Organic Certification Process


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Organic Certification Process

  1. 1. ATTRA Organic Certification Process A Publication of ATTRA - National Sustainable Agriculture Information Service • 1-800-346-9140 • www.attra.ncat.orgBy Ann Baier This guide is to help organic producers and handlers understand, prepare for, and get the most fromNCAT Agriculture the process of organic certification to USDA National Organic Standards (see It discusses the purposes and benefits of the inspection for organic certification, provides a general© NCAT 2005 description of the organic certification process, and outlines the role of the organic inspector. A com- panion ATTRA publication, Preparing for an Organic Inspection: Steps and Checklists, is written for those already familiar with the basic certification process, to help them prepare more systematically for an initial or annual inspection. It includes steps for preparing for the organic inspection and checklists of audit trail documents and required records for certification of organic crop and livestock production and handling facilities. OContents rganic certificationPurposes and Benefits provides thi rd-of the Organic party confirma-Inspection ......................... 2 tion that a production orSteps to Organic handling operation is inCertification...................... 3 compliance with organicThe Role of the Organic standards. CertificationInspector ........................... 5 enables qualified produc-Resources .......................... 6 ers and handlers to mar- ket agricultural products under a USDA certified organic seal. In its sim- plest terms, the organic seal assures the consumer of organic integrity. First, a product is grown in an organic production system that emphasizes plant and The author (right) conducting a field inspection with Delfina Córcoles and her daughter. Photo by Rex Dufour, NCAT. animal health, preven- tative management of pests, and judicious ingredient processed product. The label use of allowed materials. Then, the product may carry a claim of “100 percent organic,” is tracked and protected from contamina- “Organic” (95% to 100%), or “Made with tion from the field to final sale, whether it organic ingredients” (at least 70% organic is a raw agricultural commodity or a multi- ingredients). As an organic inspector, I have heard from both farmers and food processors that an important ben-ATTRA - National Sustainable efit of organic certification is that it requires and inspires them to keep better records. Records helpAgriculture Information Serviceis managed by the National Cen- identify and solve problems more readily. A newly certified organic bakery described how the organicter for Appropriate Technology certification process immediately paid off in that business.(NCAT) and is funded under agrant from the United States • The bakery was having problems with one type of organic bread they were baking. SeveralDepartment of Agriculture’s batches did not rise properly. The resulting loaves did not have good texture and could not beRural Business-CooperativeService. Visit the NCAT Web site sold. The bakers turned to the record-keeping system they had recently put into place for their( organic certification. This audit trail allowed them to track every ingredient to its source. Theyhtml) for more informa- looked at their batch sheets and found that they could trace the problem back to a certaintion on our sustainableagriculture projects. ���� (continued on page 2)
  2. 2. (continued from page 1) lot-number of flour. They contacted the supplier and asked not to be sold that particular lot- number of flour in the future. Their bread quality quickly returned to its usual high standards. Dairy farmers describe how their record keeping helped them maintain healthier herds and good milk production, after their first year of organic certification. • Gary and Patricia Belli of Belli Dairy in Ferndale, California, noticed a drop in their herd’s milk production. They were keeping track of their purchases of organic feed, with lot numbers and amounts delivered from various sources. By looking at their feed purchase records, they could see the relationship between the decrease in production and the time when they used feed from a certain source. They asked their supplier to avoid a feed lot that appeared to be of poor quality. When they resumed feeding better quality feed from other lots, their milk production problem was solved. • Robin and Maralyn Renner (brother and sister) manage Diamond R Ranch in Ferndale, Califor- nia. They run the family dairy and raise organic beef. They described how much healthier their herd was once they began operating as a certified organic operation. Organic certification required that they keep accurate and more detailed records. They said that after working with these records for several months, “We began to recognize patterns.” Better records helped them to connect the dots. They saw correlations and discerned causes and consequences.Related ATTRA They improved their organic production system by putting what they learned into practice.Publications When I spoke with him recently, Robin reiterated what Maralyn had articulated a year or two earlier: there are practical benefits to keeping the records required for organic certification.Preparing for an Their cows are healthier and they have better farm management. “We’re glad we did it, “ heOrganic Inspection: said. “Every year gets better.”Steps and Checklists –Ann Baier, organic inspectorNCAT’s Organic CropWorkbookNCAT’s Organic Purposes and Benefits of Benefits of the inspection process for organic certification include the following.Livestock Workbook the Organic Inspection • Building consumer confidence in the The organic inspection doesn’t need to be meaning of the organic label scary, stressful, or onerous. The inspec- tion process can be useful to producers of • Fulfilling requirements to get or main- crops or livestock, and processors or han- tain organic certification dlers of agricultural products. The organic • Improving farm record-keeping systems inspection is a unique opportunity because and keeping up-to-date records it involves the most face-to-face contact • Providing an opportunity to better under- between the producer or handler and an stand organic standards inspector who works for the certifier. • Getting updated information about allowed Organic certifiers conduct annual inspec- and prohibited materials tions of all their clients (certified parties) • Learning about public educational to verify, through on-site review of actual opportunities or sources of informa- activities and the corresponding records, tion and technical assistance avail- that the clients are in compliance with the able through your certifier, Cooperative relevant organic standards. Every USDA- Extension, local farm organizations, or accredited certification agency must make industry networks. (Please note that this annual inspections. Most inspections are is not part of the inspection, but an inci- scheduled with the client in advance; how- dental benefit. The role of the inspector ever, some inspections are unannounced. is discussed below.) This publication will help you incorporate management practices that will keep you The steps that help you prepare for your prepared for an inspection at any moment. inspection for organic certification will also help you maintain healthy farming systems and viable business practices.Page 2 ATTRA Organic Certification Process
  3. 3. Steps to Organic integrity (with regard to borders and buffers, application, planting and har-Certification vest equipment, post-harvest handlingStep 1: Selection of a certifier and storage), planting, production, har- vest and sales records, monitoring sys-The producer or handler chooses a certi- tems, and product labeling.fier and requests an application packet.USDA-accredited certification agencies • Livestock Production: Source of animals,(ACAs or certifiers) are listed on the NOP feed and feed supplements, descriptionWeb site ( of housing and living conditions, healthAgents/Accredited.html). All USDA-accred- care practices and materials, manage-ited certifiers—whether private (non-profit ment practices (i.e., access to the out-or for-profit) or governmental—certify to doors and pasture for ruminants), physi-the same USDA National Organic Stan- cal alterations, manure management,dards. Some certifiers, however, are bet- record-keeping system, and productter recognized in the organic industry/mar- labeling.ketplace, and some may offer certification • Handling Operations: Sources of ingre-to additional standards—such as Interna- dients and processing aids, materialstional Foundation for Organic Agriculture and standard operating procedures for(IFOAM), European Union (EU), Japanese cleaning, sanitation, and pest control,Agricultural Standards (JAS), Conseil des measures to protect organic integrityappellations agroalimentaires du Québec (prevention of commingling and contam-(CAAQ), Biodynamic, GAP, Kosher, or Fair ination), packaging, record-keeping sys-Trade—while other certification agencies tem, product formulations, and productmay provide services such as newsletters, labeling.workshops, or educational opportunities.Consider your marketing needs—whetheryour approach to marketing requires verifi-cation of compliance to other standards—as An Organic System Planwell as your personal interests. should include informa- tion about management practices such as ani-Step 2: Application and submission mals’ access to pastureof an organic systems plan and outdoors. The pastured layer hensThe producer or handler submits an appli- at left belong to Paul andcation and an Organic System Plan (OSP) Leti Hain of Tres Pinos,to the certification agency, using the certifi- California. Photo by Ann’s forms and guidelines and attaching anyrequested documentation, licensing agree-ments, and fees. The OSP consists of writtenplans and relevant information concerning Step 3: Application and Organicall aspects of your operation. Following are System Plan Review by the Certifiersome examples of required information. The certifier reviews the Organic System• Crop Production: Land use history doc- Plan (OSP) and accompanying documenta- umentation, field maps, crop rotation tion for completeness and assesses the appli- plans, soil improvement and pest man- cant’s capacity to operate an NOP-compli- agement plans, seed sources, material ant operation. The certifier determines that inputs (soil amendments, fertilizers, com- the operation can meet the requirements post, manure, pest control materials, or for certification as outlined in the OSP. The any other materials) used and planned certifier will then assign a qualified organic for use, measures to maintain organic inspector to do an on-site ATTRA Page 3
  4. 4. pests, water systems (for irrigation and post-harvest handling), storage areas, and equipment. • The livestock inspector inspects feed production and purchase records, feed rations, animal living conditions, pre- ventative health management practices (vaccinations and other medications cur- rently being used or planned for future use), and health records. The inspector observes and assesses the animals’ con- dition. • The handler or processing inspector inspects the facility and evaluates theOrganic inspectors receiving, processing, and storage areasassess the adequacy of used for organic ingredients and finishedprocedures to prevent products. Critical control points are ancontamination.Photo by Ann Baier. essential part of any handling opera- tion and its inspection. The inspector analyzes potential hazards and assesses Step 4: Organic inspection organic control points—the adequacy of procedures to prevent contamination Organic inspections come prior to ini- (from sanitation supplies, pest manage- tial certification, then annually thereafter. ment materials, or non-organic process- The inspection must occur when a person ing aids), and to prevent commingling knowledgeable about the operation is pres- with non-organic ingredients. ent, and should occur where and when the crops, livestock, and/or processing or other At the end of the inspection, the inspec- handling can be observed. tor conducts an exit interview with the inspected party to confirm the accuracy The Inspection Preparation Checklists in and completeness of the inspector’s observa- the ATTRA publication Preparing for an tions. The inspector will review any requests Organic Inspection: Steps and Checklists pro- for additional information and any issues of vide a detailed description of the documen- potential non-compliance with respect to the tation required for the three major types of National Organic Standards. The inspector operations: crops, livestock, and handling. provides the inspected party with a written In all three types of operations, the organic copy of the exit interview before leaving the inspector conducts an on-site inspection inspection. The inspector then provides a and review of record keeping to verify that report to the certifier. The inspector reports the OSP accurately reflects your operation his or her observations only and does not and is in compliance with NOP standards. make the certification decision. Records to be verified include input materi- als, production, harvest and sales records, Step 5: Review of the inspection as well as appropriate product packaging report by the certifier and labeling. The inspector assesses the risk of contamination from prohibited materials, The certifier will review the report and and may take soil, tissue, or product sam- determine whether the operation is eligi- ples as needed. ble for organic certification. The final deci- sion is then communicated in writing to • The farm (crop) inspector inspects fields, the client seeking certification, along with soil conditions, crop health, approaches any requirements for initial or continu- to management of weeds and other crop ing certification. The certifier may requestPage 4 ATTRA Organic Certification Process
  5. 5. further information or remediation, or issue approved by the certifier), b) whether thea notice of noncompliance, if the operation practices and inputs are in compliance withis not in full compliance with all pertinent the USDA National Organic Standard, andorganic standards. Significant noncompli- c) whether those practices and inputs areances may result in denial or revocation of adequately documented. The certifier thencertification and/or require correction prior makes the certification decision based onto organic certification or renewal. Minor information provided in the OSP, the inspec-non-compliance issues are those that do not tion report, and associated documents.threaten the integrity of the organic prod- The inspector can do the following:ucts. (For example, procedures are properlycarried out but inadequately documented.) • provide information about the certifica-The notice will cite the issues of concern tion processand specify the time by which the opera- • answer general questions about organiction must remedy the noncompliance and standards and requirementsprovide documentation of the remediation • explain the range of practices and/orto the certifier. record keeping that the certifier considers sufficient to show complianceStep 6: Organic certification • make referrals to pub-A certificate of organic certification is lic sources of information,issued if the operation is determined to be such as Cooperative Exten-compliant under the NOP (and any other sion services, USDA agen-applicable) standards. Upon issuance of cies, farm organizations,the organic certificate, the operation may trade associations, andbegin selling its products as organic. Prod- ATTRA’s toll-free line anduct labels must identify the certifier (“Cer- publicationstified organic by…”) beneath the name andidentifying information of the producer or The inspector cannot serve ashandling company. Use of the USDA and/ your advisor or consultant. Theor the certifier’s seal is optional. The certi- inspector may not recommend spe-fied party should review the details of label- cific products, practices, animaling in NOP section 205.300-311, and ask or plant varieties, or give advicethe certifier to review any labels prior to for overcoming identified barriersprinting. All certified operations must be to certification. The inspector mustinspected annually. not hold a commercial interest in the business being inspected, provide paidThe Role of the Organic consulting services, accept gifts, favors, or The organic inspector payments other than the prescribed inspec- can refer clientsInspector tion fee. Finally, the inspector does not to sources of informa-The “inspector” is not the same as the “cer- tion about organic make the certification decision. Any of the compliance.tifier.” It is important for the producer or above constitutes a conflict of interest that Photo by Ann Baier.handler to have clear expectations about is strictly prohibited by law, as described inthe role of the inspector—what services he NOP Section 205.501.or she can and cannot provide. As noted in The certified entity can be assured that theStep 4: Organic Inspection, the primary role inspector has signed both a conflict of inter-of the inspector is to gather on-site informa- est and a confidentiality agreement with thetion and provide an accurate report to the certifier to protect all proprietary informa-certifier. The inspector verifies a) whether tion of the inspected operation.observations of an operation’s daily prac-tices are consistent with the client’s Organic Even when you take into consideration theSystem Plan (previously submitted to and limitations of the inspector (as ATTRA Page 5
  6. 6. above), the inspection can still be a useful opportunity questions you have, in particular about the certificationto expand your knowledge of organic requirements, the process and where to go for assistance in answeringprocesses necessary to meet those requirements, and further questions. To avoid potential conflicts of inter-associated information. As you prepare for your inspec- est, please be aware of the limitations on the role oftion, you might find it helpful to make notes of any your inspector.ResourcesThe National Organic Program (NOP) International Organic Inspection Manual IFOAM IOIA, December 2000. Order from:Organic Materials Review Institute Independent Organic Inspector’s (IOIA)International Federation of Organic P.O. Box 6Agriculture Movements Broadus, MT 406-436-2131 telephone/FAX ioia@ioia.netBiodynamic Farming and Gardening Association Acknowledgements Thanks to Brian Magaro and Lois Christie, organic inspectors who provided their pre-inspection letters as resources for developing this publication. Appreciation to the following reviewers: Lois Christie, Fiesta Farms Doug Crabtree, Montana Department of Agriculture, Organic Certifier George Kuepper, Program Specialist, NCAT Nancy Matheson, Program Specialist, NCAT Jim Riddle, Organic Independents Jeff Cunningham, Organic InspectorPage 6 ATTRA Organic Certification Process
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  8. 8. Organic Certification Process By Ann Baier NCAT Agriculture Specialist ©NCAT 2005 Paul Williams, Editor Robyn Metzger, Production This publication is available on the Web at: or IP 262 Slot 266 Version 112905Page 8 ATTRA