Answers to Your Questions: OCTOBER

Developed by The New Farm® Answer Team

October 14, 2003: Here are some of the certification-related questions you’ve asked us recently, along with responses from our answer team.

1. 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 certifying agent.

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:

1. Allow plenty of time in your schedule for the inspection.
2. 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.
3. 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.
4. 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.
5. 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!

2. I am 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.

3. My certifying 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.

4. 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:

1. Isolate incoming animals in a separate pen (labeled "Organic Animals")
2. Slaughter organic animals first to ensure that equipment is free of remnants from processing conventional animals
3. Identify carcasses as "Organic"
4. 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.