“Organic” is a word commonly seen by shoppers in the supermarket. There are signs announcing where you can find organic foods. There are aisles designated for these products and entire stores that sell only organic produce. The labels on the packages proudly state the contents are “Organic”. This term refers to foods that are produced by organic farming, a practice that has strict standards for methods and materials used. The best known objective is to produce food that does not contain substances that are considered objectionable, but there are lesser known objectives as well.
According to the National Organic Program (NOP) administered by the United States Department of Agriculture, this labeling term includes many other considerations besides producing food that is more healthy. The methods of production must utilize “cultural, biological and mechanical practices that foster cycling of resources, promote ecological balance and conserve biodiversity”. One of the important themes of the organic rule is to promote methods and objectives that will help preserve the resources and productivity of the earth. In the final analysis we all depend on the earth for our livelihood. So a case can be made that when you buy organic foods you are benefiting the earth as well as the health of your family.
As a part of this theme Organics includes the more commonly known requirement for prohibiting the use of substances such as synthetic fertilizers, sewage sludge, irradiation, and genetic engineering. With the legislative backing of the Organic Foods Production Act of 1990, the NOP has evolved with extensive studies of many agricultural materials to determine whether they could be used without compromising organic principles and objectives. In the Regulations, synthetic materials, (substances that have been altered from their natural state), are commonly prohibited, but there is a list of ones that have been studied and are considered acceptable. Also there is a list of “non-synthetic” substances that are prohibited. If a non-synthetic substance is not listed as prohibited, it is considered acceptable.
What is Regulated and How?
The emphasis is on food products including both crops and livestock. Also, some non-food products are sold as organic such as cotton, wool and beauty products (shampoo). These non-food products were encouraged by the National Organic Standards Board in 2009 but enforcement is limited.
In order to use the word Organic to describe the product, larger producers must be “certified” according to standards set by the regulations. Smaller operations under $5,000 in annual sales may sell organic but are exempted from formal certification. They still must comply with the standards and must agree to a records audit if requested. In order to use the USDA Organic seal on the label the product must contain at least 95% organic ingredients. If the percentage is lower, but at least 75%, the label states that the product was “made with organic ingredients” and clarifies what the ingredients are. The name of the “certifier” must appear on the label.
Accredited certification agencies administer the regulations. These are entities that are a part of the state governments or are non-profit and private businesses. All must adhere to stringent standards enforced through accreditation audits conducted by USDA.
To enforce the standards, the certifiers employ inspectors who are trained in the standards of NOP regulations. Each year they inspect each “producer” (farmer who raises the product whether crop or livestock) or “handler” (firm that handles the product and continues the marketing process after harvest). This annual inspection may be the most important single part of the process because it is the only opportunity for direct contact on the site of production or handling operation. When the accreditation audit of the certifier is conducted by the USDA, the auditor selects a few of the annual inspections of operations to audit. So there are auditors to inspect the inspectors and quality is assured (or at least increased).
I was an Organic Inspector as part of my job until in 2012 I retired from full time work. Now I do organic inspections and reviews of inspections part time as an independent contractor with more extra time to write articles like this. I have first-hand knowledge of the process and can vouch for the trials and tribulations as well as the satisfactions.
Most of the participants (farmers, ranchers and handlers) I have inspected are sincere and dedicated to the principles of the program. They try hard to comply with requirements but it is not always easy. An example of difficulty encountered is the standard that indicates that soil fertility must be maintained or increased. Fertility as measured by soil organic matter and crop vigor varies with the conditions encountered. Soil can retain many of the nutrients associated with fertility but it is hard to show that you are maintaining or increasing fertility in a series of dry years or when other adverse conditions prevail over which the producer has no control or limited control, such as hailstorms, weed or pest infestations or excess heat or cold. There are times when even the best operators have to struggle to minimize losses.
Steps Toward Organic Certification
When a producer decides to apply for certification, there are five basic steps that are completed.
Step 1: Application to the certifying agency and development of the Organic System Plan (OSP):
The plan describes the operation in detail including maps and land descriptions. The plan emphasizes how the producer expects to comply with the standards. The form varies with the certifying agency but typically involves a series of questions the operator must answer.
The resulting plan specifies which crops or livestock will be raised. The operator lists methods of tillage, cultivation, crop rotation, pest management, livestock health care, harvest and transportation of crops, storage and processing methods. Throughout the plan the emphasis is on practices that provide biodiversity, such as by designating natural undisturbed areas on the farm.
Conventional control methods such as poisons cannot be used to reduce populations of nuisance species such as gophers. Therefore, predators such as raptors (hawks and eagles) are allowed to maintain a presence. The producers also must show how they are maintaining soil fertility by crop rotation and prevention of erosion. The plan explains provisions for preventing contamination of organic crops and livestock with substances such as prohibited pesticides, herbicides, synthetic fertilizer, antibiotics or non-organic livestock feed.
There is a requirement for humane treatment of animals with consideration given to the comfort levels of livestock raised. Antibiotics must be given to an animal if needed to prevent suffering from illnesses. The animal is then designated as non organic.
Each material used, such as inoculant for legume crops or natural fertilizer, must be listed in the plan and the source identified. Crop seeds must be certified organic unless it can be shown that no organic source is available. Seeds can only be treated with approved materials and genetic modification of seeds is prohibited.
The plan must describe how the producer expects to monitor the effectiveness of the practices used. Most farmers walk through the fields regularly and make notes of what they see. Other monitoring measures include soil testing, product quality testing or body conditioning scores for monitoring livestock herd health.
If the farm adjoins non organic operations there must be a means of avoiding conflicts such as drift of herbicide or insecticide spray across the boundaries. Buffer zones are maintained between organic and non organic fields. If the operation includes non organic crops in addition to the organic it is very important to show how the crops are kept separate to avoid commingling.
The plan must be flexible to keep up with changing conditions. Any changes must be reported in at least annual updates or complete rewrites if there is a major revision.
Step 2: Review of the Plan:
The certifier reviews the application and plan and evaluates whether the operation complies with the regulations. If anything else is needed the applicant will be asked to supply it. If the operation appears to comply or can be made to comply the application is approved and an inspection is scheduled. An inspection is required each year from then on.
Step 3: Inspection:
A trained inspector visits and makes notes on site. The purpose is not to consult and provide advice on the operation but to assess compliance, verify that the plan accurately reflects the activities and to ensure that prohibited substances have not been applied. The findings of the inspection are to be described to the producer who acknowledges and signs off on the findings.
Record keeping is an important part of the requirements and one that is difficult for many. The tendency of many farmers and ranchers, including non organic operations, is to keep track of some record items only in their heads especially when they seem obvious, routine and easy to remember, and not to spend much time writing dates and amounts down or having a filing system that will make documents available on demand. However, the certifier must confirm or verify important information that shows compliance with the regulations rather than just taking the word of the producer. As a result much time at the inspection is spent on the records. As could be expected, some producers are talented at this, but others not as talented even though they may be otherwise good managers dedicated to the objectives.
What Records are Required?:
Ideally records should be available that would show the date and method used of all actions taken and purchases made (with copies of invoices) in producing a crop. This includes the seeding rate, the acres planted, times of monitoring of the crop, dates of starting and completion of harvesting, yield per acre, transporting of the crop into the storage bins, taking the crop out of storage when sold or moved, and sales to the purchaser. Many farmers can show most of the ideal information on their farm journal where they write things down as in a diary. Typically some but not all of the needed records are present.
An important objective of record keeping is reconciliation of the volume of organic products produced or received with the amount of organic products shipped, handled and sold.* Audits are conducted of crops produced. One of the most important needs for record keeping is the yield and sale information to finalize the tracking of the crop from seeding through harvest and sale.
The inspector must be able to judge whether the yield was reasonable and account for where it was sold as an organic crop or taken for storage. If there is a discrepancy, such as amounts sold exceeding the yield, there may be reason to suspect non organic crop has been sold as organic, which would be one of the most serious violations. As might be expected, there are probably at least some violations, either intentional or accidental, that are sometimes not detected but the inspection serves as a strong deterrent against problems and incentive to do a good job.
Inspection findings are reviewed with the operator, completing the process of communication. The operator must be informed of any discrepancies. The inspector prepares a detailed report to be sent to the certifier.
Step 4: Review of Inspection Report
The certifying agency makes a review of the report within a reasonable time, usually 30 days. The reviewer considers the OSP and all known information in addition to the inspection report. The reviewer must be someone different from the person making the final approval decision. The reviewer recommends whether to certify, to certify with conditions, to issue a non-compliance determination (where approval is withheld until the remedy is completed), or denial of certification.
Step 5: Certification Decision: An organic certificate is issued if the operation complies or is capable of complying. This certificate authorizes the sale of the organic product. Each year another inspection is completed after the operator sends the plan update in for consideration. Also if there are changes made in the operation at any time the operator must notify the certifier right away. Examples would include:
- Application of any prohibited substance. An example is where it is necessary to use herbicides if an infestation of a noxious weed is discovered. If this happens the sprayed area is fenced off and taken out of production for three years before being reinstated for certification of any crop or grazed by livestock.
- Use of a new material that was not listed in the OSP.
- Addition to or removal of portions of fields.
- Any change of methods or practices that might affect compliance with the NOP regulations.
Why Purchase Organic Foods?
As can be seen by this brief summary of the process, organic foods are produced under an ambitious framework of rules developed by experts and enforced by many trained employees. The topic is worldwide in scope. An impressive variety of products are covered in many countries, many of which use rules that are different from the United States regulations, but throughout the world organic producers are held to strict standards. Often the price to purchase organic foods is higher than conventional food but in many instances there is only a small difference in the retail cost. Cost of production of organic products may be lower because of not using conventional materials that are not allowed. However, synthetic fertilizer is not allowed and yields are sometimes lower as a result. Many of the benefits of organics are apparent but further study is needed which may discover advantages previously unknown.