October 14, 2003:
Here are some of the certification-related questions you’ve
asked us recently, along with responses from our answer team.
I am requesting organic certification of my 400 acre farm.
I grow corn, soybeans, and hay in the rotation. I am very
apprehensive about the inspection. What should I expect?
It is the inspector's job to gather information and verify
the accuracy of your Organic Farm Plan and assess your operation’s
compliance with the standards. The inspector verifies the
organic crops you are growing, and assesses the risk of contamination
through observations of field borders, buildings, and equipment
used in your organic operation. You accompany the inspector
to answer questions and provide information about your farming
systems. The inspector may take pictures. Soil, tissue or
product samples are taken if the inspector suspects contamination
or use of prohibited materials, or is asked to do so by the
About half the inspection time is spent reviewing your records,
examining seed and input (fertilizers and pest control products)
labels, answering questions about the Farm Plan and the operation,
and completing an inspection affidavit and exit interview
record. You receive a copy of the inspection affidavit you
sign. At the end of the inspection, the inspector conducts
an Exit Interview to review issues of concern which have been
noted during the inspection.
Tips to help you have a pleasant inspection experience:
- Allow plenty of time in your schedule
for the inspection.
- During the tour, point out to the inspector potential
issues you have already identified or areas of
interest, such as roadside spraying, buffers you already
maintain, wildlife areas, erosion control measures, etc.
- Organize your records. Make sure that
planting, cultivation, harvest, storage and sales records;
seed and input labels; receipts; non-GMO seed verification
letters; letters to local government units or electric companies
regarding roadside spraying; letters to and from your neighbors;
and other pertinent records are easy to find.
- Have accurate acreage totals of organic
and non-organic crops ready, especially if crop plans have
changed since your Organic Farm Plan was filled out.
- Have a total of your crop sales from the previous
year prepared for individual crops, with sales
records or weight tickets available.
Use the inspector as a source of information to understand
compliance to the USDA National Organic Program. Good luck
and have fun!
a certified organic farmer. Why do I need to keep a complaint
log for organic certification? I have never had any complaints!
The complaint log is a requirement for all clients of certifying
agents that are accredited under the USDA’s International
Organization for Standardization Guide 65 (ISO 65) program.
It is not a requirement under the National Organic Program
rules. ISO 65 is an international standard for certification
bodies. Compliance with ISO 65 is a requirement for access
to European and other world markets.
agent instructed me to keep "monitoring records"
for water quality. I irrigate some fields using river water.
What kinds of records should I be keeping?
Monitoring records might include dates and/or times of irrigation,
records of water usage, salinity tests, residue analyses if
specific contaminants are known or suspected, soil moisture
tests, and dates when water filters were changed. Section
205.200 of the rule states, “Production practices …
must maintain or improve the natural resources of the operation,
including soil and water quality.” Your Organic Farm
Plan should outline your strategies to maintain or improve
water quality, including your practices to conserve water,
minimize salinization, and prevent water contamination. Your
irrigation water should not be a source of prohibited materials.
I am a certified organic beef
farmer working on organizing a meat pool to market organic
meats. I have identified several slaughter facilities and
am helping them with organic certification. What issues should
I be concerned about?
First, you should thoroughly read Sections 205.270 through
205.311 and Sections 205.605 and 205.606 of the National Organic
Program Final Rule. These sections detail processing and handling
requirements for organic certification.
In general, commingling of organic products with non-organic
products and contamination with prohibited substances are
two of the biggest issues for all processing facilities. In
order to prevent commingling, slaughter facilities will:
- Isolate incoming animals in a separate pen (labeled "Organic
- Slaughter organic animals first to ensure that equipment
is free of remnants from processing conventional animals
- Identify carcasses as "Organic"
- Keep records, tracked by ear tag numbers of incoming animals,
of all organic slaughter activities. When carcasses are
ready to be cut up or further processed, these activities
are typically done first before other meat is cut up when
equipment, knives and other tools are clean, and non-organic
meat is not present.
To avoid contamination with prohibited substances, be sure
that pest control products are used only on the outside of
the facility, but not in the vicinity of the pens holding
organic animals. Organic products, ingredients, and packaging
materials used for organic products must not come into contact
with pesticides. Develop a plan to move organic products and
packaging materials in the event that the application of pesticides
occurs in the facility. If a structural pest management plan
is not already in place, the slaughter facility needs to develop
a plan to prevent pest problems, compliant with 205.271. Records
must be kept of all pesticide applications and measures must
be taken to protect organic products from exposure.
Records are also needed to document the cleaning of equipment
prior to organic meat processing. USDA slaughter facilities
are required to have HAACP (Hazard Analysis Critical Control
Points) plans in place. Use this plan as your starting point
to develop your written "Organic Handling Plan".
Labeling organic products is also an issue. Design a label
that meets both USDA’s Food Safety Inspection Service
and NOP requirements. The label needs to be pre-approved by
FSIS and your organic certifier. If you make sausage, hot
dogs, jerky, or other multi-ingredient organic products, ingredients
and processing aids need to meet NOP requirements. Available
label claims will depend on whether the products are 100%
organic, contain at least 95% organic ingredients, or contain
between 70-95% organic ingredients.
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