Abstract
The author (right) conducting a field inspection with Delfina
Córcoles and her daughter. Photo
by Rex Dufour, NCAT. |
This guide is to help organic producers and handlers understand,
prepare for, and get the most from the process of organic certification
to USDA National Organic Standards (see www.ams.usda.gov/nop).
It discusses the purposes and benefits of the inspection for organic
certification, provides a general description of the organic certification
process, and outlines the role of the organic inspector. A companion
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.
Table Of Contents
Introduction
Organic certification provides third-party confirmation that a
production or handling operation is in compliance with organic standards.
Certification enables qualified producers and handlers to market
agricultural products under a USDA certified organic seal. In its
simplest terms, the organic seal assures the consumer of organic
integrity. First, a product is grown in an organic production system
that emphasizes plant and animal health, preventative management
of pests, and judicious use of allowed materials. Then, the product
is tracked and protected from contamination from the field to final
sale, whether it is a raw agricultural commodity or a multi-ingredient
processed product. The label may carry a claim of "100 percent
organic," "Organic" (95% to 100%), or "Made
with organic ingredients" (at least 70% organic ingredients).
As an organic inspector, I have
heard from both farmers and food processors that an important
benefit of organic certification is that it requires and inspires
them to keep better records. Records help identify and solve
problems more readily. A newly certified organic bakery described
how the organic certification process immediately paid off
in that business.
- The bakery was having problems with one type of organic
bread they were baking. Several batches did not rise properly.
The resulting loaves did not have good texture and could
not be 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. They looked at their batch sheets and found
that they could trace the problem back to a certain 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, California. 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. They improved their organic production
system by putting what they learned into practice. 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.
Their cows are healthier and they have better farm management.
"We're glad we did it," he said. "Every year
gets better."
-Ann Baier, organic inspector |
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Purposes and Benefits of the Organic Inspection
The organic inspection doesn't need to be scary, stressful, or
onerous. The inspection process can be useful to producers of crops
or livestock, and processors or handlers of agricultural products.
The organic inspection is a unique opportunity because it involves
the most face-to-face contact between the producer or handler and
an inspector who works for the certifier.
Organic certifiers conduct annual inspections of all their clients
(certified parties) to verify, through on-site review of actual
activities and the corresponding records, that the clients are in
compliance with the relevant organic standards. Every USDA-accredited
certification agency must make annual inspections. Most inspections
are scheduled with the client in advance; however, some inspections
are unannounced. This publication will help you incorporate management
practices that will keep you prepared for an inspection at any moment.
Benefits of the inspection process for organic certification include
the following.
- Building consumer confidence in the meaning of the organic label
- Fulfilling requirements to get or maintain organic certification
- Improving farm record-keeping systems and keeping up-to-date
records
- Providing an opportunity to better understand organic standards
- Getting updated information about allowed and prohibited materials
- Learning about public educational opportunities or sources of
information and technical assistance available through your certifier,
Cooperative Extension, local farm organizations, or industry networks.
(Please note that this is not part of the inspection, but an incidental
benefit. The role of the inspector is discussed below.)
The steps that help you prepare for your inspection for organic
certification will also help you maintain healthy farming systems
and viable business practices.
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Steps to Organic Certification
Step 1: Selection of a certifier
The producer or handler chooses a certifier and requests an application
packet. USDA accredited certification agencies (ACAs or certifiers)
are listed on the NOP Web site (www.ams.usda.gov/nop/CertifyingAgents/Accredited.html).
All USDA-accredited certifiers—whether private (non-profit
or for-profit) or governmental—certify to the same USDA National
Organic Standards. Some certifiers, however, are better recognized
in the organic industry/marketplace, and some may offer certification
to additional standards—such as International Foundation for
Organic Agriculture (IFOAM), European Union (EU), Japanese Agricultural
Standards (JAS), Conseil des appellations agroalimentaires du Québec
(CAAQ), Biodynamic, GAP, Kosher, or Fair Trade—while other
certification agencies may provide services such as newsletters,
workshops, or educational opportunities. Consider your marketing
needs—whether your approach to marketing requires verification
of compliance to other standards—as well as your personal
interests.
An Organic System Plan should include information about management
practices such as animals' access to pasture and outdoors. The
pastured layer hens at left belong to Paul and Leti Hain of
Tres Pinos, California. Photo by
Ann Baier. |
Step 2: Application and submission of an organic systems
plan
The producer or handler submits an application and an Organic System
Plan (OSP) to the certification agency, using the certifier's forms
and guidelines and attaching any requested documentation, licensing
agreements, and fees. The OSP consists of written plans and relevant
information concerning all aspects of your operation. Following
are some examples of required information.
- Crop Production: Land use history documentation, field maps,
crop rotation plans, soil improvement and pest management plans,
seed sources, material inputs (soil amendments, fertilizers, compost,
manure, pest control materials, or any other materials) used and
planned for use, measures to maintain organic integrity (with
regard to borders and buffers, application, planting and harvest
equipment, post-harvest handling and storage), planting, production,
harvest and sales records, monitoring systems, and product labeling.
- Livestock Production: Source of animals, feed and feed supplements,
description of housing and living conditions, health care practices
and materials, management practices (i.e., access to the outdoors
and pasture for ruminants), physical alterations, manure management,
record-keeping system, and product labeling.
- Handling Operations: Sources of ingredients and processing aids,
materials and standard operating procedures for cleaning, sanitation,
and pest control, measures to protect organic integrity (prevention
of commingling and contamination), packaging, record-keeping system,
product formulations, and product labeling.
Step 3: Application and Organic System Plan Review by
the Certifier
The certifier reviews the Organic System Plan (OSP) and accompanying
documentation for completeness and assesses the applicant's capacity
to operate an NOP-compliant operation. The certifier determines
that the operation can meet the requirements for certification as
outlined in the OSP. The certifier will then assign a qualified
organic inspector to do an on-site inspection.
Organic inspectors assess the adequacy of procedures to prevent
contamination. Photo by Ann Baier. |
Step 4: Organic inspection
Organic inspections come prior to initial certification, then annually
thereafter. The inspection must occur when a person knowledgeable
about the operation is present, and should occur where and when
the crops, livestock, and/or processing or other handling can be
observed. The Inspection Preparation Checklists in the ATTRA publication
Preparing for an
Organic Inspection: Steps and Checklists provide a detailed
description of the documentation required for the three major types
of operations: crops, livestock, and handling. In all three types
of operations, the organic inspector conducts an on-site inspection
and review of record keeping to verify that the OSP accurately reflects
your operation and is in compliance with NOP standards. Records
to be verified include input materials, production, harvest and
sales records, as well as appropriate product packaging and labeling.
The inspector assesses the risk of contamination from prohibited
materials, and may take soil, tissue, or product samples as needed.
- The farm (crop) inspector inspects fields, soil conditions,
crop health, approaches to management of weeds and other crop
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, preventative
health management practices (vaccinations and other medications
currently being used or planned for future use), and health records.
The inspector observes and assesses the animals' condition.
- The handler or processing inspector inspects the facility and
evaluates the receiving, processing, and storage areas used for
organic ingredients and finished products. Critical control points
are an essential part of any handling operation and its inspection.
The inspector analyzes potential hazards and assesses organic
control points—the adequacy of procedures to prevent contamination
(from sanitation supplies, pest management materials, or non-organic
processing aids), and to prevent commingling with non-organic
ingredients.
At the end of the inspection, the inspector conducts an exit interview
with the inspected party to confirm the accuracy and completeness
of the inspector's observations. The inspector will review any requests
for additional information and any issues of potential non-compliance
with respect to the National Organic Standards. The inspector provides
the inspected party with a written copy of the exit interview before
leaving the inspection. The inspector then provides a report to
the certifier. The inspector reports his or her observations only
and does not make the certification decision.
Step 5: Review of the inspection report by the certifier
The certifier will review the report and determine whether the
operation is eligible for organic certification. The final decision
is then communicated in writing to the client seeking certification,
along with any requirements for initial or continuing certification.
The certifier may request further information or remediation, or
issue a notice of noncompliance, if the operation is not in full
compliance with all pertinent organic standards. Significant noncompliances
may result in denial or revocation of certification and/or require
correction prior to organic certification or renewal. Minor non-compliance
issues are those that do not threaten the integrity of the organic
products. (For example, procedures are properly carried out but
inadequately documented.) The notice will cite the issues of concern
and specify the time by which the operation must remedy the noncompliance
and provide documentation of the remediation to the certifier.
Step 6: Organic certification
A certificate of organic certification is issued if the operation
is determined to be compliant under the NOP (and any other applicable)
standards. Upon issuance of the organic certificate, the operation
may begin selling its products as organic. Product labels must identify
the certifier ("Certified organic by...") beneath the
name and identifying information of the producer or handling company.
Use of the USDA and/or the certifier's seal is optional. The certified
party should review the details of labeling in NOP section 205.300-311,
and ask the certifier to review any labels prior to printing. All
certified operations must be inspected annually.
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The Role of the Organic Inspector
The "inspector" is not the same as the "certifier."
It is important for the producer or handler to have clear expectations
about the role of the inspector—what services he or she can
and cannot provide. As noted in Step 4: Organic Inspection, the
primary role of the inspector is to gather on-site information and
provide an accurate report to the certifier. The inspector verifies
a) whether observations of an operation's daily practices are consistent
with the client's Organic System Plan (previously submitted to and
approved by the certifier), b) whether the practices and inputs
are in compliance with the USDA National Organic Standard, and c)
whether those practices and inputs are adequately documented. The
certifier then makes the certification decision based on information
provided in the OSP, the inspection report, and associated documents.
The organic inspector can refer clients to sources of information
about organic compliance. Photo
by Ann Baier. |
The inspector can do the following:
- provide information about the certification process
- answer general questions about organic standards and requirements
- explain the range of practices and/or record keeping that the
certifier considers sufficient to show compliance
- make referrals to public sources of information, such as Cooperative
Extension services, USDA agencies, farm organizations, trade associations,
and ATTRA's toll-free line and publications
The inspector cannot serve as your advisor or consultant. The inspector
may not recommend specific products, practices, animal or plant
varieties, or give advice for overcoming identified barriers to
certification. The inspector must not hold a commercial interest
in the business being inspected, provide paid consulting services,
accept gifts, favors, or payments other than the prescribed inspection
fee. Finally, the inspector does not make the certification decision.
Any of the above constitutes a conflict of interest that is strictly
prohibited by law, as described in NOP Section 205.501.
The certified entity can be assured that the inspector has signed
both a conflict of interest and a confidentiality agreement with
the certifier to protect all proprietary information of the inspected
operation.
Even when you take into consideration the limitations of the inspector
(as described above), the inspection can still be a useful opportunity
to expand your knowledge of organic requirements, the processes
necessary to meet those requirements, and associated information.
As you prepare for your inspection, you might find it helpful to
make notes of any questions you have, in particular about the certification
process and where to go for assistance in answering further questions.
To avoid potential conflicts of interest, please be aware of the
limitations on the role of your inspector.
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Related ATTRA Publications
Additional Resources
The National
Organic Program (NOP)
Organic Materials Review Institute
International Federation of
Organic Agriculture Movements
Biodynamic
Farming and Gardening Association
International Organic Inspection Manual IFOAM and IOIA,
December 2000.
Order from:
Independent Organic Inspector's Association (IOIA)
P.O. Box 6
Broadus, MT 59317-0006
406-436-2131 telephone/FAX
ioia@ioia.net
www.ioia.net
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 Inspector
Organic Certification Process
By Ann Baier, NCAT Agriculture Specialist
Paul Williams, Editor
Cole Loeffler, HTML Production
IP 262
Slot 266
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