Opening a window on organic inspection
Pennsylvania field day demystifies the inspection process by giving farmers a first-hand look.

By Laura Sayre

The Pennsylvania Association for Sustainable Agriculture (PASA), Pennsylvania Certified Organic (PCO), and Delaware Valley College teamed up recently to help answer that question. The three groups agreed to turn the real-life, first-time inspection of a part of the college's farm into an educational event. About 35 people attended, including conventional farmers interested in transitioning to organic, non-certified organic farmers interested in certification, and people with various kinds of farming experience interested in becoming organic inspectors.

"We are inundated with requests from people wanting to transition," explained PASA program coordinator Heather House. In tandem with PCO, they decided that the 'open inspection' would be a new and different way to disseminate information about transitioning to organic—and hopefully help allay fears farmers may have about the certification process.

PCO executive director Leslie Zuck said they were especially pleased to have received an application for certification from Delaware Valley because if the certification goes through, it will mark the first certified acres at an institution of higher learning in Pennsylvania. Penn State University has some acreage in transition, but has not yet received full certification on any of its farm or research lands.

A four-year private institution, Delaware Valley College was founded in 1896 by a Jewish rabbi who believed in integrating intellectual and practical education. Today it is one of just a handful of private agricultural colleges (as opposed to public agricultural universities) in the United States. It's also, as Jim Diamond, dean of agriculture and environmental sciences, noted in his introductory remarks, become "an island of agriculture in a sea of development" in this area north of Philadelphia.

The college has nine agricultural units—including orchards, a dairy barn, a farm market, greenhouses, and an equestrian center—each with its own farm manager, on a total of about 600 acres. "All of this exists for one purpose only," said Diamond, "for the students to get hands-on experience."

Al Johnson (l) and Neil Myerov (r) start the inspection with a tour of the fields. "Most farmers are most comfortable in their fields, so it's a good way to break the ice." --Al Johnson

The farm manager for the proposed organic acreage—a two-acre block, including a 1/2-acre of blueberries—is Neil Myerov, the college's horticulture manager. Myerov's been on staff for just a year, and has 18 years of prior farming experience, most of it in conventional production. Also present was Dr. Jacqueline Ricotta, an assistant professor of horticulture and a strong supporter of the decision to transition some of the college's farmland to organic.

Organic inspector Al Johnson has been doing inspections for 15 years, and was himself an organic farmer for 13 years. Like most organic inspectors, he operates as an independent contractor. Last year alone he inspected more than a hundred organic farms and processors, mostly in the Northeast, for PCO and other certifying agents.

The inspection process has changed over the years, Johnson told the group, especially since implementation of the National Organic Program in 2003. In some ways, it's simpler, both for the inspector and the farmer. Whereas there used to be a dozen different sets of potentially applicable organic standards, now there's only one.

From the file to the field

The first thing Johnson does upon receiving an inspection assignment is to read the application, paying special attention to the 16-page Organic System Plan which forms the heart of a farm's certification paperwork. In their review of the application, the staff at PCO will have noticed and flagged potential areas of concern; Johnson does the same, knowing that his job is to confirm that what it says in the application is also what's going on in the fields.

While every inspector has his or her own system, Johnson said, he likes to begin with a tour of the fields, move on to the equipment sheds, packing and crop storage areas, and finish up with the paperwork. "Most farmers are most comfortable in their fields, so it's a good way to break the ice."

It's important to understand that the inspector functions as a neutral observer in the inspection process. "It's not my job to say, this is what you need to do," Johnson emphasized. "I simply make a report and then it goes to the certification committee for a decision." Inspectors are knowledgeable, however, and can point the farmer in the direction of needed information. As Johnson put it, "I'm not allowed to give advice—but discussions are okay."

The field tour usually begins with an examination of the farm map provided by the farmer as a part of his or her application. The inspector verifies the size and orientation of the fields, buildings, water sources, and other significant features, paying particular attention to the perimeter of the certified area, or buffer zone.

The Farm's organic fields are bordered on three sides by mature tree rows and by a 20-foot-wide grass strip on the fourth as buffers.

The federal rule has no set buffer-width requirement, but Johnson said a good rule of thumb is that if the distance is less than 25 feet, you need to look more closely. Wider, taller or more densely vegetated buffers may be required if adjacent land use activities present a strong possibility of contamination. Myerov's proposed organic fields are bordered on three sides by mature tree rows, unbroken except for an access road, which is a good thing, Johnson noted, because the adjacent areas included a conventionally managed orchard. The fourth side has no tree row, but here there is a 20 foot wide grass strip bordering a rough pasture in which some of the college's dairy cows were grazing. Judging from the mix of grasses and forbs in the pasture, it was unlikely to have been treated with any prohibited materials.

Organic farmers on larger acreages sometimes choose to plant their buffer strips to corn, hay, or another crop. In that case, Johnson said, the farmer must have a plan for handling and marketing the buffer harvests separately from their organic harvest.

While touring the fields, Johnson asked Myerov about different aspects of his operations. Farmers should expect the inspector to ask questions such as, "What's your soil fertility management program?" "What's your rotation?" "What's your weed control program?" "What are your biggest production challenges?"

"There's never a perfect time to do an inspection," Johnson admitted. "It's never going to be the best time to see all the things that you could see." What the inspector can do, however, is look at the general health of the crops, the size and species of weeds, the condition of the soil, the evidence of drainage patterns in the fields. Signs like these can say a lot about how the season is going and what past management practices have been like.

On a vegetable farm, the field tour would also typically include a visit to the greenhouse. Although Delaware Valley has a number of greenhouses, Myerov explained that he planned to put up a dedicated organic high-tunnel later in the year. Johnson made a note of this, explaining that PCO would probably seek to verify in the spring that the high tunnel had in fact been built or that the farm had some other means of producing or obtaining organic seedlings.

On to the barn: tools, materials, and storage

In the equipment shed, Johnson began by asking to see Myerov's weed management implements. The college farm had recently invested in a tool bar system with spring-tine, knife, and sweep attachments. "Is this and other equipment used only in the organic fields?" Johnson wanted to know. If not, then Myerov needs to keep a log showing that implements are inspected and, if necessary, cleaned down each time they are taken from the conventional to the organic fields.

Equipment on a mixed-operation farm can pose a cross-contamination risk if not exclusively used for either the organic production or the conventional production.

Johnson said he also pays attention to a farm's tractors, trucks, and wagons. A tractor that's way too big for the size of the fields being farmed, for instance, could indicate a potential compaction problem. On a mixed conventional and organic farm, wagons can also be potential vectors for contamination.

After the equipment area, the group admired the college's composting operation, which is managed by another staff member and handles all the manure and bedding from the on-campus equine center. For any compost obtained off-farm, Johnson noted, you must have a letter stating that it has been produced in accordance with NOP standards.

The college's composting operation handles all the bedding and manure from their on-site equine center.

With regard to other inputs, Johnson emphasized adherence to NOP materials lists. "I can't tell you what to use or not use, but together we can look it up," he said. Johnson carries a copy of the federal rule and current materials lists from the Organic Materials Review Institute (OMRI) for that purpose.

Another issue that tends to cause anxiety for farmers is the necessity of documenting seed sources. NOP regulations center on three requirements: not using genetically-modified seed, not using treated seed, and trying to use certified organic seed. The inspector can get an idea of a farmer's practices just by noting the business name on the invoice: some seed companies, like Johnny's, have pledged not to sell GM seed; others, like High Mowing, sell only organic seed. "If you have a long seed invoice and a mixed [organic and conventional] operation," Johnson suggested, it's helpful to "go through and highlight the seed purchased for the organic operation."

In the washing and packing area, Johnson asked Myerov questions like, "What do you use for harvest containers?" "What's your system for keeping organic and non-organic produce from getting mixed up?" Mixed operations sometimes designate different colored harvest containers for organic and conventional produce; walk-in coolers should have clearly designated organic and conventional areas.

And then, the paperwork

The first thing to keep in mind when submitting your certification application, Johnson said, is to be neat. "You don't have to type it, but be neat." "Usually, once I've met with the farmer, I come to like them, because 99 percent of the people in this business are good people, but still, if I get a sloppy application, it gives me a bad first impression."

Second, be accurate, and third, be thorough. Other forms making up a farm's certification file include a field report, materials list, prior land use statement, harvest records, storage records, and sales records. The inspector will use the latter three to verify a correlation in scale between acreage, production, and sales.

If a farm has storage bins for grain or other large-volume crops, a lot-number system is necessary so that each saleable unit can be traced back to a given field and a given harvest. Finally, Johnson noted, the federal rule requires certified farmers and processors to keep a record of any complaints they receive about the organic integrity of their product.

At the end of the inspection, the inspector fills out two forms for submission to the certifier: the on-farm inspection report and the exit interview. In addition, if there have been any changes to the Organic System Plan (OSP) since it was sent it to the certifier, these are made on the OSP in red pen and initialed by both the farmer and the inspector.

The inspection report is where the inspector notes any areas of concern. Each comment has to reference the relevant section of the federal rule. "I try to write this out as much for the farmer as for anyone else," said Johnson. In Myerov's case, Johnson noted among other things that the field records needed to be completed more fully, including the exact date of all compost and other materials applications.

Myerov admitted he was nervous because he didn't know what to expect. Hopefully, these open inspections will help alleviate that anxiety for other transitioning farmers.

All in all, the group seemed to feel that the inspection had gone well. "The first time through can be relatively easy," Johnson said. "The second year is often harder because you're finding out if the paperwork is adequate for the operation in reality. By the third year, hopefully, the issues are mostly worked out."

Even so, at the end of the afternoon, Myerov admitted that he was relieved to be through with his first-ever organic inspection. Did the experience meet his expectations? "I think that's why I was nervous," he replied, "because I didn't know what to expect."

Laura Sayre is senior writer for NewFarm.org.