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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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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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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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
All Regions
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2012