Preparing for an Organic Inspection: Steps and Checklists


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Preparing for an Organic Inspection: Steps and Checklists

  1. 1. PREPARING FOR AN ORGANIC INSPECTION: 1-800-346-9140 STEPS AND CHECKLISTSATTRAThe National Sustainable Agriculture Information Service MARKETING, BUSINESS, AND RISK MANAGEMENT Abstract: This guide is to help organic producers and handlers understand, prepare for, and get the most from their annual inspections for certification of compliance with USDA National Organic Standards ( nop).By Ann BaierNCAT Agriculture SpecialistJanuary 2005©NCAT 2005 Table of Contents Introduction . . . . . . . . . . . . . .1 Inspection Preparation . . . . . . .2 Summary . . . . . . . . . . . . . . . .8 References . . . . . . . . . . . . . . .8 Acknowledgements . . . . . . . . .8 IntroductionThis publication provides checklists of the docu-mentation needed for organic certification. Thesewill help organic producers or handlers organizetheir paperwork for an organic inspection. Itincludes steps for preparing for the organic in-spection and checklists of audit-trail documentsand required records for certification of organic On a Salinas Valley, California, organic farm, horticulturist Ericcrop and livestock production and organic han- Brennan harvests a bundle of a late-summer rye cover crop. Photodling facilities. by Scott Bauer ©2005 ARSATTRA is the national sustainable agriculture information service operated by the NationalCenter for Appropriate Technology, through a grant from the Rural Business-Cooperative Service,U.S. Department of Agriculture. These organizations do not recommend or endorse products,companies, or individuals. NCAT has offices in Fayetteville, Arkansas (P.O. Box 3657, Fayetteville,AR 72702), Butte, Montana, and Davis, California. ����
  2. 2. tion, your inspection will make a lot more sense. Certifiers provide a copy of the standards with Inspection Preparation their application package, and the standards are also available on the NOP Web site: www.ams.usda. gov/nop/NOP/standards/FullText.pdfOrganic certification is about verifying that youare managing an organic system to grow crops, These Standards were written to address mostraise livestock, and/or process food and fiber agricultural production and processing activi-according to the National Organic Standards. ties. Not all portions will be applicable to everyAn important part of being prepared is being operation. As you review them, look for andable to track your product from the field or point focus on the parts that do apply to your opera-of purchase to the consumer, ensuring that the tion. The definitions in Part 205.2 will help youproduct has been kept separate from non-organic understand key terms.products and has not been contaminated in anyway by materials prohibited for use in organic • Crop Producers: Production Require-production. Producers and handlers will find ments in Sections 205.200 through 205.207;it useful to follow the following four steps to Materials on the National List in Sectionsprepare for their annual inspection. 205.600 through 205.603; Recordkeeping in Section 205.103; and Labeling in Sections 205.300 through 205.311. • Livestock Producers: Production Re- quirements in Sections 205.236 through 205.239; Materials on the National List in Sections 205.600 and 205.603- 604; Recordkeeping in Section 205.103; and Labeling in Sections 205.300 through 205.311. (Livestock producers who raise their own feed must also comply with the requirements for crop production.) • Handlers: Handling Requirements in Sec - tions 205.270 through 205.272; Mate- rials on the National List in Sections 205.600 and 205.605-606; Recordkeeping in Section 205.103; and Labeling in Sections 205.300 through 205.311. Review your Organic Systems Plan (OSP) The OSP must be updated and submitted to your certifier whenever a significant change is made Photo by Scott Bauer ©2005 ARS to your operation. Each certifier has particular forms and procedures for keeping OSPs current. In preparation for your annual inspection, verifyReview the sections of the National that your OSP is current and complete, with allOrganic Standards that are relevant to pertinent attachments. If you have not alreadyyour operation submitted them to your certifier, be prepared to provide updates at the time of your inspec-To their detriment, people often do not read the tion. Keep copies for your files. You must haveNational Organic Standards. They may seem a complete, current OSP on file at all times. Belong and overwhelming, but if you are familiar prepared to show records of how you implementwith the key standards relevant to your opera- each part of your OSP.PAGE 2 ATTRA //PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS
  3. 3. Review any communications from your Communications from your certifier may also include general memos to all certified clientscertifier that you have received in the explaining updates to the lists of allowed orpast year prohibited brand-name materials, changes or updates to manuals, renewal procedures, fees,Each year you will receive a letter that addresses inspection protocol, and interpretation or clarifi-your certification status. (Certifiers have differ- cation of standards. The inspection and certifica-ent names for this letter: certification determina- tion process will go more smoothly if you knowtion letter, notice of noncompliance, certification what to expect and keep yourself educated aboutstatus report, remediation letter, conditions any changes that occur.letter, evaluator’s circle, etc.) Does this letterdescribe any areas in which your operation wasfound to be other than fully compliant by the Gather your records using the followingprevious inspection and review process? Have organic inspection checklistsyou resolved the issues that were raised afteryour previous inspection? Have you responded Organic Inspection Checklistsin writing to any requests made by your certi- The National Organic Standards specify that re- cords must “fully disclose all activities and trans- actions in sufficient detail as to be readily under- stood and audited” (NOP Section 205.103(b)(2)). Are you prepared to explain your recordkeeping system? Is anything missing or incomplete? You can make your inspection easier and more efficient by doing a self-audit beforehand, using the following checklists. Please note that these lists are comprehensive, and some items may not apply to your operation. Crop production documentation checklist  List of crops being grown, field locations (maps), acreages, and estimated yields Field history or land use documentation, if any new land is added this year Field activity logs for all practices per- formed (cultivation, weed control, use Photo by Scott Bauer ©2005ARS of manure or fertilizers, spraying, pruning, beneficials released, etc.)fier? Can you provide documentation to showhow you have addressed these issues? The an-  Input purchase/source records of all in-nual inspection must verify that all previously puts used for crop nutrients, pest, disease,cited noncompliances have been corrected. Be or weed controlprepared to demonstrate and provide documen-  Receiptstation that you have taken corrective measures  Invoicesand that your operation is fully compliant with  Delivery tagsthe standards cited in the notice of noncompli-  Receipts or logs recording the pick-upance. or delivery of free materials  Labels and/or documentation demon- strating that each material is allowed for use in organic production. ATTRA//PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS PAGE 3
  4. 4.  A generic material (e.g., mined lime-  Your unsuccessful search for stone) must be on the National List commercially available organic as allowed. seed or planting stock (most  A brand name product must either certifiers require documentation  have a label that discloses all of non-availability from three ingredients, including inert in- sources), and gredients, so that they all may  Verification that the seed or be verified as allowed; or stock used is not genetically  be listed as an allowed brand- modified or treated with prohib- name material on a list ited materials approved by the certifier (e.g.,  Documentation of compliance of any the Organic Materials Review inoculants or seed coatings (non-GMO Institute (OMRI) Brand Names status of inoculant organisms and List, the Washington State allowed status of all seed coating Depart ment of Agriculture materials) (WSDA) list, or others). Find out from your certifiers whether  Audit trail documents that track products they maintain their own list from the field of origin to final use or sale. of approved materials, per- A random audit is part of inspection proce- form their own brand-name dures. It may require the following. material reviews, or wheth-  Field, planting and production records er they honor other lists, and if  Harvest and yield records so, which.  Post-harvest handling records  Note that manure must either be com-  Storage records posted according to NOP standards or  Transport records its date of incorporation documented  Sales records to comply with the required number of days before harvest of a crop intended  Soil management activities, including crop for human consumption. rotation and erosion prevention activities Input application records (material, source  Pest management activities for control of / brand name / manufacturer, regulato- crop pests ry status, field location, date, and rate or (insects/mites/invertebrates/vertebrates), quantity used) diseases, and weeds, including:  Seeds (crop and cover crop), planting  Preventative practices stock, annual seedlings, and transplants  Materials used, if any  Seed coatings and inoculants  Pesticide use reports, as required by  Greenhouse materials (e.g., potting soils law, if applicable (Some states require re- or soil mix ingredients) porting of all applications of EPA-regis-  Crop nutrients and soil amendments tered materials to commercial crops to the  Pest management materials County Agricultural Commissioner, De-  Beneficial insect releases partment of Weights and Measures.)  Natural, organic, or plastic mulches  Any other materials applied  Organic Integrity: Documentation of mea- sures to avoid contamination and commin- Seed, planting stock, and transplant re- gling, as applicable to your operation cords  Information about neighboring land use  Documentation that seeds and annual  Prevention of contamination from bor- transplants are certified organic, or ders  For any non-organic seed or planting  Production, harvest, and sales records stock used, documentation of: for buffer crops, transitional or conven- tional cropsPAGE 4 ATTRA //PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS
  5. 5.  Material storage: adequate separation processing/post-harvest handling, trans - of allowed materials from any non-al- port, and sales records) lowed products  Irrigation water and system for conta-  Housing and living conditions, including mination prevention (i.e., diagram of grazing management and outdoor access valves, backflow prevention, and/or records documentation of purge or flushing procedures to prevent contamination  Animal medications, including a list from shared water systems where fertil- of all products used or that may be used izers or other prohibited materials are (everything in your medicine cabinet or re- used) frigerator, with product names, ingredi-  Clean-out or purge logs for equipment ents, manufacturers, and regulatory status) used for both organic and conventional operations  Health management records, including  Documentation of procedures to verify vac cinations and all other materials, veteri- the absence of sanitizer residues, if sani- narian bills, purchase invoices, records of tizers are used medication used, reason for use, and ani - mal identification Certification documentation of any organ- ic product purchased for resale  Marking and segregating methods for ani- mals treated with prohibited materials Labels and labeling  Printed packaging, bags, boxes, ties,  Soil management, erosion control, crop bands, and stickers nutrition, and pasture management  Lot numbering of retail and bulk prod- ucts, if applicable  Manure management (must not contrib- ute to contamination of crops, soil, or wa-Livestock Production Documentation ter)Checklist  Pest management, including parasite man- agement Animal lists, including livestock or poultry descriptions and/or numbers and identi-  Off-site processing records, including fication methods slaughter, cold storage, and meat packing (These activities must take place at facili- Source of poultry and/or livestock, includ- ties that are already certified organic, or ing breeding, birth, hatching, and/or pur- they must be inspected as part of your chase records operation.) Feed harvest and storage records  Product or animal sales records Feed rations for each type of animal during  Labels, if applicable each stage of growth and development Feed and feed supplement purchase re- Handling Production Documentation cords and documentation that they are cer- Checklist tified organic or allowed  Product identification and composition for Drinking water, including source, addi- all organic products produced (This must tives, potential sources of contamination, include current formulations, recipes, or and results of any water analysis batch sheets that support the percentage of organic ingredients in your product Audit trail documents that track animals label claim—“100% Organic,” “Organic,” or animal products (harvest or slaughter, or “Made with organic….”) ATTRA//PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS PAGE 5
  6. 6.  Facility map(s) showing the facility on file. If prohibited materials (substanc- perimeter and buildings, all equipment, es not on the National List) are used in- and areas used for receiving, raw mat- side your facility, be prepared to show erial storage, processing, packaging, fin- documentation of how organic products ished product storage, and shipping and materials are protected from contami- nation during pest control applications. Production flow chart(s) that includes equipment used in each step or stage  Sanitation of the process and shows the flow of You will need documentation of standard products through the facility from operating procedures, equipment cleaning, receiving of raw ingredients to shipping equipment purge logs, and residue test- of the final product ing. Residue test procedures must be ap- propriate for the sanitation materials used. Documentation of sources of ingredients For example, if chlorine is used as a sani- and processing aids tizer, a chlorine test strip with sensitivity  Organic ingredients and processing in the low (0-10 ppm) range must be used aids: You must have on file a copy of to show that the level of chlorine remaining the organic certificate from the supplier is below 4 ppm, the level allowed in NOP of any organic ingredient or pro- section 205.606. Materials that are not listed cessing aid, showing that it is certified as allowed sanitizers are now allowed, but to NOP standards, along with the level if they are used, they must be completely of certification that supports the label removed before running organic products. claim you intend to make For example, For example, if acid or alkaline sanitizers if your label makes the claim of 100% are used, a pH test with a neutral result organic, all ingredients and processing (or one that matches the plain water used aids must be documented to be certified in the facility) indicates that the sanitizer as 100% organic. material has been washed off. Quaterna-  Non-organic agricultural ingredients ry ammonia is not listed and not allowed, and processing aids: You must provide and therefore must be completely re- documentation affirming that each spe- moved, such that there are no detect- cific ingredient a) is not commercially able residues, and residues do not contami- available as organic, b) does not contain nate organic products. Records must be prohibited inputs and has not been pro- maintained for each area or production line duced using prohibited methods where organic processing occurs, showing (genetic engineering), c) has not been how organic products and packaging ma- treated with ionizing radiation, and teri als are protected from contamination d) is not produced from a crop grown by conventional product residues and/or using sewage sludge. sanitation chemicals on food contact sur-  Non-agricultural ingredients: All non- faces. agricultural ingredients must be listed on and consistent with the annota-  Water tions of the National List (NOP Sections You will need documentation of source, 205.605 through 205.606). use, additives, and any applicable tests re- sults. Pest management Documentation for preventative practic-  Culinary steam es, procedures, maps, logs, service reports, Provide a list of all boiler additives, MSDS and incident records must be provided. pages for all additives, results from any Whether your pest management is done carryover tests, and explain how the or- in-house or by a contracted pest control ganic product is protected from boiler addi- company, you must document what tive contamination. materials are used, if any, including main- taining product labels or MSDS pagesPAGE 6 ATTRA //PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS
  7. 7.  Organic integrity (organic critical control  Off-site storage / contracted facilities points) If your operation uses off-site, contract- You will need documentation of ed warehousing or outside contractors for systems and procedures to prevent handling of ingredients or finished prod- commingling and/or contamination of ucts, you will need to provide information organic ingredients and products through- about how the off-site facility is used De- out all steps of processing. pending on what they do, such facilities may need to be certified to operate under Audit trail/audit control documents the certificate of the entity for whom they The organic recordkeeping system must provide custom services, or provide an af- accomplish two objectives: 1) trace prod- fidavit that they meet the criteria of an ex- ucts as certified organic from the raw ingre- cluded operation (see NOP Section 205.101 dients to final sale (for verification of sourc- for definitions and requirements). es and/or sample recall from final destina- tion); and 2) verify the input–output bal- General Checklist for all Organic ance of organic ingredients and organic Operations products, including current inventory. Be prepared to supply samples of paper- work during the inspection to track  Current state organic registration (Depart- ingredients to finished products for any ment of Food and Agriculture or Depart - item and for any time that may be ran- ment of Health Services), if applicable domly selected for an input/output audit.  The audit documents for purchase, re-  Complaint Log (procedure for response to ceiving, storage, production, packag- any complaints related to organic integ- ing, handling, transport, and sales may rity). This is an ISO 65 requirement if any include, but are not limited to, in- products are to be exported. voices, weight slips, purchase orders for incoming materials, invoices  Documentation and/or demonstration of for finished product, descriptions the correction of previously cited issues of product tracking or coding, logs for of noncompliance receiving, processing, storage and inventory systems, transport cleaning Checklist for Planning for Inspection Day documentation for incoming and/or outbound materials, and product  Ensure that you can devote the time and at- labels. tention needed to complete the inspection.  The input/output balance audit docu- ments may include, but are not limited  Make prior arrangements for someone else to, inventory, purchase, production, to handle work-related tasks and/or and storage records—including typical family commitments. conversion figures for shrinkage, recon- ditioning, donated products, samples,  Have all your records ready and accessible. dumping, shipping, and sales records.  Provide a space where you and the inspec- Labels and labeling tor can comfortably review records. While You will need finished product labels (re- a tailgate may suffice for some operations tail and wholesale labels on printed pack- on a sunny day, a clear table and place to aging, boxes, etc.), with the proper sit out of the wind and weather are prefer- placement of the phrase identifying the able. Some inspectors require space for a certifier, relative size of USDA and certifier laptop computer. logos, lot number, and market destination, as applicable.  Be prepared to provide easy and prompt access to all fields, buildings, and storage areas, both on- and off-farm. This may in- ATTRA//PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS PAGE 7
  8. 8. clude having keys to gates and sheds and 406-436-2131 (telephone/FAX) having other management personnel avail- able. If you have multiple fields or sites, be sure to advise your inspector, so that suffi- cient time is alloted for your inspection. The National Organic Program (NOP) Have enough gas in the pickup (or other appropriate vehicle) to reach the more re- Organic Materials Review Institute mote parts of the farm or facilities. Summary AcknowledgementsThe on-site inspection is an important part of the Thanks to Brian Magaro and Lois Christie,organic certification process. It can be useful to organic inspectors who provided their pre-in-you as an organic producer or handler in at least spection letters as resources for developing thistwo significant ways: a) by providing you with publication.a certificate of organic certification to the USDANational Organic Standards and other applicable Appreciation to the following reviewers:standards and b) by providing the impetus and Luis Brenes, Organic Inspector and Trainerinspiration to develop and implement organic Lois Christie, Fiesta Farmssystems for production and handling and their Doug Crabtree, Montana Department ofcorresponding record-keeping systems. This Agriculture, Organic Certifierpublication is intended to show how organic Jeff Cunningham, Organic Inspectorproduction or handling systems and sound re- George Kuepper, Program Specialist, NCATcord-keeping systems reinforce each other to sup- Nancy Matheson, Program Specialist, NCATport continuous learning about organic systems Jim Riddle, Organic Independentsdesign and good business management. Preparing for an Organic Inspection: Steps and Checklists By Ann Baier References NCAT Agriculture Specialist January 2005 ©NCAT 2005 IP261Biodynamic Farming and Gardening Slot# 265 Association Edited by Paul Williams Formatted by Cynthia Arnold Version 030105International Federation of Organic Agriculture Movements The electronic version of Preparing for an Organic Inspection: Steps and Checklists isInternational Organic Inspection Manual located at: IFOAM and IOIA, December 2000. Order HTML from: Independent Organic Inspector’s Associa- organic_inspection.html tion (IOIA) PDF P.O. Box 6 organic_inspection.pdf Broadus, MT 59317-0006PAGE 8 ATTRA //PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS