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14, 2004: What's it really like to go through an organic
farm inspection for the first time? The Pennsylvania Association
for Sustainable Agriculture (PASA), Pennsylvania Certified
Organic (PCO), and Delaware Valley College teamed up recently
to help answer that question. The three groups agreed to turn
the real-life, first-time inspection of a part of the college's
farm into an educational event. About 35 people attended,
including conventional farmers interested in transitioning
to organic, non-certified organic farmers interested in certification,
and people with various kinds of farming experience interested
in becoming organic inspectors.
"We are inundated with requests from people wanting
to transition," explained PASA program coordinator Heather
House. In tandem with PCO, they decided that the 'open inspection'
would be a new and different way to disseminate information
about transitioning to organic—and hopefully help allay
fears farmers may have about the certification process.
PCO executive director Leslie Zuck said they were especially
pleased to have received an application for certification
from Delaware Valley because if the certification goes through,
it will mark the first certified acres at an institution of
higher learning in Pennsylvania. Penn State University has
some acreage in transition, but has not yet received full
certification on any of its farm or research lands.
A four-year private institution, Delaware Valley College
was founded in 1896 by a Jewish rabbi who believed in integrating
intellectual and practical education. Today it is one of just
a handful of private agricultural colleges (as opposed to
public agricultural universities) in the United States. It's
also, as Jim Diamond, dean of agriculture and environmental
sciences, noted in his introductory remarks, become "an
island of agriculture in a sea of development" in this
area north of Philadelphia.
The college has nine agricultural units—including orchards,
a dairy barn, a farm market, greenhouses, and an equestrian
center—each with its own farm manager, on a total of
about 600 acres. "All of this exists for one purpose
only," said Diamond, "for the students to get hands-on
experience."
The farm manager for the proposed organic acreage—a
two-acre block, including a 1/2-acre of blueberries—is
Neil Myerov, the college's horticulture manager. Myerov's
been on staff for just a year, and has 18 years of prior farming
experience, most of it in conventional production. Also present
was Dr. Jacqueline Ricotta, an assistant professor of horticulture
and a strong supporter of the decision to transition some
of the college's farmland to organic.
Organic inspector Al Johnson has been doing inspections for
15 years, and was himself an organic farmer for 13 years.
Like most organic inspectors, he operates as an independent
contractor. Last year alone he inspected more than a hundred
organic farms and processors, mostly in the Northeast, for
PCO and other certifying agents.
The inspection process has changed over the years, Johnson
told the group, especially since implementation of the National
Organic Program in 2003. In some ways, it's simpler, both
for the inspector and the farmer. Whereas there used to be
a dozen different sets of potentially applicable organic standards,
now there's only one.
From the file to the field
The first thing Johnson does upon receiving an inspection
assignment is to read the application, paying special attention
to the 16-page Organic System Plan which forms the heart of
a farm's certification paperwork. In their review of the application,
the staff at PCO will have noticed and flagged potential areas
of concern; Johnson does the same, knowing that his job is
to confirm that what it says in the application is also what's
going on in the fields.
While every inspector has his or her own system, Johnson
said, he likes to begin with a tour of the fields, move on
to the equipment sheds, packing and crop storage areas, and
finish up with the paperwork. "Most farmers are most
comfortable in their fields, so it's a good way to break the
ice."
It's important to understand that the inspector functions
as a neutral observer in the inspection process. "It's
not my job to say, this is what you need to do," Johnson
emphasized. "I simply make a report and then it goes
to the certification committee for a decision." Inspectors
are knowledgeable, however, and can point the farmer in the
direction of needed information. As Johnson put it, "I'm
not allowed to give advice—but discussions are okay."
The field tour usually begins with an examination of the
farm map provided by the farmer as a part of his or her application.
The inspector verifies the size and orientation of the fields,
buildings, water sources, and other significant features,
paying particular attention to the perimeter of the certified
area, or buffer zone.
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The federal rule has no set buffer-width requirement, but
Johnson said a good rule of thumb is that if the distance
is less than 25 feet, you need to look more closely. Wider,
taller or more densely vegetated buffers may be required if
adjacent land use activities present a strong possibility
of contamination. Myerov's proposed organic fields are bordered
on three sides by mature tree rows, unbroken except for an
access road, which is a good thing, Johnson noted, because
the adjacent areas included a conventionally managed orchard.
The fourth side has no tree row, but here there is a 20 foot
wide grass strip bordering a rough pasture in which some of
the college's dairy cows were grazing. Judging from the mix
of grasses and forbs in the pasture, it was unlikely to have
been treated with any prohibited materials.
Organic farmers on larger acreages sometimes choose to plant
their buffer strips to corn, hay, or another crop. In that
case, Johnson said, the farmer must have a plan for handling
and marketing the buffer harvests separately from their organic
harvest.
While touring the fields, Johnson asked Myerov about different
aspects of his operations. Farmers should expect the inspector
to ask questions such as, "What's your soil fertility
management program?" "What's your rotation?"
"What's your weed control program?" "What are
your biggest production challenges?"
"There's never a perfect time to do an inspection,"
Johnson admitted. "It's never going to be the best time
to see all the things that you could see." What the inspector
can do, however, is look at the general health of the crops,
the size and species of weeds, the condition of the soil,
the evidence of drainage patterns in the fields. Signs like
these can say a lot about how the season is going and what
past management practices have been like.
On a vegetable farm, the field tour would also typically
include a visit to the greenhouse. Although Delaware Valley
has a number of greenhouses, Myerov explained that he planned
to put up a dedicated organic high-tunnel later in the year.
Johnson made a note of this, explaining that PCO would probably
seek to verify in the spring that the high tunnel had in fact
been built or that the farm had some other means of producing
or obtaining organic seedlings.
On to the barn: tools, materials, and storage
In the equipment shed, Johnson began by asking to see Myerov's
weed management implements. The college farm had recently
invested in a tool bar system with spring-tine, knife, and
sweep attachments. "Is this and other equipment used
only in the organic fields?" Johnson wanted to know.
If not, then Myerov needs to keep a log showing that implements
are inspected and, if necessary, cleaned down each time they
are taken from the conventional to the organic fields.
Johnson said he also pays attention to a farm's tractors,
trucks, and wagons. A tractor that's way too big for the size
of the fields being farmed, for instance, could indicate a
potential compaction problem. On a mixed conventional and
organic farm, wagons can also be potential vectors for contamination.
After the equipment area, the group admired the college's
composting operation, which is managed by another staff member
and handles all the manure and bedding from the on-campus
equine center. For any compost obtained off-farm, Johnson
noted, you must have a letter stating that it has been produced
in accordance with NOP standards.
With regard to other inputs, Johnson emphasized adherence
to NOP materials lists. "I can't tell you what to use
or not use, but together we can look it up," he said.
Johnson carries a copy of the federal rule and current materials
lists from the Organic Materials Review Institute (OMRI) for
that purpose.
Another issue that tends to cause anxiety for farmers is
the necessity of documenting seed sources. NOP regulations
center on three requirements: not using genetically-modified
seed, not using treated seed, and trying to use certified
organic seed. The inspector can get an idea of a farmer's
practices just by noting the business name on the invoice:
some seed companies, like Johnny's, have pledged not to sell
GM seed; others, like High Mowing, sell only organic seed.
"If you have a long seed invoice and a mixed [organic
and conventional] operation," Johnson suggested, it's
helpful to "go through and highlight the seed purchased
for the organic operation."
In the washing and packing area, Johnson asked Myerov questions
like, "What do you use for harvest containers?"
"What's your system for keeping organic and non-organic
produce from getting mixed up?" Mixed operations sometimes
designate different colored harvest containers for organic
and conventional produce; walk-in coolers should have clearly
designated organic and conventional areas.
And then, the paperwork
The first thing to keep in mind when submitting your certification
application, Johnson said, is to be neat. "You don't
have to type it, but be neat." "Usually, once I've
met with the farmer, I come to like them, because 99 percent
of the people in this business are good people, but still,
if I get a sloppy application, it gives me a bad first impression."
Second, be accurate, and third, be thorough. Other forms
making up a farm's certification file include a field report,
materials list, prior land use statement, harvest records,
storage records, and sales records. The inspector will use
the latter three to verify a correlation in scale between
acreage, production, and sales.
If a farm has storage bins for grain or other large-volume
crops, a lot-number system is necessary so that each saleable
unit can be traced back to a given field and a given harvest.
Finally, Johnson noted, the federal rule requires certified
farmers and processors to keep a record of any complaints
they receive about the organic integrity of their product.
At the end of the inspection, the inspector fills out two
forms for submission to the certifier: the on-farm inspection
report and the exit interview. In addition, if there have
been any changes to the Organic System Plan (OSP) since it
was sent it to the certifier, these are made on the OSP in
red pen and initialed by both the farmer and the inspector.
The inspection report is where the inspector notes any areas
of concern. Each comment has to reference the relevant section
of the federal rule. "I try to write this out as much
for the farmer as for anyone else," said Johnson. In
Myerov's case, Johnson noted among other things that the field
records needed to be completed more fully, including the exact
date of all compost and other materials applications.
All in all, the group seemed to feel that the inspection
had gone well. "The first time through can be relatively
easy," Johnson said. "The second year is often harder
because you're finding out if the paperwork is adequate for
the operation in reality. By the third year, hopefully, the
issues are mostly worked out."
Even so, at the end of the afternoon, Myerov admitted that
he was relieved to be through with his first-ever organic
inspection. Did the experience meet his expectations? "I
think that's why I was nervous," he replied, "because
I didn't know what to expect." 
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