Whether you're an experienced certified farmer or just
starting the transition, you'll have questions about
certification - especially with the new rules going
into effect on October 21, 2002. We'd like to hear about
those questions, and about any mistakes you've made
or lessons you've learned the hard way. Sharing your
experience could help others avoid the same problems.
us your questions and stories about certification by
clicking here. We'll answer as many questions
as we can.
The most common mistakes made
by certified crop operators and/or certification applicants
By James A. Riddle
Farmers who choose to apply for organic certification must
agree to follow the rules, now codified in the USDA's National
Organic Standard. Because many farmers like to spend their
time farming instead of reading rules or filling out forms,
mistakes can be made. These mistakes can end up with the farmer
being denied certification, or, if already certified, having
the certification be suspended or revoked. At the very least,
a farmer might receive conditional certification, and be placed
under additional scrutiny, because of inadvertent errors.
The following list of common mistakes made by certified crop
farmers and/or certification applicants was compiled with
input from members of the Independent Organic Inspectors Association,
the OTA's Organic Certifiers Council, and the National Association
of State Organic Programs, based on years of organic certification
experience. Hopefully, reading the mistakes of others will
help you avoid making costly mistakes on your farm.
- Getting a product or practice approved by a certifier,
but not getting the approval in writing, and then misunderstanding
- Failure to submit requested documentation to the certifier
(such as prior land use forms, non-GMO letters, adjoining
land use forms, water test results, etc.)
- Not understanding and/or not complying with certification
requirements (minor non-compliances) from the previous year.
- Failure to complete required paperwork on time, or at
- Not registering with the state organic program, if applicable.
- Failure to pay certification and/or inspection fees.
- Use of non-approved substances (incl. treated seeds),
due to negligence and/or not understanding the requirements.
- Use of non-approved substances, due to trusting an input
supplier who gave assurances that the material was "approved"
for organic farming.
- Failure to inquire about the GMO status of inputs, especially
inoculants and Bt products.
- Not having documentation of non-GMO status of inputs,
including seeds, inoculants, and Bt products.
- Not correctly calculating the amount of time from the
last date of application of a prohibited input - and the
required 36 months have not passed. The farmer then wrongly
thinks that the present year's crop will be saleable as
certified organic, when it is not certifiable.
Documentation of approved inputs:
- Failure to obtain and/or retain adequate documentation
for purchase of approved inputs.
- Failure to document attempts to source organic seeds.
- Lack of adequate detail or clarity on field maps and/or
use of inaccurate maps.
- Field maps which do not show acres, field numbers, and/or
adjoining land uses.
- Not keeping field activity records up to date.
- Failure to keep seed and input labels and receipts in
an organized and accessible manner.
- Failing to keep records for contracted services, such
as planting, spraying, harvesting, and/or trucking.
- Failure to keep bin records up to date.
- Not recording field numbers on harvest and/or storage
- Not using lot numbers or not using a consistent lot numbering
- Not providing adequate documentation to buyers when organic
products are sold.
- Not keeping records of steps taken to inspect and clean
- Not maintaining adequate records for operations with
both organic and conventional production.
Organic system plan:
- Failure to follow the operation's organic plan.
- Filing "renewal" farm plans with entries marked "No Change",
when there have been significant changes, such as new leased
or purchased fields, discontinued leases, sub-divided fields,
new crops, new inputs, changes to field numbers, changes
to lot numbering system, etc.
Commingling and contamination:
- Failure to properly clean harvesting equipment and/or
storage units, resulting in commingling or contamination
of organic crop.
- Failure to segregate crops harvested from buffer zones.
- Lack of cleaning logs for spray equipment that is also
used for prohibited inputs.
- Work area contamination for post harvest handling (e.g.
washing vegetables, cutting vegetables, packing vegetables,
- Mislabeling or mishandling of crop by mistake by workers
who are not fully informed of organic certification requirements.
- Misapplication of prohibited materials by workers who
are not fully informed of organic certification requirements.
- No GMO drift management plan - not knowing where the
nearest GMO fields are located.
- Failure to inform neighbors, utility companies, highway
departments and/or other authorities that land adjacent
to organic fields should not be sprayed (or sign no-spray
agreements when these are available).
- Failure to post "Do Not Spray" signs when and where these
would add protection.
Based on information provided by members of
the Independent Organic Inspectors Association, the OTA's
Organic Certifiers Council, and the National Association of
State Organic Programs. Compiled January 18, 2002, by James
A. Riddle, Organic Independents, Winona, MN, USA.