JULY 9, 2003:
Here are some of the certification-related questions you’ve
asked us recently, along with responses from our answer team.
I am planning
to purchase an existing organic farm. I have never been certified,
but the farm I am purchasing has been certified for 5 years.
Can the farm’s certification be passed on to me?
Even though the farm you are purchasing is currently certified,
you need to complete an Organic System Plan and be certified
by an accredited certification agency in order to sell organic
products. (If you sell less than $5,000 of organic products
annually, you need not be certified, but you must comply with
NOP organic production standards in order to market your products
as organic). To expedite the process, if you have permission,
you can draw on the previous owner’s organic plan for
ideas, and possibly use their maps and field history sheets.
(Make sure that all information is still accurate.) You might
also be able to work with the seller and the certifying agent
for the seller’s certification to remain in effect while
your paperwork is being processed.
On the other hand, if the farm is incorporated, and you become
part of the corporation, then all licenses and/or certifications
would remain in force. The operation would need to be re-inspected
and the certification and Organic System Plan updated, but
a new certificate would not need to be issued. At any rate,
you will need to be inspected and approved before the operation
is certified in your name. Check with your certifier for the
exact procedures to follow. Since the farm is currently certified,
the process should be relatively seamless.
I plan to purchase has 5,000 bushels of certified organic
soybeans in a grain bin on the farm. Can I purchase the soybeans
with the farm, and still sell them as certified organic?
Good question. Buying, storing, and re-selling the soybeans
would make you a “handling operation”. Here’s
why. The NOP defines handling operation as “any operation
or portion of an operation (except final retailers of agricultural
products that do not process agricultural products) that receives
or otherwise acquires agricultural products and processes,
packages, or stores such products.” If you buy the bin
full of soybeans, you would be “acquiring” and
“storing” organic products. In addition, the NOP
defines handle as “to sell, process, or package agricultural
products, except such term shall not include the sale, transportation,
or delivery of crops or livestock by the producer thereof
to a handler.”
Since you were not the producer of the soybeans, and you
would take physical possession and store the crop, you would
be acting as a handling operation in this instance. As such,
you should conclude your own certification prior to selling
the soybeans. That way, certification can be passed on, and
new certificates or transaction certificates issued, without
any problems. Make sure to keep a copy of the grower’s
organic certificate, along with an invoice or receipt for
your purchase of the soybeans. It would also be good to get
a copy of the grower’s bin register or storage record
for your file. Start your own bin register for the grain bin,
and include the purchased soybeans as starting inventory.
Make sure to assign a lot number when you sell the soybeans,
and use bills of lading and clean transport affidavits when
the soybeans are sold. Keep copies of your sales invoices
and scale tickets.
How do I get
my honey certified organic? It's from Mexico.
Though there are no specific apiculture standards in the
national organic regulation, the USDA’s National Organic
Program issued a policy statement on May 2, 2002, indicating
that honey and other agricultural products can be certified
organic. Some accredited certification agencies offer apiculture
certification. If the honey is to be sold as “organic”
in the United States, it needs to have been certified by a
USDA-accredited certification agency. You will find a list
of accredited certifiers at www.ams.usda.gov/nop/CertifyingAgents/Accredited.html.
For additional guidance, you should read the National Organic
Standards Board’s Apiculture Task Force Report from
September 15, 2001, which can be viewed at www.ams.usda.gov/nosb/lscommRMR/reports/apiculture.html
I am planning on getting two
fields certified organic next year. One of the fields borders
a subdivision. I know that I need a buffer zone for fields
that border conventional crop production. Do I need a buffer
zone where my field borders suburban lots?
NOP section 205.202.c requires that “any field or
farm parcel from which harvested crops are intended to be
sold, labeled, or represented as "organic," must
have distinct, defined boundaries and buffer zones such as
runoff diversions to prevent the unintended application of
a prohibited substance to the crop or contact with a prohibited
substance applied to adjoining land that is not under organic
If suburban landowners are applying prohibited materials
to land which adjoins your organic field, then you would need
to maintain a buffer zone to prevent the prohibited materials
from contacting your organic crop. On the other hand, if the
landowners all agree not to apply prohibited materials near
your field, you might not need a buffer zone. (Your certification
agency would need to accept such an arrangement.) You would
need to get the landowners to agree annually in writing, (on
forms commonly called “adjoining land use affidavits”),
and you should maintain copies of the affidavits in your file.
I’m a dairy farmer. What can I use for fly control in
the barn and in the milk house?
In order to be certified organic, you must implement preventative
practices and proactive management to control flies and other
pests, both in the barn and in the milk house. Approved strategies
include: 1) augmentation or introduction of predators or parasites
of the pest species; 2) development of habitat for natural
enemies of pests; and 3) non-synthetic controls such as lures,
traps, and repellents. Good manure management; pasture rotation;
clean, dry bedding; moisture control; and release of fly parasites
are all part of successful fly management systems. In addition,
many dairy farmers use walk-through fly traps to remove flies
from cows when they enter the barn or milking parlor. Many
also use sticky strips or tapes, and some use bug zappers
and jar traps baited with attractants. If an insecticide is
to be used in the barn or milk house, the material must either
be derived from natural sources or be on the National List
of Allowed and Prohibited Substances. If you have questions
about any methods or inputs, be sure and ask your certifier
see a lot of products advertised as “organic”
fertilizers. As a certified organic farmer, am I required
to use organic fertilizers?
There is a great deal of confusion about use of the word
“organic” on fertilizers and other products. Fertilizer
labeling is currently regulated by state officials, and most
use the term as in organic chemistry – a compound that
contains carbon. Be aware that fertilizer products labeled
“organic” may contain synthetic urea, other synthetic
plant nutrients, or sewage sludge, all of which are prohibited
for use in organic production. Binding agents and pelleting
materials may also be synthetic, and not listed on the ingredients
label. As an organic farmer, you are required to use fertilizers
approved for use in organic production. These include: compost;
uncomposted plant materials; animal manures (with certain
restrictions on timing of application/harvest); wood ash;
mined substances such as limestone, potassium sulfate and
gypsum; fish products; micronutrient products; and other fertilizers
on the National List. The Organic Materials Review Institute’s
brand name list includes many products that have been reviewed
against NOP standards, and is available at www.omri.org.
Once again, when in doubt, check with your certifier before
purchasing or applying a material.
For a full list of your questions and our
answers as well as some highlighted articles, visit our certification
archives or click on the desired category below.
Allowed and Prohibited Substances