October
14, 2004: Organic inspectors have traditionally
reviewed information for accuracy and identified issues of
concern at the end of each inspection. I never want anything
I write in my inspection report to be a “surprise”
to the farmer, so I like to talk about what I’ve seen
before I leave the farm. It’s just common courtesy to
discuss the important issues that will affect a farmer’s
certification.
The National Organic Program (NOP) formalized this process
with the “Exit Interview” in §205.403(d)
which states “The inspector must conduct an exit interview
with an authorized representative of the operation who is
knowledgeable about the inspected operation to confirm the
accuracy and completeness of inspection observations and information
gathered during the on-site inspection. The inspector must
also address the need for any additional information as well
as any issues of concern.”
Some certifying agents have specific forms that are filled
out during the “Exit Interview.” Additional information
that is needed from the farmer as well as specific issues
of concern are identified on this form. Some agencies even
have the farmer sign the form to verify that the exit interview
occurred and the farmer participated in the process.
Minimize issues of concern
As an inspector, I must identify all areas where your operation
may not comply with the NOP. During the inspection and exit
interview, you have the opportunity to give me as much information
as possible so I fully understand the situation. It is my
job to give the certification agency an accurate representation
of your operation.
For instance, the sorghum sudan seed you purchased was untreated
but not certified organic. The seed was listed in your organic
plan. You explained to me that you called several seed dealers
but were not able to find organic seed. Good job, so far.
But, in order to verify this, you also need to keep a record
of those attempts. Most certifying agents require three attempts
of seed dealers who offer organic seeds. Thus, an issue of
concern is identified: no documentation of attempts to obtain
organic sorghum sudan seed.
You can save yourself a lot of time and hassle by doing a
“self-assessment” of your farm. Walk through the
farm, look in your buildings, examine your equipment, and
review your records, including product labels, receipts, and
seed tags, to make sure that you have all of the information
that the inspector will want to see. Does your farm having
any “issues of concern?” If so, try to address
them before the inspector arrives.
If you can’t address issues before the inspection,
try addressing them during the inspection. Every time the
inspector identifies an issue of concern, propose a solution.
Instead of waiting for the inspector to submit a report, and
for the certifying agent to send you a letter listing your
farm’s non-compliances, go ahead and implement that
record documenting your attempts to obtain organic seed. It
may be a blank record at first, but it is in place and ready
to go. That way, there is no concern. The inspector can report
you have implemented the record for future use. Some concerns
cannot be addressed this way, but it is to your advantage
to eliminate as many concerns as possible.
Send in additional information as soon
as possible
When we were getting our own farm certified this year, the
inspector needed more ingredient information on some soil
mix we had purchased. We bought the soil mix during a silent
auction for MOSES, so we did not have an invoice or label
information. We called the company during the inspection and
left a message. The next day, the company returned our call
and faxed us the information we needed. We then faxed the
information to the inspector. Thanks to quick follow through,
the inspector was able to submit a complete inspection report.
The exit interview can be tough, as you are forced to come
face to face with your farm's short-comings, but be forthright
and cooperative and the process will be much less painful.
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