The Inspector’s Notebook #12
To plant or not to plant

Answers to all your questions on organic seeds—what they are, where to find them and which will get your fields DQed for three years

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.

Jim Riddle serves as vice-chair of the USDA’s National Organic Standards Board and organic policy advisor for He was the founding chair of the Independent Organic Inspectors Association (IOIA).

February 2, 2005:Since the National Organic Program (NOP) was implemented in October 2002, organic farmers have been required to use certified organic seeds when planting organic crops and cover crops. This was big news to many organic farmers, since previously they were only required to attempt to use untreated seeds.

There are four types of seeds for organic farmers to be aware of:

  1. Certified organic seeds: Labeled as “certified organic” or “organic” these seeds are grown in accordance with the NOP. The certifying agent should be listed on the label.
  2. Untreated seeds: These seeds are grown conventionally, but have not been treated with any prohibited substances.
  3. Treated seeds: These seeds are grown conventionally and are treated with prohibited substances, such as Captan or Apron or other fungicides or insecticides used on many seeds that are planted in cold soil. The EPA classifies Captan as a probable human carcinogen. Treated seeds must not be used by organic farmers!
  4. GMO seeds: These include crops that have been genetically engineered to include genes from viruses, bacteria, plants, and animals to make them herbicide tolerant or to contain toxins that kill pests. GMO seeds are prohibited for organic production!

Technically (see §NOP 205.204), organic farmers must use organically grown seeds, annual seedlings and planting stock. In the event that a seed variety is not commercially available organically, an organic farmer may use untreated seeds. If untreated seeds are not commercially available, an organic farmer may use seeds and planting stock treated with a substance included on the National List §205.601. Currently, there are no synthetic seed treatments on the National List.

Just to make things a bit more confusing, some natural seed treatments are allowed. Examples of allowed natural seed treatments are bacterial (non-GMO) inoculants for legumes and clay pelleting for small seeds such as carrots. The Organic Materials Review Institute (OMRI) Brand Names List (January 2005 issue, page 13) lists 6 allowed seed treatments by brand name.

So where can you find certified organic seeds? A number of seed companies have moved into this niche market. Many certifying agents provide a list of organic seed companies upon request.

There is also a wealth of seed information on the web. Many organizations including certifiers have posted their lists on their websites. For example, the Midwest Organic Services Association, a Wisconsin based certifier, lists 45 seed suppliers, offering corn, soybean, alfalfas, clover and a variety of vegetables. ATTRA also provides a list of organic seed suppliers on their website, To go directly to the seed list, click You can also find lists of organic seed suppliers through OMRI at The “Save Our Seed Project” is producing organic and heirloom seeds in the southeast region of the United States and includes a list of their available seeds at Or for more information on growing organic seeds try

Most of the seed companies on the lists mentioned above are not exclusively organic, so you need to read the description or understand the catalog symbols in order to be sure you are ordering organic seed.

There may be instances where the specific seed you want is not available as certified organic. The NOP allows you to use untreated seed if organic seed is not available in the form, quality, quantity or equivalent variety you need.

In our certified organic vegetable operation, about half of the seeds we use are available as certified organic. We grow cabbages. We have always planted a variety called Stonehead because it matures early prior to the arrival of the cabbage moth. This variety allows us to harvest cabbages without using any allowed insecticides, such as Bt. Early maturation is a quality of this particular variety of seed. Stonehead cabbage was simply not available as organic seed this year. So I bought conventionally-grown, untreated Stonehead seeds, with records to show I searched 3 seed companies supplying organic vegetable seeds. I wrote down on my seed log why this particular variety is important to me. I am also trying a different variety of cabbage that is available organically as a trial.

Check with your certifying agent for seed supplier lists and their recordkeeping requirements when using untreated seed. They may require a non-GMO statement from your seed supplier if the seed you use is non-organic. I use seed suppliers that provide a non-GMO pledge in their catalog. Called the Safe Seed Pledge, you and your certifying agent can be assured that the seed company does not knowingly buy or sell genetically engineered seeds or plants.

Keep samples of your seed labels and/or seed packaging. These provide verification that your seeds are certified organic or untreated. Inspectors may also want to review your seed invoices.

Under no circumstances should you use seeds treated with prohibited substances. Fields where treated seeds are used will be disqualified for organic certification for 36 months following the planting of these seeds.

To recap – organic, always; untreated, if you must; treated, proceed with extreme caution, some natural treatments are allowed but as a general rule stay away. Tune in next month when we’ll investigate soil erosion on the organic farm.