Organic Certification Process

1. ATTRA Organic Certification Process
A Publication of ATTRA - National Sustainable Agriculture Information Service • 1-800-346-9140 • www.attra.ncat.org
By Ann Baier This guide is to help organic producers and handlers understand, prepare for, and get the most from
NCAT Agriculture the process of organic certification to USDA National Organic Standards (see www.ams.usda.gov/nop).
Specialist It discusses the purposes and benefits of the inspection for organic certification, provides a general
© NCAT 2005 description of the organic certification process, and outlines the role of the organic inspector. A com-
panion ATTRA publication, Preparing for an Organic Inspection: Steps and Checklists, is written for those
already familiar with the basic certification process, to help them prepare more systematically for an
initial or annual inspection. It includes steps for preparing for the organic inspection and checklists of
audit trail documents and required records for certification of organic crop and livestock production
and handling facilities.
O
Contents rganic certification
Purposes and Benefits provides thi rd-
of the Organic party confirma-
Inspection ......................... 2 tion that a production or
Steps to Organic handling operation is in
Certification...................... 3
compliance with organic
The Role of the Organic standards. Certification
Inspector ........................... 5
enables qualified produc-
Resources .......................... 6
ers and handlers to mar-
ket agricultural products
under a USDA certified
organic seal. In its sim-
plest terms, the organic
seal assures the consumer
of organic integrity. First,
a product is grown in an
organic production system
that emphasizes plant and The author (right) conducting a field inspection with Delfina Córcoles and her
daughter. Photo by Rex Dufour, NCAT.
animal health, preven-
tative management of pests, and judicious ingredient processed product. The label
use of allowed materials. Then, the product may carry a claim of “100 percent organic,”
is tracked and protected from contamina- “Organic” (95% to 100%), or “Made with
tion from the field to final sale, whether it organic ingredients” (at least 70% organic
is a raw agricultural commodity or a multi- ingredients).
As an organic inspector, I have heard from both farmers and food processors that an important ben-
ATTRA - National Sustainable efit of organic certification is that it requires and inspires them to keep better records. Records help
Agriculture Information Service
is managed by the National Cen-
identify and solve problems more readily. A newly certified organic bakery described how the organic
ter for Appropriate Technology certification process immediately paid off in that business.
(NCAT) and is funded under a
grant from the United States • The bakery was having problems with one type of organic bread they were baking. Several
Department of Agriculture’s batches did not rise properly. The resulting loaves did not have good texture and could not be
Rural Business-Cooperative
Service. Visit the NCAT Web site sold. The bakers turned to the record-keeping system they had recently put into place for their
(www.ncat.org/agri. organic certification. This audit trail allowed them to track every ingredient to its source. They
html) for more informa- looked at their batch sheets and found that they could trace the problem back to a certain
tion on our sustainable
agriculture projects. ���� (continued on page 2)

2. (continued from page 1)
lot-number of flour. They contacted the supplier and asked not to be sold that particular lot-
number of flour in the future. Their bread quality quickly returned to its usual high standards.
Dairy farmers describe how their record keeping helped them maintain healthier herds and good
milk production, after their first year of organic certification.
• Gary and Patricia Belli of Belli Dairy in Ferndale, California, noticed a drop in their herd’s milk
production. They were keeping track of their purchases of organic feed, with lot numbers and
amounts delivered from various sources. By looking at their feed purchase records, they could
see the relationship between the decrease in production and the time when they used feed
from a certain source. They asked their supplier to avoid a feed lot that appeared to be of poor
quality. When they resumed feeding better quality feed from other lots, their milk production
problem was solved.
• Robin and Maralyn Renner (brother and sister) manage Diamond R Ranch in Ferndale, Califor-
nia. They run the family dairy and raise organic beef. They described how much healthier their
herd was once they began operating as a certified organic operation. Organic certification
required that they keep accurate and more detailed records. They said that after working with
these records for several months, “We began to recognize patterns.” Better records helped
them to connect the dots. They saw correlations and discerned causes and consequences.
Related ATTRA They improved their organic production system by putting what they learned into practice.
Publications When I spoke with him recently, Robin reiterated what Maralyn had articulated a year or two
earlier: there are practical benefits to keeping the records required for organic certification.
Preparing for an Their cows are healthier and they have better farm management. “We’re glad we did it, “ he
Organic Inspection: said. “Every year gets better.”
Steps and Checklists –Ann Baier, organic inspector
NCAT’s Organic Crop
Workbook
NCAT’s Organic Purposes and Benefits of Benefits of the inspection process for
organic certification include the following.
Livestock Workbook the Organic Inspection
• Building consumer confidence in the
The organic inspection doesn’t need to be meaning of the organic label
scary, stressful, or onerous. The inspec-
tion process can be useful to producers of • Fulfilling requirements to get or main-
crops or livestock, and processors or han- tain organic certification
dlers of agricultural products. The organic • Improving farm record-keeping systems
inspection is a unique opportunity because and keeping up-to-date records
it involves the most face-to-face contact • Providing an opportunity to better under-
between the producer or handler and an stand organic standards
inspector who works for the certifier.
• Getting updated information about allowed
Organic certifiers conduct annual inspec- and prohibited materials
tions of all their clients (certified parties)
• Learning about public educational
to verify, through on-site review of actual
opportunities or sources of informa-
activities and the corresponding records,
tion and technical assistance avail-
that the clients are in compliance with the
able through your certifier, Cooperative
relevant organic standards. Every USDA-
Extension, local farm organizations, or
accredited certification agency must make
industry networks. (Please note that this
annual inspections. Most inspections are
is not part of the inspection, but an inci-
scheduled with the client in advance; how-
dental benefit. The role of the inspector
ever, some inspections are unannounced.
is discussed below.)
This publication will help you incorporate
management practices that will keep you The steps that help you prepare for your
prepared for an inspection at any moment. inspection for organic certification will also
help you maintain healthy farming systems
and viable business practices.
Page 2 ATTRA Organic Certification Process

3. Steps to Organic integrity (with regard to borders and
buffers, application, planting and har-
Certification vest equipment, post-harvest handling
Step 1: Selection of a certifier and storage), planting, production, har-
vest and sales records, monitoring sys-
The producer or handler chooses a certi- tems, and product labeling.
fier and requests an application packet.
USDA-accredited certification agencies • Livestock Production: Source of animals,
(ACAs or certifiers) are listed on the NOP feed and feed supplements, description
Web site (www.ams.usda.gov/nop/Certifying of housing and living conditions, health
Agents/Accredited.html). All USDA-accred- care practices and materials, manage-
ited certifiers—whether private (non-profit ment practices (i.e., access to the out-
or for-profit) or governmental—certify to doors and pasture for ruminants), physi-
the same USDA National Organic Stan- cal alterations, manure management,
dards. Some certifiers, however, are bet- record-keeping system, and product
ter recognized in the organic industry/mar- labeling.
ketplace, and some may offer certification • Handling Operations: Sources of ingre-
to additional standards—such as Interna- dients and processing aids, materials
tional Foundation for Organic Agriculture and standard operating procedures for
(IFOAM), European Union (EU), Japanese cleaning, sanitation, and pest control,
Agricultural Standards (JAS), Conseil des measures to protect organic integrity
appellations agroalimentaires du Québec (prevention of commingling and contam-
(CAAQ), Biodynamic, GAP, Kosher, or Fair ination), packaging, record-keeping sys-
Trade—while other certification agencies tem, product formulations, and product
may provide services such as newsletters, labeling.
workshops, or educational opportunities.
Consider your marketing needs—whether
your approach to marketing requires verifi-
cation of compliance to other standards—as An Organic System Plan
well as your personal interests. should include informa-
tion about management
practices such as ani-
Step 2: Application and submission mals’ access to pasture
of an organic systems plan and outdoors.
The pastured layer hens
The producer or handler submits an appli- at left belong to Paul and
cation and an Organic System Plan (OSP) Leti Hain of Tres Pinos,
to the certification agency, using the certifi- California.
Photo by Ann Baier.
er’s forms and guidelines and attaching any
requested documentation, licensing agree-
ments, and fees. The OSP consists of written
plans and relevant information concerning Step 3: Application and Organic
all aspects of your operation. Following are System Plan Review by the Certifier
some examples of required information. The certifier reviews the Organic System
• Crop Production: Land use history doc- Plan (OSP) and accompanying documenta-
umentation, field maps, crop rotation tion for completeness and assesses the appli-
plans, soil improvement and pest man- cant’s capacity to operate an NOP-compli-
agement plans, seed sources, material ant operation. The certifier determines that
inputs (soil amendments, fertilizers, com- the operation can meet the requirements
post, manure, pest control materials, or for certification as outlined in the OSP. The
any other materials) used and planned certifier will then assign a qualified organic
for use, measures to maintain organic inspector to do an on-site inspection.
www.attra.ncat.org ATTRA Page 3

4. pests, water systems (for irrigation and
post-harvest handling), storage areas,
and equipment.
• The livestock inspector inspects feed
production and purchase records, feed
rations, animal living conditions, pre-
ventative health management practices
(vaccinations and other medications cur-
rently being used or planned for future
use), and health records. The inspector
observes and assesses the animals’ con-
dition.
• The handler or processing inspector
inspects the facility and evaluates the
Organic inspectors receiving, processing, and storage areas
assess the adequacy of used for organic ingredients and finished
procedures to prevent
products. Critical control points are an
contamination.
Photo by Ann Baier. essential part of any handling opera-
tion and its inspection. The inspector
analyzes potential hazards and assesses
Step 4: Organic inspection organic control points—the adequacy
of procedures to prevent contamination
Organic inspections come prior to ini- (from sanitation supplies, pest manage-
tial certification, then annually thereafter. ment materials, or non-organic process-
The inspection must occur when a person ing aids), and to prevent commingling
knowledgeable about the operation is pres- with non-organic ingredients.
ent, and should occur where and when the
crops, livestock, and/or processing or other At the end of the inspection, the inspec-
handling can be observed. tor conducts an exit interview with the
inspected party to confirm the accuracy
The Inspection Preparation Checklists in and completeness of the inspector’s observa-
the ATTRA publication Preparing for an tions. The inspector will review any requests
Organic Inspection: Steps and Checklists pro- for additional information and any issues of
vide a detailed description of the documen- potential non-compliance with respect to the
tation required for the three major types of National Organic Standards. The inspector
operations: crops, livestock, and handling. provides the inspected party with a written
In all three types of operations, the organic copy of the exit interview before leaving the
inspector conducts an on-site inspection inspection. The inspector then provides a
and review of record keeping to verify that report to the certifier. The inspector reports
the OSP accurately reflects your operation his or her observations only and does not
and is in compliance with NOP standards. make the certification decision.
Records to be verified include input materi-
als, production, harvest and sales records, Step 5: Review of the inspection
as well as appropriate product packaging report by the certifier
and labeling. The inspector assesses the risk
of contamination from prohibited materials, The certifier will review the report and
and may take soil, tissue, or product sam- determine whether the operation is eligi-
ples as needed. ble for organic certification. The final deci-
sion is then communicated in writing to
• The farm (crop) inspector inspects fields, the client seeking certification, along with
soil conditions, crop health, approaches any requirements for initial or continu-
to management of weeds and other crop ing certification. The certifier may request
Page 4 ATTRA Organic Certification Process

5. further information or remediation, or issue approved by the certifier), b) whether the
a notice of noncompliance, if the operation practices and inputs are in compliance with
is not in full compliance with all pertinent the USDA National Organic Standard, and
organic standards. Significant noncompli- c) whether those practices and inputs are
ances may result in denial or revocation of adequately documented. The certifier then
certification and/or require correction prior makes the certification decision based on
to organic certification or renewal. Minor information provided in the OSP, the inspec-
non-compliance issues are those that do not tion report, and associated documents.
threaten the integrity of the organic prod-
The inspector can do the following:
ucts. (For example, procedures are properly
carried out but inadequately documented.) • provide information about the certifica-
The notice will cite the issues of concern tion process
and specify the time by which the opera- • answer general questions about organic
tion must remedy the noncompliance and standards and requirements
provide documentation of the remediation • explain the range of practices and/or
to the certifier. record keeping that the certifier considers
sufficient to show compliance
Step 6: Organic certification
• make referrals to pub-
A certificate of organic certification is lic sources of information,
issued if the operation is determined to be such as Cooperative Exten-
compliant under the NOP (and any other sion services, USDA agen-
applicable) standards. Upon issuance of cies, farm organizations,
the organic certificate, the operation may trade associations, and
begin selling its products as organic. Prod- ATTRA’s toll-free line and
uct labels must identify the certifier (“Cer- publications
tified organic by…”) beneath the name and
identifying information of the producer or The inspector cannot serve as
handling company. Use of the USDA and/ your advisor or consultant. The
or the certifier’s seal is optional. The certi- inspector may not recommend spe-
fied party should review the details of label- cific products, practices, animal
ing in NOP section 205.300-311, and ask or plant varieties, or give advice
the certifier to review any labels prior to for overcoming identified barriers
printing. All certified operations must be to certification. The inspector must
inspected annually. not hold a commercial interest in the
business being inspected, provide paid
The Role of the Organic consulting services, accept gifts, favors, or The organic inspector
payments other than the prescribed inspec- can refer clients
Inspector tion fee. Finally, the inspector does not to sources of informa-
The “inspector” is not the same as the “cer- tion about organic
make the certification decision. Any of the
compliance.
tifier.” It is important for the producer or above constitutes a conflict of interest that Photo by Ann Baier.
handler to have clear expectations about is strictly prohibited by law, as described in
the role of the inspector—what services he NOP Section 205.501.
or she can and cannot provide. As noted in
The certified entity can be assured that the
Step 4: Organic Inspection, the primary role
inspector has signed both a conflict of inter-
of the inspector is to gather on-site informa-
est and a confidentiality agreement with the
tion and provide an accurate report to the
certifier to protect all proprietary informa-
certifier. The inspector verifies a) whether
tion of the inspected operation.
observations of an operation’s daily prac-
tices are consistent with the client’s Organic Even when you take into consideration the
System Plan (previously submitted to and limitations of the inspector (as described
www.attra.ncat.org ATTRA Page 5

6. above), the inspection can still be a useful opportunity questions you have, in particular about the certification
to expand your knowledge of organic requirements, the process and where to go for assistance in answering
processes necessary to meet those requirements, and further questions. To avoid potential conflicts of inter-
associated information. As you prepare for your inspec- est, please be aware of the limitations on the role of
tion, you might find it helpful to make notes of any your inspector.
Resources
The National Organic Program (NOP) International Organic Inspection Manual IFOAM and
www.ams.usda.gov/nop IOIA, December 2000. Order from:
Organic Materials Review Institute Independent Organic Inspector’s Association
www.OMRI.org (IOIA)
International Federation of Organic P.O. Box 6
Agriculture Movements Broadus, MT 59317-0006
www.ifoam.org 406-436-2131 telephone/FAX
ioia@ioia.net
Biodynamic Farming and Gardening Association www.ioia.net
www.biodynamic.org.nz/demeter.html
Acknowledgements
Thanks to Brian Magaro and Lois Christie, organic inspectors who provided their pre-inspection letters
as resources for developing this publication.
Appreciation to the following reviewers:
Lois Christie, Fiesta Farms
Doug Crabtree, Montana Department of Agriculture, Organic Certifier
George Kuepper, Program Specialist, NCAT
Nancy Matheson, Program Specialist, NCAT
Jim Riddle, Organic Independents
Jeff Cunningham, Organic Inspector
Page 6 ATTRA Organic Certification Process

7. Notes
www.attra.ncat.org ATTRA Page 7

8. Organic Certification Process
By Ann Baier
NCAT Agriculture Specialist
©NCAT 2005
Paul Williams, Editor
Robyn Metzger, Production
This publication is available on the Web at:
www.attra.ncat.org/attra-pub/organic_certification.html
or
www.attra.ncat.org/attra-pub/PDF/organic_certification.pdf
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Slot 266
Version 112905
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