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.

Certifier relations:

• Getting a product or practice approved by a certifier, but not getting the approval in writing, and then misunderstanding the "approval".
• 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 all.
• Not registering with the state organic program, if applicable.
• Failure to pay certification and/or inspection fees.

Non-approved inputs:

• 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.

Record keeping:

• 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 records.
• Not using lot numbers or not using a consistent lot numbering system.
• Not providing adequate documentation to buyers when organic products are sold.
• Not keeping records of steps taken to inspect and clean transport units.
• 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, etc.)
• 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.