Preparing for an Organic Inspection: Steps and Checklists

1. PREPARING FOR AN ORGANIC
INSPECTION:
1-800-346-9140
STEPS AND CHECKLISTS
ATTRA
The National Sustainable Agriculture Information Service
www.attra.ncat.org
MARKETING, BUSINESS, AND RISK MANAGEMENT
Abstract: This guide is to help organic producers and handlers understand, prepare for, and get the most from their
annual inspections for certification of compliance with USDA National Organic Standards (www.ams.usda.gov/
nop).
By Ann Baier
NCAT Agriculture Specialist
January 2005
©NCAT 2005
Table of Contents
Introduction . . . . . . . . . . . . . .1
Inspection Preparation . . . . . . .2
Summary . . . . . . . . . . . . . . . .8
References . . . . . . . . . . . . . . .8
Acknowledgements . . . . . . . . .8
Introduction
This publication provides checklists of the docu-
mentation needed for organic certification. These
will help organic producers or handlers organize
their paperwork for an organic inspection. It
includes steps for preparing for the organic in-
spection and checklists of audit-trail documents
and required records for certification of organic On a Salinas Valley, California, organic farm, horticulturist Eric
crop and livestock production and organic han- Brennan harvests a bundle of a late-summer rye cover crop. Photo
dling facilities. by Scott Bauer ©2005 ARS
ATTRA is the national sustainable agriculture information service operated by the National
Center for Appropriate Technology, through a grant from the Rural Business-Cooperative Service,
U.S. Department of Agriculture. These organizations do not recommend or endorse products,
companies, or individuals. NCAT has offices in Fayetteville, Arkansas (P.O. Box 3657, Fayetteville,
AR 72702), Butte, Montana, and Davis, California. ����

2. tion, your inspection will make a lot more sense.
Certifiers provide a copy of the standards with
Inspection Preparation their application package, and the standards are
also available on the NOP Web site: www.ams.usda.
gov/nop/NOP/standards/FullText.pdf
Organic certification is about verifying that you
are managing an organic system to grow crops, These Standards were written to address most
raise livestock, and/or process food and fiber agricultural production and processing activi-
according to the National Organic Standards. ties. Not all portions will be applicable to every
An important part of being prepared is being operation. As you review them, look for and
able to track your product from the field or point focus on the parts that do apply to your opera-
of purchase to the consumer, ensuring that the tion. The definitions in Part 205.2 will help you
product has been kept separate from non-organic understand key terms.
products and has not been contaminated in any
way by materials prohibited for use in organic • Crop Producers: Production Require-
production. Producers and handlers will find ments in Sections 205.200 through 205.207;
it useful to follow the following four steps to Materials on the National List in Sections
prepare for their annual inspection. 205.600 through 205.603; Recordkeeping in
Section 205.103; and Labeling in Sections
205.300 through 205.311.
• Livestock Producers: Production Re-
quirements in Sections 205.236 through
205.239; Materials on the National
List in Sections 205.600 and 205.603-
604; Recordkeeping in Section 205.103; and
Labeling in Sections 205.300 through
205.311. (Livestock producers who raise
their own feed must also comply with the
requirements for crop production.)
• Handlers: Handling Requirements in Sec -
tions 205.270 through 205.272; Mate-
rials on the National List in Sections
205.600 and 205.605-606; Recordkeeping in
Section 205.103; and Labeling in Sections
205.300 through 205.311.
Review your Organic Systems Plan
(OSP)
The OSP must be updated and submitted to your
certifier whenever a significant change is made
Photo by Scott Bauer ©2005 ARS
to your operation. Each certifier has particular
forms and procedures for keeping OSPs current.
In preparation for your annual inspection, verify
Review the sections of the National that your OSP is current and complete, with all
Organic Standards that are relevant to pertinent attachments. If you have not already
your operation submitted them to your certifier, be prepared
to provide updates at the time of your inspec-
To their detriment, people often do not read the tion. Keep copies for your files. You must have
National Organic Standards. They may seem a complete, current OSP on file at all times. Be
long and overwhelming, but if you are familiar prepared to show records of how you implement
with the key standards relevant to your opera- each part of your OSP.
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3. Review any communications from your Communications from your certifier may also
include general memos to all certified clients
certifier that you have received in the explaining updates to the lists of allowed or
past year prohibited brand-name materials, changes or
updates to manuals, renewal procedures, fees,
Each year you will receive a letter that addresses inspection protocol, and interpretation or clarifi-
your certification status. (Certifiers have differ- cation of standards. The inspection and certifica-
ent names for this letter: certification determina- tion process will go more smoothly if you know
tion letter, notice of noncompliance, certification what to expect and keep yourself educated about
status report, remediation letter, conditions any changes that occur.
letter, evaluator’s circle, etc.) Does this letter
describe any areas in which your operation was
found to be other than fully compliant by the
Gather your records using the following
previous inspection and review process? Have organic inspection checklists
you resolved the issues that were raised after
your previous inspection? Have you responded Organic Inspection Checklists
in writing to any requests made by your certi-
The National Organic Standards specify that re-
cords must “fully disclose all activities and trans-
actions in sufficient detail as to be readily under-
stood and audited” (NOP Section 205.103(b)(2)).
Are you prepared to explain your recordkeeping
system? Is anything missing or incomplete?
You can make your inspection easier and more
efficient by doing a self-audit beforehand, using
the following checklists. Please note that these
lists are comprehensive, and some items may not
apply to your operation.
Crop production documentation checklist
 List of crops being grown, field locations
(maps), acreages, and estimated yields
Field history or land use documentation, if
any new land is added this year
Field activity logs for all practices per-
formed (cultivation, weed control, use
Photo by Scott Bauer ©2005ARS of manure or fertilizers, spraying, pruning,
beneficials released, etc.)
fier? Can you provide documentation to show
how you have addressed these issues? The an-  Input purchase/source records of all in-
nual inspection must verify that all previously puts used for crop nutrients, pest, disease,
cited noncompliances have been corrected. Be or weed control
prepared to demonstrate and provide documen-  Receipts
tation that you have taken corrective measures  Invoices
and that your operation is fully compliant with  Delivery tags
the standards cited in the notice of noncompli-  Receipts or logs recording the pick-up
ance. or delivery of free materials
 Labels and/or documentation demon-
strating that each material is allowed
for use in organic production.
ATTRA//PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS PAGE 3

4.  A generic material (e.g., mined lime-  Your unsuccessful search for
stone) must be on the National List commercially available organic
as allowed. seed or planting stock (most
 A brand name product must either certifiers require documentation
 have a label that discloses all of non-availability from three
ingredients, including inert in- sources), and
gredients, so that they all may  Verification that the seed or
be verified as allowed; or stock used is not genetically
 be listed as an allowed brand- modified or treated with prohib-
name material on a list ited materials
approved by the certifier (e.g.,  Documentation of compliance of any
the Organic Materials Review inoculants or seed coatings (non-GMO
Institute (OMRI) Brand Names status of inoculant organisms and
List, the Washington State allowed status of all seed coating
Depart ment of Agriculture materials)
(WSDA) list, or others). Find out
from your certifiers whether  Audit trail documents that track products
they maintain their own list from the field of origin to final use or sale.
of approved materials, per- A random audit is part of inspection proce-
form their own brand-name dures. It may require the following.
material reviews, or wheth-  Field, planting and production records
er they honor other lists, and if  Harvest and yield records
so, which.  Post-harvest handling records
 Note that manure must either be com-  Storage records
posted according to NOP standards or  Transport records
its date of incorporation documented  Sales records
to comply with the required number of
days before harvest of a crop intended  Soil management activities, including crop
for human consumption. rotation and erosion prevention activities
 Input application records (material, source  Pest management activities for control of
/ brand name / manufacturer, regulato- crop pests
ry status, field location, date, and rate or (insects/mites/invertebrates/vertebrates),
quantity used) diseases, and weeds, including:
 Seeds (crop and cover crop), planting  Preventative practices
stock, annual seedlings, and transplants  Materials used, if any
 Seed coatings and inoculants  Pesticide use reports, as required by
 Greenhouse materials (e.g., potting soils law, if applicable (Some states require re-
or soil mix ingredients) porting of all applications of EPA-regis-
 Crop nutrients and soil amendments tered materials to commercial crops to the
 Pest management materials County Agricultural Commissioner, De-
 Beneficial insect releases partment of Weights and Measures.)
 Natural, organic, or plastic mulches
 Any other materials applied  Organic Integrity: Documentation of mea-
sures to avoid contamination and commin-
 Seed, planting stock, and transplant re- gling, as applicable to your operation
cords  Information about neighboring land use
 Documentation that seeds and annual  Prevention of contamination from bor-
transplants are certified organic, or ders
 For any non-organic seed or planting  Production, harvest, and sales records
stock used, documentation of: for buffer crops, transitional or conven-
tional crops
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5.  Material storage: adequate separation processing/post-harvest handling, trans -
of allowed materials from any non-al- port, and sales records)
lowed products
 Irrigation water and system for conta-  Housing and living conditions, including
mination prevention (i.e., diagram of grazing management and outdoor access
valves, backflow prevention, and/or records
documentation of purge or flushing
procedures to prevent contamination  Animal medications, including a list
from shared water systems where fertil- of all products used or that may be used
izers or other prohibited materials are (everything in your medicine cabinet or re-
used) frigerator, with product names, ingredi-
 Clean-out or purge logs for equipment ents, manufacturers, and regulatory status)
used for both organic and conventional
operations  Health management records, including
 Documentation of procedures to verify vac cinations and all other materials, veteri-
the absence of sanitizer residues, if sani- narian bills, purchase invoices, records of
tizers are used medication used, reason for use, and ani -
mal identification
 Certification documentation of any organ-
ic product purchased for resale  Marking and segregating methods for ani-
mals treated with prohibited materials
 Labels and labeling
 Printed packaging, bags, boxes, ties,  Soil management, erosion control, crop
bands, and stickers nutrition, and pasture management
 Lot numbering of retail and bulk prod-
ucts, if applicable  Manure management (must not contrib-
ute to contamination of crops, soil, or wa-
Livestock Production Documentation ter)
Checklist
 Pest management, including parasite man-
agement
 Animal lists, including livestock or poultry
descriptions and/or numbers and identi-  Off-site processing records, including
fication methods slaughter, cold storage, and meat packing
(These activities must take place at facili-
 Source of poultry and/or livestock, includ- ties that are already certified organic, or
ing breeding, birth, hatching, and/or pur- they must be inspected as part of your
chase records operation.)
 Feed harvest and storage records  Product or animal sales records
 Feed rations for each type of animal during  Labels, if applicable
each stage of growth and development
 Feed and feed supplement purchase re- Handling Production Documentation
cords and documentation that they are cer- Checklist
tified organic or allowed
 Product identification and composition for
 Drinking water, including source, addi- all organic products produced (This must
tives, potential sources of contamination, include current formulations, recipes, or
and results of any water analysis batch sheets that support the percentage
of organic ingredients in your product
 Audit trail documents that track animals label claim—“100% Organic,” “Organic,”
or animal products (harvest or slaughter, or “Made with organic….”)
ATTRA//PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS PAGE 5

6.  Facility map(s) showing the facility on file. If prohibited materials (substanc-
perimeter and buildings, all equipment, es not on the National List) are used in-
and areas used for receiving, raw mat- side your facility, be prepared to show
erial storage, processing, packaging, fin- documentation of how organic products
ished product storage, and shipping and materials are protected from contami-
nation during pest control applications.
 Production flow chart(s) that includes
equipment used in each step or stage  Sanitation
of the process and shows the flow of You will need documentation of standard
products through the facility from operating procedures, equipment cleaning,
receiving of raw ingredients to shipping equipment purge logs, and residue test-
of the final product ing. Residue test procedures must be ap-
propriate for the sanitation materials used.
 Documentation of sources of ingredients For example, if chlorine is used as a sani-
and processing aids tizer, a chlorine test strip with sensitivity
 Organic ingredients and processing in the low (0-10 ppm) range must be used
aids: You must have on file a copy of to show that the level of chlorine remaining
the organic certificate from the supplier is below 4 ppm, the level allowed in NOP
of any organic ingredient or pro- section 205.606. Materials that are not listed
cessing aid, showing that it is certified as allowed sanitizers are now allowed, but
to NOP standards, along with the level if they are used, they must be completely
of certification that supports the label removed before running organic products.
claim you intend to make For example, For example, if acid or alkaline sanitizers
if your label makes the claim of 100% are used, a pH test with a neutral result
organic, all ingredients and processing (or one that matches the plain water used
aids must be documented to be certified in the facility) indicates that the sanitizer
as 100% organic. material has been washed off. Quaterna-
 Non-organic agricultural ingredients ry ammonia is not listed and not allowed,
and processing aids: You must provide and therefore must be completely re-
documentation affirming that each spe- moved, such that there are no detect-
cific ingredient a) is not commercially able residues, and residues do not contami-
available as organic, b) does not contain nate organic products. Records must be
prohibited inputs and has not been pro- maintained for each area or production line
duced using prohibited methods where organic processing occurs, showing
(genetic engineering), c) has not been how organic products and packaging ma-
treated with ionizing radiation, and teri als are protected from contamination
d) is not produced from a crop grown by conventional product residues and/or
using sewage sludge. sanitation chemicals on food contact sur-
 Non-agricultural ingredients: All non- faces.
agricultural ingredients must be listed
on and consistent with the annota-  Water
tions of the National List (NOP Sections You will need documentation of source,
205.605 through 205.606). use, additives, and any applicable tests re-
sults.
 Pest management
Documentation for preventative practic-  Culinary steam
es, procedures, maps, logs, service reports, Provide a list of all boiler additives, MSDS
and incident records must be provided. pages for all additives, results from any
Whether your pest management is done carryover tests, and explain how the or-
in-house or by a contracted pest control ganic product is protected from boiler addi-
company, you must document what tive contamination.
materials are used, if any, including main-
taining product labels or MSDS pages
PAGE 6 ATTRA //PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS

7.  Organic integrity (organic critical control  Off-site storage / contracted facilities
points) If your operation uses off-site, contract-
You will need documentation of ed warehousing or outside contractors for
systems and procedures to prevent handling of ingredients or finished prod-
commingling and/or contamination of ucts, you will need to provide information
organic ingredients and products through- about how the off-site facility is used De-
out all steps of processing. pending on what they do, such facilities
may need to be certified to operate under
 Audit trail/audit control documents the certificate of the entity for whom they
The organic recordkeeping system must provide custom services, or provide an af-
accomplish two objectives: 1) trace prod- fidavit that they meet the criteria of an ex-
ucts as certified organic from the raw ingre- cluded operation (see NOP Section 205.101
dients to final sale (for verification of sourc- for definitions and requirements).
es and/or sample recall from final destina-
tion); and 2) verify the input–output bal- General Checklist for all Organic
ance of organic ingredients and organic Operations
products, including current inventory. Be
prepared to supply samples of paper-
work during the inspection to track  Current state organic registration (Depart-
ingredients to finished products for any ment of Food and Agriculture or Depart -
item and for any time that may be ran- ment of Health Services), if applicable
domly selected for an input/output audit.
 The audit documents for purchase, re-  Complaint Log (procedure for response to
ceiving, storage, production, packag- any complaints related to organic integ-
ing, handling, transport, and sales may rity). This is an ISO 65 requirement if any
include, but are not limited to, in- products are to be exported.
voices, weight slips, purchase orders
for incoming materials, invoices  Documentation and/or demonstration of
for finished product, descriptions the correction of previously cited issues
of product tracking or coding, logs for of noncompliance
receiving, processing, storage and
inventory systems, transport cleaning Checklist for Planning for Inspection Day
documentation for incoming and/or
outbound materials, and product  Ensure that you can devote the time and at-
labels. tention needed to complete the inspection.
 The input/output balance audit docu-
ments may include, but are not limited  Make prior arrangements for someone else
to, inventory, purchase, production, to handle work-related tasks and/or
and storage records—including typical family commitments.
conversion figures for shrinkage, recon-
ditioning, donated products, samples,  Have all your records ready and accessible.
dumping, shipping, and sales records.
 Provide a space where you and the inspec-
 Labels and labeling tor can comfortably review records. While
You will need finished product labels (re- a tailgate may suffice for some operations
tail and wholesale labels on printed pack- on a sunny day, a clear table and place to
aging, boxes, etc.), with the proper sit out of the wind and weather are prefer-
placement of the phrase identifying the able. Some inspectors require space for a
certifier, relative size of USDA and certifier laptop computer.
logos, lot number, and market destination,
as applicable.  Be prepared to provide easy and prompt
access to all fields, buildings, and storage
areas, both on- and off-farm. This may in-
ATTRA//PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS PAGE 7

8. clude having keys to gates and sheds and 406-436-2131 (telephone/FAX)
having other management personnel avail- ioia@ioia.net
able. If you have multiple fields or sites, be www.ioia.net
sure to advise your inspector, so that suffi-
cient time is alloted for your inspection. The National Organic Program (NOP)
www.ams.usda.gov/nop
 Have enough gas in the pickup (or other
appropriate vehicle) to reach the more re- Organic Materials Review Institute
mote parts of the farm or facilities. www.OMRI.org
Summary Acknowledgements
The on-site inspection is an important part of the Thanks to Brian Magaro and Lois Christie,
organic certification process. It can be useful to organic inspectors who provided their pre-in-
you as an organic producer or handler in at least spection letters as resources for developing this
two significant ways: a) by providing you with publication.
a certificate of organic certification to the USDA
National Organic Standards and other applicable Appreciation to the following reviewers:
standards and b) by providing the impetus and Luis Brenes, Organic Inspector and Trainer
inspiration to develop and implement organic Lois Christie, Fiesta Farms
systems for production and handling and their Doug Crabtree, Montana Department of
corresponding record-keeping systems. This Agriculture, Organic Certifier
publication is intended to show how organic Jeff Cunningham, Organic Inspector
production or handling systems and sound re- George Kuepper, Program Specialist, NCAT
cord-keeping systems reinforce each other to sup- Nancy Matheson, Program Specialist, NCAT
port continuous learning about organic systems Jim Riddle, Organic Independents
design and good business management.
Preparing for an Organic Inspection: Steps and
Checklists
By Ann Baier
References NCAT Agriculture Specialist
January 2005
©NCAT 2005
IP261
Biodynamic Farming and Gardening Slot# 265
Association Edited by Paul Williams
www.biodynamic.org.nz/demeter.html Formatted by Cynthia Arnold
Version 030105
International Federation of Organic Agriculture
Movements
www.ifoam.org/standard/ The electronic version of Preparing for an
Organic Inspection: Steps and Checklists is
International Organic Inspection Manual located at:
IFOAM and IOIA, December 2000. Order HTML
from: http://www.attra.ncat.org/attra-pub/
Independent Organic Inspector’s Associa- organic_inspection.html
tion (IOIA) PDF
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P.O. Box 6
organic_inspection.pdf
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PAGE 8 ATTRA //PREPARING FOR AN ORGANIC INSPECTION: STEPS AND CHECKLISTS