated from the non organic one in order to maintain integrity of organic production and ease monitoring procedures.

    However, economically speaking parallel production may be the best avenue for some producers and/or processors, like bee keepers or seed growers.The issue should be adressed by taking each specific case into account. I see organic production standards being compromised if there is no differentiation possible between the crops being grown, so parallel production only if there is differentiation by crop by identification type or by time grown and handled.
    I would to follow the european rules.

  33. Larry Nason permalink
    March 26, 2010 11:33 am

    I would like to express my thoughts on this issue. Our farm will not be involved with parallel production and we would like to see all certified farms do likewise. Having said that, we understand that there are numerous situations that make it very difficult if not impossible for this to happen. We are in an age where it is very difficult to turn a profit or break even farming full time so parallel production should be allowed. I would like to think that once the certified organic portion of an operation is profitable then the non organic portion would be transitioned to organic ( I know that there are cases where that is not feasible but not the norm). We have got to be very careful with how we deal with processors that have parallel productions. Most producers would not have the market for their products due to economy of scale in processing. So for the time being we do need both parallel producers and processors. I would like to think that the certifing bodies are going to be encouraging whole farm transition as quick as possible.

  34. Hubert permalink
    March 30, 2010 3:34 pm

    The current discussion shows the sides of larger farms and of the small farms. Larger farms advocate the parallel production with strict oversight of a CB, as this would be the most practical solution.

    While the whole farm concept would be the ideal situation, from a regulation and control perspective it is a position that easily can (and has been) circumvented. The producer splits his operation in two legal operating entities, with or without separate land holding. One farm can lease land from the other farm, share equipment etc. and will still be certified in its own right. From a CB point of view we would rather see the oversight on both farm entities, and with the parallel production with strict oversight this will be the case. Thus, while the whole farm concept is preferable, the oversight is only on the split-off portion, while the other portion of the farm has no oversight at all. Oversight on both areas (certified and conventional) and asking for control systems in both portions of the farm – as it is one operations it is easy to have such conditions in place – will keep the whole operation honest. It will also lead to an easier transition process to the whole farm being certified, as the conventional part can be “prepped” for transition and the whole entity gets to be known by the CB (and CC) .

    From a practical farming prospective – and as has been eloquently described in this blog-chain, it is less risky to start the organic operation with a small split-off of the main conventional farm operation. Although the Standard asks for a transition plan, such a plan is never carved in stone. It is not the role of the CB to be a regulator where the farmer and the CB (or CC) negotiate strict schedules and deadlines for a conversion. Such a role is not included the standard, and the CB will not have the stick to enforce it. Therefore it would be better to have a system where the division between certified and conventional production is based on each year’s plan update and market conditions. If the farm ends up as a complete certified entity, that would be a bonus. In the mean time the CB/CC will put in conditions that ensure the strict adherence to the product segregation. Once these systems are in place, they are easily monitored with audits. One does not need to be on the farm at all times to “control” this.

    We can accept parallel processing/handling with control systems and oversight in place, why not parallel production?

    • Richard Favreau permalink
      April 14, 2010 2:59 pm

      Je m’oppose à l’autorisation de produire la même denrée, dans la même unité de production de façon à la fois biologique et conventionnelle. Je pressens des difficultés de contrôle de l’intégrité de sproduits biologiques et je crois aussi que cela ouvre la porte à des mélanges de lots malattentionnés.. et lucratifs.

      Quoique la certification biologique ait pour objet les produits spécifiques dans son application légale, elle a dans l’esprit qui oriente ses règles l’évolution des systèmes de productions et des philosophies de gestion.

      Ainsi, les critères de certifications expriment plus des moyens de mesures minimales que l’atteinte des objectifs poursuivis qui sont plus vastes, et difficilement mesurables.

      Les critères de certification sont à cet égard réducteurs. Normalement, une entreprise engagée dans la crtification devrait dépasser la simple atteinte de ses critères et adopter multiples pratiques s’inscrivant dans une vision holistique de la ferme.

      Permettre la double production de fait que répondre à des objectifs mercantilistes et opportunistes.

      Toutefois, une certaine ouverture, très circonscrites dans le temps et l’espace, avec un contrôle approprié et plus serré, pourrait être concédée aux établissements en transition qui convertissent progressivement leur parcelle à l’agriculture biologique. Par exemple, les productions conventionnelles permises devraient être pré-certifiables (i.e. répondre à tous les critères de certification excepté le délai de trois ans documenté sns pesticides ni engrais de synthèse) et dûment inspectées au mêm tuitre que ls productions biologiques.

      • rousseau martin permalink
        April 14, 2010 5:39 pm

        Je suis contre la production paralelle, ceux qui veulent faire cette sorte d’agriculture se fichent du bio; ils ne sont intéresés que par l’appât du gain. Méfions-nous.

      • April 14, 2010 6:52 pm

        Par mon expérience sur le terrain, par la connaissance des normes biologiques, je suis catégorique: opposition stricte à la culture parallèle sur une unité de production biologique.

        Ne nous cachons pas que, même si les registres s’avèrent bien complétés, (tout peut s’écrire!) et excellente ségrégation, l’intégrité du produit bio peut être difficilement respectée.

        De plus, cela peut amener plus de producteurs à revendiquer, dans leur espace de production, des produits bio et des produits conv. Plus de gestion entre les parties, qui sème plus de doutes…

  35. Gaston Bélanger permalink
    April 14, 2010 10:07 pm

    Je suis catégoriquement contre l’autorisation de toute forme de culture parallèle produite sur la même entreprise certifiée biologique.

    Je crois sincèrement que ceux qui propose un tel mode de production n’ont en tête que les possibilités lucratives du bio et non les raisons fondamentales et convictions profondes qui nous poussent et inspirent , producteurs et productrices certifiés biologique, à produire et distribuer le fruit de nos efforts avec intégrité et fièreté.

  36. Marc Bérubé permalink
    April 15, 2010 1:53 pm

    Bonne journée,
    Pour demeurer crédible encore longtemps et en faire un message clair, la certification Bio. ne devrait accepter ancune flexibilité. On est Bio., ou on ne l’est pas. Ce n’est pas en assouplissant les normes que lnous rassurerons et augmenterons en nombre les consommateurs.
    Bien sûr le Bio. est une façon de faire, mais il ne faut surtout pas oublier que la grande force du Bio. est de nourrir les microorganismes du sol. On ne peut être chimique et Bio. en même temps et les microorganismes du sol ne supportent pas les intrants chimiques et violents. L’unité de production sur une ferme devrait être protégée et exigée, sauf peut-être, sur une ferme en transition ou encore sur une ferme avec champs et avec serres, où jamais on ne cultiverait les produits de serres en champs (ex.: tomate), si ce sont les serres qui sont certifiées Bio. et vice versa.
    La certification Bio. ne doit pas s’assouplir, sinon elle perdra sa crédibilité, et chez les producteurs, et chez les consommateurs.
    Bonne journée souriante, Marc Bérubé, paysan certifié par Ecocert-Canada.

  37. Julie Malenfant permalink
    April 15, 2010 1:59 pm

    Je suis contre la production parallèle. C’est déjà difficile pour le consommateur de démêler les différentes appellations et certification (terre vivante, biologique, sans intrants…). Pour le consommateur, c’est une question de confiance envers le produit. Il faut éliminer les doutes et les erreurs possibles. C’est une question d’intégrité.

  38. IDA Michaud permalink
    April 19, 2010 10:40 am

    Parallel production? NO-NO-NO
    More flexibility on the issue of parallel production? NO-NO-NO
    ORGANIC = healty and living soil = healty and living food.
    Organic producers will not appreciate.

    Contortion of strict rules is not the label of organic food

  39. Geneviève Lemire permalink
    April 26, 2010 7:33 pm

    Merci d’offrir aux acteurs du bio une tribune pour exprimer leur opinion et permettre ainsi d’approfondir la question.

    Comme bien d’autres l’ont déjà exprimé, je suis contre les productions parallèles car elles sont incompatibles avec la philosophie du mouvement bio. Peu importe les arguments apportés par ceux qui sont pour, le fondement de leur argumentation revient toujours à l’aspect monétaire. L’agriculture bio ne pourra garder sa crédibilité si l’argumentaire financier est mis en priorité sur les aspects humains et environnementaux, comme ça l’est déjà en agriculture conventionnelle.

  40. Cathy Holtslander permalink
    May 18, 2010 2:24 pm

    Parallel production is growing the same crop organically and non-organically at the same time. It is NOT having part of your farm organic and part in transition, or having part of your operation certified and part not certified.

    The problem with allowing parallel production under our Canadian Regulation is how such a rule could change the structure of organic agriculture in Canada. Parallel production would allow farms to set up/operate with absolutely no intention of transitioning into full organic certification. Rather than being concerned about how an existing organic farmer might be tempted to cheat, I think we should be concerned about big corporate farms that have no organic values whatsoever using this rule change to add a side operation of organic production as a business opportunity. Because these corporations are interested in expanding and increasing their market share, I expect the result would be that the parallel production operators would use their clout to undercut full-time organic farmers and force prices down, perhaps even put them out of business altogether.

    Furthermore, in the US the “organic brand” has been seriously damaged by the parallel production practices of large corporate farms. The result is that a lot of consumers see the organic label as a bit of a sham, and a method to extract extra money from their pockets. I don’t think we want that to happen here in Canada.

    I think there may be the odd legitimate exception that could be allowed, but that should be dealt with on a case by case basis, and reviewed regularly to see if the original conditions still apply.

  41. monty permalink
    July 19, 2010 6:03 pm

    no do not allow parallel production. there is just to big a chance of mixing up with chemical grains.

  42. April 13, 2011 7:22 pm

    My first thought was no side by side operations, however, after reading some of the comments, I think perhaps it should be decided case by case, since all situations are different.

  43. November 29, 2014 5:12 pm

    What’s up to every single one, it’s in fact a pleasant for me to pay a
    visit this web site, it consists of valuable Information.

  44. December 4, 2014 6:49 pm

    I feel the fee is what might discourage small – say under 5000.00 to stay as certified – if there was a way to make the fee more reflective of what the small producer can afford we could get more farmers certified


  1. Changes to the Organic Standard « ACORN the blog

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: