“There are a lot of rumors circulating about how difficult organic certification is,” says Garth Kahl, “especially if I put myself in the shoes of a farmer who is new to the process."
Garth Kahl is a certified organic farmer and an independent organic inspector, inspecting crop, livestock and handling entities for compliance with the US Department of Agriculture (USDA) National Organic Program (NOP). He and I are spending the afternoon casually discussing organic food production. Involved in the organic industry for more than three decades, Garth started out as an organic farmer himself and continues to this day. When he’s not inspecting farms in Belize, Mexico or rural land stateside, Garth can be found on his own organic pasture in Southern Oregon.
We narrow in on the topic of organic inspections. The onsite inspection, an in-person visit to an organic operation, provides consumers with a critical link in the organic food chain by validating the integrity of any product that carries the USDA Organic seal. The USDA NOP Code of Federal Regulations (CFR), the rule governing distribution of the USDA Organic Seal to certified operations, requires that each production unit, facility or site that produces or handles organic products receive an annual onsite inspection. This inspection is used to determine if the organic certification of an operation should be granted or continue, based on proof of a producer’s compliance with USDA organic regulations.
“I see a lot of angst around certification and inspections,” explains Garth. “Specifically, people are concerned with recordkeeping,” he says. Recordkeeping can be a common pitfall for producers when it comes to maintaining organic certification. The NOP CFR requires that certified organic operations maintain records concerning production, harvesting, and handling of products sold, labeled or represented as organic. Records should be sufficient enough to demonstrate compliance with organic production requirements.
Garth proceeds to offer practical tips for operations when preparing for an organic inspection throughout the year.
#1 Your records should reflect organic integrity.
“The litmus test when it comes to recordkeeping," says Garth, "is, 'does it affect organic integrity?'" Records should validate the organic integrity of the operation. For example, a dairy operation needs appropriate feed records for organic alfalfa fed to cows. A processing facility claiming an organic cupcake mix Is 95% organic needs batch records to demonstrate the ingredient formulation. “An operation that is missing records so vital to the organic production process are big factors affecting our ability to verify organic integrity” says Garth.
#2: Your organic records should be doing double or triple duty.
Your recordkeeping system shouldn’t solely benefit your organic certification – it should also make your operation more efficient. “What I often tell people," says Garth, "is the type of recordkeeping that you need to keep for organic certification is the type of recordkeeping that you should already be keeping if you’re running a successful business. Really, there should not be duplication.”
An organic record can be helpful in making business, financial, marketing and/or tax decisions for your operation. Records, such as purchasing receipts, provide a good example of this. Purchasing receipts can help a producer when it comes to preparing end of year taxes, creating a marketing strategy or figuring out which enterprises in your farm are making money or which ones are losing money. “If you address your records with this mindset,” says Garth, “then it’s not an undue burden because it’s really something that you should be doing anyway."
#3: You should work with the record keeping process you're comfortable using, whether a desktop blotter calendar or your mobile phone.
“Some of the best organic records I’ve ever seen were kept by an older Mennonite grower in Oregon," recalls Garth. “Every night after work, he would sit down on the couch and on a paper calendar, in tiny little block lettering, he would write out what he had done that day on his farm,” says Garth. The detailed records in the farmer's logbook included application records, seed purchases and documented seed searches. The entire set of records sat next to his couch. “It was incredibly complete,” exclaims Garth, “and there’s no reason why a spiral notebook or Rite in the Rain® notebook from a farmer’s pocket or on the tractor cannot be very complete records." A key stipulation is that an operation must be able to present this sufficient information to an inspector when requested, during a planned or a surprise organic inspection.
#4: You, the organic farmer, should record anything applied to your ground that is not normally there.
Consider cows on pasture, for example. “If you let your cows graze and they apply manure to your fields naturally through the process of grazing, that does not require a manure application record,” Garth tells us. “However, if you take a manure spreader and spread manure onto your fields, then that activity should have a corresponding record,” he explains. Any activity resulting in an input added to the field should have a record or a document that it happened.
Maintaining a record of manure spreading is also a good example of a useful farm management principle. “This is the sort of thing I would want to know as an owner of a farm operation," says Garth. A record of manure application on a field will help document the quantity of what is being applied to each field. An operation can use this data in combination with other data to determine if the ground is providing a yield response. “If I’m dumping a bunch of manure on a field and I’m not seeing any big yield response,” says Garth, “then maybe it’s time to re-sow that field, or maybe it’s time to put in some drainage or improve the irrigation. If I’m putting a bunch of nitrogen on it and it is not giving me significant yield, then I’m basically throwing money at that field for no reason." Useful and well-documented records can help identify where these production gaps are or where there are areas for improvement.
#5: You should keep your receipts.
A common misstep at an organic inspection is the failure of an operation to have receipts. “These are the kinds of things that you would expect to have available if you’re going to fill out your Schedule F IRS Form at the end of the year,” explains Garth. “You would need to have receipts. We certainly do, and we’re a smaller operation." Receipts for things such as lime, feed, seeds, product ingredient purchases, are all examples of the types of receipts that are used to verify organic integrity.
“Recordkeeping is the biggest perceived barrier in organic inspections,” says Garth. However, with careful attention and logical management, an operation can ensure that time spent in managing information is useful, non-duplicative and valuable for continuing organic inspection. This can allow operations to get out and do what they are most passionate about – producing valuable organic supply for the industry as a whole.