Organic Materials Compliance
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Organic Materials Compliance

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    Organic Materials Compliance Organic Materials Compliance Document Transcript

    • Organic Materials Compliance Materials for Organic Production, Handling, and Processing: Planning for Compliance with USDA’s National Organic Program A Publication of ATTRA - National Sustainable Agriculture Information Service • 1-800-346-9140 • www.attra.ncat.orgBy Ann Baier and The USDA’s National Organic Program regulates the use of substances and materials for farming, handling,Lance Gegner and processing. This publication discusses three basic steps to ensure that materials use is compliantNCAT Agriculture with organic standards and certification. First, understand the regulations relevant to your operation.Specialists Next, create an Organic System Plan with your certifier. Finally, keep records of your purchase and use of all materials. Following these steps will help ensure compliant use of materials, and avoid any use of© 2008 NCAT a prohibited material or incorrect use of a restricted material—which could necessitate an additional three-year transition process.Contents Materials that are used to produce andThree Steps to Ensure handle organic crops under the USDA’sOrganic-Compliant Use National Organic Program (NOP) mustof Materials for Organic be selected for compliance and used in the Photo: Rex DufourProduction andHandling context of organic principles for farmingStep One........................2 and handling practices.Become familiar withNational Organic The NOP regulations describe organicProgram regulations farming systems as those that maximizeabout materials for yourtype of operation. cycling of nutrients through crop rota- Beneficial insect hedgerow along organic field edge.Step Two ......................4 tions, cover crops, and green manures.List every material you The systems are designed to conserve soil, Certified organic producers and handlersuse or plan to use in the improve soil health, enhance biodiversity, must use only materials that are approved forOrganic System Plan with use according to the standards to which theysupporting and prevent pest problems. Organic farm-documentation as ing is not simply the substitution of nat- will be certified. Therefore, the first step isrequired, and obtain ural materials for synthetic ones. It is a to understand the standards relevant to one’sapproval from your operation. Prior to using any material, certi-organic certifier of this whole-systems approach.Plan before you use any fied operations must include in their Organicmaterial. Organic producers and handlers first must System Plan (OSP) a list of all materials theyStep Three ....................7 be able to describe and document how their use or plan to use. They must have the OSPDocument every input operations apply organic principles and approved by their organic certifier.material purchase and implement proactive strategies to preventuse, and keep those problems. Then they verify and document Finally, organic producers and handlers mustrecords for a minimum offive years. compliant use of materials employed for keep records of the purchase and application specific purposes within those operations. of all materials. This three-step process will enable the producer or handler and their cer- Whether a material is allowed or not tifier to evaluate materials for their intended depends on the context. Some types of specific use, and to ensure their complianceATTRA—National Sustainable materials are integral to maintaining an with relevant standards.Agriculture Information Ser- organic system. Others may be used onlyvice is managed by the National when cultural, biological, mechanical, or Non-compliance can jeopardize certifica-Center for Appropriate Technol-ogy (NCAT) and is funded under physical methods are insufficient. This tion status. Use of a prohibited material ora grant from the United States paper discusses some basic steps to ensure violation of a restriction (annotation) onDepartment of Agriculture’sRural Business- Cooperative that the materials proposed for use are com- the use of a material can set an operationService. Visit the NCAT Web site pliant with organic standards and certifica- back three years to begin the transition(www.ncat.org/agri.html) for more informa- tion to NOP standards. process again.tion on our sustainableagriculture projects.
    • Three Steps to Ensure Organic-Compliant Use To help ensure compliant use and documentation of materials for organic production and handling, follow these essential steps: STEP ONE — Become familiar with NOP regulations about materials for your type of operation. The regulatory texts of the National Where in the Standards can I Organic Program standards are find the rules about materials?R available on USDA’s National Organic ead the Program website: Sections 205.105 and 205.600-606, the Rule: www.ams.usda.gov/nop/indexIE.htm National List of Allowed and Prohibited In general, Substances, are the main places to find To view the production and handling stan- information about allowed and prohib-Natural Materials dards, go to the above page. Under General ited materials. However, there are also spe-are allowed (unless Information, click on Regulations to bring cific regulations within the standards forthey are prohibited); up a new window. Then under Regulatory certain materials. For example, applica-Synthetic Materi- Text, click on Electronic Code of Federal tion of raw manure is addressed in sectionals are prohibited Regulations. It is important to review the 205.203(c)(1); production of manure-based full set of regulations in order to find and compost in 205.203(c)(2), and other materi-(unless they are understand the key parts that apply to your als used for soil fertility in 205.203(d).allowed). Then, pay operation.attention to The General Rule for Organicannotations. What do the NOP Standards say Crop and Livestock Production: about Input Materials? Or: Natural materials are allowed. Why isn’t the answer simple? Synthetic materials Several sections of the National Organic are prohibited. Program regulations (the “Rule”) describe which materials are allowed for what pur- For organic crop and livestock production, poses and under what circumstances. Sec- the Rule clearly states that natural materi- tions of the Rule that address materials als are allowed unless specifically prohibited, allowed for specific purposes can be found in and that synthetic materials are prohibited the paragraphs that discuss crop production, unless they are specifically allowed. livestock production, and handling (process- ing). Several materials are listed with anno- The Exceptions: tations that limit or restrict products to spe- Allowed Synthetic Materials cific uses within these broader purposes. For example, hydrated lime may be used as an The following sections list the exceptions to ingredient in Bordeaux mixture for disease this general rule. Section 205.601 lists syn- management on fruit trees—when other pre- thetic substances allowed for use in organic ventative practices are not enough and its use crop production. This list includes sub- is consistent with Rule section 205.206(e). stances such as fish extracts for fertilizer, But hydrated lime cannot be used as a soil chlorine for washing vegetables (discharge or amendment. effluent water concentration below drinkingPage 2 ATTRA Organic Materials Compliance
    • Organic calves on pasture on LaMacchia Ranch, Gonzales, California, owned and managed by Frank and Irene LaMacchia. Organic livestockoperations use compliant practices and materials to manage their fields and pastures as well as their animals’ health. Photo: Ann Baierwater standards), and copper sulfate for crop Materials lists for organicdisease control. Section 205.603 lists syn-thetic substances allowed for use in livestock processing and handling Related ATTRAproduction, and includes materials such as are organized differently. Publicationsiodine, vaccines, vitamins, and minerals. For organic processing and handling, the National Organic lists of materials that are allowed for use Program ComplianceThe Exceptions: are in separate sections of the National List Checklist for (205.605 and 205.606). These lists are orga- ProducersProhibited Natural Materials nized differently than crop and livestock National OrganicSections 205.602 and 205.604 list nonsyn- lists, in that they name specific allowed Program Compliancethetic (natural) materials prohibited for crop and restricted materials. Section 205.605 Checklist for Handlersand livestock production, respectively. lists non-agricultural substances allowed for Organic Farm use in or on processed products labeled as Certification & theWhile each of these lists is fairly short, it “organic” or “made with organic ingredients” National Organicis important to become familiar with the (product claims). The National List section Programprohibited materials as well as the allowed 205.606 lists non-organically produced agri-materials. cultural products that are allowed as ingre- Organic Crop Production OverviewJust as some of the synthetic materials are dients in products labeled as “organic” or “made with organic ingredients.” NCAT’s Organic Cropsrestricted by annotations, some of the pro- Workbook – A Guidehibited natural substances have exceptions You can list a material or product planned to Sustainable andthat permit their limited use. for use in your Organic System Plan (OSP) Allowed Practices with relative confidence by verifying that it NCAT’s Organic Live- is allowed. stock Workbook – A Guide to Sustainable and Allowed Practices Organic System Plan (OSP) Templates for In the hedgerow shown on page one, a Certifiers Monarch butterfly larva and aphids feed on narrowleaf milkweed, as the chrysalis Organic Certification sparkles like a jewel. This native perennial Process hedgerow was planted at Fong Farms in Woodland, California, to attract beneficial Preparing for an organisms. The aphids, larva and chrysa- Organic Inspection: lis represent diversity on the farm. They Steps and Checklists also serve as non-pest alternate hosts for parasites and predators that are feeding on And many more listed farm pests. The field in the background is at www.attra.ncat.org/ planted with organic alfalfa. organic.html Photo: Rex Dufour.www.attra.ncat.org ATTRA Page 3
    • STEP TWO — List every material you use or plan to use in your Organic System Plan (OSP) with supporting documentation as required, and obtain approval from your organic certifier of this Plan before you use any material. Verify the precise identity of Check whether the material or any material you plan to use, product you plan to use is including the product brand currently listed or registered name, formulation, and on one or more of theC reate an manufacturer/source of every approved lists of Brand Name Organic material in your Organic or Generic materials. System System Plan. Always use the most current informationPlan with a list of Avoid the common mistake of confusing the available. The websites of OMRI and WSDAcompliant materials manufacturer of a product (who made it) listed on page six are best to verify any claimthat you plan to use. with the distributor or supplier (who sold it of listing. A very recent printed guide is nextYour certifier must to you). It is the identity of the manufacturer best. It is the organic producer or handler’s that is important in determining whether a responsibility to verify any claim of listingapprove this Plan. product is allowed. Whether you bought it for compliance by checking it against cur- from the local hardware store or the farm rent lists on the website. When in doubt, supply is unimportant. contact your certifier to determine the sta- tus of any material that you are considering for use. Find out if your organic certifier has a list of approved If the material/product you are brand name materials, or interested in using is not on a whether they honor other lists. current approved list, follow Many certifiers recognize the Organic Mate- your certifier’s instructions to rial Review Institute (OMRI) and/or the verify its compliance. Washington State Department of Agricul- Work with your certifier to evaluate the ture (WSDA) products lists (see direct links material by providing supporting documen- and explanation of these lists below). In this tation (product label, Material Safety Data case, certified clients can refer to these cur- Sheet–MSDS, manufacturer’s statement, rent lists of acceptable brand name mate- and/or ingredient list with all ingredients rials. Some certifiers maintain their own including inert ingredients). You and your internal lists instead of, or in addition to, certifier will need sufficient information OMRI and WSDA. about the product and its production pro- cess to assess whether the material is allowed under the standards. The NOP issued a memo to Accredited Certification Agencies on March 5, 2008 regarding “Verification of Materials” and documentation of such: http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5066877Page 4 ATTRA Organic Materials Compliance
    • Maintain your OSP to be current Verify materials use in theand accurate by reviewing and context of the OSP.updating it regularly. In addition to materials, the OSP must also include a description of your produc-The Organic System Plan is essentially a con- tion practices and procedures, monitoring,tract that includes written plans concerning recordkeeping system, and prevention ofall aspects of agricultural production or han- commingling and contact with prohibiteddling (NOP Section 205.201). Any materials materials, and any other information as spec-used or planned for use must be in current ified in Section 205.201. This other infor-compliance. mation provides the context under which aYou should review and update your Organic material may or may not be allowed for use.System Plan at least annually or as changes Even if a given input is on a list that the cer-are made. Keep a copy for yourself and sub- tifier recognizes—whether WSDA, OMRI,mit any updates promptly to your certifier, or even their own list of materials—a certi-as required by 205.400(f). fier may still deny the use of a material in M the context of the OSP. any certifiers agree Excerpts from OMRI’s website and publications explain their work. that OMRI Products Lists are invaluable The Organic Materials Review Institute (OMRI) is a tools to help find 501(c)(3) nonprofit organization that specializes in the review compliant materials. of substances for use in organic production, processing, and handling. OMRI’s services are directed to all aspects of the Find the most organic industry with a primary focus on the decision mak- current lists on their ers who deal with the compliance status of generic materials website: and brand name products. With the OMRI Generic Mate- www.OMRI.org. rials List and OMRI Products List, OMRI provides guid- ance on the suitability of material inputs under the USDA National Organic Program standards. How products are reviewed OMRI reviews applications from input suppliers for products in crops, livestock, and processing. To assess compliance with the National Organic Program Rule, OMRI requires product applications to contain all the relevant public and proprietary information regarding product ingredients, formulations, and manufacturing processes. OMRI operates under a rigorous confidentiality policy to guard against disclosure of proprietary product information to unauthorized individuals. As a nonprofit organization, OMRI is able to offer an independent, third-party review of products that can balance the need for confidentiality in reviewing proprietary formulations with the necessity to ensure that products comply with the National Organic Program Rule. The review process consists of two steps: review and recommendation by OMRI staff, and decision-making by an independent Review Panel. All products are reviewed according to published policies and standards.www.attra.ncat.org ATTRA Page 5
    • B) Washington State Department of Materials Lists Agriculture Materials List A) The Organic Materials Review http://agr.wa.gov/FoodAnimal/Organic/ Institute (OMRI) Products List MaterialsLists.htm www.omri.org/OMRI_datatable.htm The Washington State Department of OMRI’s primary reference manuals are Agriculture (WSDA) registers several brand the OMRI Products List (brand name name materials for use in organic production materials, available on their website) and handling. WSDA provides the following and the OMRI Generic Materials List explanation of their brand name lists: (available for purchase on their website). “In order to comply with National Organic These resources help interpret the NOP’s Standards, producers and handlers must National List and enable producers and use substances in compliance with National processors to determine under what cir- Organic Program requirements (7 CFR Part cumstances a material or product is allowed 205). WSDA Organic Food Program hasW for use in organic production. OMRI lists evaluated the products on the Brand Name ash- are updated quarterly, and users should be Material List (BNML) and determined that ington sure they are using the most current version they comply with the National Organic State of the list. The most current product listings Standards.Department of can be found on OMRI’s website. WSDA does not imply any guarantee orAgriculture also OMRI’s services are valuable to facilitate endorsement of any of the products listedevaluates understanding of materials and products on the BNML. In addition, manufacturersmaterials and that are consistent with the National List, of these products are not required to listmaintains a list of even though OMRI is not officially accred- their products on the BNML. Therefore,allowed brand ited by the NOP. Inclusion on the OMRI this is not a comprehensive list of brandname products. Products List must be renewed every year name materials that meet organic standards. by the manufacturer. Some products may be Please refer to the National List of Allowed listed one year and not the next. Reformula- and Prohibited Substances for further tions can render a product non-compliant. information regarding materials for use in Alternately, a reformulation can bring a pre- organic food production.” viously non-compliant product into compli- ance. In some instances, a producer will be C) Your Certifier’s List required to document the lot number of a Ask about whether one exists and how you product in order to verify its compliance. can access its information. Note: The program is voluntary and many The U.S. Environmental Protection registrants of NOP-compliant products Agency (EPA) has issued a notice for have chosen not to identify their how pesticide registrants can obtain products as such. For more information, EPA approval to identify products that visit the EPA’s website: comply with the NOP Rule for organic www.epa.gov/oppbppd1/biopesticides/ production and handling. regtools/organic-pr-notice.htmPage 6 ATTRA Organic Materials Compliance
    • STEP THREE — Document every input material purchase and use, and keep those records for a minimum of five years.Input purchase records may include receipts ATTRA’s Record Keeping & Workbook draftor invoices, delivery tags, and receiving by Ann Baier and Holly Bornlogs. Input application records must include http://attra.ncat.org/downloads/organic_ Be Careful!Material (Brand name/formulation), Manu- cert/recordkeeping_budgeting.pdf.facturer/source, Crop, Location, Frequency, Prior to usingRate and Quantity, Purpose (e.g. fertilizer, ATTR A’s workbooks, checklists, sam- any substancepest control), and Date Applied. ple forms, and other guides for organic in an organic certif ication including documenta- operation,Your certifier may provide forms to facilitate tion forms for livestock, field crops, mar- carefullydocumentation of input applications. Several ket farms, and orchard, vineyard, and evaluate thetypes of sample documentation forms are berry crops can be downloaded for free at status ofalso available from ATTRA: http://attra.org/organic.html. the material according to the National List and the Brand Name Material List. ����� ������ Some substances �� ���� ��� �� ���� ����� �� ��� ��������� ������������� ���� ������� ���������� ���� ����������� ���������� ����� ���� ��� ����� �� ���� ����� �������� ��� �� ����� ����� ��� ���� ������������ ��� �������� �� ���� which were ������� �� ������ �� ���������� previously ���� ����� ���� ����� approved for �������� ������� ����� use in organic ���� ������ �� ������ ����� ������������� ������������ ������� ������ systems are no longer approved. Use of these substances is considered the use of a prohibited material and may result in a loss of organic certification for 36 months. Many certifiers have forms for tracking input use. One exam- ���������� ����� ��� ������������� ple is pictured to the left. It can be found among a collection of useful forms at www.ccof.org/certif ������� ������������� ��������������� ����� ��� ����������������������� ������� ������� ��������� icationassistance.phpwww.attra.ncat.org ATTRA Page 7
    • Special thanks for input and review from: James Wynn and Brian Baker Organic Materials Review Institute (OMRI) Miles McEvoy and Katherine Withey Washington State Department of Agriculture (WSDA) Organic Program Jim Riddle University of Minnesota. Organic Materials Compliance— Materials for Organic Production, Handling, and Processing: Planning for Compliance with USDA’s National Organic Program By Ann Baier and Lance Gegner NCAT Agriculture Specialists © 2008 NCAT Karen Van Epen, Production This publication is available on the Internet at: www.attra.ncat.org/attra-pub/organicmaterials.html or www.attra.ncat.org/attra-pub/PDF/organicmaterials.pdf IP313 Slot 312 Version 081808Page 8 ATTRA