The Inspector’s Notebook #4
The exit interview made easy
Jim shares his tips for getting the inspector off your property as quickly as possible.

By Jim Riddle

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.

October 14, 2004: Organic inspectors have traditionally reviewed information for accuracy and identified issues of concern at the end of each inspection. I never want anything I write in my inspection report to be a “surprise” to the farmer, so I like to talk about what I’ve seen before I leave the farm. It’s just common courtesy to discuss the important issues that will affect a farmer’s certification.

The National Organic Program (NOP) formalized this process with the “Exit Interview” in §205.403(d) which states “The inspector must conduct an exit interview with an authorized representative of the operation who is knowledgeable about the inspected operation to confirm the accuracy and completeness of inspection observations and information gathered during the on-site inspection. The inspector must also address the need for any additional information as well as any issues of concern.”

Some certifying agents have specific forms that are filled out during the “Exit Interview.” Additional information that is needed from the farmer as well as specific issues of concern are identified on this form. Some agencies even have the farmer sign the form to verify that the exit interview occurred and the farmer participated in the process.

Minimize issues of concern

As an inspector, I must identify all areas where your operation may not comply with the NOP. During the inspection and exit interview, you have the opportunity to give me as much information as possible so I fully understand the situation. It is my job to give the certification agency an accurate representation of your operation.

For instance, the sorghum sudan seed you purchased was untreated but not certified organic. The seed was listed in your organic plan. You explained to me that you called several seed dealers but were not able to find organic seed. Good job, so far. But, in order to verify this, you also need to keep a record of those attempts. Most certifying agents require three attempts of seed dealers who offer organic seeds. Thus, an issue of concern is identified: no documentation of attempts to obtain organic sorghum sudan seed.

You can save yourself a lot of time and hassle by doing a “self-assessment” of your farm. Walk through the farm, look in your buildings, examine your equipment, and review your records, including product labels, receipts, and seed tags, to make sure that you have all of the information that the inspector will want to see. Does your farm having any “issues of concern?” If so, try to address them before the inspector arrives.

If you can’t address issues before the inspection, try addressing them during the inspection. Every time the inspector identifies an issue of concern, propose a solution. Instead of waiting for the inspector to submit a report, and for the certifying agent to send you a letter listing your farm’s non-compliances, go ahead and implement that record documenting your attempts to obtain organic seed. It may be a blank record at first, but it is in place and ready to go. That way, there is no concern. The inspector can report you have implemented the record for future use. Some concerns cannot be addressed this way, but it is to your advantage to eliminate as many concerns as possible.

Send in additional information as soon as possible

When we were getting our own farm certified this year, the inspector needed more ingredient information on some soil mix we had purchased. We bought the soil mix during a silent auction for MOSES, so we did not have an invoice or label information. We called the company during the inspection and left a message. The next day, the company returned our call and faxed us the information we needed. We then faxed the information to the inspector. Thanks to quick follow through, the inspector was able to submit a complete inspection report.

The exit interview can be tough, as you are forced to come face to face with your farm's short-comings, but be forthright and cooperative and the process will be much less painful.