New farmers, and farmers experienced in conventional agriculture, often find that obtaining organic certification for their crops is quite challenging. This guide is intended to help lead farmers through the organic certification process. Chapters 1 through 4 explain the National Organic Program (NOP) and describe the process of organic certification. Later chapters explain specific USDA organic regulations that apply to planting, soil fertility, pest management, and other farm practices. In addition to interpreting the regulations, this guide explains the practices and materials that are allowed for organic production.
All Regions
PDF
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2012
Guide for Organic
Crop Producers
By Pamela Coleman
National Center for Appropriate
Technology (NCAT)
Agriculture Specialist
November 2012
CHAPTER 1
INTRODUCTION
N
Chapter 2
Organic Agriculture –
Description and History………………3
ew farmers, and farmers experienced in conventional agriculture, often find that
obtaining organic certification for their crops is quite challenging. This guide is
intended to help lead farmers through the organic certification process. Chapters
1 through 4 explain the National Organic Program (NOP) and describe the process of
organic certification. Later chapters explain specific USDA organic regulations that apply
to planting, soil fertility, pest management, and other farm practices. In addition to interpreting the regulations, this guide explains the practices and materials that are allowed for
organic production.
Chapter 3
The Certification Process…………….7
Who should read this guide?
Contents
Chapter 1
Introduction……………………………………..1
Chapter 4
Writing the Organic
System Plan (OSP)…………………………13
Chapter 5
Soil Fertility……………………………………..18
Chapter 6
Seeds and Planting Stock………… 25
Chapter 7
Crop Rotation……………………………….. 29
Chapter 8
Managing Pests, Weeds,
and Diseases…………………………………..32
Chapter 9
The National List of
Allowed and Prohibited
Substances……………………………………..37
Chapter 10
Greenhouse Production………….. 43
Chapter 11
Preventing Contamination
of Organic Crops…………………………. 46
Chapter 12
Post-Harvest and Labeling……… 50
Chapter 13
Recordkeeping…………………………….. 54
Chapter 14
Structural Pest
Management……………………………….. 57
Chapter 15
Resources………………………………………..61
•
•
•
•
Conventional farmers who are considering organic certification for their crops.
Farmers in the process of converting to organic practices.
Farmers who are new to organic certification.
Farmers who are exempt from certification because they sell less than $5,000
of organic produce per year.
• Extension personnel and other information providers.
This guide was designed to be read before completing an application for organic certification. This is not a required document; it is a helpful guide that you may use as you wish.
How to use this guide
To be certified organic by the U.S. Department of Agriculture (USDA),
farms must be managed in accordance with the regulations in Title 7, Part
205 of the Code of Federal Regulations. Where the USDA organic seal
appears, the text quotes from these Federal regulations. The verbatim text
of the regulation language follows the section and paragraph (for example,
§ 205.203). The verbatim text is followed by an explanation of the regulation.
This guide uses the term “USDA organic regulations” to refer to the United States’ Federal
regulations that govern organic crop production, livestock production, handling, processing,
and labeling. Different terminology is often used in other publications to refer to the same
regulations: “National Organic Standards,” “NOP Final Rule,” or simply “standards,” “Rules,”
or “requirements” are common examples. In this guide, some of the section titles in the
regulations are referred to as “standards” to correspond with the actual text—for example,
“§ 205.204 Seeds and planting stock practice standard.”
The term “standard” is also commonly used in relationship to the National Organic Standards Board (NOSB). The NOSB is a citizen advisory board that helps the U.S. Department
of Agriculture (USDA) determine which substances and practices may be used in certified
organic production and handling. However, these recommendations are not part of the
USDA organic regulations until the USDA decides the appropriate regulatory direction after
completing a formal review and receiving public comments.
The book icon indicates publications available from ATTRA-National Sustainable Agriculture Information Service. ATTRA provides farmers and educators with information
about sustainable agriculture via toll-free helplines, an extensive Web site, and hundreds
of publications. These publications can be downloaded from the ATTRA Web site, or you
can call the ATTRA helpline to request a print copy. ATTRA’s Web site is www.attra.ncat.org.
Its English-language helpline number is 800-346-9140; the Spanish-language helpline
number is 800-411-3222.
Additional useful resources can be found at the end of this guide.
This icon indicates resources that are available on the Internet.
This icon precedes the questions at the end of each chapter. The questions serve as a
checklist to help you evaluate your farm’s eligibility for organic certification and identify
areas where your practices may need to be changed.
Consider each of the questions carefully and place a check in the appropriate Yes, No, or
Not Applicable box. Answers that accurately reflect your current circumstances will be the
most helpful to you. Ideally, most of your checks will be in the Yes boxes. Negative answers
may indicate a need to modify your farm practices to comply with the regulations.
When you have questions about whether a particular practice or product is allowed in
organic production, consult a certifying agent.
This icon at the end of a chapter indicates a place where you can add your own notes.
Notes
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Guide for Organic Crop Producers
CHAPTER 2
ORGANIC AGRICULTURE –
DESCRIPTION AND HISTORY
The origins of organic farming
C
ontemporary American organic farming has its roots in the humus farming movements that spread across Great Britain and continental Europe from the 1920s
through the 1950s. These movements evolved largely in response to the increasing
use of synthetic fertilizers and pesticides. The proponents of humus farming believed that
the highest quality food and the sustainability of agriculture were achieved by “feeding the
soil,” thereby building soil fertility. Their goal was to increase the humus—the fully decomposed organic matter that has reached a stable state in the soil. Humus farming was typified
by mixed farms that included livestock, food crops, feed crops, and green manures. Humus
farming made little or no use of soluble commercial fertilizers or pesticides, in part because
the health of the soil rendered them unnecessary.
The 1960s and 1970s brought more visibility to organic farming in the United States,
as public concern over pesticide use increased. In the minds of consumers, the non-use
of pesticides was an important part of organic agriculture. The growth of the organic
industry during this era led to the establishment of standards and third-party certification. Third-party certification is an assessment process carried out to verify compliance
with standards. It involves the producer (farmer), the consumer (buyer), and a third
party—the certifying agent who affirms that the product is produced in accordance with
the organic regulations.
As the organic industry expanded during the 1980s, different certifiers developed their own
standards and certification processes. As a result, some certifiers did not accept the validity of organic certification by other certifiers. These disparities among certifier standards
resulted in barriers to trade, which led many to believe that a consistent set of standards
was needed: a single set of U.S. standards for organic production, labeling, and marketing. Eventually, Congress passed the Organic Foods Production Act (OFPA) of 1990. This
act mandated creation of the National Organic Program (NOP), which is part of the U.S.
Department of Agriculture (USDA) and the National Organic Standards Board (NOSB).
Related ATTRA
publications
www.attra.ncat.org
National Organic Program
Compliance Checklist
for Producers
Organic Standards for
Crop Production:
Highlights of the USDA’s
National Organic Program
Regulations
The NOSB is an advisory board of 15 volunteers:
• Organic producers (farmers)
• Organic handlers (processors)
• Retailers
• Environmentalists
• Scientists
• Consumer advocates
After the NOSB makes a recommendation on a new regulation or standard, there is a
review and comment period. The NOP then determines the appropriate regulatory action
to carry forward. In addition to the setting of standards (rulemaking), the accreditation of
organic certifiers and the enforcement of the regulations are important tasks of the NOP.
The definition of organic
With regulation came the need for more formal definitions of the term “organic.” In 1995,
the NOSB defined organic agriculture as “an ecological production management system
that promotes and enhances biodiversity, biological cycles, and soil biological activity.”
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In 2002, the NOP defined organic agriculture: “Organic production [is] a production
system that…respond[s] to site-specific conditions by integrating cultural, biological, and
mechanical practices that foster cycling of resources, promote ecological balance, and
conserve biological diversity” [§ 205.2].
O
“
This definition conveys both what makes each organic farm unique and all organic farms
alike. Each farm is unique because farmers must make management decisions based on
the singular conditions found in their own operations. Soil types, crop varieties, fertility
requirements, pest pressures—no two organic farmers will manage all the variables that
impact their farms the same way. Nor will changes in annual conditions such as rainfall
and frost date allow an organic farmer to operate the same way year in and year out. Each
season, organic farmers encounter a one-of-a-kind set of natural resource and environmental conditions to which they must adapt and respond.
rganic
production [is]
a production
system that…respond[s]
to site-specific conditions
by integrating cultural,
biological, and
mechanical practices
that foster cycling of
resources, promote
ecological balance, and
conserve biological
diversity” [§ 205.2].
Organic agriculture as a production system
Both definitions of organic agriculture above describe organic agriculture as a production system. This systems approach strives to understand how all parts of the system work
together. In a systems approach, the farmer will consider how soil, water, plants, animals,
insects, bacteria, fungi, and all other parts of the system can interact to cause problems or
prevent them.
The farmer’s management toolkit combines three types of techniques: cultural (e.g., planting
disease-resistant varieties); biological (e.g., pheromone traps); and mechanical (e.g., appropriate tillage). Organic farmers combine these practices into a productive management
system that minimizes the impact to the off-farm environment. All organic farmers share
this approach, though their specific objectives determine how they implement it.
Since its beginning, organic agriculture has also been based on the principle of sustainability. Sustainability can be defined as meeting the needs of the present without compromising the ability of future generations to meet their own needs. In practice, this means
that sustainable farming includes a focus on building the soil with farm-generated fertility,
which will be covered in more detail in Chapter 5. Many farmers who convert from conventional to organic systems find that over time, as they add organic matter, populations of
soil microbes and soil invertebrates will naturally increase, resulting in a rich, productive
soil. This process can take several years. In time, the healthy, biologically active soil will
produce healthy plants. The farmers then need fewer off-farm inputs because their crops
are better able to resist drought, diseases, and insects.
In addition to building healthy soil, successful organic farmers focus on preventing problems, rather than reacting to them. For example, organic farmers prevent insect problems
by providing habitat for beneficial insects that keep populations of harmful insects in
check. This guide provides many more examples in later chapters.
The importance of soil building and the need for a systems approach to organic production are sometimes overlooked or underestimated. For example, a standard practice in conventional agriculture is to plant large acreages in a single crop, which is very attractive to
insect pests. The farmer monitors insect populations, and when the populations get so high
that they might damage the plants, the farmer sprays insecticides. When farmers approach
organic agriculture with an “input substitution” mentality, they react to high insect populations in the same way— search the list of allowed insecticides and choose which one to
spray. This approach can be frustrating to the farmer. When it comes to broad-spectrum
insecticides, there are fewer tools in the organic toolbox than in the conventional toolbox,
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Guide for Organic Crop Producers
and the tools approved for organic use can be more expensive. From this perspective, farmers might view organic production as a very limiting approach to farming.
“Input substitution,” however, is not the approach encouraged by the organic regulations.
This guide explains many techniques available to build soil, grow healthy crops, and prevent pest outbreaks. Many farmers who converted from conventional to organic practices
found that this approach contributed to their success.
Another approach to organic farming is sometimes referred to as “organic by neglect.”
In this approach, essentially no inputs are used. The farmer avoids the use of prohibited
chemicals but also neglects the farm-management practices needed to build soil fertility
and prevent pest and disease outbreaks. This often results in poor crop quality and productivity and is in contrast to the organic philosophy of active management to build soil
organic matter and enhance biodiversity.
The National Organic Program
The NOP began in 1990 to develop regulations applicable to organic certification. These
regulations—known as the NOP Final Rule at the time—went into effect in October
2002 and govern organic crop production, livestock production, handling, processing,
and labeling. The regulations can be found under Title 7, Part 205, of the Code of Federal
Regulations. Title 7 deals with agriculture, one of 50 broad topic areas that are subject
to Federal regulation.
The regulations include certification requirements, which producers must meet to sell
their products as organic. Organic certification is the process of verifying compliance with
organic regulations. The assessment process is carried out by a third-party certifier—an
independent body that is not linked to either the seller (the farmer) or the buyer. Products
to be sold as organic in the United States must be certified organic to the regulations and
must be certified by a USDA-accredited certifying agent (ACA). There are about 100 such
ACAs currently operating worldwide. Some certified organic products may be labeled with
the USDA organic seal.
S
ustainability can
be defined as
meeting the needs
of the present without
compromising the ability
of future generations to
meet their own needs.
Many other countries, including Japan and members of the European Union (EU), have
their own standards for organic products. Organic producers planning to export their
products (or sell them to distributors who may export them) should ask their buyers
whether they need to be certified to additional standards as well as USDA organic regulations. The United States has equivalence arrangements with Canada and, beginning June
1, 2012, with the EU. Organic products certified to the USDA organic regulations may
be sold, labeled, and represented as organic in Canada and EU member countries. This
arrangement eliminates the need for U.S. organic operations to have a separate certification
to the Canadian or EU standards and vice versa. There are a few exceptions to this equivalence, called “critical variances.” For example, a critical variance for EU-bound food is that
crops produced using antibiotics (streptomycin for fire blight control in apples and pears)
may not be sold as organic in the EU under the arrangement. Check the NOP Web site for
current information regarding critical variances.
The USDA organic regulations also include general requirements for accreditation, which
establish the requirements that certifiers must meet in order to issue organic certificates.
The processes for farm certification and certifier accreditation are similar: an application
that describes the operation’s procedures, an onsite inspection, and a report that indicates
any changes that must be made to comply with the regulations. This accreditation process
ensures that all certifiers apply the regulations in the same way. The NOP maintains a list
of ACAs on its Web site.
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Organic certification
§ 205.100 What has to be certified
Under the regulations, most operations or portions of operations that produce
or handle agricultural products that are intended to be sold, labeled, or represented
as organic must be certified. Producers who illegally represent their products as organic
may be subject to prosecution and fines of up to $11,000 for each violation.
During the application process, many certifiers will require farmers to sign an agreement that they
will comply with the organic production and handling regulations in accordance with Title 7 CFR Part
205 National Organic Program Rule.
§ 205.101 Exemptions and exclusions from certification
Producers who market less than $5,000 of organic products annually are not required to apply
for organic certification. They must, however, comply with the organic production and handling
requirements of the regulations, including recordkeeping. The products from non-certified
operations cannot be used as organic ingredients in processed products produced by another
operation, cannot be used as feed for organic animals, and may not display the USDA organic seal.
Online Resources
USDA National Organic Program, www.ams.usda.gov/nop
U.S.–European Union Organic Equivalence Arrangement Questions and
Answers, www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5097061
Notes
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Guide for Organic Crop Producers
CHAPTER 3
THE CERTIFICATION PROCESS
C
ertification under the National Organic Program (NOP) is required to label,
represent, and market qualifying products as organic. Organic regulations are covered in Title 7, Part 205 of the Code of Federal Regulations. Subpart C is entitled
“Organic Production and Handling Requirements.” The full text of the organic regulations is
available on the NOP Web site and key portions of the text are excerpted in ATTRA’s “Organic
Standards for Crop Production.” The regulations are arranged in outline format, using letters,
numbers, and Roman numerals to indicate the levels, as follows— § 205.203 (a)(1)(i).
This guide does not include the full text of the regulations; rather, it provides excerpts from
the text and an interpretation of the regulations that apply to fruits, vegetables, field crops,
herbs, and greenhouse operations. If you raise mushrooms, sprouts, or livestock, you’ll
need to consult additional references.
There are two categories of organic operations: producers and handlers. Organic producers
may grow crops, collect plants from the wild, or raise livestock. These farming operations
receive an organic producer certificate. Organic handlers may buy food for resale or may
process foods (slicing, freezing, drying, mixing, blending, etc.). These operations receive
an organic handler certificate. The organic certificate verifies that the producer or handler
has complied with organic regulations and allows her or him to sell or represent the product as organic. Producer certificates include the type of crop (e.g., carrots, apples) and may
include other information as well. Sometimes crop varieties are listed (Fuji apples), as well
as farm acreage and the name of the field from which the crop has been harvested.
This guide covers only the regulations for crop producers. Producers who are processing their products—into jams, bread, or juice, for example—need to ask their certifier
if a handler certificate is required for those products. In some cases, certifiers will allow
farmers to do some minor processing, such as freezing or drying, without applying for
a separate certification.
The process of getting certified has several steps and often requires 3 to 6 months
to complete. In applying for certification, the farmer agrees to understand the regulations,
be available for inspection, allow the certifier access to the farm, and answer all of the
certifier’s questions. The certifier reads the application, assigns an inspector, reviews the
inspection report, and makes the certification decision.
Related ATTRA
publications
www.attra.ncat.org
Organic Certification
Process
Organic Field Crops
Documentation Forms
Organic Market Farm
Documentation Forms
Organic Standards for
Crop Production
Before beginning the certification process, it is important to consider whether your land is
eligible for organic status, as explained below.
Transitioning to organic production
A field is eligible for organic status if no prohibited materials have been applied for a period
of 36 months. For example, if an apple orchard was last sprayed with a synthetic fungicide on August 1, 2010, then a crop harvested September 1, 2013, may be sold as organic,
but only if you have a certificate verifying the organic status. You will need to be able to
document all land use and material applications during the transitional time period. See
Chapter 4 “Writing the Organic System Plan” for more information about documentation
needed for new sites.
Many of the fertilizers, insecticides, herbicides, and fungicides used by conventional farmers are prohibited in organic production. This includes the fungicides present on treated
seeds. Chapter 9 “The National List of Allowed and Prohibited Substances” explains how
to determine if a product is allowed or prohibited. Certain practices, while not allowed
in organic production, would not constitute application of a prohibited material, and so
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Page 7
would not render land ineligible for certification during the transition period. Examples
include the use of nonorganic seed or planting stock, application of manure to a food crop
within 90 days of harvest, and cultivation of genetically modified crops.
The certification process
If you understand the regulations and your land is eligible for transitional or organic
status, you’re ready to begin the certification process. The steps are as follows:
1. The farmer submits an application to a certifier
Producers obtain certification from state or private certifiers who are accredited by the
NOP. Farmers may apply to any accredited certification agent (ACA). A list of all ACAs can
be found on the NOP Web site listed at the end of this chapter.
The cost of organic certification is borne by the certified operations and is paid directly to
the certifying agent. Certification fees may vary significantly among certifiers. Most certifiers charge a one-time fee to new applicants to cover the administrative and review costs.
Annual renewal fees, usually based on the sales of organic products, are assessed each year.
The NOP currently operates a cost-share program to help defray the cost of certification for
organic farmers. The program is explained below under Funding Opportunities.
To allow time for the entire certification process, submit your application at least 3 to 4
months before the harvest of your first organic crop. If you need a certificate more quickly,
some certifiers will expedite your application for an additional fee.
The documents sent to a certifier are often collectively called the “application,” but in
reality there are several separate documents required:
• Application
• Organic System Plan
• Farm map
• Field histories for new fields
• Operator agreement or affirmation
• Report of organic yields and sales
The Organic System Plan (OSP) is your opportunity to describe your farm and farming
operation to a person who has never seen it. Understanding what is needed and why it is
needed makes the process easier. The next chapter will provide more detail about how to
develop the OSP.
The person who signs the operator agreement agrees to adhere to the regulations and
affirms that the information supplied to the certifier is correct. This agreement must be
signed by the person who has responsibility for making decisions about the operation—
typically the farm owner.
New applicants will be asked to estimate their projected organic sales. Upon renewal of
certification, farmers are required to report the yield and sales of organic products. Ordinarily, the sales are reported in the calendar year during which the money is collected.
For example, the income from apples harvested in September, stored, and sold the following January will be reported as income in January. There are several reasons for collecting information on yield and sales. This information can serve as a basis for conducting
an audit, which can then be used to discover fraud—for example, conventional produce
sold as organic. Sales also are used to determine annual certification fees; typically, larger
operations pay higher fees.
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Guide for Organic Crop Producers
2. The certifier reviews the application
The certifier will read the farm plan and determine whether the practices are described in
sufficient detail and whether the farm appears to meet organic regulations. There are cases
where an application is denied or delayed. For example, if a farmer sprayed herbicides in
March 2010 and applied for certification in April 2010, the application would be denied for
2010. In this case, the land may be eligible for transitional status after March 2011 (if the
certifier offers transitional certification) but would not be eligible for organic certification
until April 2013.
To achieve organic status, a 3-year transition period is required. In other words, no prohibited substances may be applied to the land for 36 months prior to the harvest of any crop
that will be represented as organic. The first organic crop may be planted at any time prior
to or during the conversion period. One purpose for this transition period is to allow the
farmer to build healthy soil by adding natural soil amendments, rather than fertilizers, and
restore biodiversity by avoiding pesticides.
If you are purchasing or renting land that is not currently certified and you wish to
document that it has not had prohibited substances applied, you must obtain verification
from the previous landowner or manager. Some certifiers require documentation by the
local county Agricultural Commissioner, who keeps pesticide-use records in States that
require 100 percent reporting of materials registered by the U.S. Environmental Protection Agency (EPA).
3. The inspector visits the farm
Every organic farm must be inspected each year. The individual who conducts the inspection—the organic inspector—represents the certifying agent. It is the inspector’s responsibility to verify that the system plan accurately reflects the operation and that the farmer is
following the plan, as well as to look for any violations. Organic inspectors are trained to
look critically at all aspects of an organic operation and to maintain strict confidentiality.
Information you provide about yield, sales, or farm practices will not be shared with anyone except the certifier.
During the inspection, you must allow the inspector complete access to your operation,
including all production facilities and offices. Additional inspections may be announced or
unannounced at the discretion of the certifier or the State organic program.
One of the most important responsibilities of the inspector is to examine records that document your farming practices. Specifically, the inspector will look at invoices, records of
material applications, organic sales, harvest, and yield. Chapter 13 “Recordkeeping” provides examples of the type of documentation forms that inspectors may wish to examine.
The inspector can explain the organic regulations but is not allowed to provide advice
on how to farm or how to overcome identified barriers to certification. This separation
between the farmer and the certifier maintains the “independent third party” nature of the
transaction. Similarly, inspectors are not allowed to accept gifts because it may appear to
compromise their independent status.
As a representative of the certifier, the inspector may request samples for residue testing.
Results of the test will be provided to you. If the levels of pesticide residue exceed 5 percent
of EPA tolerance levels, the product may not be sold, labeled, or represented as organic [§
205.671]. Residue testing is not an acceptable substitute for strategies to prevent contamination. It can, however, serve as an indicator that selected strategies are effective.
During the inspection, the inspector will ask questions about your operation, visit each
field, look at paperwork, and point out any areas where the farm may not comply with regulations. At the conclusion of the inspection, there will be an exit interview during which
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Page 9
the inspector will review any areas of concern. After the inspection, the inspector will
write a report and send it to the certification agency, typically within 2 weeks.
4. The certifier reviews the inspection report
I
f you receive a
letter (from your
certifier) and do not
understand the technical
language, call your
certifier for clarification.
You can also call ATTRA
for advice on how to
resolve an issue and
bring your operation
into compliance.
The certifier reviews the inspection report and decides whether the farm meets the requirements of the organic regulations. The reviewer will pay particular attention to any issues
mentioned in the exit interview and will decide the seriousness of those issues. If your
farm is in compliance, you will receive a letter along with an organic certificate. More commonly, especially for a first inspection, there will be some issues that need to be addressed.
In this case, certification would be delayed until these problems are corrected. The specific
areas of concern should not be a surprise to the farmer because the inspector should have
discussed them in the exit interview. One thing that is often a surprise is the formal language of the letter, which can be written as a Notice of Noncompliance. Often the specific
issues are easily corrected, and you can receive organic certification once you resolve them.
There are several types of letters that new applicants may receive from their certifiers:
• If the operation is in compliance with the regulations, the certifier issues an
organic certificate.
• If the operation needs to provide additional information or correct minor practices, the certifier issues a certificate with conditions.
• If there is something that threatens the organic integrity of the product, but it can
be corrected, the certifier issues a Notice of Noncompliance.
• If there are major noncompliance issues that cannot be corrected, the certifier
issues a Notice of Denial of Certification to new applicants. For example, if a crop
duster accidentally applies a synthetic fungicide to your organic field, that would
be considered an application of a prohibited material, and the application for
organic certification would be denied.
• If there are major noncompliance issues during renewal of certification, the
certifier issues a Notice of Noncompliance, which may be followed by or sent at the
same time as a Notice of Proposed Suspension or Notice of Proposed Revocation.
The producer is provided an opportunity to appeal; otherwise, the organic certification will be suspended or revoked. This happens only rarely.
If you receive a letter and do not understand the technical language, call your certifier for
clarification. You can also call ATTRA for advice on how to resolve an issue and bring your
operation into compliance.
5. The certifier issues the organic certificate
Once certification is granted, it remains in effect until surrendered, suspended, or revoked.
Any action to suspend or revoke certification must be handled in the manner prescribed
in regulations § 205.660 through § 205.664. If the status of your certification is threatened
and you wish to dispute the charge, a formal grievance process exists.
Every organic operation is required to renew its certification each year or surrender it.
Certification may be suspended if it is not renewed.
The renewal process is comprised of the following steps:
• Update the Organic System Plan
• Sign an operator agreement
• Address all noncompliance issues that have not been resolved
• Pay the annual certification fees
• Undergo an annual inspection
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Guide for Organic Crop Producers
Funding opportunities
As of this writing, there are two Federal programs that reimburse farmers for some of the
costs of organic production. The NOP administers a certification assistance cost-share program available to certified organic operators. The program reimburses farmers and handlers for a percentage of their certification fees. More information is available at the NOP
Web site listed below. The application process is simple. More information can be obtained
from your certifier, your State department of agriculture, the NOP, or ATTRA.
In addition to the NOP, the USDA Natural Resources Conservation Service (NRCS) provides funding to farmers as they implement practices that conserve natural resources. This
program, the Environmental Quality Incentives Program (EQIP), has a special section for
organic farmers because many organic practices focus on soil conservation. This program
offers an opportunity for organic producers to receive substantial grant funding, but the
application process can be lengthy. More information is available at your local NRCS office.
The meaning of organic certification
It is important to recognize that organic certification addresses the process involved
in producing and handling a product. Organic certification is a process claim, not a
product claim, and the OSP is the principal document that describes the production
process on a specific farm. Organic certification assures the consumer that the organic
farmer followed the requirements and restrictions spelled out in the regulations. Organic
certification does not guarantee that the product is completely free of all pesticide
residues or genetically modified organism (GMO) contamination.
Online Resources
National Organic Program, www.ams.usda.gov/nop
New Farm Guide to U.S. Organic Certifiers, www.rodaleinstitute.org/
certifier_directory
Questions
• Do you have easy access to the USDA organic regulations?
• If you are now selling crops as organic, do they all come from land that has been free of
prohibited substances for a minimum of 36 months prior to harvest?
• Did you advise your certifier of any previous applications for certification?
• If you are renewing your certification, have you addressed all noncompliance issues and
conditions previously noted by the certifier?
• Are you documenting the harvest, yield, and sale of all organic crops?
• Are you saving purchase receipts for all inputs?
• Are you documenting the applications of fertilizers and pest-control materials?
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Notes
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CHAPTER 4
WRITING THE ORGANIC SYSTEM PLAN (OSP)
§ 205.201 Organic production and handling system plan
Under the USDA organic regulations, each certified organic farm must have an
Organic System Plan (OSP). The OSP is a detailed outline that explains how you
intend to operate your farm or ranch to satisfy the requirements of the regulations.
According to § 205.201(a), the OSP must contain the following:
• A description of farm practices, including the frequency with which they will be
performed
• A list of each substance to be used as a production input
• A description of monitoring practices, including the frequency with which they will
be performed, to verify that the plan is effectively implemented
• A description of the recordkeeping system implemented to comply with the
requirements established in § 205.103 (see Chapter 13)
• A description of the management practices and physical barriers established to
prevent commingling of organic and conventional products and to prevent
contamination of organic products with prohibited substances
Related ATTRA
publications
• Any additional information deemed necessary by the certifying agent to evaluate
compliance with the regulations
Organic System Plan
Templates for Certifiers
www.attra.ncat.org
D
eveloping and then maintaining the OSP is an essential part of the initial and ongoing certification process. The OSP must be written by the producer and approved
by the certifier. Taking care to write clearly and thoroughly can save time later. The
OSP provides a description of your farm to a person who has never seen it. It must be sufficiently detailed so that the certifier can get a clear picture of your farm’s crops, harvest,
sales, recordkeeping, soil-building practices, pest management, and any other practices
related to organic production. The plan must allow the certifier to assess whether you can
meet the requirements for organic certification.
Organic System Plans:
Market Farms and
Greenhouses
Organic System Plans:
Field and Row Crops and
Pasture and Range Systems
The OSP covers many aspects of your organic farm:
• Crops to be grown
• Farm acreage — organic
• Source of seeds or plants
• Maintaining soil fertility
• Preventing pest outbreaks
• Controlling weeds
• Managing diseases
• Sales and marketing
Producers should use the OSP to explain the practices they use to manage their farms. It
is particularly important to describe all management practices used to prevent problems
rather than merely reacting to them. For example, apple growers should have plans to monitor codling moth, and asparagus growers should have plans to manage asparagus aphids.
Having these monitoring and management practices in place will enable an organic farmer
to address pest pressure before an infestation becomes severe. The time spent to ensure
accuracy and completeness on your OSP is worthwhile because the OSP is vital for managing your farm and assuring compliance with the regulations.
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It is standard practice for the OSP to be incorporated in the application materials that are
required by certifiers. In other words, you are completing your OSP at the same time that
you are filling out your application for certification. There may be some instances in which
plans submitted to qualify for Federal aid or assistance programs may satisfy the requirement for an OSP.
Some useful
definitions
• Buffer zones—the
boundary between
conventional crops
and organic crops.
Buffer zones are
established to prevent
organic crops from
being contaminated
by spray drift.
• Commingling—the
mixing of an organic
product with a similar
conventional product.
• Contamination—
contact with a prohibited substance (conventional pesticides,
for example). This
includes physical contact with conventionally grown products.
• Parallel production—
a subset of split
production. The term
is used to describe
a situation in which
the same crop (and
often the same crop
variety) is produced
both organically and
conventionally on the
same farm operation.
• Split production or
mixed operations—
those operations that
produce both organic
and nonorganic products. (The nonorganic
category includes
transitional products.)
The materials list
The OSP includes a list of each substance to be used as a production input, sometimes
called a Materials List. This is simply a list of composts, fertilizers, insecticides, fungicides,
or other materials that might be used. Certifiers realize that farmers are not able to predict
every eventuality and that unforeseen problems will occur. If there is a need to apply a pest
control or other material that was not originally listed in the system plan, contact your certifier to add it to your OSP. Many certifiers will accept notifications by telephone, fax, or
email. Do not wait until inspection to update your OSP.
There have been unfortunate instances of farmers who applied a material without receiving approval from their certifier, only to discover later that the material was prohibited. If
this happens, the certifier must revoke certification from the fields to which the prohibited
material was applied. The land is not eligible for organic status again for 36 months from
the last application of the prohibited material.
Split operations
Many conventional farmers choose to explore organic production by converting only a
small portion of their land to organic practices, while continuing to farm the rest of land
in a conventional manner. Production of both organic and nonorganic products is called
split production. Crops grown during the 36-month transition period are considered conventional. Parallel production, a subset of split production, refers to a situation where the
same crop is produced both organically and conventionally on the same farm operation.
In parallel operations, it is particularly important that the OSP address all hazards
of contamination and commingling that may arise. Contamination can be defined as
contact with a prohibited substance (for example, conventional pesticides). This includes
physical contact with conventionally grown products. Commingling is the mixing
of an organic product with a similar conventional product (for example, mixing organic and conventional grain in the same grain bin). For split operations, many
certifiers request information on both conventional and organic crops. The certifier and
the inspector will want to ensure that procedures are well documented to ensure the
integrity of organic products. Chapter 11 “Preventing Contamination of Organic Crops”
provides additional information.
§ 205.202 Land requirements
Fields from which organic crops are harvested must have distinct, defined
boundaries and buffer zones. No prohibited materials can be applied to the land
for a period of 36 months prior to harvest of the organic crop. Prohibited materials
include synthetic fertilizers and seeds treated with fungicides, as well as most synthetic
(chemical) herbicides, pesticides, and fungicides.
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The farm map
An accurate map of all farm acreage and production units is typically required as part of
the OSP. Important map features include the following:
• Consistent scale
• Permanent field numbers or names
• Buildings, roads, and permanent features
• Streams, ponds, irrigation ditches
• Field boundaries
• Adjoining land use: conventional, organic, or fallow
• Buffer zones
Organic crops must be protected from contamination by prohibited substances, such
as pesticides and fertilizers, used on adjoining lands. Preventing contamination usually
requires a multi-pronged approach for organic systems.
Strategies may include one or more of the following:
• Isolation. Fields located at substantial distances from conventional production or
roadside spraying are considered to be adequately protected.
• Barriers. Tall plants and trees serve as barriers to airborne contaminants.
• Buffer zones. Buffers are used to separate adjoining crops that are conventionally
managed. Crops harvested from buffer zones must be sold as conventional.
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• Drainage diversion. Water runoff from conventional fields is diverted.
• Posting of property. Signage reading “Organic Farm: Do Not Spray” is placed at
field boundaries. You may need to assume responsibility for weed control on roadsides and post signs reading “Owner Will Maintain.”
• Formal notification. Written notification of your organic status is provided to
neighbors who manage adjoining lands. Copies of formal notification letters must
be kept on file.
Regulations do not specify the required width for a buffer zone, but they state that buffers
must be “sufficient to prevent contamination.” It is the farmer’s responsibility to assess the
risks and take appropriate measures to minimize contamination. Therefore, the width of
buffers must be adjusted for individual circumstances. For example, a more significant buffer is needed where adjacent land is sprayed by plane or airblast sprayer or where there are
prevailing winds that blow across nonorganic fields onto the organic farm. A smaller buffer may be needed if a row of tall trees provides a barrier to drift. Regardless of the size of
the buffer, any crops harvested from buffer zones must be sold as conventional. Sale must
be documented and available for review at inspection.
Water runoff from conventional fields can contaminate organic crops. If the possibility of
contamination exists, a drainage ditch will be needed.
Field histories for new fields and new farms
Field histories will be required the first time you request to have a field certified organic. To
obtain organic certification for a field, you must be able to document all materials applied
to that field for 36 months prior to the harvest of a first organic crop.
Field histories for new fields should document the following:
• Field size (You may use square footage for greenhouse/production beds.)
• Crops, including cover crops, for the past 36 months
• All inputs used for the past 36 months
Online Resources
Rodale Institute’s Organic System Plan Tool, www.tritrainingcenter.org/
code/osp_index.php
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Questions
• Have you completed your Organic System Plan (OSP)?
• Is your farm map complete and accurate?
• Have you completed a field history for each new field?
• Are the numbers/names used on your map consistent with those used on field
histories, audit documents, and other records?
• Do all fields have buffers that are adequate to prevent contamination?
• If there is danger of contamination from adjoining land or conventional crops,
are you taking steps to minimize the risk?
Notes
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CHAPTER 5
SOIL FERTILITY
§ 205.203 Soil fertility and crop nutrient management
practice standard
Section (a) of this regulation states that the producer must “maintain or improve
the physical, chemical, and biological condition of the soil and minimize erosion.”
Section (c)(1) regulates the application of raw manure to organic crops, and Section (c)
(2) regulates the process of making of composts from animal manures.
H
ealthy soil is the basis for organic agriculture. Healthy soil can provide an abundant crop of healthy plants, which in turn provide healthy food and feed. When
grown in good soils, crops are better able to resist disease, survive drought, and
tolerate insects.
This chapter provides a brief overview of building and conserving the soil. For more
detailed information, consult additional references tailored to your climatic region and
soil type. The materials listed in the Further Resources section are a good place to start.
Related ATTRA
publications
www.attra.ncat.org
Federal Conservation
Resources for Sustainable
Farming and Ranching
Sustainable Soil
Management
Soil building
Adding organic matter is a fundamental way to build soils. Organic matter provides food
for microorganisms such as fungi and bacteria and macroorganisms such as earthworms.
As these diverse soil organisms decompose organic matter, they convert nutrients into
forms that are available to plants. Soils high in organic matter also have improved waterholding capacity, helping plants resist drought.
For centuries before the advent of chemical fertilizers, farmers supplied all the nutrients
for their crops solely by adding organic matter to the soil. As fresh organic matter, such as
crop residues, decomposes, it forms a stable substance called humus. Organic matter can
be added to soils with compost, animal manures, or green manures.
Green manures
Green manures are crops grown specifically for soil improvement. They are typically incorporated into the soil after they have produced a large amount of biomass, or fixed a significant amount of nitrogen in the case of legumes. Managing green manure crops to increase
organic matter and provide the maximum amount of nitrogen to the following crop is both
an art and a science.
Annual grasses, small grains, legumes, and other useful plants like buckwheat can be
inserted into the cropping sequence to serve as green manures. Their roots pull nutrients
from deeper soil layers, and the tops are plowed into the soil to add organic matter and a
stable source of nutrients. In particular, deep tap-rooted crops such as alfalfa, sweet clover,
rape, and mustard are known to extract and use minerals from the deeper layers of soil.
Legumes add nitrogen to the soil. Nitrogen accumulations by leguminous cover crops can
range from 40 to 200 pounds of nitrogen per acre. The amount of nitrogen captured by
legumes depends on the species of legume grown, the total biomass produced, and the percentage of nitrogen in the plant tissue. Cultural and environmental conditions that limit
legume growth—such as a delayed planting date, poor stand establishment, and drought—
will reduce the amount of nitrogen produced. Conditions that favor high nitrogen
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production include a good stand, optimum soil nutrient levels and soil pH, good nodulation, and
adequate soil moisture.
Animal manures
Conservation of manure and its proper application are key means of recycling nutrients
and building soil. Farms without livestock often buy manure or compost because they are
considered to be among the best fertilizers available, though sole reliance on fertilizers
from other farms can have its drawbacks.
Manures from conventional systems are allowed in organic production, including manure
from livestock grown in confinement and from those that have been fed genetically engineered feeds. Manure sources containing excessive levels of pesticides, heavy metals, or
other contaminants may be prohibited from use. Such contamination is likely present in
manure obtained from industrial-scale feedlots and other confinement facilities. Certifiers
may require testing for these contaminants if there is reason to suspect a problem.
Herbicide residues have been found in manures and manure-based composts. One type—
aminopyralid—is used in pastures for control of broadleaf weeds. Grass and corn are not
affected by the herbicide, and cows are not affected when they eat the grass or silage. However, the herbicide can be present in their manure in concentrations high enough to stunt
the growth of tomatoes, peppers, and other susceptible broadleaf crops.
W
hen grown
in good soils,
crops are
better able to resist
disease, survive drought,
and tolerate insects.
If a manure source is suspected of being contaminated with excessive amounts of prohibited substances, appropriate testing should be conducted. If test results indicate that the
manure is free of excessive contamination, and it is subsequently used in production, the
test results should be kept on file.
Used properly, manures can replace all or most needs for purchased fertilizer, especially
when combined with a whole-system fertility plan that includes crop rotation and cover
cropping with nitrogen-fixing legumes. Manure is typically applied just ahead of a crop
requiring high fertility, such as corn or squash. Manures also can be applied just prior to a
cover crop planting. Incorporating the manure as soon as possible after application, rather
than allowing it to remain on the soil surface, will conserve the maximum amount of the
nitrogen. Although manure is an excellent fertilizer for crops, and it has been used that
way for centuries, manure may harbor microorganisms that are pathogenic to humans. To
minimize the possibility of illness due to organic foods, there are strict regulations on the
use of manure in organic crops.
The 90–120-day rule
Application of manure to organic crops is restricted by what is known as the 90–120-day
rule, as described in § 205.203(c)(1). You may not apply raw, uncomposted livestock manure
to food crops unless it is:
1. Incorporated into the soil a minimum of 120 days prior to harvest when the edible
portion of the crop has soil contact; OR
2. Incorporated into the soil a minimum of 90 days prior to harvest of all other food crops.
Incorporation is generally assumed to mean mechanical tillage to mix the manure into
the soil. Crops that have soil contact include leafy greens, melons, squash, peas, and many
other vegetables. Any harvestable portion of a crop that can be splashed with soil during
precipitation or irrigation might be considered to have soil contact. Crops that do not have
soil contact include tree fruits and sweet corn.
Take note that the 90- and 120-day restrictions apply only to food crops; they do not apply
to fiber crops, cover crops, or to crops used as livestock feed.
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Compost
Perhaps no other process is more closely associated with organic agriculture than composting. Composting is one of the most reliable and time-honored means of conserving
nutrients to build soil fertility. Because matured, well-made compost is a stable fertilizer
that will not burn plants and because composting kills most human and plant pathogens,
compost can safely be used as a side-dress fertilizer on food crops.
C
omposting is one
of the most
reliable and
time-honored means of
conserving nutrients to
build soil fertility.
Animal manures used in organic crop production often are composted before use, in part
because some types of raw manure will burn plants if applied directly to crops. Composting reduces the number of viable weed seeds, creates a uniform product with predictable
nutrient levels, and eliminates worries about human pathogens. If manures are composted
according to USDA organic regulations, then they are considered compost, not manure,
and may be applied without restrictions. If manure is aged but not composted according to
the regulations, then the material is still considered manure and must be applied in accordance with the 90–120-day rule explained above.
The regulations define compost as “the product of a managed process through which
microorganisms break down plant and animal materials into more available forms suitable
for application to the soil…” Compost used in organic production must be made according to the criteria set out in § 205.203(c)(2). This section of the regulations specifies that:
1. The initial carbon:nitrogen ratio of the blended feedstocks must be between 25:1
and 40:1.
2. T he temperature must remain between 131 °F and 170 °F for 3 days when an
in-vessel or a static-aerated-pile system is used.
3. The temperature must remain between 131 and 170°F for 15 days when a windrow
composting system is used, during which period the windrow must be turned at least
five times.
The composting procedures above are adapted from U.S. Environmental Protection
Agency (EPA) and USDA’s Natural Resources Conservation Service (NRCS) guidelines for
composting biosolids. This policy was established to ensure the elimination of pathogens
that cause illness in humans.
Organic farmers often maintain a compost pile on the farm as an efficient and cost-effective
way to retain nutrients on the farm and build soil. If compost feedstocks include raw manure,
they must be composted in the method detailed above. This composting process must be
explained in your system plan and documented with temperature records. If those requirements are not met, then the resulting compost must be applied according to the 90-120-day
raw manure rule. If compost feedstocks do not include raw animal manures, then the resulting compost is considered plant material and there are no restrictions on its use.
Compost tea
Some organic farmers apply compost teas to crops or soil to increase the populations
of beneficial microbes. If compost tea will be applied to organic crops, it is critical that
the compost used to produce the extract has been made according to USDA organic regulations. The procedures for making both the compost and the compost tea must be explained
in your OSP. Applications of teas made from uncomposted manure must follow the 90-120day rule. The tea extract may need to be tested to ensure that it is free of dangerous pathogens, particularly if the tea has been made with compost tea additives. The additives, such
as molasses, provide nutrients for microbes and thereby increase their rate of growth. There
is some concern that any human pathogens present will grow more abundantly in a tea
made with these additives. Further details on the recommendations for the use of compost
tea are available in the NOP publications listed at the end of this chapter.
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Vermicompost
Vermicompost is compost that uses worms to digest the feedstocks. Since feedstocks may
include animal manures, there has been debate as to whether the 90-120-day rule should
apply to vermicompost. The NOP has issued the following guidance: feedstocks for vermicompost materials may include organic matter of plant or animal origin. Feedstocks should
be thoroughly macerated and mixed before processing.
Vermicomposting systems depend upon regular additions of thin layers of organic
matter at 1- to 3-day intervals. Doing so will maintain an aerobic environment and avoid
temperature increases above 35 °C (95 °F), which will kill the earthworms. The composting process must be described in the OSP, reviewed by the certifier, and well documented
on the farm. Further details are available in the NOP publications listed at the end of
this chapter.
Processed animal manures
Heat-treated, processed manure products may be used in organic production. There is no
required interval between application of processed manure and crop harvest. From the
standpoint of the farmer, of course, these inputs would be applied well before harvest, so
that the nutrients would be available to the crop. To be considered processed, the manure
must be heated to 150 °F for 1 hour and dried to 12 percent moisture or less.
T
he key to soil
conservation is to
keep the ground
covered for as much of the
year as possible.
Soil conservation
Organic farmers have long recognized the value of basic soil conservation. There are many
practices that help conserve soil, including cover crops, mulches, conservation tillage,
contour plowing, and strip cropping.
Careful conservation and management of crop residues is part of organic soil management, since this residue plays a valuable role in improving and protecting the soil. The
key to soil conservation is to keep the ground covered for as much of the year as possible.
Since water erosion is initiated by raindrop impact on bare soil, any management practice that protects the soil from raindrop impact will decrease erosion and increase water
entry into the soil. Mulches, cover crops, and crop residues all serve this purpose well. A
major limitation of organic row-crop farming is that cultivation is used for weed control,
since herbicides are not allowed. This cultivation creates and maintains bare ground,
which increases the likelihood of soil erosion. By contrast, soil that is covered with an
organic mulch of crop residue, such as that typically found in no-till fields, is less likely
to erode. Organic no-till systems have yet to be perfected for annual row crops, but they
work well for perennial fruit crops and pasture, allowing for year-round ground cover
and virtually no soil erosion.
Cover crops
Cover crops are single species or mixtures of plants grown to provide a vegetative cover
between perennial trees, vines, or bushes; between annual crop rows; or on fields between
cropping seasons. The vegetative cover on the land prevents soil erosion by wind and water,
builds soil fertility, suppresses weeds, and provides habitat for beneficial organisms. Cover
crops also can help reduce insect pests and diseases, and legume cover crops fix nitrogen.
Any crop grown to provide soil cover is considered a cover crop, regardless of whether that
crop is later incorporated into the soil as a green manure. Both green manures and other
types of cover crops can consist of annual, biennial, or perennial herbaceous plants grown in
a pure or mixed stand during all or part of the year. When cover crops are planted to reduce
nutrient leaching following a cash crop, they are termed “catch crops.” This type of cover crop
is typically grown over the winter when the field would otherwise be unoccupied.
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Organic mulches
Organic mulches cover the soil and provide many of the same benefits as cover crops,
especially the prevention of soil erosion. Many organic materials, such as straw, leaves,
pine needles, and wood chips, can be effective mulches. Straw and other materials that are
easily decomposed are applied to strawberries and vegetables during the growing season.
The mulch can be tilled in at the end of the season, where it will quickly decompose. Wood
chips, because they decompose very slowly, are more commonly applied to perennial crops
such as blueberries, where they will not be tilled in. Applying organic mulch can be laborintensive. Tree fruit growers sometimes mow the drive rows and blow the green clippings
into the tree rows, which automates the mulching process.
Heavy mulches can be a benefit by suppressing weed growth, or a nuisance by providing
a haven for slugs. Organic mulches keep the soil cool, which may be a boon for blueberries in hot climates and a drawback for tomatoes in cool spring weather. Organic mulches
have a beneficial long-term effect because they add nutrients to the soil as they decompose.
Mulches of high-carbon material may have the opposite effect because they tie up nitrogen
during the decomposition process. However, this should not be a problem if mulches are
used properly—that is, placed on top of the soil, and not incorporated.
Conservation tillage
In conservation tillage, crops are grown with minimal soil cultivation. This is also known
as no-till, minimum till, incomplete tillage, or reduced tillage. When the amount of tillage
is reduced, the residues from the plant canopy are not completely incorporated into the soil
after harvest. Crop residues remain on top of the soil and prevent soil erosion, a practice
known as crop residue cover. The new crop is planted into this stubble or small strips of
tilled soil within the stubble.
Contour cultivation and strip cropping
Slope plays a role in soil conservation, in that flat ground erodes less than sloping ground
with equal amounts of ground cover. Contour plowing is the practice of plowing across
a slope following its elevation contour lines, rather than straight up and down the slope.
The cross-slope rows formed by contour plowing slow water runoff during rainstorms to
prevent soil erosion.
Strip farming, also known as strip cropping, alternates strips of closely sown crops, such
as hay or small grains, with strips of row crops, such as corn, soybeans, or cotton. Strip
farming helps prevent soil erosion by creating natural dams for water, helping to preserve
the soil.
Federal programs for sustainable agriculture
Sustainable and organic agricultural systems produce some of the best conservation results
in the Nation, as they enhance the natural resource base and provide multiple environmental services. These systems can conserve biodiversity and improve soil quality, water quality, air quality, carbon sequestration, energy efficiency, and wildlife habitat. The adoption
of sustainable and organic systems of production is directly in line with NRCS’s mission of
“helping people help the land.”
In recognition of the benefits of sustainable farming systems, the 2008 Farm Bill
authorized funding to encourage implementation of conservation practices. The bill led
to implementation of specific provisions for organic and sustainable farmers:
• The Environmental Quality Incentive Program (EQIP) Organic Initiative
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• The Conservation Stewardship Program (CSP)
• The Conservation Reserve Program Transition Option
To apply for these programs, contact your local NRCS office or visit its Web site.
Applications for these programs can be challenging, as these are competitive programs.
Several organizations are working to help farmers, especially small and mixed-crop
farmers, successfully compete for funds. Helpful publications are available from ATTRA
or the National Sustainable Agriculture Coalition (NSAC). Web sites are listed at the end
of this chapter.
Nutrient management: nitrogen and trace minerals
Although organic matter plays an important role in building productive soils, there
are specific crops and soil types that will benefit from additional applications of
specific nutrients. Organic farmers are allowed to use a variety of fertilizers to provide
micronutrients to their crops. Before applying micronutrients, soil deficiencies must be
documented through soil tests, plant tissue tests, observing the condition of plants, or
evaluating crop quality at harvest.
Nitrogen is often a limiting nutrient, especially for vegetables and other row crops. Including legumes in the rotation can help to ensure sufficient nitrogen for the following crop. Biological nitrogen fixation in legumes results from a symbiotic relationship between the plant
and Rhizobium bacteria. These bacteria “infect” the roots of legumes, forming nodules. The
bacteria then fix nitrogen from the air, which results in sufficient nitrogen both for their own
needs and for subsequent crops.
The inoculation of legume seed may be necessary to optimize nitrogen fixation. Be certain
that you are purchasing an inoculant appropriate to the kind of legume you are planting
and verify that it is not genetically modified. Genetically modified inoculants are prohibited in organic production.
Online Resources
Alternative Farming Systems Information Center, http://afsic.nal.usda.gov
Building Soils for Better Crops, www.sare.org/publications/soils.htm
Compost and Vermicompost in Organic Crop Production, NOP Program
Handbook, www.ams.usda.gov/nopprogramhandbook
Farmers’ Guide to the Conservation Stewardship Program,
www.sustainableagriculture.net/wp-content/uploads/2011/09/
NSAC-Farmers-Guide-to-CSP-2011.pdf
National Sustainable Agriculture Coalition publications list,
www.sustainableagriculture.net/publications
Natural Resources Conservation Service, www.nrcs.usda.gov
NOP Program Handbook, www.ams.usda.gov/nopprogramhandbook
Processed Animal Manures in Organic Crop Production, NOP Program Handbook,
www.ams.usda.gov/nopprogramhandbook
Sustainable Agriculture Research and Education, www.sare.org
The Rodale Institute, www.rodaleinstitute.org
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Questions
• Do you keep your current and past soil test results on file as a means of monitoring
the effects of your farming practices?
• Do you make fertility management decisions based on soil tests, tissue tests,
or observed nutrient deficiencies?
• Are you using cultural practices to maintain or improve soil organic matter?
a) Green manures
b) Animal manures
c) Composts
• Are you using cultural practices to conserve soil?
a) Cover crops
b) Organic mulches
c) Conservation tillage
d) Contour cultivation
e) Strip cropping
• Are all the fertilizers and soil amendments you use allowed in organic production? See Chapter 9 “The National List of Allowed and Prohibited Substances” for
assistance with choosing materials.
• Do you keep records of all fertilizer and amendment purchases and applications,
along with product labels?
• If your compost contains animal manure, has it been prepared according to the
requirements of § 205.203(c)(2)?
• Are soil amendments, including compost and manure, applied according to soil
and crop needs?
• Are all your manure applications to food crops in compliance with the 90- and
120-day rules?
• Are your sources of manure and compost free of contamination from excessive
amounts of prohibited substances?
• Are records kept of manure applications that include date, tonnage, and fields
receiving application?
Notes
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CHAPTER 6
SEEDS AND PLANTING STOCK
§ 205.204 Seeds and planting stock practice standard
1. O
rganic seeds must be used unless they are not commercially available.
2. Seeds may not be treated with prohibited substances.
3. G
enetically engineered varieties are prohibited.
§ 205.204(a)(4) states: “[N]onorganically produced planting stock to be used to produce a
perennial crop may be sold, labeled, or represented as organically produced only after the
planting stock has been maintained under a system of organic management for a period of
no less than one year…”
T
he USDA organic regulations address three basic categories of propagation materials: seeds, annual seedlings, and planting stock. The term “seeds” is self-explanatory.
“Annual seedlings” are transplants of annual crops that have been removed from
their original place of production and replanted elsewhere [§ 205.2]. “Planting stock” is
defined as “[a]ny plant or plant tissue other than annual seedlings but including rhizomes,
shoots, leaf or stem cuttings, roots, or tubers, used in plant production or propagation” [§
205.2]. Ideally, only organic seed and planting stock would be used in organic production.
When you purchase organic seeds, transplants, and planting stock, you are assured that
the variety is not genetically engineered and that any seed treatments that may have been
used are allowed for organic production. However, because the organic industry represents
only a fraction of the total agriculture industry, organic seeds and planting stock may not
be available. The applicable regulations are discussed below.
Related ATTRA
publications
www.attra.ncat.org
Transgenic Crops
Seeds
Organic seeds must be used unless they are not commercially available. When an equivalent organic variety is not commercially available, conventionally grown seed may be used.
The determination of “equivalent” is made by the farmer, who takes into account the plant
variety, maturity dates, disease resistance, and other desired characteristics. In order to use
conventional seed, the farmer must provide documentation to verify that: (1) the organic
seed was not available; (2) the variety is not genetically engineered; and (3) the seed was not
treated with prohibited materials. Each of these is discussed in more detail below.
Commercial availability
First, in order to document that organic seed was not commercially available, certifiers want clear indication that several (at least three) suppliers have been contacted in an
attempt to locate organic seed sources. This usually entails records of phone calls, letters, or
emails to and from seed suppliers documenting your attempts to find an organic source. If
you are required to use a specific variety by the buyer of the crop, then the buyer must supply documentation to verify that the variety was not available in organic form.
A variety of seed is considered commercially unavailable if the farmer could not locate an
organic supplier, if the organic supplier could not provide seed in the quantities needed, or
if the seed quality was substandard. Seed quality may be substandard due to the presence of
seed-borne disease, very low germination percentages, or high weed-seed content. The higher
cost of organic seed is not considered an acceptable reason for using nonorganic seed.
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Genetic engineering
G
enetically
modified crops
that are now
being planted or will
soon be available include
alfalfa, beets, corn,
soybeans, papaya, plum,
rapeseed, tobacco,
potato, tomato, squash,
cotton, and rice.
Second, if conventional seed is planted, the certifier will request proof that it is not genetically engineered. This verification is becoming more important each year, as the number
of genetically modified (GM) crops increases. The use of GM seeds is prohibited in organic
agriculture, and it is the responsibility of organic growers to make certain that the crops
they grow are not genetically engineered. GM crops that are now being planted or will soon
be available include alfalfa, beets, corn, soybeans, papaya, plum, rapeseed, tobacco, potato,
tomato, squash, cotton, and rice. This list is expected to change, as genetically engineered
versions of several other crops have been developed but have not yet been released for commercial production. The most current information about GM crops is maintained by the
USDA Animal and Plant Health Inspection Service (APHIS). The planting of GM crops is
regulated—new varieties may not be widely planted until they’ve been approved by USDA.
Seed companies that develop a new variety of genetically modified seeds must submit a
petition to APHIS before that seed can be distributed to the public. These varieties are
identified by APHIS on the list of Petitions for Nonregulated Status (see Online Resources
at the end of this chapter).
Genetic engineering is considered an excluded method and is defined as “a variety of methods used to genetically modify organisms or influence their growth and development by
means that are not possible under natural conditions or processes and are not considered
compatible with organic production. Such methods include cell fusion, microencapsulation
and macroencapsulation, and recombinant DNA technology (including gene deletion, gene
doubling, introducing a foreign gene, and changing the positions of genes when achieved
by recombinant DNA technology). Such methods do not include the use of traditional
breeding, conjugation, fermentation, hybridization, in vitro fertilization, or tissue culture.”
Again, if it is necessary to use conventional seeds, it is essential to verify that the variety
has not been genetically engineered and to keep documentation of this verification, as your
inspector will ask to see it. Seed companies that have taken the Safe Seed Pledge may be
convenient sources of non-GMO seeds. The Safe Seed Pledge was developed by the Council
for Responsible Genetics and has been signed by numerous seed companies.
The Safe Seed Pledge
“Agriculture and seeds provide the basis upon which our lives depend. We must protect this
foundation as a safe and genetically stable source for future generations. For the benefit of
all farmers, gardeners and consumers who want an alternative,
We pledge that we do not knowingly buy or sell genetically engineered seeds or plants.
The mechanical transfer of genetic material outside of natural reproductive methods and
between genera, families, or kingdoms, poses great biological risks as well as economic,
political, and cultural threats. We feel that genetically engineered varieties have been insufficiently tested prior to public release. More research and testing is necessary to further assess
the potential risks of genetically engineered seeds. Further, we wish to support agricultural
progress that leads to healthier soils, genetically diverse agricultural ecosystems and ultimately healthy people and communities.”
Treatment with prohibited materials
Third, seed must not be treated with prohibited materials, such as conventional fungicides
and inoculants made with GMO bacteria. Conventional seed treatments are usually
fungicidal; most fungicides used for this purpose are prohibited in organic production. If
fungicides are present on seeds it will be obvious, as the seeds must be tinted (commonly
bright pink or green). The seed packets also will state that fungicides have been used.
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Some seed treatments are allowed in organic production—the inoculation of legume seeds
with beneficial bacteria, for example. However, since some inoculants might be genetically
engineered, it is important to ensure that the product is approved. Labels for seed inoculant
do not typically state whether or not the product contains genetically engineered materials. If the label does not clearly state the information, you can obtain written documentation from the manufacturer. Several inoculants are listed by the Organic Materials Review
Institute (OMRI). Visit the OMRI Web site and search for “inoculants” to obtain the names
of allowed materials.
Planting seeds treated with prohibited materials on land that is certified organic is considered an application of a prohibited material. The land where those seeds were planted will
be removed from organic certification and will not be eligible for organic status again until
36 months after the seeds were planted.
Even if the seeds are purchased for the farmer, such as crops grown under contract for processors, the farmer will need verification that the variety is not available in organic forms,
that the variety is not genetically engineered, and that the seeds are not treated with prohibited materials. That documentation should be provided to the farmer by the processor
who supplies the seeds, and it should be available at inspection.
Many farmers ask whether the organic seed requirement also applies to cover crop seeds.
Cover crop seed must be organic as well. Commonly, cover crops are chosen for being well
adapted to the local growing area. If a nearby neighbor grows conventional cover crop
seeds and you wish to plant them because they are locally adapted, you may claim that
organic seeds of that variety are not commercially available. However, the cover crop seed
must still be neither genetically engineered nor treated with a prohibited substance.
Annual seedlings
Transplants, starts, or seedlings used to produce an annual organic crop must have been
organically grown. This section of the regulations applies to tomatoes, sweet potatoes, peppers, flowers grown from transplants (e.g., snapdragons sold as cut flowers) and similar
crops. The farmer must have documentation that the transplants are organic. Documentation may be obtained by an organic certificate from the seller or an invoice on which the
purchase is identified as organic. If large quantities of transplants will be needed, it will be
necessary to order them well in advance.
A variance to use conventional seedlings to grow an organic crop may be granted only if
the original transplants were destroyed through “…drought, wind, flood, excessive moisture, hail, tornado, earthquake, fire or other business interruption…” Contact your certifying agent to obtain a variance.
Planting stock
Whenever possible, organic planting stock should be used for organic production. At the
time of this writing, many plant varieties are not commercially available in sufficient quantity, which may require the use of nonorganic planting stock. However, it is necessary to
search for organic sources and to document that search.
Planting stock for annual crops is subject to the same requirements as seeds for annual
crops. Note that this part of the rule applies to crops like garlic, white potatoes, and flowers
grown from bulbs (e.g., daffodils or tulips sold as cut flowers).
Planting stock for perennial crops may be obtained from nonorganic sources but must be
under organic management for at least 12 months before the first harvest of an organic
crop. This rule applies to tree fruits (e.g., apples, peaches, pears), nuts (e.g., walnuts, pecans),
berries (e.g., blueberries, caneberries, strawberries), grapes, asparagus, lavender (lavender
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flowers, lavender plants), lilies, and others. Some perennial crops are managed as annuals
in some climate regions (e.g., strawberries, caneberries). If this is the case, then the rules
for annual planting stock apply.
Although the seeds, annual seedlings, and planting stock used in organic production must
not be treated with prohibited substances, there is one exception. Treatment with prohibited substances is allowed when the application of those substances is a requirement of Federal or State phytosanitary regulations. For example, strawberry crowns may be required to
be treated with fungicides prior to interstate shipments.
Online Resources
ATTRA Online Directory of Organic Seed Suppliers, www.attra.ncat.org/
attra-pub/organic_seed
Organic Seed Alliance, www.seedalliance.org
Petitions for Nonregulated Status Granted or Pending by APHIS,
www.aphis.usda.gov/biotechnology/not_reg.html
Questions
• Is all seed organically produced?
• Have you retained invoices or empty seed packets to verify organic status of seeds?
• If conventional seeds were purchased, have you documented your attempts to
source organic seeds?
• If conventional seeds were purchased, do you have verification that the varieties
are not genetically modified?
• If conventional seeds were purchased, do you have verification that no prohibited
substances were applied to the seeds?
• Are all annual seedlings and transplants acquired from organic sources?
• Have you obtained a copy of the organic certificate from the supplier of transplants?
• If annual seedlings and transplants are grown on-farm, are they produced using
organic methods?
• If seed or plant treatments are used, have you determined that they are allowed materials?
Notes
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Guide for Organic Crop Producers
CHAPTER 7
CROP ROTATION
§ 205.205 Crop rotation practice standard
Farmers are required to implement a crop rotation that maintains or builds soil
organic matter, works to control pests, manages and conserves nutrients, and
protects against erosion. Producers of perennial crops that aren’t rotated may
utilize other practices, such as cover crops, to maintain soil health.
C
rop rotation refers to the sequencing of crops over time on a field or planting bed.
It is not unique to organic systems; it is practiced by many conventional farmers
as well. Organic systems are unique in that crop rotation is specifically required in
the USDA organic regulations.
Crop rotation in annual crops
For producers of annual crops, complying with NOP crop rotation standards is straightforward and often beneficial for crop health. Crop rotation can:
Related ATTRA
publications
www.attra.ncat.org
Overview of Cover Crops
and Green Manures
• Interrupt insect life cycles
• Suppress soilborne plant diseases
• Prevent soil erosion
• Build organic matter
• Fix nitrogen
• Increase biodiversity of the farm
Crop rotations are an important way to suppress insects and diseases. For example, farmers who raise potatoes will rotate the field out of solanaceous crops for at least 2 years
before replanting potatoes. This helps reduce populations of insects such as the Colorado
potato beetle and diseases such as late blight. Rotations typically mean that crops are not
followed by a member of the same crop family. Rotations with 3 to 5 years between the
same crop may be needed to effectively reduce insect and disease levels.
Rotations also can be designed to increase soil fertility. A crop sequence that features
soil-improving crops can counterbalance soil-depleting crops. Soil-improving crops
include sod crops dominated by perennial grasses and perennial legumes. Sod crops in
rotation build soil organic matter and reverse the decline that typically occurs when cultivated annual crops are grown year after year. Legumes, such as alfalfa, clovers, beans, and
peas, are especially beneficial because they fix nitrogen from the atmosphere and make it
available to subsequent crops.
Even short-term, nonleguminous cover crops can provide benefits when used as part of the
crop-rotation plan. The best cover crops are specific varieties adapted to the soil, climate, and
season. They are sown at a fairly high rate to cover the soil quickly and prevent erosion.
When planning crop rotations, it is important to consider that cultivated row crops such
as vegetables tend to degrade soil. Since the soil is open and cultivated between rows,
microbes break down organic matter at a more rapid pace. Furthermore, row crops have
modest root systems and consequently do not contribute enough new organic matter
to replace that lost from the open soil between rows. In most cases, above-ground crop
residues make only minor contributions to replacing lost organic matter.
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In contrast, cereals and cover crops are more closely spaced and have more extensive root systems than row crops, greatly reducing the amount of soil exposed to degradation. In addition,
these crops receive little or no cultivation after planting, which reduces organic-matter loss
even more. As a result, cereals and green manures can be considered neutral crops, replacing soil organic matter at roughly the same rate at which it breaks down. Crops that make a
perennial sod cover, such as grasses, clovers, and alfalfa, not only keep the soil entirely covered but also have massive root systems that produce far more organic matter than is lost.
Incorporating sod crops as a fundamental part of a crop rotation not only builds soil but
also supports weed-control strategies. Weed control improves because the types of weeds
encouraged by row-cropping systems are usually adapted to growing in a sod/hay crop.
To make the most efficient use of sod crops, it will be necessary to include livestock in the
system or to find a market for the hay. Livestock will assist in transferring (via manure)
nutrients from one part of the farm to another. The major drawback to selling hay is that
the nutrients it contains are shipped off the farm.
Crop rotation in perennial crops
For producers of organic perennial crops, the requirement for crop rotation can be confusing. Section 205.205, the crop rotation practice standard, is meant to ensure that the
farmer implements practices that will maintain soil organic matter, control pests, conserve
nutrients, and protect the soil against erosion. For growers of annual crops, those practices typically include crop rotation, but other practices can be substituted if rotation is not
practical. Some perennials will be part of a long-term crop rotation, which may last a few
years or even decades. Asparagus, for example, is a perennial that can be productive for
15 years or more. When a field is taken out of asparagus production, it is typically planted
with another crop to reduce the incidence of soilborne disease. That practice is considered a
long crop rotation. Several other perennials, such as strawberries, Echinacea, and lavender,
are not required to have a cover crop because they are typically part of a long crop rotation.
Other types of perennials—those that will not be part of a crop rotation—may require
additional practices to ensure soil conservation and biodiversity in the cropping system.
This is important with large perennials, such as trees, that have large drive rows between
the crop rows. For example, organic farmers must have a cover crop (often grass) between
the rows of trees in an orchard. Crops that are required to have a cover crop between crop
rows include caneberries, grapevines, blueberries, tree fruits, and nut trees.
Some perennial crops, such as alfalfa, develop a canopy that covers the ground and
prevents soil erosion. Such crops are not required to be rotated to other crops.
Biodiversity
Organic production is a system that “respond[s] to site-specific conditions by integrating …
practices that …. conserve biodiversity.” The regulations also mention that perennial cropping systems must introduce biological diversity in lieu of crop rotation.
Although farmers are encouraged to have diverse systems, there are no specific requirements, standards, or monitoring practices. Nonetheless, many organic farmers actively
manage their farms to increase biodiversity, due to its many benefits.
Biodiversity plays a particularly crucial role in pest management. Diverse agricultural systems support strong populations of predators and parasites that help keep pest populations at
manageable levels. This approach is proactive rather than reactive because a diverse system
reaches an equilibrium that prevents pest outbreaks from becoming too severe. Birds and bats
can keep insect populations low. Raptors can scare away fruit-eating birds. Coyotes, owls,
and foxes can keep rodent populations under control. These animals can be encouraged by
providing needed shelter, water, and habitat.
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Organic producers increase biological diversity in the plant canopy by planting a diversity
of crops and plant varieties in any given season. Use of cover crops and hedgerows also
adds biodiversity. The diversity of vegetation, combined with reduced use of broad-spectrum pesticides, increases the diversity of insects and spiders in the plant canopy. Introducing beneficial insects and providing habitat for them to become established will increase
biodiversity. To promote biodiversity in the soil, it is helpful to minimize tillage, introduce
microorganisms in compost, and avoid broad-spectrum pesticides. These practices will
increase the variety of bacteria, fungi, and invertebrates in the soil.
For helpful resources that expand on the idea of biodiversity, see materials on the Wild
Farm Alliance Web site.
Online Resources
Crop Rotation on Organic Farms: A Planning Manual, www.sare.org/
Learning-Center/Books/Crop-Rotation-on-Organic-Farms
Managing Cover Crops Profitably, www.sare.org/Learning-Center/
Books/Managing-Cover-Crops-Profitably-3rd-Edition
Western SARE Farm Internship Curriculum and Handbook,
www.attra.ncat.org/intern_handbook/crop_rotation.html
Wild Farm Alliance, www.wildfarmalliance.org/resources/organic_BD.htm
Questions
• If your crops are annuals, have you implemented a crop rotation that maintains
soil organic matter, controls pests, minimizes diseases, and prevents erosion?
• If your crops are perennials, have you established cover crops between the plant
rows to prevent soil erosion?
• Are you managing your cover crops to support beneficial insects and wildlife,
as well as to preserve soil health?
• Are you providing additional habitat for beneficial insects and wildlife?
• Have you taken steps to maintain or increase biodiversity on your farm?
• Do you apply approved fertilizers and manures so that runoff and leaching
are prevented?
• Do you manage all your fields to prevent soil erosion?
Notes
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CHAPTER 8
MANAGING PESTS, WEEDS, AND DISEASES
§ 205.206 Crop pest, weed, and disease management
practice standard
This section of the USDA organic regulations requires that producers use a threetiered approach in deciding how to deal with pest, weed, and disease problems.
This can most easily be explained by designating these levels A, B, and C.
Level A, § 205.206 (a), is prevention of the problem.
Level B, § 205.206 (b, c, d), involves the use of mechanical or physical methods.
Level C, § 205.206 (e), is the application of allowed materials.
Each level is explained in more detail later in this section.
Related ATTRA
publications
www.attra.ncat.org
Intercropping Principles
and Production Practices
Farmscaping to Enhance
Biological Control
Principles of Sustainable
Weed Management
for Croplands
F
armers who transition from conventional to organic production systems often find
that pest, disease, and weed control are their biggest challenges. For insect control,
conventional farmers can wait until they see an outbreak of insects and then choose a
chemical to control the insect. This approach is workable for conventional farmers because
they have a large toolbox of chemicals available. For disease prevention, conventional farmers can fumigate the soil with broad-spectrum pesticides. Fumigation also kills beneficial
soil organisms, which has negative long-term consequences. Organic farmers have fewer
chemical tools available because there are far fewer insecticides, fungicides, and herbicides
allowed for application to organic crops. In order to successfully transition to an organic
system, farmers should be willing to approach these challenges from a different perspective. The key difference is preventing problems by designing a system that prevents most of
the pest problems. Preventing severe pest outbreaks will allow the farmer to avoid broadspectrum pesticides that will lead to future imbalances in the ecosystem.
Three levels of pest management
The USDA organic regulations are written to require farmers to employ tactics to minimize pest and disease problems using a three-level hierarchical approach.
Level A
The first line of defense in managing weed, insect, and disease pests is a systemsbased approach. It is based on the fact that a well-designed and healthy organic system
will naturally have fewer pest problems. The system is designed to prevent pest and
disease outbreaks.
Level B
The second line of defense is utilized if the practices of level A are not sufficient to control the
weed, insect, or disease problem. Level B generally includes mechanical and physical practices that are traditional in organics, as well as the use of nonsynthetic or natural materials.
Level C
The third line of defense is used if the level of pest control required is not achieved after A
and B control options are applied. Level C practices include the use of inputs such as biologicals and botanicals to control pests. This level also provides the option of using those
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materials included on the National List under § 205.601 Synthetic substances allowed for
use in organic crop production.
If you anticipate the need for level C control measures, be sure that you indicate this in
your Organic System Plan. Be specific about the control materials you might be using and
outline the indicators or thresholds you monitor that will trigger the use of those materials. See Chapter 9 “The National List of Allowed and Prohibited Substances” for information on choosing materials, verifying that they are allowed, and informing your certifier
regarding their use.
The organic regulations prescribe the type of practices but allow farmers to choose the
specific practices that will work best for their systems. The remainder of this chapter will
discuss specific level A and level B practices. Since many practices control both diseases
and arthropod pests (insects and mites), these will be discussed together, and weed management will be discussed separately.
Pest and disease management
Organic producers maintain that organic soil-building practices will result in crops that
are properly nourished and thereby less susceptible to attack by pests and diseases. Natural
biological pest control arises in a healthy organic system in the form of an active complex
of natural predators and parasites that suppress pest populations. Incorporating habitat
and food sources for beneficial insects into your farm, known as farmscaping, can provide
long-term benefits.
In many field crop and vegetable systems, maintaining a diverse, healthy ecosystem and
using well-timed cultural practices are sufficient for pest management. Pests may not be
eliminated, but damage levels are low enough to be tolerated.
N
atural
biological pest
control arises in
a healthy organic system
in the form of an active
complex of natural
predators and parasites
that suppress pest
populations.
Examples of Level A practices to manage pests and diseases
Cover crops: Some cover crops, including sudangrass, rapeseed, and mustard, are effective
at suppressing nematodes.
Crop rotation: Solanaceous crops, including tomatoes and potatoes, are planted in rotation
with other crops that are not in the same family. This minimizes the risk of late blight disease and Colorado potato beetle outbreaks. Grain crops, including wheat, barley, and corn,
are susceptible to Fusarium head blight. Moving to a legume or oilseed in the rotation can
help break this disease cycle by allowing the grain crop residues to decompose fully.
Cultural practices: Use of disease-resistant varieties is a common cultural control. In addition, delaying spring planting until the soil is warmer minimizes fungal diseases and
allows the crop to establish a healthy stand.
Intercropping: Two or more crops grown in close proximity is known as intercropping,
strip cropping, or companion planting. This approach increases biodiversity and decreases
pest outbreaks.
Providing habitat for insect predators and parasites: In organic apple orchards, natural
populations of predatory mites become high enough to control the plant-eating spider
mites because the orchard provides a good habitat for the predatory mites. Conventional
orchards, by contrast, are susceptible to outbreaks of spider mites because pesticides reduce
the populations of beneficial predatory mites. Growing some plants that attract ladybugs or
other beneficials will help reduce populations of plant pests.
Resistant varieties: As one example, tomato varieties advertised as VFN are resistant to
Verticillium, Fusarium, and nematodes. Stem rust is a common grain disease that can be
managed by selecting resistant varieties.
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Sanitation: Sanitation entails the removal of sources of disease infection or insect pest
infestation. For example, apple and pear growers remove branches infected with fire blight
(strikes). The strikes are removed from the orchard and burned to kill the bacteria that
cause fire blight. Mushroom growers pasteurize the compost to kill fungi that would
compete with the mushroom crop.
Trap crops: These are small plantings of a crop or crop variety intended to draw a particular pest away from the main crop. For example, alfalfa planted in strips amid cotton
attracts lygus bugs away from the cotton crop. Typically, trap crops must be destroyed to
kill the pests that have been attracted to them. Use of trap crops requires a good understanding of the biology of the pest.
Examples of Level B practices to manage pests and diseases
Burning crop residues: In organic production, the burning of crop residues is allowed only for
suppression of disease. Rice straw often is burned in the field. Before using this disease-control practice, it must be clearly stated in the organic system plan and approved by the certifier.
Canopy management: By training and pruning trees, orchardists can increase airflow and
decrease disease pressure. Viticulturists practice leaf removal to control Botrytis bunch rot
of grapes.
Introducing insect predators and parasites: Several types of insects can be purchased in
large quantities and released on the farm. For example, to control aphids, release ladybugs
and provide favorable conditions to encourage the ladybugs to stay and eat the aphids.
Mulching: Mulching can reduce disease on tomatoes and similar crops by reducing soil
contact and maintaining an even soil moisture. However, organic mulches also can serve
as habitat for certain pests, such as the squash bug and slugs.
Row covers: Floating row covers, made of lightweight fabric, can keep insects out of shortseason crops. For example, they can prevent flea beetles in arugula and prevent cabbage
root maggots in radishes.
Solarization: Soil solarization is achieved by covering the soil with plastic during the summer.
This allows the soil to get hot enough to kill many pathogens, yet it allows microbial spores
to survive. Survivors can re-establish the microbial populations needed for healthy soil.
Weed management
According to the USDA’s Invasive Weed Management Unit, the most critical problem facing today’s organic grower is weeds. Weeds compete with crops for moisture, nutrients, and
sunlight. Weeds do not always need to be eliminated—short weeds in a tall corn crop may
be harmless—but weeds do need to be managed. Fortunately, there are many classic ways
to reduce the number of weed seeds, and new ways are being developed to remove weeds
that compete with crops. The appearance of many difficult-to-control weeds may be an
indication that the soil has nutritional or physical problems and nature is trying to restore
health and balance.
Examples of Level A practices to manage weeds
Variety selection: Select grain varieties that emerge early and close the canopy as quickly
as possible. This shades the soil so weeds are not as competitive.
High-crop seeding rates: Some crops can be planted at high rates to smother weeds.
Another strategy is to increase the crop density by decreasing within-row distance or
between-row distance. This is especially true when planting cover crops, forages, or grains.
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Nurse crops: Companion crops can be sown with other crops to suppress weeds during the
establishment year. A common example is planting oats to serve as the nurse crop for alfalfa.
Sanitation: For long-term weed control, it is important to avoid letting weeds go to seed.
This keeps the field free of weed seeds for the next crop. Crops that go to seed also can
become weeds the following year.
Cover crops: Rotations that include cover crops can provide some weed control, especially
fast-growing cover crops, such as buckwheat. If cover crops are likely to self-seed, it will be
necessary to mow them before seed sets.
Solarization: Clear plastic traps the sun’s heat to raise the soil temperature.
Examples of Level B practices to manage weeds
Cultivation: Mechanical cultivation is effective in killing weeds, especially if done at the
seedling stage. Hilling potatoes controls the weeds while covering the tubers with soil.
Flaming: Flamers kill the above-ground portions of plants. They do not kill the roots, nor
do they prevent weeds from re-sprouting. Several types of flamers are available, including
small hand-held propane flamers and tractor-mounted flamers typically used in orchards.
Grazing: Animals such as goats or geese can control the height of cover crops sown in the
drive rows in orchards. Animals must be removed 90 days before harvest of the crop, in
accordance with the 90-120-day rule on manure applications. Chickens in movable pens
can remove all weeds from small areas.
Hand weeding: Organic growers are all too familiar with the expense (if you hire someone)
and exhaustion (if you do the work yourself) of hand weeding. However, hand weeding is
still an effective method of weed control.
Mowing: In orchards, the cover crops in the drive rows are kept mowed.
Mulching: A thick layer of mulch can smother weed seedlings. Mulch is less effective on
perennial weeds because weeds that emerge from rhizomes, stolons, or tap roots may be
able to grow through the mulch. Mulches are most commonly used when they can serve
more than one purpose because applying mulch can be labor-intensive and therefore costly.
For example, wood-chip mulches are commonly used in blueberry plantings to smother
weeds, add organic matter, reduce soil pH, retain moisture near the soil surface, and keep
the soil cool, all of which are important for shallow-rooted blueberry plants.
Transplanting: Transplanting onions rather than direct seeding gives the onions a head
start on the weeds.
Weed cloth or black plastic: Weed cloth is often used in perennials, such as organic blueberry plantings, because the cloth controls weeds for several years. Black plastic is more
commonly used in annual crops, such as tomatoes. Plastic mulches should not be allowed
to photodegrade or deteriorate in the field; they may not be disced, plowed, or otherwise
incorporated into the soil. In annual production systems, plastic mulch must be removed
at the end of the growing season.
Online Resources
Biorationals: Ecological Pest Management Database, www.attra.ncat.
org/attra-pub/biorationals
Organic IPM Field Guide, www.attra.ncat.org/attra-pub/summaries/
summary.php?pub=148
Guide for Organic Crop Producers
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Page 35
Questions
• Does your production system keep insects and diseases at manageable levels?
• Which of the following practices do you use?
Beneficial insects
Canopy management
Companion planting
Cover crops
Crop rotation
Cultivation
Flaming
Grazing
Habitat for beneficial insects
Habitat for predators
Hand weeding or hoeing
High crop seeding rates
Intercropping
Mowing
Mulching
Resistant crop varieties
Row covers
Sanitation
Solarization
Trap crops
Weed cloth
• Are all of the insect, pest, weed, and disease control materials you are using allowed
in organic production? See Chapter 9 “The National List of Allowed and Prohibited
Substances” for more information on choosing pest-control materials.
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CHAPTER 9
THE NATIONAL LIST OF ALLOWED AND PROHIBITED
SUBSTANCES
T
he National List of Allowed and Prohibited Substances identifies substances that
may or may not be used in organic crop production. In general, synthetic substances
are prohibited unless specifically allowed and non-synthetic substances are allowed
unless specifically prohibited.
§ 205.105 Allowed and prohibited substances, methods,
and ingredients in organic production and handling
There are two main criteria that determine whether a given substance, such
as a fertilizer or pesticide, is allowed in organic crop production:
1. Synthetic substances are prohibited unless specifically allowed on the National List.
2. Nonsynthetic (natural) substances are allowed unless specifically prohibited on the
National List.
In addition to these guidelines, genetically modified organisms are prohibited because
they are produced by a prohibited method. Sewage sludge is prohibited because it usually
contains prohibited substances.
Related ATTRA
publications
www.attra.ncat.org
Sources of Organic
Fertilizers and
Amendments
§ 205.601 Synthetic substances allowed for use in organic crop production
The National List of synthetic substances includes materials that are specifically allowed
in organic crop production. The list includes algaecides, disinfectants, sanitizers, irrigation
system cleaners, herbicides, animal repellents, insecticides, miticides, pheromones, rodenticides, slug baits, plant disease controls, soil amendments, and plant growth regulators;
in short, many of the materials needed for crop production. Any synthetic substance that
is not on the National List is not allowed. For example, herbicides containing the synthetic
material glyphosate are prohibited. Herbicides containing only natural substances, such as
vinegar and clove oils, are allowed.
§ 205.602 Non-synthetic substances prohibited for use in organic
crop production
This is the National List of natural, or nonsynthetic, materials that are specifically prohibited in
organic crop production. This list includes natural—but highly toxic—materials, such as arsenic.
First, it’s important to define a few terms. An “input” is any material applied to a crop,
including compost, pheromones, and any pesticides. The term “pesticide” refers to any
agent used to kill a pest. For example, insecticides kill insects, fungicides kill fungi, and
herbicides kill plants. The National List uses the word “substance” to include not only
inputs to crops but also any materials used for other purposes, such as rodent baits. All
substances are listed by the generic terms only (e.g., sodium bicarbonate), not by the brand
name (e.g., Arm and Hammer baking soda). This avoids suggesting that any one brand is
better than any other.
In this context, the term “product” will refer to the brand name of an input material. For
example, Biomin® Calcium 2-0-0 is the name of a calcium product manufactured by JHBiotech, Inc. Pesticides contain an active ingredient, which is the material that kills the pest.
Both pesticides and fertilizers also have inert ingredients, which make up the remainder
of the product. Active ingredients are listed on the label, but inert ingredients typically are
not listed. Although the inert ingredients are not listed on the product labels, they must be
allowed for organic production, in order to use a specific product.
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There are two organizations that review products and publish lists of products allowed for
organic production: the Organic Materials Review Institute (OMRI) and the Washington
State Department of Agriculture (WSDA) Organic Food Program. These organizations
obtain information about all the inert and active ingredients in a product formulation,
review them, and assess whether the product is allowed.
As explained in the previous chapter, the USDA organic regulations require that farmers
implement pest-management practices in a hierarchical fashion, beginning with a systems
approach. If that approach is not sufficient, inputs may be needed, whether for plant nutrition,
disease prevention, or pest management. This chapter explains broadly the types of materials allowed and specifically how to choose a product that will be approved by your certifier.
T
Allowed pesticides
here are two
organizations
that review
products and publish lists
of products allowed for
organic production:
the Organic Materials
Review Institute (OMRI)
and the Washington State
Department of
Agriculture (WSDA)
Organic Food Program.
Generally speaking, pesticides derived from natural materials or living organisms are
allowed in organic production as long as they do not contain synthetic additives or are not
specifically prohibited on the National List under § 205.602. By contrast, most synthetic
pesticides are not allowed; those few that are can be found on the National List under
§ 205.601.
Allowed inputs typically include but are not limited to the following:
• Biological pesticides
• Botanical pesticides
• Dormant and summer oils
• Fatty acid insecticidal soaps
• Minerals
• Pheromones
Biological pesticides
Biologicals may contain living microbes, such as the fungi Beauveria bassiana or Trichoderma harzianum. Other biologicals contain toxins derived from naturally occurring
microbes, such as the Bt toxin, produced by the bacterium Bacillus thuringiensis. There are
various formulations of Bt, all of which control insect larvae.
Spinosads are a relatively new class of biological insecticides derived from a rare form of
soil-dwelling actinomycete. Spinosads control a variety of insect pests, including thrips,
fruit flies, and caterpillars, without harming beneficial insects.
Botanical pesticides
Botanicals are derived from plants. They include pyrethrum, rotenone, sabadilla, neem,
ryania, and garlic. Strychnine and nicotine are also botanicals, but are expressly prohibited
in organic production. Since botanical pesticides are relatively nonselective, they can affect
natural predators and other nontarget organisms. Rotenone, for example, is highly toxic to
fish. For this reason, many organic growers use botanical pesticides only as a last resort.
Spray oils
Vegetable- or animal-derived oils are generally allowed as suffocating (stylet) oils, summer
oils, dormant oils, and surfactants. Some petroleum-derived oils, referred to as “narrowrange oils,” are allowed for the same purposes. Spray oils are commonly used to control
scale and mite pests.
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Insecticidal soaps
Fatty acid insecticidal soaps are synthetic pesticides specifically allowed in organic production. Safer® Brand Insect Killing Soap Concentrate II is a product that is commonly used
by organic farmers. Insecticidal soaps can be hard on beneficial predatory mites, so they
should be used with caution.
Minerals
Mineral-based pesticides include sulfur, copper products, diatomaceous earth, and kaolin
clay. These must be used with caution, even though they are allowed. Sulfur can reduce
the populations of some beneficial insects and may burn plants if used during hot weather.
Diatomaceous earth can cause respiratory problems and itching in the farmworkers who
apply it. Copper can accumulate in soils, so it is allowed with restrictions. The organic
regulations state that “copper-based materials must be used in a manner that minimizes
accumulation in the soil…” Certifiers may require soil testing to verify that copper is not
accumulating in the soil. Certain highly toxic minerals, including arsenic and lead, are
specifically prohibited.
Pheromones
Pheromones are chemicals released from insects that cause other insects of the same
species to change their behavior. Pheromones are not considered pesticides because they
do not kill the insects. The pheromones used for pest control are often called mating
disrupters because they alter mating behavior. Being totally natural, the pheromones themselves are allowed in organic production. However, some of the inert ingredients in mating
disrupter products are prohibited.
Allowed fertilizers
Allowed fertilizers and amendments typically include, but are not limited to, the following:
• Plant materials such as crop residues
• Rock dusts such as gypsum, rock phosphates, granite dust, greensand, natural
potassium sulfate, sulfate of potash-magnesia, and glacial gravel dust
• Animal byproducts
• Manures
• Composts
• Marine products and byproducts, such as seaweed and fish emulsion
• Non-GMO microbial inoculants
• Sodium nitrate (Chilean nitrate), only if its use constitutes no more than
20 percent of the crop’s total nitrogen requirement
How to determine if a product is allowed
for organic agriculture
The allowed pesticides on the National List are called active ingredients when they are formulated into a commercial product. Even if the active ingredient in a pesticide is allowed,
if an inert ingredient is not allowed, the pesticide may not be used in organic crop production. The U.S. Environmental Protection Agency provides four classifications of inert
ingredients: List 1, List 2, List 3, and List 4. At this time, only a small fraction of the inert
ingredients on these lists is allowed in organic production.
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The active ingredient is listed on the product label, but the inert ingredients often are not
listed, and companies may choose not to reveal that information. Determining whether
a commercial pesticide is allowed for organic production is a daunting task.
The same situation holds true for fertilizers and soil amendments. For example, the commonly sold agricultural gypsum often is made from recycled wallboard, a construction
material that contains synthetic chemicals. For that reason, gypsum used in organic
production must be obtained only from a mined source.
E
ven if the
catalog or the
manufacturer
claims that a product is
allowed, it’s a good idea
to verify that the product
approval is current
before it is applied to
organic land.
The safest option for organic farmers is to avoid using any product unless you’re sure that it is
allowed. One way to verify the product’s status is to review the lists published by OMRI and
the WSDA Organic Food Program. When companies develop a fertilizer or pesticide that
they believe is suitable for organic production, they typically list the product with OMRI or
WSDA, or both. The organizations review the products, including the inert ingredients, and
determine if they meet the requirements of the USDA organic regulations. Organic farmers
can use these listed products with confidence that their use will not jeopardize their organic
certification. The review does not include a review of product effectiveness, and the listing is
not an endorsement of the product. On the other hand, organic producers should be aware
that many companies choose not to list their products with OMRI or WSDA, yet their products are allowed in organic agriculture.
Using the OMRI list
OMRI has two lists: the OMRI Products List and the OMRI Generic Materials List. Both
include materials for crops, livestock, and processing. To use either OMRI list, start on the
OMRI Web site home page, and click “OMRI list” on the left side of the page. The next
screen allows you to search the OMRI lists for your product.
For example, if you search using the word “gypsum,” the Products List will include brand
names of several products (e.g., Ida-Grow Pelletized Gypsum). The generic materials list
will simply list gypsum.
At the bottom of the page, there is a link to download the Products List as a PDF file. If you
use the downloaded file, be sure to update it frequently, as new products are added and others are removed on an ongoing basis. The OMRI Web site also has links to the names and
addresses of suppliers to make it easier to purchase approved materials.
Using the WSDA Brand Name Materials List
The Brand Name Material List (BNML) is maintained by the WSDA Organic Food Program and can be accessed on its Web site. There are three versions: Sorted by Product,
Sorted by Company, and Sorted by Type. Each of these lists can be downloaded as a PDF
file. The list of materials sorted by product is best used to look up a specific product, such
as MicroPak PolyAmine, which is a fertilizer sold by Northwest Agricultural Products. The
list of materials sorted by company is useful when searching for products from a particular company, such as Bio-Gro, NuFarm, or Northwest Agricultural Products. The list of
materials sorted by type can be used to find an approved product. For example, searching
under D&PC (Disease and Pest Control), there are numerous sub-types, including neem,
pheromones, and fungicides.
Although this list was developed by one certification agency, it is accepted by most of the
certifiers in the United States.
Caveats
Companies that sell agricultural products will often state in their catalog that a product
is OMRI or WSDA approved. Some manufacturers will state on the package that the mate-
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rial is listed with OMRI or WSDA. Even if the catalog or the manufacturer claims that a
product is allowed, it’s a good idea to verify that the product approval is current before it is
applied to organic land.
When using either WSDA or OMRI lists to verify the product’s status, be sure to check
the most recent version. Each list is updated several times each year, and the most current
version is posted online. Using the complete and correct name of the product will make it
easier to find the product if it is listed.
Restrictions on use of approved products
Although products may be listed by OMRI or WSDA, there may be restrictions on their
use. The WSDA indicates restrictions in the column on annotations. For example, the
product Biomin Zinc is allowed as a fertilizer, but there is a restriction: soil deficiency must
be documented by testing. Before applying zinc to crops, farmers are required to obtain a
soil test to verify that the crop needed additional zinc. Some certifiers will accept fruit or
leaf tests that indicate a deficiency in the plant, as opposed to the soil.
The Organic System Plan
Each year, when a farmer prepares the paperwork to renew organic certification, one of the
questions will be: “Please list any materials you plan to use in this year’s growing season.”
This list should be based on the types of inputs applied in the previous year or the past
few years. This is a list of materials that might be applied, but they should only be applied
if they are needed. Always, if it is necessary to use a product that is not on the Organic
System Plan, the certifier must be notified before use.
Online Resources
OMRI Materials Lists, www.omri.org/omri-lists
WSDA Materials Lists, www.agr.wa.gov/FoodAnimal/Organic/
MaterialsLists.aspx
Biorationals Database, www.attra.ncat.org/attra-pub/biorationals
Questions
• Do you have a list of all inputs used for insect control in the previous growing season?
• Do you have a list of all inputs used for weed control in the previous growing season?
• Do you have a list of all inputs for disease control in the previous season?
• For a product listed by OMRI or WSDA, do you have evidence that it is allowed for
organic agriculture? This can be a label or a copy of the online listing.
• If you are using natural materials such as gypsum, do you have evidence that they
are from a naturally mined source?
• Do you understand any restrictions on the use of the products and have you
complied with the restrictions?
• Have you kept invoices of all materials purchased?
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Notes
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CHAPTER 10
GREENHOUSE PRODUCTION
T
his chapter does not reference a particular section of the USDA organic regulations
because there is no one section addressing greenhouse production. Whether growing plants in the field or in the greenhouse, organic producers must comply with all
practice standards related to fertility management, pest control, allowed materials, seed,
and treated lumber. For example, treated lumber may be allowed for structural support of
buildings, benches, or trellises, but it is not allowed for raised beds or plant supports.
The word “greenhouse” traditionally refers to a heated, permanent structure. The discussion in this chapter refers to plants grown in any enclosed structure, whether heated or
unheated, temporary or permanent, including cold frames and hoop houses, since many
of the same considerations apply to all enclosed systems.
There are several types of greenhouse growing systems. Plants can be grown in containers, in the ground, or in water. Container-grown plants may be short-term crops, such as
annual transplants, nursery perennials, or research studies, or they may be grown for harvest.
Peat, compost, vermiculite, perlite, and many typical ingredients in soilless potting mixes
are allowed in organic production. Other ingredients are not allowed, such as the chemicals
used to increase water-holding capacity of the soil and the fertilizers that are added to some
potting mixes. Before using a potting mix, read the label carefully, list the brand name on
your system plan, and save an empty bag to show your inspector. A greenhouse with container-grown plants will not need a 3-year transition period to become certified organic. If
the pots are reused, they can be cleaned with soap and water or disinfected with a chlorine
solution. The method used to sanitize containers will need to be approved by the certifier.
Hoop houses often are used to cover plants growing directly in the ground, rather than
in pots. If plants are grown in the ground within the greenhouse, the soil will require a
36-month period free of prohibited materials, just like an outdoor field. Cover crops typically
are not used in a greenhouse, but rotation may be required if crops are grown in the ground.
When there is both organic and conventional production at the same location, either in adjacent or shared greenhouse structures, there are additional challenges related to avoiding
contamination and commingling. For example, you must take extra care to ensure that
pesticide drift does not reach organic crops and that shared equipment is adequately cleaned.
Split production within a single greenhouse structure is not prohibited but is discouraged
due to the difficulties in controlling pesticide drift and monitoring fertilizer applications.
Handling, labeling, and segregation procedures must be well established to guarantee that
conventional and organic products are not commingled. The inspector will observe a split
operation closely to ensure that organic products are grown and handled properly.
Related ATTRA
publications
www.attra.ncat.org
Organic Greenhouse
Tomato Production
Organic Greenhouse
Vegetable Production
Herbs: Organic
Greenhouse Production
Potting Mixes for Certified
Organic Production
Despite the emphasis that organic agriculture places on the importance of soil, crops grown
in a hydroponic system, rather than soil, can be certified organic. Hydroponics is the production of plants in a soilless medium, whereby all of the nutrients supplied to the crop are
dissolved in water. Aquaponics is a type of hydroponic production in which nutrient-rich
effluent from fish tanks fertilizes the crops grown in hydroponic production beds. The waste
products of one biological system—the fish tank—produce nutrients for a second biological
system—the crop plants.
Management of insects, diseases, and weeds
Regardless of the system they use, greenhouse growers will need to have a plan for insect
and disease management. In an enclosed environment such as a greenhouse, insects and
foliar diseases can reach damaging levels very quickly. Conventional greenhouse production
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can rely on pesticides for control. In contrast, many organic producers focus on a systems
approach for insect and disease management:
• Choose crops adapted to greenhouse production
• Plant a diversity of crops
• Use screens to exclude insects
• Introduce predators such as ladybugs to reduce insect populations
• Break the pest cycle using heat or cold
In order to break the pest cycle, choose a time when the greenhouse is not in use for crops
and create conditions unfavorable for insect survival. A greenhouse used in the winter can
be closed in summer and allowed to heat to high temperatures to kill insects. Conversely,
a greenhouse used in the summer can be opened in the winter so that insects are killed by
cold temperatures.
Foliar diseases can become a problem in the enclosed, humid greenhouse environment, but
there are simple techniques to minimize disease outbreaks:
• Water plants early in the day
• Space plants far enough apart to allow air flow
• Use drip irrigation rather than overhead watering
• Open vents to encourage air movement
The goal of all these techniques is to reduce humidity and minimize periods of leaf wetness. When ventilating an organic greenhouse, be sure to avoid drift from attached conventional greenhouses or from pesticides sprayed outside the greenhouse.
Weed control can be a challenge in a greenhouse. Only approved herbicide materials may
be used inside the greenhouse, even if you are spraying the ground and all the plants rest
on benches. Use of black plastic or landscape fabrics for weed control must follow the
guidelines for organic production, as explained in Chapter 8.
Questions
• Are all planting media ingredients allowed in organic production?
• Are all fertilizers allowed in organic production?
• Do you actively take steps to prevent disease and pest outbreaks?
• If growing trays and pots are reused, are they cleaned using approved practices
and materials?
• Do you manage weeds in and around the greenhouse site with allowed technologies and inputs?
• Are your greenhouse structures adequately distanced or protected from sources
of pesticide drift?
• Are greenhouse construction materials selected and managed to prevent contamination of producing soils and crops? Pay special attention to the use of treated lumber.
• If you produce conventional crops, are separate structures used to segregate
conventional and organic production? Is air exchange prevented?
• Are adequate barriers present and/or procedures in place to prevent pesticideladen air movement from conventional production areas into organically
managed sections?
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Questions
• Are the organic production areas situated to prevent contamination by drainage
from conventional areas?
• Are sprayers and other application equipment for organic use labeled and segregated?
• Does shared equipment have clearly defined cleanup protocols? Are cleanup logs
maintained?
• Where fertigation is used in split production, are the water systems fully segregated to prevent contamination?
Notes
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CHAPTER 11
PREVENTING CONTAMINATION OF
ORGANIC CROPS
T
his chapter discusses various precautions and additional recordkeeping that are
needed to prevent contamination of organic crops. These precautions are important for split operations (farms that raise both organic and conventional crops) and
are essential for parallel production (farms that raise the same crop in both an organic and
conventional manner). Managing a split operation requires extra care to ensure the organic
integrity of the crops because of the risk of spray drift, contaminated equipment, or accidental sprays of conventional chemicals on organic crops. Preventing contamination also
is a concern if contractors are hired for seeding, spraying, or harvesting, or if spray drift
from neighbors is a possibility.
Related ATTRA
publications
www.attra.ncat.org
Sources of Spraying
Prohibited Signs for
Organic Farms
Transgenic Crops
It is the responsibility of the organic farmer to ensure that organic crops are not contaminated with conventional materials. Contractors hired for seeding, spraying, or harvest may
not be familiar with practices needed to prevent contamination of organic crops. If a prohibited material is applied, even if it is done by a contractor by mistake, an organic farmer
can lose organic certification for 3 years. Certainly this would have an economic impact.
It pays to educate employees and contractors and verify that they follow organic practices
carefully.
Seeding
Many conventional growers use seeds treated with fungicides that are prohibited in organic
production. These fungicide-treated seeds are required by law to be dyed, usually bright
pink or green, so the fungicide will be obvious to the user. Before seeding equipment
is used to plant organic crops, all fungicide-treated seeds must be completely removed
from the planting equipment. The seed drills may need special attention, typically cleaning with compressed air, to remove fungicide deposits or seeds that may be caught. After
cleaning the equipment, it’s a good idea to check that the fungicide-treated seeds have all
been removed. If the seeding equipment is not cleaned and treated seeds are distributed
throughout the field, this will be considered an application of a prohibited material and the
field will lose organic status for 36 months.
Special considerations apply to split operations that grow genetically modified (GM) crops,
or that have nearby neighbors that grow GM crops (also referred to as GMOs, or Genetically Modified Organisms). Pollen from GM crops has been contaminating organic crops
with increasing frequency. There is little information on the distance that would be needed
to prevent pollen from traveling from the GM crop to the organic crop. The distance will
depend on the type of crop, the surrounding vegetation, and the terrain that separates
the two crops. The isolation distances used for seed production are intended to minimize
transfer of pollen from one crop to another. These will provide a starting place to determine the isolation distance needed to prevent organic crop contamination with GM pollen,
but there are no guarantees.
Spraying and maintaining buffers
As an organic farmer, you are responsible for all materials applied to your fields, even when
you do not apply those materials yourself. Organic crops can be contaminated through
residues in spray equipment, drift from nearby fields, accidental sprays, or mistakes made
by employees.
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Residues from spray used for conventional crops must be thoroughly removed before
equipment is used to spray organic crops. Although most farmers rinse equipment with
water after spraying, some conventional pesticides, such as DDT, are hard to remove, so
rinsing may not be adequate. Residues may be removed more effectively by using a cleaner
such as Nutra-sol.
Pesticide drift is a concern if there are conventional crops growing near organic crops. Even
if a farm is entirely organic, pesticide drift may occur if the neighbors manage conventional
fields near the organic fields. In the past, farmers maintained a 25-foot buffer between
organic and conventional crops, but this is no longer considered a standard. Buffers may
need to be larger than 25 feet, or they may be smaller, but they must be large enough to
prevent measurable drift. Windbreaks, made of hedgerows or tall crops such as corn, will
reduce the likelihood of drift. If the conventional crop is fruit trees sprayed with an airblast sprayer, a large buffer will be needed. Conversely, if the nearby conventional spray is
for weed control, using a backpack sprayer near the ground, a smaller buffer will be sufficient. It is important to educate neighbors and employees to be careful to avoid drift onto
organic crops.
Accidental spraying of conventional pesticides onto organic fields is something that should
never happen, but it does. A neighbor might believe he or she is being helpful by spraying herbicides at the edges of your organic fields, or custom applicators might apply aerial
sprays to the wrong fields. To minimize the chances of instances such as these happening,
notify your neighbors in writing that some of your fields are organic. Supplying a map—
perhaps the map sent as part of the Organic System Plan (OSP)—can be very helpful. Additionally, if organic crops are planted near roadsides, it may be necessary to inform county
authorities that they should not spray herbicides near your organic crops. Some counties
provide free signs that state “Owner Will Maintain.” These are placed at the beginning
of the organic property to indicate that the owner will control weeds along the roadside.
Other sources of signs are provided in the ATTRA publication “Sources of Spraying Prohibited Signs for Organic Farms.”
Mistakes by employees should never happen, but they do. During the transition period
from conventional to organic, it’s easy to reach for familiar conventional pesticides without
realizing that they are prohibited. If employees will be spraying pesticides, it is essential to
educate them about the use of materials approved for organic production, the proper cleaning of sprayers, the importance of accurate spray records, and any other organic procedures
for which they are responsible. One common mistake is to use a material that is allowed in
organic production in the United States but is not allowed according to the organic standards in Europe. If any product will be exported, be especially vigilant to be aware of additional restrictions.
Fertilizing (custom mixing)
Each material applied to an organic crop must be documented, reported to the certification
agency, and allowed for use in organic production. The list of ingredients used in a custom
mix, including the brand names and copies of invoices, must be available for review by the
organic inspector.
Irrigation
The USDA organic regulations have very little to say about irrigation and irrigation water
quality. However, since it is the general intent of these regulations that crops and soils not
be contaminated with prohibited substances, producers should take precautions to ensure
that irrigation water is not loaded with agricultural pesticides or other polluting chemicals.
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If you have a split operation and shared irrigation equipment is used for fertigation or other
chemical application, protocols for decontamination of the equipment and a cleanout log
will be required. It is probably easier to use separate irrigation equipment for organic and
conventional crops. If irrigation lines require a cleaning agent, an algaecide, or any antimicrobial chemical, consult your certifier to be certain the material you choose is allowed
for use in organic production.
Harvest
If the same equipment is used to harvest both organic and conventional crops, there is a
possibility of commingling, or combining, of organic products with conventional products. Several precautions are needed to prevent commingling. Cleanout procedures need
to be established and documented to ensure that product mixing does not occur. Along
with clearly written protocols, a log of cleanout dates also will be expected by the certifier.
Before beginning the organic harvest, organic farmers often rely on purging to scour
combines and other harvesting equipment that is used for conventional crops. One way
to purge equipment of conventional crops is to harvest the first organic crop row and
sell it as conventional. This is a common technique for hay balers and combines. Purging may not be an adequate cleanout technique in circumstances where the remains of
GM crops need to be removed. Very small quantities of GM crops can be detected with
current testing procedures.
Transportation of organic products
Transporting organic crops from the field to the storage location might present a contamination hazard. If trucks have been used to transport conventional crops, they need to be
thoroughly cleaned before being used to transport organic crops. Even small details can be
very important. For example, cleanout protocols must include cleanup of the tarps used to
cover grain trucks or hay bales.
Cleaning procedures for harvest and transportation equipment will depend on the specific
crop. The protocols, or step-by-step procedures, should be written down so that employees can easily follow the directions. A cleaning log should be used to document the dates
that cleaning occurred. This is especially important if contractors are used. Farm produce
that is transported by your own farm equipment is covered under your OSP for the farm
certification. If other transportation is used, truck or rail, the company must be mentioned
in your OSP.
Storage
In a split operation, several precautions should be taken to avoid commingling of organic
and conventional crops in storage. Organic crops must be stored separately from conventional crops. Separation can be achieved with a separate location in the storage area, identified by clearly readable signs, or an entirely separate room. Your certifier will determine
whether the separation is adequate. All bins and storage areas should be clearly labeled.
Inventory records, cleanout protocols, and cleanout logs must be current. The inspector
may conduct a detailed in/out audit to compare the amount of product sold to the amount
of product harvested. All records should be available at inspection.
Pest-management decisions for storage areas will need to follow organic guidelines as well.
These are explained in chapter 14 “Structural Pest Management.”
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Online Resources
Isolation Distances and Pinning Maps in Organic Seed Production, www.
extension.org/pages/18435/isolation-distances-and-pinning-maps-inorganic-seed-production
NOP 5031 Draft Guidance: Handling Bulk, Unpackaged Organic Products,
www.ams.usda.gov/nopprogramhandbook
Questions
• If planters or seeders are also used to apply prohibited materials, are cleanout
protocols clearly established and cleanout logs maintained?
• If conventional crops are grown, is separate spraying equipment available and
clearly marked?
• If sprayers are also used to apply prohibited materials, are cleanout protocols
clearly established and cleanout logs maintained?
• If both organic and conventional crops are irrigated using the same equipment, are
you taking steps to ensure that prohibited materials do not contaminate organic
crops?
• Is all runoff from conventionally managed land properly diverted to prevent
contamination of land and water resources used in organic production?
• If equipment is used to harvest both conventional and organic products, are
cleanout protocols established and cleanout logs maintained?
• When harvesting equipment is purged, have adequate records been kept on the
quantity of organic product used in purging and how it was subsequently used or
disposed of?
• Are crops harvested from buffer zones segregated, documented, and sold as
nonorganic product?
• Are cleanout protocols maintained for farm-owned trucks?
• Do all hired trucks have either clean truck affidavits or cleanout logs?
Notes
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CHAPTER 12
POST-HARVEST AND LABELING
T
he importance of maintaining organic integrity not only while the crop is being
grown but also after the crop is harvested cannot be overstated. To ensure organic
integrity from the field to the consumer, it is important to develop standard procedures, or protocols, for harvesting, washing, storing, transporting, and labeling organic
produce. These protocols should be written in the Organic System Plan (OSP), approved by
the certifier, and followed by all farmworkers.
Protocols differ from farm to farm, depending on the size of the farm and the storage facilities.
On every farm, there are two common goals: preventing contamination of organic crops
and preventing commingling of organic crops with conventional crops. This chapter discusses some important considerations for harvesting, washing, storing, packing, labeling,
and transporting organic crops. Chapter 13 “Recordkeeping” will discuss the importance
of an audit trail, which allows products to be traced from the consumer back to the farm
and perhaps to the field where the crop was grown.
Containers
Any container used for harvest, storage, or shipping can present a threat of contamination to organic produce. This includes bins, cardboard boxes, and trucks used to transport
produce from the farm to a local market.
As organic producers harvest crops into containers, they should consider the potential for
contamination and take appropriate steps to prevent it. Harvest and storage bins should
be clean and free of residue left from conventional produce. Almost any type of soap or
detergent can be used to clean containers, as long as the containers are thoroughly rinsed.
A few sanitizers, such as quaternary ammonium compounds, are prohibited because they
leave residues that are difficult to remove. If the harvest containers must be sanitized,
several brands of chlorine and peroxyacetic acid sanitizers are allowed for organic use. The
chlorine residues can be easily washed off with water. Peroxyacetic acids may not even need
rinsing because they will decompose into water and oxygen and because washing with
water after using peroxyacetic acid risks further contamination.
Packaging and shipping materials that are impregnated with prohibited pesticides can
contaminate organic products. For example, reusing cardboard boxes that have been
used for conventional produce is an excellent idea from the standpoint of sustainability.
However, many of those boxes have been treated with fungicides, so they should not be
used for organic produce.
Washing produce
Microbial contamination of water used to wash fresh produce is a high-profile issue in the
organic community. Some types of produce, such as lettuce, are simply rinsed with plain
water to remove field heat. In those cases, the farmer needs to be aware of basic food safety
and ensure that the water used is potable. For other types of produce, such as apples, synthetic materials are added to the wash water to reduce microbial loads. Adding hydrogen
peroxide, ozone, or chlorine to control microbial growth is allowed in organic processing,
but there are restrictions on the use of these chemicals.
Section 205.605 of the National List of Allowed and Prohibited Substances states that chlorine (Cl) materials are allowed for “disinfecting and sanitizing food contact surfaces” in
organic processing. The regulation also states that “residual chlorine levels in the water
shall not exceed the maximum residual disinfectant limit under the Safe Drinking Water
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Act,” which is currently 4 parts per million chlorine. The interpretation of this regulation
caused some confusion, leading the NOP to issue additional guidance. The guidance document can be found in the NOP Program Handbook as NOP5026, “The Use of Chlorine
Materials in Organic Production and Handling,” and is summarized below.
When washing produce, the rinse water that makes final contact with the organic product
must not contain more than 4 ppm chlorine. In other words, a food product, such as apples,
may be bathed in water containing a higher concentration of chlorine, if it is permitted by
the U.S. Food and Drug Administration (FDA), but that product must receive a final rinse
of water containing no more than 4 ppm chlorine. The procedures used to wash produce
and to monitor chlorine levels in the wash water must be included in the OSP.
Some farmers may choose to use chlorine materials for irrigating crops or cleaning irrigation systems. For those purposes, the water must contain no more than 4 ppm chlorine.
Storing produce
Storing produce appropriately is just as important as growing it. Your OSP should state
the names of any storage facilities that you use. The farm inspector will want to visit any
storage facilities that are used for organic crops, even if they are offsite. Storage in an open
container, such as an apple bin, presents more possibility of contamination or commingling
than produce stored in a closed container, such as a 40-pound cardboard box of apples. For
bulk storage of certain crops such as apples and potatoes, it may be necessary to have a dedicated organic cooler to avoid contact with post-harvest chemicals applied to conventional
crops. Potato storages, in particular, must be carefully cleaned after storage of conventional
crops and before storage of organic crops.
T
he NOP
Program
Handbook
includes a guidance
document titled
“The Use of Chlorine
Materials in Organic
Production and
Handling.”
Labeling nonretail containers
Nonretail containers include cardboard boxes, plastic bins, totes, or other containers used
to transport fruits and vegetables to the warehouse, farmers market, or retailer. Such containers must be labeled with information that allows the product to be traced back to the
farm and field where it was grown. Nonretail containers on the farm include only raw agricultural products, but these rules apply as well to processed (e.g., frozen) products kept in
bulk storage by processors.
For many small farmers who market raw products, it will be sufficient to label the container
with the word “organic” and the farm name. The USDA organic seal or the seal of the certification agency may be used, but they are not required. Farmers who have multiple fields
of the same crop will need to assign lot numbers to the crops harvested from different fields
and ensure that the lot number is attached to the container. For example, a farmer with
three fields of sweet corn, all being sent to a processor to be frozen, may choose lot numbers
of swc_JY30, swc_AU15, and swc_AU30. This code indicates the crop (swc), the harvest
month (JY, AU) and the harvest day (15, 30).
Labeling retail containers
§ 205.301 Product composition
(a) Products sold, labeled, or represented as “100 percent organic.”
(b) Products sold, labeled, or represented as “organic.”
(c) P
roducts sold, labeled, or represented as “made with organic” (specified ingredients
or food group(s)).
(d) Products with less than 70 percent organically produced ingredients.
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The rules for labeling organic retail products, both raw and processed, are addressed under
the “Product Composition” section of the USDA organic regulations. The regulations cover
the wording allowed on both the front panel and the information panel of a packaged product. The four categories of labeling based on product composition are summarized below:
• “100 percent organic” can be used to label any product that contains 100 percent
organic ingredients (excluding salt and water, which are considered natural). Most
raw, unprocessed farm products can be designated “100 percent organic.” Likewise,
many value-added farm products that have no added ingredients—such as grain
flours, rolled oats, etc.—can also be labeled “100 percent organic.”
• “Organic” can be used to label any product that contains a minimum of 95 percent
organic ingredients (excluding salt and water). Up to 5 percent of the ingredients
may be nonorganic agricultural products that are not commercially available as
organic and/or nonagricultural products that are on the National List.1
• “Made with Organic ______” can be used to label a product that contains at least
70 percent organically produced ingredients (excluding salt and water). There are
a number of detailed constraints regarding the ingredients that comprise the nonorganic portion.
• The specific organic ingredients may be listed in the ingredient statement of products containing less than 70 percent organic contents—for example, “Ingredients:
water, barley, beans, organic tomatoes, salt.”
Many farmers make jams, teas, salsas, or other processed products from their excess
produce. These value-added products can be an excellent source of income, but there
are additional requirements if they are to be labeled organic. Depending on the certifier,
simple processing—such as drying of herbs, freezing of fruits, or grinding of grains—may
be covered under the farm’s Organic Producer certificate. If the product undergoes complex processing and is labeled organic on the front panel, an Organic Handler certificate
will be required. If the organic ingredients are only listed in the information panel and
those ingredients are grown on the farm, then the Organic Handler certificate is not necessary. For example, farmers can list organic strawberries as an ingredient in the jam if they
make jam from organic strawberries that they grow. The certifier will want to review copies
of the labels to ensure that they comply with organic regulations.
Online Resources
NOP 5026 Guidance: The Use of Chlorine Materials in Organic Production
and Handling, www.ams.usda.gov/nopprogramhandbook
NOP 5031 Draft Guidance: Handling Bulk, Unpackaged Organic
Products, www.ams.usda.gov/nopprogramhandbook
1
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For an explanation of the National List, see Chapter 9 “The National List of Allowed and Prohibited Substances.”
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Questions
• If both organic and conventional crops are grown, are harvest procedures sufficient
to ensure segregation? Do adequate labeling protocols exist to ensure segregation?
• Have labels been sent to the certifier for approval?
• If you are reusing bags or containers, are you taking measures to ensure that there
is no risk of commingling with nonorganic products or of contamination with
prohibited substances?
• Are all packaging materials free of impregnated pesticides or other prohibited
substances?
Notes
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CHAPTER 13
RECORDKEEPING
§ 205.103 Recordkeeping by certified operations
Certified operators must maintain records concerning the production,
harvesting, and handling of organic products. The records must:
• Be well adapted to the business being conducted
• Disclose all activities and transactions in adequate detail
• Be maintained for not less than 5 years beyond their creation
• Be sufficient to demonstrate compliance with Federal regulations
Records must also be available for inspection and copying during normal business hours
by authorized representatives of the certifying agent.
T
he previous chapter discussed the importance of implementing protocols to prevent
contamination and commingling after harvest. In order to verify that the protocols
are followed, they must be documented as part of the recordkeeping requirements
for organic operations. Each organic farm receives a visit from an inspector only once a
year. The records verify that the protocols have been followed throughout the remainder of
the year. The inspector reviews records as evidence that the farm practices are being carried out according to the Organic System Plan. Thus, the records are essential for ensuring
organic integrity because they demonstrate compliance with organic standards.
Related ATTRA
publications
www.attra.ncat.org
Organic Market Farm
Documentation Forms
Organic Field Crops
Documentation Forms
Organic Orchard,
Vineyard, and Berry Crop
Documentation Forms
Forms, Documents,
and Sample Letters for
Organic Producers
The actual amount of documentation the individual producer will need in order to comply
with organic regulations will depend on the complexity of the operation. A list of the types
of documents kept by organic farmers is provided at the end of this chapter. Although the
list may appear to be rather lengthy, many of these records are the same ones kept by any
farmer, such as records of planting, fertilizing, spraying, harvest, and sales.
The audit trail
The records of particular importance to the organic industry are the documents necessary to
determine the source, movement, and transfer of ownership of any organic product. These
records, also called the audit trail, provide a paper trail that can trace the product from farm
to table. A complete audit trail allows a product—an apple in a grocery store, for example—
to be traced back to the orchard where the apple was grown. Processed products will have
a lot code to allow each ingredient in the product to be traced back through the processor
and to the farmer. The audit trail for fresh produce will be simpler than that for a processed
product, but it may still involve records kept by several operations including the grower, the
warehouse, the packer, the distributor, and the final retail store, plus all shippers. The records
will include harvest records, purchase invoices, sales invoices, bills of lading, and others as
needed. Sometimes the concept of audit trail is also extended to include production records
and inputs, which also serve to demonstrate that the producer is farming organically.
Lot numbers
Lot numbers are an important aspect of a good audit trail. Lot numbers are codes assigned
by producers to link products to the fields of origin and the year or date on which they were
produced. Lot numbers may not be necessary for farmers who sell all produce directly to
consumers soon after harvest, such as farmers who grow for a subscription Community Supported Agriculture (CSA) program. A lot number or other tracking system is useful for farmers who sell into wholesale markets or to processors. A good lot numbering system is logical
and can readily be decoded. For example, Lot No. OC0603 might indicate Organic Corn,
from bin #06, which was harvested in 2003. Lot No. B041433 might indicate Broccoli, from
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field 04, harvested on the Julian day 143 (May 23), in the year 2003. In the Julian Date Calendar, each day is assigned a number in sequence from 001 through 365 (366 in leap years). The
Julian system is commonly used for product coding.
Types of records
Correspondence
• Organic System Plan sent to certifier
• Application materials sent to certifier (map, affidavit, record of sales, etc.)
• Notices to neighbors, county road maintenance authorities, utilities, and others
that demonstrate efforts protect organic fields from spray drift
• Correspondence from your certifier
• Correspondence to your certifier, addressing corrective actions to address any
compliance issues
• Complaint log
Land
• Maps, with field names
• Field history sheets
Seeds and Planting Stock
• Verification of the organic status of seeds, seedlings, transplants
• Invoices to verify purchase of organic seeds and stock
• Documentation of efforts to procure organic seeds and planting stock when
nonorganic materials have been used
• Verification of non-GMO status of nonorganic inputs
Production
•
•
•
•
•
•
•
Planting records
Material application records
Soil tests
Activity records with dates of field operations
Labels from fertilizers
Labels from pest control materials
Invoices for purchased materials
Harvest and Storage
•
•
•
•
•
Harvest equipment cleanout logs
Storage unit cleanout logs
Storage records
Harvest and yield records
Packout records
Transportation and Sale
•
•
•
•
•
Clean truck affidavits
Sales invoices
Sales records
Outgoing bills of lading
Weigh tags
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Questions
• Can your records be easily understood and audited?
• Are you maintaining a complete set of operation records covering the production,
harvesting, and handling of all of your organic crops?
• Are sales records maintained to ensure a complete audit trail?
• Does your lot-numbering system permit accurate tracking of products from
harvest through storage and marketing?
• Do you retain all records applicable to your operation for at least 5 years?
Notes
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CHAPTER 14
STRUCTURAL PEST MANAGEMENT
T
he previous chapters of this guide have focused on the contamination of organic
crops that can occur when materials are applied to crops in the field. The possibility
of contamination also exists if crops or soil come in contact with treated lumber used
as part of a trellis system, a raised bed, or structural support in a greenhouse. Crops may
also be contaminated or commingled if they are kept in storage after harvest. This chapter
explains regulations on treated lumber, storage facilities, and pest control inside buildings.
§ 205.206 (f). The producer must not use lumber treated with arsenate or
other prohibited materials for new installations or replacement purposes in
contact with soil or livestock.
Lumber has many uses on a farm: trellises, fences, tomato stakes, the sides of raised beds,
and structural support in greenhouses. The usefulness of lumber can be limited because
pines and other common tree species will quickly decay when exposed to soil and humidity. Conventional farmers often use lumber treated with arsenate or other fungicides, which
prevents or slows the natural decay of wood. These fungicides are highly toxic and they can
leach into soil where they remain for a long time. For this reason, the NOP prohibits organic
farmers from installing treated lumber in places where it can contaminate soil or contact
livestock. The prohibition applies to new and replacement installations—treated wood on
existing structures will not need to be replaced unless the certifier identifies a clear hazard.
Treated lumber is also harmful to humans. It is recommended that farmers wear a dust mask
as they cut treated lumber to avoid breathing the sawdust laden with arsenic.
Related ATTRA
publications
www.attra.ncat.org
Pressure-Treated Wood:
Organic and Natural
Alternatives
Treated lumber may be used in circumstances and in ways that ensure that contamination
cannot and will not occur. For example, trellises can be installed outside the perimeter of
the organic site, far enough away from the organic crop to avoid contamination. The distance will need to be approved by the certifier. Treated wood can be used in the base of a
greenhouse, where plants are grown above ground on benches.
There are several alternatives to treated lumber. Alternative structural materials, such as
metal posts, can be used for trellises. Tree species that resist decay, such as cedar or black
locust, can be used for fence posts. There are also some natural treatments that can help
prevent wood decay, although they are not as effective as arsenic treatments.
Structural pest management
§ 205.271 Facility pest management practice standard
The facilities where organic products are stored must use management
practices to prevent pests.
This section on pest control applies to any buildings where organic product is stored or handled, such as grain bins, cold rooms, freezers, warehouses, packing sheds, and farm stands.
When food is stored, there is the possibility that it may become contaminated by insects,
rodents, or other pests. As explained in Chapter 8 “Managing Pests, Weeds, and Diseases,”
a multi-level hierarchical approach is required when dealing with pests. The first three levels, A, B, and C, are analogous to those discussed previously to manage pests on crops in
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the field. The fourth level, D, is available for use inside and around the outside perimeter of
buildings if the organic products can be protected from contamination.
Level A
The first line of defense is prevention. Exclusion of pests from the facility saves time and
money by reducing the need for further pest control. To prevent pests from entering a storage building, use screens on windows, keep doors closed, and ensure that doors are wellsealed when they are closed. If crops such as alfalfa are stored in an open barn, be sure
they are covered to avoid contamination from bird droppings. Removing food sources will
prevent pest populations from increasing. This may include sweeping up spilled grains and
ensuring that food left in a lunch room is in sealed containers. Managing the environment
so that it is unfavorable for pests will also prevent outbreaks. The area outside the facility
should be kept clear so there are no places for rodents to hide. Inside the storage rooms,
bins and boxes should be kept at least 12 inches from the walls. This will allow traps to be
set for rodents, which like to run next to walls.
Level B
The second line of defense is the use of mechanical and physical controls. Level B practices
include insect lights that attract and kill insects and mechanical rodent traps baited with
food, such as cheese. Baits that kill rodents or insects are Level C practices.
Level C
The third line of defense, Level C, is to be used only after A and B control options are
applied. Level C practices include the use of materials on the National List, section §
205.601. Examples include vitamin D3 bait to kill rodents, and diatomaceous earth placed
in grain bins to kill insects. If any pest-control materials are used, application records must
be maintained.
Level D
The fourth line of defense, Level D, may only be considered if pest control actions A, B,
and C do not adequately prevent or control facility pests. Level D practices include the use
of synthetic insecticides or rodenticides not on the National List. These substances, which
are prohibited for most uses in organic agriculture, may be used only as a last resort. Use
of prohibited pest control materials must be approved by the certifier. Before approving a
Level D application, the certifier will verify that Level A, B, and C pest control actions have
already been employed. The certifier will review the substance to be applied, the method of
application, and the measures to be taken to prevent contact with organic products.
If use of a prohibited pesticide is required by Federal, State, or local laws or regulations,
notify your certifier and agree on a plan to ensure that measures are taken to prevent contamination of organic products. If your certifier has agreed to the practice, it will not compromise your organic status.
Storage buildings
Just as every field where organic crops are grown must be inspected annually, every building where organic crops are stored must be inspected annually. All buildings where organic
crops are handled or stored must be listed on your organic system plan. Examples include
seed cleaning, potato washing, or controlled-atmosphere apple warehouses. These areas
must be under your control, or else they must have their own organic certification, if there
is any chance that organic integrity could be compromised while the product is in the storage or handling facility. Retail stores and other operations that have products packaged in
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sealed retail containers do not need to be inspected or certified because there is no danger
of contamination, and some retail stores are exempt or excluded from the requirement of
certification according to § 205.101.
Records of crop storage will vary depending on the type of crops and length of storage.
Vegetables kept in a cold room for a few days typically do not require complex storage
records. On the other hand, grain bins where a large volume of grain is stored for a long
period of time will require more detailed records.
Records for grain storage may include:
• Bin capacity
• Status of crop (organic, conventional)
• Name of crop (wheat, corn)
• Date of harvest
• Source of crop (field identification)
• Amounts of grain added or removed
• Dates on which grain was added or removed
• Cleanout dates
• Dates when pest control treatments were applied
If storage rooms include both organic and conventional products, the organic products
should be stored in a manner that reduces the possibility of contamination or commingling
with conventional products. Areas where organic product is stored must be clearly labeled.
Organic products should always be stored on the upper shelves and conventional products
stored on the lower shelves. Storing organic products on upper shelves reduces the chances
of commingling. For example, an organic apple falling into a conventional lot means the
loss of organic status and price premium for a single apple. A conventional apple falling
into an organic lot is a violation of organic integrity and results in the loss of organic status
and premium for the entire lot. Storing organic products on higher shelves also reduces the
chances of contamination from pesticide residues and other prohibited materials.
Questions
• Are all pest-control products allowed for organic use?
• If you were obliged to use a synthetic pest-control material, did you obtain
approval from your certifier?
• If you have used pest-control materials in buildings, are pesticide-use records
maintained?
• Are grain storage bins sealed to prevent infestation by rodents, birds, and pest animals?
• Is each storage container or shelf clearly labeled “organic” or “conventional”?
• Are cleanout protocols established after storage of conventional crops?
• Where both conventional and organic produce is stored, are the storage areas
clearly marked and segregated from each other?
• Are prohibited materials (for example, fuels, pesticides, etc.) stored well away from
organic crop storage areas?
• If pest-control products are used, is their use recorded in a pest-control log?
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Questions
• If a pest-control company is contracted to manage pest control, has it been notified
that it must comply with organic standards?
• Are storage facilities large enough to segregate organic and conventional crops as
needed?
• If crops are stored off-farm, are the off-farm storage units either certified organic
or included in your farm’s inspection and certification?
• Are fence posts constructed of approved materials or located where they cannot
contaminate organic crops?
• Are trellis posts constructed of approved materials?
Notes
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CHAPTER 15
RESOURCES
T
he information presented in this chapter is intended as a helpful reference. It is for
information purposes only and inclusion in this list does not constitute endorsement
by USDA. It is the user’s responsibility to verify the accuracy of any information.
The following resources provide information on organic regulations, the organic products
industry, and food-safety regulations. This list is not intended to be exhaustive. There are
many additional resources available, notably in the areas of business management or
government programs for small business.
Acres USA
www.acresusa.com
Acres USA publishes a national magazine that offers a comprehensive guide to sustainable
agriculture. It also sponsors a conference and distributes books and videos on alternative
agriculture.
Alternative Farming Systems Information Center (AFSIC)
http://afsic.nal.usda.gov
AFSIC is part of the USDA National Agricultural Library (NAL). AFSIC focuses on topics
related to sustainable and alternative agricultural systems, crops and livestock, and implementing the NAL mission of “advancing access to global information for agriculture.” Such systems
include sustainable, low-input, regenerative, biodynamic, and organic farming and gardening.
ATTRA
www.attra.ncat.org
ATTRA–National Sustainable Agriculture Information Service is managed by the National
Center for Appropriate Technology (NCAT). ATTRA has produced more than 300 publications on a variety of sustainable agriculture topics, as well as a number of webinars and
other resources.
eOrganic
www.eorganic.info
The goal of eOrganic is to foster a national organic research and outreach community and to disseminate information about organic farming practices and regulations.
eOrganic provides information to the agriculture community in the form of articles,
videos, and webinars. Its resources are part of the Cooperative Extension System, called
eXtension (www.extension.org/organic_production).
National Sustainable Agriculture Coalition (NSAC)
www.sustainableagriculture.net
NSAC is an alliance of grassroots organizations that advocates for Federal policy reform to
advance the sustainability of agriculture, food systems, and natural resources. Its Web site
has current information about the Farm Bill and other legislation that will impact organic
farmers. NSAC publishes several documents that explain Federal programs, food safety, and
public policy that affects agriculture. One recent publication is the “Farmer’s Guide to the
Conservation Stewardship Program,” which can be found at www.sustainableagriculture.net/
wp-content/uploads/2011/09/NSAC-Farmers-Guide-to-CSP-2011.pdf. The complete publications list can be found at www.sustainableagriculture.net/publications.
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Natural Resource, Agriculture, and Engineering Service (NRAES)
www.nraes.org
The NRAES publishes practical books on agriculture and related subjects. One example is
the book “Crop Rotation on Organic Farms: A Planning Manual.”
Organic Farming Research Foundation (OFRF)
www.ofrf.org
The OFRF sponsors grants for research in organic farming, offers free publications on its
Web site, and educates the public about the importance of organic agriculture.
Organic Materials Review Institute (OMRI)
www.omri.org
OMRI provides an independent review of products intended for use in organic agriculture
and processing. The OMRI list of allowed products can be found on its Web site.
Organic Seed Alliance (OSA)
www.seedalliance.org
The OSA conducts research on organic seed production and hosts the Organic Seed Growers Conference each year. Its Web site includes a list of seed companies that sell organic seed.
Organic Trade Association (OTA)
www.ota.com
The OTA is a business association geared to wholesaling organic products in North America.
OTA maintains “The Organic Pages,” a directory of suppliers of organic products, at www.
theorganicpages.com. It also maintains a Web site, www.HowToGoOrganic.com, that offers
information on the transition from conventional to organic farming and processing.
Rodale Institute
www.rodaleinstitute.org
Rodale Institute conducts research on its organic farm in southeast Pennsylvania. The
institute publishes ”New Farm” magazine, offers a free online course in organic farming,
and has an information-packed Web site. Two areas of special interest to organic farmers
are the guide to organic certifiers at www.rodaleinstitute.org/certifier_directory and the
organic system plan tool at www.tritrainingcenter.org/code/osp_index.php.
Sustainable Agriculture Research and Education (SARE)
www.sare.org
SARE promotes research and education to improve profitability and sustainability of
farms. SARE’s learning center contains books, videos, online courses, and fact sheets. The
publications are typically national in scope and provide a thorough review of the subject.
SARE also provides grants to farmers, researchers, and extension personnel to conduct onfarm research.
The Soil and Health Library
www.soilandhealth.org
This is a free, electronically accessible public library offering a collection of books on
holistic agriculture. Many titles are out of print. It is an excellent place to find classic
organic farming texts by pioneers from the early and mid 1900s.
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USDA Cooperative Extension System
www.csrees.usda.gov/Extension
The Cooperative Extension System is a nationwide, noncredit educational network.
Each U.S. State and territory has a State office at its land-grant university and a network
of county offices to provide information related to local issues.
USDA National Organic Program (NOP)
www.ams.usda.gov/nop
The mission of the NOP is to ensure the integrity of USDA organic products in
the United States and throughout the world. The NOP implements the Organic Foods
Production Act. Its Web site has a link to the electronic Code of Federal Regulations
applicable to organic production and handling, a list of accredited certification agencies,
a list of all certified organic operations, and a wealth of other information. The Program
Handbook, which can be downloaded from the Web site, provides guidance to assist in
complying with NOP regulations.
USDA Natural Resources Conservation Service (NRCS)
www.nrcs.usda.gov
The NRCS provides technical assistance, through its employees or through Technical Service Providers (TSPs), to enhance soil- and water-conservation efforts on the farm. TSPs
have technical expertise in conservation planning and design for a variety of conservation
activities. TSPs are hired by farmers to provide these services on behalf of the NRCS.
Washington State Department of Agriculture (WSDA)
www.agr.wa.gov/FoodAnimal/Organic/MaterialsLists.aspx
The WSDA Organic Food Program reviews materials allowed in organic production
and publishes the WSDA Materials List on the Web.
Publications
Farmers’ Guide to the Conservation Stewardship Program, www.sustainableagriculture.
net/wp-content/uploads/2011/09/NSAC-Farmers-Guide-to-CSP-2011.pdf
Building Soils for Better Crops, www.sare.org/publications/soils.htm
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The U.S. Department of Agriculture (USDA) prohibits discrimination against its customers. If you believe you experienced discrimination when
obtaining services from USDA, participating in a USDA program, or participating in a program that receives financial assistance from USDA,
you may file a complaint with USDA. Information about how to file a discrimination complaint is available from the Office of the Assistant
Secretary for Civil Rights.
To file a complaint of discrimination, complete, sign and mail a program discrimination complaint form, available at any USDA office location
or online at www.ascr.usda.gov, or write to: USDA, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, S.W.,
Washington, D.C. 20250-9410.
Or call toll free at (866) 632-9992 (voice) to obtain additional information, the appropriate office or to request documents. Individuals who are
deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay service at (800) 877-8339 or (800) 845-6136 (in
Spanish). USDA is an equal opportunity provider, employer and lender.
Persons with disabilities who require alternative means for communication of program information (e.g., Braille, large print, audiotape, etc.)
should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD).
This publication is available online at:
www.attra.ncat.org
or by calling NCAT’s ATTRA project: 800-346-9140
IP222
Slot 92
For more information, please contact the
USDA National Organic Program:
N
ational Organic Program
Agricultural Marketing Service
U.S. Department of Agriculture
1400 Independence Avenue, SW
Stop 0268, Room 2648-S
Washington, DC 20250-0268
Tel. 202-720-3252
Fax 202-205-7808
www.ams.usda.gov/NOP
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www.ams.usda.gov/nop
Guide for Organic Crop Producers