| Editor’s
NOTE:
Certified organic farmers do an odd thing – they
pay people to visit their farms with a critical eye
to assure they are adhering to every aspect of the USDA’s
national organic standard.
The farmers should already be trying to produce, harvest
and market their organic crops, livestock and related
products by these rules. The on-farm review of fields,
facilities and records by an approved inspector sent
by the farmer’s accredited organic certifier is
the critical point in confirming that the farmer and
the farm meet the organic standards – and can
prove it to anyone who needs to know.
The visits are pivotal for applying farmers to become
certified, and for certified farmers to keep that certification.
For the good of organics, we want to help build the
foundation for effective inspection visits. We’ve
asked Jim Riddle to provide an inspector’s inside
view to help farmers understand an inspector’s
role, responsibilities and limitations. In the months
ahead, Riddle will elaborate on many of the items mentioned
in this introductory column to help farmers understand
regulations that apply to them, and how to document
their compliance.
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Jim Riddle has been on hundreds of farms in the inspector
role, and he’s been inspected himself during his
time as a farmer. His leadership in bringing professional
training to inspectors helped to earn greater acceptance
of organic farming in the U.S. He serves as vice-chair
of the National Organic Standards Board, which advises
the USDA on organic agriculture policies and regulations.
He has been an organic farmer, gardener, inspector,
educator, policy analyst, author, and consumer.
He was founding chair of the Independent Organic Inspectors
Association, (IOIA), and co-author of the IFOAM/IOIA
International Organic Inspection Manual. Riddle has
helped train hundreds of organic inspectors throughout
the world. In 2003, Jim was appointed Endowed Chair
of Agricultural Systems at the University of Minnesota.
He serves as an organic policy specialist for NewFarm.org.
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Posted August
3, 2004: For me, the best part of being an inspector is
interviewing the farmer. I get the opportunity to hear first hand
the stories of organic farmers - their successes and failures, their
excitement and pride in what they are doing.
As an inspector, I try to make the inspection a good experience.
I want the farmer to get something out of it. At the same time,
I have to make sure the information is accurate and the paperwork
is complete. Otherwise, certification can be delayed or even denied.
On one memorable inspection, finishing at midnight was no fun for
me or the farmer. We had started the inspection at 6:00 pm. After
inspecting numerous fields and locating the beef herd in a distant
pasture, we sat at the kitchen table to complete the paperwork.
What took so long was the fact that the 50+ fields had acreage
and number changes (and new maps) since the farmer had completed
his Organic System Plan (OSP). He also had some changes in the crops
he planted versus what he had planned to plant – a common
occurrence. He had not prepared a new acreage list or updated the
farm map. Consequently, we spent about two hours redoing his “crops
requested for certification” table, since accurate information
is required for organic certification.
Many inspections take longer than necessary, often due to the fact
that the farmer is not prepared: previous certification conditions
have not been addressed; maps and field histories are not up to
date; records are not accessible; seed and other product labels
are not saved or are not accessible; organic harvest and sales records
are not available; or records are not organized to track products
from sale back to the field(s) of production.
Other factors can delay the inspection. For example, farmers often
keep old products or containers from prohibited substances formerly
used on the farm. The presence of such containers raises additional
questions, extending the length of the inspection.
Here are some simple ideas to shorten the inspection time:
- Read the letters you get from
the certifying agent. Prepare any information
requested by the certifying agent. During the inspection, I review
all previous conditions for certification and issues of concern
identified by the certifying agent. These letters clarify what
issues I will be discussing with you, so be prepared to respond.
- Organize your records
in file folders or a ring binder with separate sections. Have
your records readily accessible for the inspection.
- Provide accurate and up to date
written information. If your crop plans, planting
dates, field sizes, crop locations, or input plans have changed
since the OSP was submitted, be prepared to provide written documentation
to the inspector.
- Verify your acreage.
The total of individual organic field acreages must equal your
total acreage requested for certification. To be sure, add up
your individual field sizes and compare to the total acreage requested
for certification, before the inspection.
- Keep all labels and receipts
– this includes seed bags or packets, soil mix
ingredients, and all inputs including fertilizers, pest control
products, animal health care products, animal feeds, and feed
supplements.
- If you use a lot of inputs, use
an input inventory sheet (with columns for the
brand name, source, location used, date first used, date when
approved by the certifying agent, and date discontinued use).
This helps clarify what inputs are used, and if they have been
approved. If an input has already been approved, the inspector
does not have to write down all label information, saving valuable
inspection time. Input inventory sheets can be used for fertilizers,
pest control products, and animal health care products. ATTRA
has free downloadable examples of all types of records available
on the website, www.attra.ncat.org
or call 1-800-346-9140 for hard copies.
- If you sell bulk commodities,
keep accurate harvest totals and sales records per crop.
The inspector will choose one of your crops to do a “sample
audit balance” to see if your records can track the crop
from sale back to the field(s) where it was grown and to assess
if the amount you harvested and sold was realistic for that crop.
- If you are a market gardener
or if you sell products directly to consumers, keep daily or weekly
sales totals, along with accurate input and production
records. The inspector will need to review your production and
sales records.
- Walk through your storage areas
before the inspector arrives and get rid of any products you no
longer use. Check with your local Extension Service office for
proper disposal options.
Thanks for being prepared. It helps me do a better inspection and
facilitates your organic certification. 
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