02 / GOVERNANCE

Rules before reputation

Independence is
an enforceable structure.

ICS governs how a contaminant certification standard is set, kept independent, reviewed, versioned, and enforced. Each program publishes its own limits and methodology; this institutional surface publishes the rules around them.

PUBLISHED CONTROLS

Impartiality, conflicts, publication ethics, corrections, and appeals.

The governance model now resolves to a controlled policy register with identifiers, effective dates, current status, and a versioning rule.

Open policy register

EVIDENCE GOVERNANCE NOTES

Every major synthesis now has a public standards disposition.

The register states what each finding changes in scope, testing, surveillance, or claims—and why it cannot silently choose a limit.

Open evidence notes

01 / SEPARATION OF POWERS

What each face may publish is fixed.

The firewall is defined by permissions and prohibitions, not by whether two properties share an operator.

01

The index

MAY

May publish literature and regulatory evidence.

MAY NOT

May not publish a certification threshold, endorse a certifier, or expose brand-level program data.

02

The certification program

MAY

May publish the standard, methodology, analyte coverage, and certification requirements.

MAY NOT

May cite the index for context, but may not make the index justify or endorse a certification decision.

03

The Institute

MAY

May govern method, impartiality, registry structure, verification, enforcement, and revision rules.

MAY NOT

May not publish program threshold tables or private brand-level records on the institutional surface.

02 / MECHANICAL FIREWALL

Enforced in the build and in the data plane.

BUILD BARRIER

Threshold language is rejected on index surfaces.

A build-blocking check prevents certification-framed thresholds, percentile candidates, and derivation records from publishing on the literature index.

DATA BARRIER

Public properties cannot read private program records.

Evidence, standards workbench records, certified-lot findings, and brand-level data occupy separate data states and publication paths.

CITATION BARRIER

The program may cite the index. The index never cites back.

One-way citation supplies literature context without allowing the evidence surface to endorse a commercial certification decision.

03 / HOW INITIAL STANDARDS ARE SET

Government-anchored at publication. Separately ratcheted later.

The literature index describes occurrence and context. It does not choose an initial certification value.

1

Define the exact cell

Fix product form, intended consumer, analyte species, unit, and native basis.

2

Find applicable sovereign rules

Identify credible government maximum levels that govern the exact cell.

4

Disclose the unresolved edge

Use sovereign read-across, a documented control, or keep the cell in development.

POST-PUBLICATION

The Standards Ratchet uses eligible certified-lot data, never the public occurrence pool.

Tightening requires broad, sustained performance under the separate governed trigger and a published transition record. The starting anchor and the later ratchet use different data, at different times, for different purposes.

04 / OVERSIGHT & CONFLICTS

Common ownership is disclosed. Authority to overrule must be real.

ICS is operated under Paleo Certified, Inc., which also operates the literature index. That relationship is stated plainly. Structural independence depends on documented decision rights, recusal rules, data separation, and outside review rather than obscured ownership.

Being constituted

Standards & impartiality committee

The governance model assigns review and override authority to members without certified-brand or certification-revenue interests. Committee composition and the conflict register will publish as appointments are completed.

Published by rule

Conflict and separation policy

Literature curation, methodology authority, and final certification decisions are separated by role, with conflicts declared and recusals recorded.

In pursuit

ISO/IEC 17065 accreditation

ICS is pursuing third-party accreditation of its product-certification controls. Until granted, accreditation is stated as an objective, never a credential.

05 / MARK USE & ENFORCEMENT

A certificate states what was tested. It does not declare a product “safe.”

MARK USE

Coverage travels with the certificate.

The mark identifies a stated standard, basis, analyte panel, and certificate number. Covered and uncovered analytes remain visible alongside the claim.

ENFORCEMENT

Status is current, not ceremonial.

Certifications are live relationships. A mark can be suspended or withdrawn, and verification must reflect the current state at the moment a record is checked.

PUBLIC NOTICE

Enforcement is reported as an event.

Public notices name a party only where the matter is already public record. The institutional site does not become a brand directory.

Current program

Heavy Metal Tested & Certified

Current standards, effective dates, methodology, and certification applications are published by the program, not duplicated by ICS.

Open the standards index