USA: After certification: Organic production calls for documentation, inspection

Source: agriview.com
By JEFFREY HOFFELT

OrganicPortal NewsRoom

As illustrated in the first part of this series, the path to organic certification is a winding road of dedication, record-keeping and awareness. To ensure the validity of organic products in the marketplace, certifiers say that producer commitment and industry cooperation must continue through all stages of niche production.

Cissy Bowman, CEO of Indiana Certified Organic and an organic certifier, says the strategy is based on the organic system plan included in the organic application process.

"This needs to include a long-term plan of what you're going to do on your operation and how you will handle problems that may come up," she says, indicating that the thought-out proposal serves as a reference piece during production. "Also, show how you will keep records. When you're getting started, it's important to begin keeping records before the certification process to get into that habit."

Jackie Von Ruden, a farm certification manager at Midwest Organic Services Association (MOSES) in Viroqua, explains that the scope of records required through organic production varies based on each operation.

"Sometimes, farmers split part of the farm into organic and some remains conventional, this would require different records," she says. "You need to build a relationship with a certifier and start asking questions to see what works for you. It's very specific to your type of farming; however, the overall requirements are the same."

The certifiers agree that adequate records are a vital component on successful organic operations they work with. Because organic producers must prove that their land has been free of prohibited materials for at least 36 months prior to the harvest of their first organic crop, records will help to show proof of physical barriers and prevention of comingling in split operations.

"Bottom line, you must maintain the soil; the roots of organic farming are in the ground," Bowman says. "You're supposed to maintain or improve your soil with natural methods: crop rotation, erosion prevention, natural methods of fertilizing and crop protection. Before you take action, your organic system plan is going to tell us what you intend to do so that any problems can be stopped."

Along with specific regulations for compost, water use and allowed synthetics, Von Ruden explains that producers must also comply with livestock rules under the National Organic Standards Board (NOSB).

The rule currently states that animals that are going to be slaughtered must be organically managed from the last third of their gestation; poultry have to be organically managed from the second day of their life after hatching; and dairy cows require 12 months of organic management with certified organic feed (or fed for 12 months using third-year homegrown transitional feed harvested during the timeframe 24 to 36 months after the last synthetic input).

"Animals can't be rotated in and out of organic production," Von Ruden states, indicating the commitment organic producers agree to. "You give a cow a prohibited treatment and she's out of the herd. That's part of the cost of doing business as an organic farmer: you're going to have to cull some animals if they have repetitive ailments."

A recent regulation adds to the list of livestock directives by mandating that all animals be granted year-round outdoor access. Further, all livestock must consume at least 30 percent of their dry matter intake through pasture forage.

"The biggest thing about organic is the principle around it; it is the entire system being used, so humane treatment of animals is taken into consideration," Bowman says. "In times of inclement weather or if an animal is ill, animals should be taken care of in a humane way. There are allowed reasons for confinement; you must just document why the animal is not going outside."

To ensure that animals are being cared for under organic regulations and that all supplements, minerals and materials provided are approved by the operation's certifier, annual inspections are conducted on all certified organic operations.

Von Ruden says that inspectors go through a training program with the International Organic Inspectors Association and work separately from certifiers.

"The inspector has a very specific role," she says. "They are the eyes and the ears for the certification agency as the person that comes to your farm at least once a year to verify that the organic system plan is complete, that it is being followed and that there are no major discrepancies."

"They investigate complaints for certification agencies; however, inspectors are not the final word," she admits. "They report to the certifier as every agency requires some kind of report from the inspector about your farm."

Though the certifier is the person able to reprimand organic producers, Von Ruden says that the opinions of inspectors are imperative in the process. The experienced professionals can also help to improve operations.

"You want them to come to your farm; you're paying them to help you better your operation," she says. "This is your chance to have someone on the farm that has experience and advice. We want to hear about your farm, so if you can tell us about it rather than us asking questions that's better."

Organized and auditable records will smooth the process that can last from two to eight hours per visit.

"About half of it is visual," Von Ruden says. "The inspectors are checking all of your facilities, livestock and then going through your documents. Be prepared to show absolutely everything on the land and in the barn-equipment, medicine, rented land, input labels."

After the visual inspection, inspectors spend time auditing the operation's records.

"The system of records must give the inspector a clear picture of what's going on so we can monitor your management practices," she says. "The audit can be done pretty quickly if you know your long-term plan and how you're working to meet what's coming down the pike. It's similar record-keeping to taxes."

According to Von Ruden, the audit portion is often the biggest issue for noncompliance. In the organic world, records are required for all aspects of production, including: field work, feed purchases, cleaning supplies and verification of any organic input purchased.

If records are kept each day, Bowman says the process is manageable.

"It doesn't have to be painful or burdensome; it just has to be complete," she says. "Do it as you go and it won't seem so overwhelming. You will learn a lot from keeping the records. Once you start doing it, you will really be happy that you did."

After the audit and inspection are completed, the inspector conducts a closing interview to confirm what he or she observed.

"Different inspectors see different things but the idea is always continuous improvement," Bowman says, explaining that what is said during the closing interview is often included in the report to the certifier.

The certifier then uses that information to evaluate the organic producer. If regulations were not met during inspection, the certifier can issue noncompliance notifications. Noncompliant producers are first given the opportunity to correct the problem area(s).

"If you choose not to, the certifier may not certify your farm," Bowman says. "If you make the changes and update your plan with the changes, you're good to go."

"Documentation is a key aspect in doing that; it's what proves your organic system plan," she emphasizes. "If records aren't your forte, certified organic farming may require you to contract with somebody to help you keep good records."

Both certifiers recommend working with the certifier before compliance issues occur.

"Seek permission on your inputs," Von Ruden advises. "It's so much easier to ask the certifier if you can do something than to try to justify why you did it and maybe did it wrong. There's a zero tolerance with a lot of the regulations in organic."

"We will work with you to help you become compliant," she assures. "We want you to be organic producers."

Tip: OrganicPortal USA - Organic Agriculture

OrganicPortal NewsRoom

10.02.2012

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