Organic Crop Certification
Organic System Plan
To ensure natural cycles are managed in a proactive manner, the National Organic Program (NOP) requires producers to complete a soil and pest management plan called the Organic System Plan (OSP). The OSP, or Farm Plan, as it sometimes called, is unique to their operation and is submitted to the certification agency for review and approval. The OSP must be sufficiently detailed so that the certifier can get a clear picture of the 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 the producer can meet the requirements for organic certification. Producers should use the OSP to explain the practices they use to manage their farms. A thorough, well-thought-out plan that covers every possible contingency is essential, since any deviation from the plan must be approved in writing by the certifying agency before it can be implemented. For example, if there is any chance that an organically approved pesticide will be applied to the crop the grower should include this information in the organic system plan. Valuable time can be lost in seeking approval for plan modifications while in the midst of a pest crisis. As previously mentioned, the initial OSP submitted with the certification application must be updated and approved annually.
Requirements of an Organic System Plan
The organic system plan is the forum through which the grower and certifying agent collaborate to define, on a site-specific basis, how to achieve and document compliance with the requirements of certification. The organic system plan commits the producer to a sequence of practices and procedures resulting in an operation that complies with every applicable provision in the regulations. Accreditation qualifies the certifying agent to attest to whether an organic system plan complies with the organic standard. The organic system plan must be negotiated, enacted, and amended through an informed dialogue between certifying agent and producer or handler, and it must be responsive to the unique characteristics of each operation. An organic system plan must meet the requirements set forth in § 205.201 organic production and handling system plan standard. An organic production or handling system plan must include:
Description of Practices
The first element of the organic system plan requires a narrative or other descriptive format that identifies the practices and procedures to be performed and maintained, including the frequency with which they will be performed. Practices are tangible production and handling techniques, such as the method for applying manure, the mechanical and biological methods used to prepare and combine ingredients and package finished products, and the measures taken to exclude pests from a facility. Procedures are the protocols established for selecting appropriate practices and materials for use in the organic system plan, such as a procedure for locating commercially available, organically produced seed. Procedures reflect the decision-making process used to implement the organic system plan.
The OSP includes a list of each substance to be used as a production input, sometimes called a Materials List. In order to comply with NOP Regulations, producers and handlers must use input materials and substances that are in compliance with the regulations. Both the active ingredients in a substance, as well as any inert or minor ingredients, must fully comply with the NOP regulations to be used in or on organic crops, products, or sites. This requirement encompasses both natural and synthetic materials allowed for use in production and handling operations. For natural materials, which may be used in organic operations under specific restrictions, the organic plan must detail how the application of the materials will comply with those restrictions.
Natural and Approved Synthetic Substances
The NOP regulations allow the use of natural substances unless they are specifically prohibited (for example: strychnine and nicotine are prohibited). Conversely, synthetic substances are prohibited unless they are specifically allowed according to the NOP regulations. Sections 205.601 and 205.602 of the National List contain the list of allowed and prohibited substances for use in organic crop production.
The third element of the organic system plan is a description of the methods used to evaluate its effectiveness. This part of the Organic System Plan is designed to verify that the plan is effectively implemented and monitor the effectiveness of the organic practices to identify areas that need improvement. For example, production objectives could be measured through regular tallies of bushels or pounds of product sold from the farm or in numbers of cases sold from a handling operation.
The fourth element of the organic system plan is a description of the recordkeeping system that must fully disclose all activities in sufficient detail and in a format that can be readily understood, audited, and available for inspection. Section 205.103 of the NOP regulations requires that certified operations maintain records, which can be challenging. Many new applicants are unsure of what documents are needed, and they do not know what an inspector needs to review during inspection. Records must be adapted to the particular commodity that the certified operation is producing. For example, an organic apple grower must keep records pertaining to the processes and facilities involved in the production, handling, and marketing of the organic apples, such as storage and transportation records. Certified operations must make records available for review by the NOP, the applicable State programs governing State official, and the certifying agent during normal business hours (� 205.103(c)).
Organic Crop Producer Records
The records listed below are examples of records that can be used to demonstrate compliance with the recordkeeping requirements in the NOP regulations. Records maintained by the certified farm, ranch, handler or processor to demonstrate compliance with the NOP regulations need to be listed in the organic system plan. Check with your certifying agent to ensure that you are maintaining appropriate records to demonstrate compliance. Other records not listed below may also be useful to verify compliance with the NOP regulations. Please note that this list is only to be used as guidance, and is not a list of all required records.
Seeds and Planting Stock Practice Standard
The general rule requires the use organic seeds (including cover crop seed), annual seedlings and planting stock. However, if an equivalent organic variety is not “commercially available,” then the groer is allowed to use non-organic (untreated and non-GMO) seed, annual seedlings, and planting stock. The grower may determine that organic seed is not “commercially available” based on appropriate form (such as pelleted or non-pelleted), quality, or quantity. Most certifiers require a search of three seed suppliers that carry organic seed to see if organic seed meeting those needs for form, quality, and quantity is available.
Split Production Records
Keep in mind that if an organic farm grows the same crop organically and conventionally, the inspector will need to see all harvest, storage, and sales records for both the organic and conventional crops. This is necessary to verify that no commingling occurs between organic and nonorganic crops. Additionally, the records must show that all equipment was cleaned between uses in organic and nonorganic fields.
Sources for Organic Recordkeeping Materials
There are number of organic recordkeeping materials are available for organic growers. In addition to forms provided by certifiers, National Sustainable Agriculture Information Service�s (ATTRA) Documentation Forms for Organic Crop and Livestock Producers provides a set of documentation forms to help producers of organic crops and livestock record their on-farm practices and production activities.
Management of Split Operations
The fifth element which, must be included in an organic system plan, pertains to split production or handling operations. This provision requires an operation that produces both organic and nonorganic products to describe the management practices and physical barriers established to prevent commingling of organic and nonorganic products during all stages of production, harvest, storage, and transportation.
Regulations do not specify the required width for a buffer zone (See Figure 2.3), 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.
The last element of the organic system plan provides additional information deemed necessary by the certifying agent to evaluate compliance with the regulation. This may include:
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