Ossendrecht, 14 maart 2006

Afz:
Hugo Jansen
Laagstraat 30, 4641 SP Ossendrecht
The Netherlands

Tel: 00 31 164672403 | Fax: 00 31 164674512 | Mobiel : 00 31 624 545 506

To: The IOAS, to Mr. David Crucefix.

About: The accreditation of ACT, Thailand.

Dear sir,

With this letter I want to inform you that I have found fraud at a farm in Thailand which is certified by an organisation that is accredited by IOAS:  NN. (NN)

The adress of the farm is:  Thailand, province of Kanchanaburi, Village of Bankao or Ban Kao.    NN has two farms there. The conventional one is called Bankao-1. The organic one is called Bankao-2. I did visit both farms on 14, 15 and 16 december 2005, and spoke to the chief of mechanics, mr. Phaholrat. The boss of Bankao-2, mr. Wichai was at a conference in Pechaburi, planning the future strategy of the company with all other NN top executives.

The facts:
The fraud consists in this: I have found seeds that were treated with chemicals in the soil of one of their fields. It happened on the 16^th of december 2005.

The seeds were sweetcorn-seeds ( as opposed to babycorn), which I concluded from the seeding distance. The plants were about 35 cm apart in the row, and not 12 cm which is normal for baby-corn.  At that moment the corn was about 10 cm high.

I have visited Bankao-2 four times. At the third time I saw a tractor with a machine for seeding 2 rows of corn behind it. In the seeds-reservoir I saw treated seeds: seeds with a red-purple color. As Mr. Phaholrat had told me that NN used to grow sweetcorn at Bankao 1 in the past, but now they grew their sweetcorn in Chiangmai province, this machine was very probably not used on Bankao-1, but on Bankao-2, the organic farm.

This gave me to the idea to go back the next day, search for a field of young sweetcorn, and pick out some plants to check.  So I did, and I did indeed find treated seeds still hanging at the roots of the small cornplants. I took two plants plus seeds back home.

As the corn I found must have been seeded several weeks before, and the tractor was standing there with treated seeds in the reservoir, it may well be that the field which I found  was not the latest to be seeded with treated seeds.

A second fact and reason for complaint is this:
NN is controlled by ACT, which is accredited by IFOAMS accreditationbody IOAS.
NN should be on a ACT- list of certified producers of organic produce. It is not.
The Thai certification body ACT did not comply to IFOAM norms 5.2.1.h.

After repeated request they never produced a list of producers (certified by them) that contained NN as a member. You will find details of this at enclosure 1.

Four other reasons for concern:

1. Not enough fertilizer.
I inquired at a nearby company how much Nitrogene is needed for 1 hectare of sweetcorn.

From its chief  mr. Manoon Sritaikham I learned that normally you use 105 kg of Nitrogene per hectare. Also I learned that he sells organic fertilizer, and that this contains between 0,5 and 2 % of Nitrogene.
To replace artificial fertilizer by organic fertilizer, and yet give enough Nitrogene, one should give a lot of organic fertilizer.
One 100 kilo contains on average 1,25 kg of  N.   To have 104 kg we need  8300 kg.
Organic farmers apply their manure or fertilizer almost always right before seeding. On my visits at Bankao-2 I saw two fields being prepared for seeding, and I saw the organic fertilizer that was waiting to be spread out on the fields.
One field was about  a half hectare. I saw 12 bags of organic fertilizer lying on the field. That could be 300 kg. So they use 600  kilo per hectare, instead of  8300 kilo’s.
On another field I saw heaps of burnt rice skins (chaff) , that is what it looked like. As mr Phaholrat told me: these skins from rice seeds were ‘composted’  for 6 months. Per hectare there were about 24 kuub . But the weight of  this chaff is very low. It may have been 2400 kilo.  The percentage of N in this is probably very low. It looked like ashes, and was a little warm too, if I did feel it well.

There seems to be a fertiliser deficit on this farm. How do they fill this gap?

2. Are they using dissolved artificial fertilizer ?

On my orientation travels through Thailand I have learned that conventional farmers dissolve artificial fertilizers in water and then inject it near the roots of young plants (potatoes that were very small). The advantages will be: no loss of N. by heavy rains, nor by long draughts; immediate intake by the plant is possible;  application near to the roots so that it will be used instead of washed away. If organic farmers would use this method there would be an extra advantage: chances of being ‘caught’ are very low.
On several fields of this farm I saw plastic vessels, 200 liter oildrum size, standing. They contained water.  But why ?  What was their purpose?  The whole farm has around 6 or 8 hose reels. In fact: the size of the plots was comlpetely adapted to the capacity of the hose reels: each field was about 200 meters long and 40 meters wide. In the middle was a path for the tractor to draw the hose and irrigation gun out. Some smaller fields  had a web of small sprinklers.  Yet there is this water barrel/vessel standing.  It remembers me of an organic farm in Portugal which I also visited unexpectedly. There were one or 2 hose reels on that farm too, yet I saw small old women watering the small onionplants with wateringcans. As I came nearer I saw that the boss ( a woman) was throwing in bottles of chemicals into the barrel out of which the wateringcans were filled.

3. Scholars say that organic sweetcorn is very difficult to grow inThailand.

At Kasaetsart University near Bankok I spoke to the following scholars (See enclosure 5)

Professor Ed Sarobol ph.D. Director Crop research.
Dr. Chokechai Aekatasanawan. Senior researcher Corn and Sorghum.
Wiwat Suasa-ard  Ph.D.  Director of national Biological Control  research.

At Chiang mai University:

Dr. Saran.  SME management (The Royal project)
Dr. Pittaya Sarvamsiri. Industrial vegetables.

At Maejo University I spoke to:

Mr. Prawit Puddhanon M.Sc. plant breeding, specialised in corn.

From all these talks two conclusions emerged: It is very difficult to grow organic sweetcorn. There is a long list of bugs and funghi that make it difficult. Another big problem is that there is not enough fertilizer.  One or two respondents mentioned River Kwai  and said that NN seemed to be able to overcome problems because of certain breeds: sweetcorn varieties that can withstand the threads.  They must have felt that it is very unprobable to have a variety that has only good characteristics, and they did not tell more about it.

4. Companies that sell organic produce say they cannot produce organic sweetcorn ears (See enclosure 5)

In the Chiang Mai province I visited several companies:
Lanna Agro Industry  Co.ltd.  Mr. Anucha Hiriwiriyakul
Sun Sweet Co. ltd. (a.k.a. Sun Valley) Mr. Khanson Somna
Chiangmai Frozen Foods Public Co.ltd.  Mr. Prapas Pholpipattanaphong

They all have organic products in their prospects, and are known as such.  Only Mr. Anucha from Lanna Agro was able to sell me organic sweetcorn ears. He was going to make an offer for me. I asked him whereabout he was going to grow the corn. He answered that he would buy it from another company: Sun Valley.  But I had just visited Sun Sweet (= Sun valley), and they were unable to sell it to me. They were producing very small amounts of organic corn which was flown to Taiwan to be sold fresh. It was a difficult and unsuccesful trial so far. That is what I learned from Mr. Somna.

Had I not popped up at their plant and just inquired by phone from Europe, I might have been able to buy organic corn ears. I made it clear that I was going to do some controlling.

I was and still am interested in buying genuine organic ears.

_______

Reasons for filing a complaint this late.

Why do I file this written complaint 3 months after finding the facts?

1. After returning home I have tried to find independent people of some reputation to fly toThailand and corroborate what I had seen. I did not find them. Not even when I offered them to pay the flight myself
2. From past experiences I have learned that filing a complaint does not mean that it has consequences for the perpetrators. In these 3 months I have learned a lot about international control organisations ( certifiers and accreditors). In essence they rely on local controllers. This they do everywhere in the world, regardless the country’s position on the CPI: The Corruption Perception Index.
   Thailand has a score of 3,8 . As much as 73 countries in the world have a better score.
   The U.K. has the same as The Netherlands: a score of 8,6 which is fine.
   If I file my complaint nothing will be found. The most I can expect is that a controller will loose his job, and one of the many fields of NN will be taken out of production. Nobody knows how many fields NN has and where the sweetcorn is produced. They can even double their export after being ‘caught’ !
   It simply has no effect.
3. When I phoned to ACT last november and asked to speak to Mr. Vitoon Panyakul, he was not there. Mrs. Natrudee told me he was one of their controllers. (He is also ‘boss’ of Greennet, which is certified by ACT. So he controls himself in this case).  If I would doubt the quality or integrity of ACT I could complain at IOAS. But there we meet Mr. Vitoon in two functions: as a member of the board and as a member of the accreditation committee. If I would feel uneasy with all this I maybe could go to the president of IFOAM. This was until last september Mr. Rundgren, a swedish entrepreneur with a large Consultancy. It might be mr. Vitoon Panyakul picking up the phone, because he is also an employee at Mr. Rundgrens Grolink company.Enough to make a man a sceptic, I believe.
4. On the other hand: if I do not file a complaint I cannotset in motion any control.
   That is why I decided to file a complaint. To see what will be done next.
   I do not expect that it still is possible to find the treated seeds on the field where I found them.
   But I may be wrong there.

 What I would like to see happen is this:

• I would like thatACT(the Thai controller of NN) will not be notified of this complaint.
• I would like that a non Thai controller would go to the fields of NN ( At Bankao 2 and preferably at other production sites too) andlook for recently emerged sweetcorn plants.

I am convinced that they will find treated seeds. If not, then I would like to hear immediately about the exact location of these fields. I would like to go there and see it for myself.

• Another thing I would like to be clarified is the question how this corn receives the 105 kg. ofNitrogenethat it needs. I spoke to Mr. Rob Hardy at Biofach and he told me it would be possible to clarify this.
• Finally I think it would be normal if all the production fields of NN would be published, and not stay a secret as it is now.  In the “IFOAM Norms” book 2005 we read at page 93: 5.2.1.h : The certification body shall make publicly available the following: A current list of certified operators , including name, location and the scope of the certification.

Now we have the situation that a small farmer with a licence for his 0,5 hectare farm has to be on a ‘public’ list of ACT. But a big company like NN which has more than 500 hectares in different parts of Thailand, can suffice with only one adress.
NN sells for millions of euro’s on the international markets and is only controlled by ACT.
Corruption is part of the routine in Thailand, but S.A. and IOAS clearly think that ACT is the exception on the rule. Why ?
ACT does not even mention NN on its list of members, as it is obliged to.  (Enclosure 1)
This omission was not signalled and not corrected by S.A. and by the IOAS. This shows that either S.A. and IOAS don’t have an adequate control before granting the accreditation, or that ACT has shown them a list with NN on it, but is not willing to publish this list upon (my) request.

Yours sincerely, Hugo Jansen