Organic Broadcaster

Organic inspector shares tips to make inspection go smoothly

By Mariann Holm, Organic Inspector

These winter months are a natural time to regroup, reassess, and make new plans on the farm. The farm desk calls out for our attention as the season of taxes, seed orders, and paperwork has arrived. Record-keeping is a fact of life for all of us, but especially for those certified as organic producers.

On my own farm, we have been certified organic since 2004. First our land was certified, and our herd of Jersey dairy cattle followed the next year. I remember that our organic transition had a bit of a false start. Initially, we sent in $50 to a certification agency to begin the paperwork of organic transition. The agency sent us back a stack of papers somewhere between two and three inches high to read and review along with a lengthy application. Those forms sat on the desk for a year. We were just too busy, or perhaps that paper pile was just a bit too intimidating.

The next year, as I remember, we asked for the paperwork once more. We paid for our procrastination—$75 was now the cost of receiving the paperwork. This time, we completed the paperwork with help and advice of those at MOSES and from our certification agency. Input from other organic farmers was invaluable to us, then and now. A little encouragement and guidance made the difference!

Now, as an organic crop and livestock inspector, I sit on the other side of the table from farmers at organic inspections. I appreciate all the forms and paperwork involved in organic certification because I have a much better understanding of the intent and purpose of them than I did over a decade ago. I also understand why confusion and frustration can arise over the process. The sight of that stack of papers remaining on the desk for a year remains vivid to this day.

Understanding what goes on at the certification agency can help us embrace the paperwork and appreciate the inspection process as vital and important. We, as organic farmers, are proving through verifiable documentation that our production methods have met the National Organic Program standards.

Organic System Plan Update
Each year, organic certification agencies require that their organic clients update their organic system plans. The organic system plan is an important link between the organic farmer, the certification agency, and the USDA National Organic Program (NOP). This document details the many ways the farmer is operating in compliance with the federal organic standards.

The annual update is an opportunity to communicate planned changes to your certifier. An additional organic inspection sometimes can be required due to potential changes or additions to types of crops being grown, livestock raised, or products planned for sale. For the certifier, knowing at the beginning of the year how many inspections need to be scheduled and when inspections need to take place helps to ensure they can meet a producer’s timing needs.

The best practice before adding any new input used for crops, livestock, or in processing is to contact the certifier for material approval. Inputs can be expensive and non-refundable. Certification agencies aim to work cooperatively with you, their client, to help ensure that your production is in compliance with the NOP requirements. Materials review of inputs is an ongoing and intricate process. Inputs can incur changes and lose their status as eligible for use in organic. Product labels themselves sometimes can also be misleading. A seed dealer, an agri-business salesperson or a neighbor isn’t a good replacement for your certification agency’s approval for a product. Using a prohibited substance, even by misunderstanding, can throw land out of organic status for 36 months or cause an animal to lose organic eligibility. Updating any and all inputs listed on your organic system plan helps ensure that these items get reviewed by certification staff who can flag inputs that are no longer allowed.

Recordkeeping
Annual update time is also a good time to decide if your recordkeeping system is working well for you. If you dread inspection and find yourself putting off the necessary paperwork, perhaps you need to lift your spirits by refreshing how you keep records. Small but practical steps can go a long way. Set up a colorful, tabbed binder on your kitchen shelf to store invoices or receipts. Hang a big calendar in the barn as a visual reminder to make herd health notes. Carry a pocket diary to record field and crop notes. There is no one right way to keep records. The important thing is to develop a system that works for you. A fresh start to the year may also include communicating the need for records to all those involved on the farm and reviewing who will be responsible for each area of pertinent records.

Annual Inspection
When your certifying agency receives your annual update, certification staff will do the initial review. If they have no further questions at that time, they will notify you that the initial review is complete and schedule your inspection.

The initial review letter often contains reminders of items that will be covered or needed at inspection. Read your letter and spend a few minutes to review the items requested. Highlight the areas you know need your attention in your recordkeeping system. For example, if a document verifying adjoining land use expires soon, or soil or water tests need to be done, plan to have them completed in time for your inspection. Contacting neighbors and conducting tests can be a slow process.

You can save time, frustration, cost, and complication by spending time on the front end to create an accurate and detailed organic system plan. The inspector visits your farm to verify that the organic system plan is accurate and that there are no impediments to meeting organic standards. An accurate and updated organic system plan sets the stage for an efficient inspection. An accurate plan can also minimize confusion and respective follow up conditions from reviewers.

Inspectors see a diverse mix of farming operations in any given season. Part of the beauty of organics is the wide range of practices used and products that are being produced. For example, crops viewed at inspection can vary between maple syrup, hops, fruits, herbs, vegetables too numerous to list, as well as agricultural mainstays like hay, soybeans, and corn. Cover crops, too, are increasingly diverse and the corresponding cropping systems can be wonderfully complex. Due to the diversity inspectors see, they need to ask a lot of questions, which can seem rather odd or even ignorant to any one producer. The inquiries made by your inspector are made to further understand your particular practices so they can accurately report to the certifier what is happening on the farm.

Increasingly, organic farms have multiple enterprises. Multiple enterprises often make sense in organic production. Often, organic farms have multiple species of livestock. Hogs, poultry for eggs/meat, as well as goats, sheep or cattle for milk/meat/fiber/soap or other value-added products can add resiliency to a farm and bring in beneficial nutrients and additional revenue streams. Some farms have organic crops, livestock, greenhouses, processed products, and also have non-organic production.

For each organic species of livestock, crop, or product, the farmer needs to have records to verify production methods. Organic products must have the ability to be traced back to the sources, whether to the seed and field or to the origin of any one particular livestock. This sets organic apart from some other forms of agriculture at this time. For this purpose, NOP 205.103(b)(2) requires that records must fully disclose all activities and transactions of the certified operation in sufficient detail as to be readily understood and audited. This underscores the need to keep sales receipts and invoices for all inputs, crops, and livestock bought and sold, as well as for maintaining the identity of all individual livestock on the farm though records and tagging.

Many farmers find that once a good system of recordkeeping is in place, maintaining it becomes natural. Over time, they come to appreciate the value of having years of written records for making solid management decisions on the farm.

You can find checklists for organic recordkeeping on the internet. Your organic certifier also should have tips to help you prepare for inspection. Take advantage of these resources. Small steps can result in confidence and peace of mind as you go through your annual organic inspection.

Mariann Holm is an organic crop and livestock inspector. She’s also a specialist with MOSES.

 

 

From the January | February 2019 Issue

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