Inside Organics Blog

Organic needs user-friendly certification process to meet U.S. production demands

By Harriet Behar, MOSES

Organic consumption in the United States has reached a point where domestic production can’t meet the demand. In the current state of constrained growth, organic can be seen as a victim of its own success. It’s clear we need to develop better systems to increase the volume of domestic organic production. But, without an easier process for organic certification, the domestic share of the U.S. organic marketplace could continue its downward spiral.

More and more imported organic crops and products are filling the gaps in our domestic production. Organic livestock operations are being constrained by lack of domestic organic livestock feed grains and pasture land. The increased production of all types of domestic organic crops and livestock is limited by the lack of appropriately sized and located processing facilities. At the same time, consumer demand for organic products has maintained a growth curve which makes nonorganic food companies envious, and provides them a hungry market to siphon away to labels that have little to no legal definition, such as “natural.”

It is hard to see the hard work we’ve done to build the organic marketplace and the related environmental and economic benefits of organic farming being realized more and more beyond our borders. We need to change the certification system in order to change the outlook for domestic organic production.

I see two tangible changes that would encourage new producers to become certified and simplify the certification of current organic producers. One is the availability of a national list of brand name products organic producers can use when deciding which items they can purchase and use on their organic operations. The second is a generic, universally accepted Organic System Plan form.

Blog quoteCurrently each certifier, as well as the Organic Materials Review Institute (OMRI), oversees the brand name products that are allowed in organic production. Some certifiers charge their clients for this material review, others do not. There are products that may be allowed by one certifier and not by another. There is no criteria for certifiers to accept other certifier’s input decisions. This can be maddening for both suppliers who sell to organic farmers as well as for the farmers who want to make decisions on input purchases.

There are more variables in the decision to purchase an input than just whether or not it is allowed by the certifier (which of course is important). Issues such as price, transportation, application options, quality, availability, relationship with the supplier and more will influence product choices. Many farmers feel constrained to stick with their current input suppliers since it seems so difficult to find out what alternate inputs they can purchase. This is made even more difficult if a farmer changes certification agencies. This lack of transparency stifles supplier competition and provides fewer options for the organic operator.

A nationally available and comprehensive list of inputs approved by accredited certification agencies is a goal that has numerous challenges, but it must be accomplished to make it easier for organic farmers. Clear and consistent guidance from the NOP on how to review materials, as well as accreditation requirements of certifiers who do product reviews, must be fast tracked without adding more cost or paperwork. Certifiers must work together in their regions to share information about their product acceptance or denials. The National Organic Standards Board made a recommendation to the NOP more than three years ago to bring consistency to Materials Review Organizations (MROs), but the NOP has yet to act on that recommendation.

A tracking system that keeps an allowable materials list current will give producers confidence that the materials are still in compliance with the regulation. While developing this type of list might be a challenge, the NOP is well situated to obtain the information and manage or subcontract out the management of this list. OMRI’s product list is a good start, and would still remain valuable for those input suppliers who pay for the competent services OMRI provides. However, OMRI has limited scope, attractive to input manufacturers who sell nationwide or are based on the West Coast. Regional companies that sell products used by organic operators are at a competitive disadvantage in the organic marketplace due to this lack of comprehensive policy in materials review.

This is especially true in areas like the Upper Midwest, where many certification agencies operate, each with its own confidential list of approved-products. The only way an operator can determine if a given product is allowed by a certifier is to supply a label of the specific product. Certification agencies don’t typically review three or four products so the producer can have a choice. The operator usually decides on one product and then asks the certifier if it is okay to purchase and use.

At this time, each organic certification agency has their own Organic System Plan (OSP) template for their certified clients. This OSP is mandated in the US Organic Foods Production Act, and is the organic certification application that operations complete on a yearly basis, either as a long form or as an update. The current patchwork of documentation and forms has led to a significant barrier for both new producers and producers who wish to switch organic certification agencies. Many new producers, along with agricultural professionals such as extension agents, Certified Crop Advisors, and government ag agents often see the OSP as a mysterious document, and find the inconsistencies between each certifier’s documentation confusing and a barrier to understanding organic certification.

MOSES, along with other organic educational and policy advocacy organizations around the country, works diligently to provide information and tools to aid farmers to not only make the switch to organic agriculture, but to do it successfully. The Natural Resources Conservation Service has developed a Conservation Activity Plan (CAP) to aid producers in the transition to organic agriculture. The CAP addresses conservation issues, especially those that will help the producer to meet organic regulations, such as improving pasture quality for organic ruminants or putting windbreaks or beneficial insect habitat in buffer areas between organic and nonorganic production. Not having a universal OSP template that can be used by operations for their initial organic certification with any agency makes it is very difficult for agricultural professionals to shepherd individuals or groups of producers though an OSP.

Producers currently must decide which agency they want to work with before they begin the OSP completion process. Those in the very beginning stages, or who are averse to paperwork, would benefit from a familiar document that takes some of the mystery out of completing this necessary paperwork. Those attending a workshop, or having a professional (such as an NRCS technical service provider) help them complete an OSP using a universal template, could use the document they completed once they decide to choose a specific certifier, rather than transposing the information to unfamiliar paperwork. NCAT/ATTRA has a template for an OSP developed more than 10 years ago which could be a starting point for the development of a streamlined, generic OSP.

Paperwork often is cited as a significant reason producers avoid organic certification. Add to that high conventional commodity prices and saturation of some organic vegetable markets, and it’s easy to see why we’ve seen minimal growth in certified organic operations. At the same time, the pool of “exempt’ organic producers keeps growing. These mostly include farmers who sell directly to consumers. One of the main reasons these producers say they don’t become certified organic is not because they don’t sell more than $5,000 year of organically labeled products, but because they are afraid of, or confused or irritated by the process and documentation required to become certified.

Certification agencies have put a lot of work and time into the development of their own documentation and the accompanying tracking systems they must have in order to be accredited by the USDA. It might work best to give producers who are new to certification the choice to either use a specific certification agency’s paperwork or a generic OSP for their initial certification, with yearly updates done using the certifier’s documents. This would present a minimum of disruption to the certification system but would be useful in helping grow the number of organic producers.

Numerous successful and happy organic producers in every region of the United States are an important tool in gaining new organic farmers. The success of this pool of organic operators provides mentorship to new producers as well as encourages others to try this different system of production. Organic certification cost share has taken away the argument that certification costs too much. It is time the initial certification process and information on approved materials becomes more user friendly. Fixing these two issues would be a good start in encouraging new operations and improving the interaction operators have with their organic certification agencies.

Harriet Behar is an organic farmer and a MOSES Organic Specialist. She serves on state and national committees, providing the organic farmer perspective.

From the March | April 2015 Issue



Mar. 4, 2015

Dear Harriet,
Thank you for your thoughtful assessment. I have followed the organic movement in the U.S., and especially in Michigan, for several years. Over this time I have been struck by the decline on organic grower mobilization. (Witness the history of the Organic Growers of Michigan.) What are your thoughts about the possibilities of collective action (growers, processors, consumers) to address the issues that you raise?

Best, Jim

Mar. 4, 2015

I am one of those “exempt” producers. I raise everything in accordance with the NOP rules. But here in New York it impossible to find an organic poultry processor. There are exactly zero. For pork, there is a six month wait at minimum and at least a couple of two hour drives involved. It doesn’t make economic sense unless you are bringing in twenty or thirty hogs at a time. So, it is the lack of “organic certified” processing that is stifling the growth of organic livestock production here and thereby curtailing the number of producers who become certified.

I have suggested subsidizing and streamlining the certification process for processors to NOFA-NY, but that has gone nowhere.

Any suggestions?

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