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Editor’s NOTE:
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 items 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
NewFarm.org.
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September
23, 2004: Let’s face it. Lot numbers are confusing.
What are they? When and why do organic farmers use them? How
do you get one?
One of the first things I learned as an inspector was that
some organic farmers need to use lot numbers when selling
their products. Lot numbering systems are unique to each seller.
For processed products, lot numbers have long been used to
track products through a manufacturing plant, or to help recall
damaged or contaminated products. For organic processors,
incoming lot numbers on ingredients help connect each ingredient
to its source, and insure that organic ingredients are being
used for each batch of organic finished product. For organic
farmers, lot numbers track the product from the point of sale
back to the field(s) of production or storage facility.
A lot number is a unique code containing numbers or letters
that stand for specific pieces of information, connected to
a specific batch of product. Information that a lot number
should contain includes: type of crop, crop year, and either
field numbers or storage unit number.
Thus, a lot number for organic soybeans harvested in 2004
and stored in bin #1 could read “S041”. The “S”
stands for soybeans, “04” for crop year 2004,
and “1” is the bin where organic soybeans were
stored until shipped to the processor. Your storage record
for bin # 1 should show the date of harvest, the amount harvested,
and which fields were harvested and stored in bin # 1. The
lot number and storage record track your organic soybeans
back to the field(s) of production.
Now comes the tricky part. What if you aren’t storing
your soybeans, but selling them directly out of the field?
Let’s say you have 5 fields of soybeans; fields H-1,
H-4, M-2, M-6, and M-9. Using the same elements, your lot
number could be S04H1H4M2M6M9. The ‘S” stands
for soybeans, “04” is for crop year 2004, and
“H1H4M2M6M9 stand for fields H-1, H-4, M-2, M-6, and
M-9. This is a long and confusing lot number, with a good
chance of being written incorrectly on sales and shipping
records.
You can shorten this lot number by assigning a different
number or letter, such as “A” that stands for
fields H-1, H-4, M-2, M-6, and M-9. Now your lot number is
S04A. Be sure to write the lot number of the sale in your
harvest and sales records, and that “A” stands
for all the fields harvested and sold as a single lot.
If two truckloads of organic soybeans are sold directly out
of the field, the first semi load should be identified differently
from the second. The first truckload lot number could be S04A1,
and the second truckload lot number could be S04A2. Again,
be sure to write these lot numbers on the harvest record to
connect them to the specific fields harvested and included
in each load.
You can even add your own initials to a lot number to distinguish
it from other organic soybean growers, i.e., JRS04A1, where
“JR” stands for Jim Riddle.
Vegetable growers have a different problem with lot numbers.
You may harvest many different products on a daily basis,
and sell wholesale to grocery stores or restaurants and/or
directly to consumers through a CSA, a farmers market, or
an on-farm market. Organic growers selling directly to consumers
do not need to use lot numbers. You do, however, need to keep
track of what you harvest, the date, which fields are harvested,
and total sales.
A wholesale vegetable grower can use the date of the invoice
or invoice number as the lot number, with all the vegetables
being sold on that invoice connected to that lot number.
For really large vegetable growers, an individual lot number
can be designed similar to the organic soybean example above,
but adding the date of harvest. For example, for carrots harvested
August 10, 2004, a simple lot # is C8104. “C”
stands for carrot, “8” is for August, “10”
is for August 10, and “4” is the crop year, 2004.
For bulk shipments of organic products in non-retail containers,
NOP 205.307(b) requires that lot numbers be displayed on the
shipping containers. The lot number should also appear on
the associated invoice and shipping documents.
Be sure to record lot numbers on your harvest and storage
records, scale tickets, sales invoices, shipping documents,
and other appropriate records.
The bottom lines:
- Design a lot numbering system that works for you.
- Use your lot numbers consistently.
- Keep your system as simple as possible.
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