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
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
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.
farm 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 management.”
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 before use.
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.