Certified organic farmers do an odd thing –
they pay people to visit their farms with a critical
eye to assure they are adhering to every aspect
of the USDA’s national organic standard.
The farmers should already be trying to produce,
harvest and market their organic crops, livestock
and related products by these rules. The on-farm
review of fields, facilities and records by an
approved inspector sent by the farmer’s
accredited organic certifier is the critical point
in confirming that the farmer and the farm meet
the organic standards – and can prove it
to anyone who needs to know.
The visits are pivotal for applying farmers to
become certified, and for certified farmers to
keep that certification. For the good of organics,
we want to help build the foundation for effective
inspection visits. We’ve asked Jim Riddle
to provide an inspector’s inside view to
help farmers understand an inspector’s role,
responsibilities and limitations. In the months
ahead, Riddle will elaborate on many of the items
mentioned in this introductory column to help
farmers understand regulations that apply to them,
and how to document their compliance.
Jim Riddle has been on hundreds of farms in the
inspector role, and he’s been inspected
himself during his time as a farmer. His leadership
in bringing professional training to inspectors
helped to earn greater acceptance of organic farming
in the U.S. He serves as vice-chair of the National
Organic Standards Board, which advises the USDA
on organic agriculture policies and regulations.
He has been an organic farmer, gardener, inspector,
educator, policy analyst, author, and consumer.
He was founding chair of the Independent Organic
Inspectors Association, (IOIA), and co-author
of the IFOAM/IOIA International Organic Inspection
Manual. Riddle has helped train hundreds of organic
inspectors throughout the world. In 2003, Jim
was appointed Endowed Chair of Agricultural Systems
at the University of Minnesota.
He serves as an organic policy specialist for
August 3, 2004: For me, the best part of being an
inspector is interviewing the farmer. I get the opportunity
to hear first hand the stories of organic farmers - their
successes and failures, their excitement and pride in what
they are doing.
As an inspector, I try to make the inspection a good experience.
I want the farmer to get something out of it. At the same
time, I have to make sure the information is accurate and
the paperwork is complete. Otherwise, certification can be
delayed or even denied.
On one memorable inspection, finishing at midnight was no
fun for me or the farmer. We had started the inspection at
6:00 pm. After inspecting numerous fields and locating the
beef herd in a distant pasture, we sat at the kitchen table
to complete the paperwork.
What took so long was the fact that the 50+ fields had acreage
and number changes (and new maps) since the farmer had completed
his Organic System Plan (OSP). He also had some changes in
the crops he planted versus what he had planned to plant –
a common occurrence. He had not prepared a new acreage list
or updated the farm map. Consequently, we spent about two
hours redoing his “crops requested for certification”
table, since accurate information is required for organic
Many inspections take longer than necessary, often due to
the fact that the farmer is not prepared: previous certification
conditions have not been addressed; maps and field histories
are not up to date; records are not accessible; seed and other
product labels are not saved or are not accessible; organic
harvest and sales records are not available; or records are
not organized to track products from sale back to the field(s)
Other factors can delay the inspection. For example, farmers
often keep old products or containers from prohibited substances
formerly used on the farm. The presence of such containers
raises additional questions, extending the length of the inspection.
Here are some simple ideas to shorten the inspection time:
- Read the letters you get
from the certifying agent. Prepare any information
requested by the certifying agent. During the inspection,
I review all previous conditions for certification and issues
of concern identified by the certifying agent. These letters
clarify what issues I will be discussing with you, so be
prepared to respond.
- Organize your records
in file folders or a ring binder with separate sections.
Have your records readily accessible for the inspection.
- Provide accurate and up
to date written information. If your crop
plans, planting dates, field sizes, crop locations, or input
plans have changed since the OSP was submitted, be prepared
to provide written documentation to the inspector.
- Verify your acreage.
The total of individual organic field acreages must equal
your total acreage requested for certification. To be sure,
add up your individual field sizes and compare to the total
acreage requested for certification, before the inspection.
- Keep all labels and receipts
– this includes seed bags or packets, soil
mix ingredients, and all inputs including fertilizers, pest
control products, animal health care products, animal feeds,
and feed supplements.
- If you use a lot of inputs,
use an input inventory sheet (with columns
for the brand name, source, location used, date first used,
date when approved by the certifying agent, and date discontinued
use). This helps clarify what inputs are used, and if they
have been approved. If an input has already been approved,
the inspector does not have to write down all label information,
saving valuable inspection time. Input inventory sheets
can be used for fertilizers, pest control products, and
animal health care products. ATTRA has free downloadable
examples of all types of records available on the website,
or call 1-800-346-9140 for hard copies.
- If you sell bulk commodities,
keep accurate harvest totals and sales records per crop.
The inspector will choose one of your crops to do
a “sample audit balance” to see if your records
can track the crop from sale back to the field(s) where
it was grown and to assess if the amount you harvested and
sold was realistic for that crop.
- If you are a market gardener
or if you sell products directly to consumers, keep daily
or weekly sales totals, along with accurate
input and production records. The inspector will need to
review your production and sales records.
- Walk through your storage
areas before the inspector arrives and get
rid of any products you no longer use. Check with your local
Extension Service office for proper disposal options.
Thanks for being prepared. It helps me do a better inspection
and facilitates your organic certification.