Organic Inspections

Winter 2016-2017

By Jacomijn Schravesande-Gardei, MOFGA Certification Services LLC

In order to sell, label or represent products as organic in the United States, farming and processing operations must be certified. MOFGA Certification Services (MCS) is accredited by the USDA to certify and inspect organic operations. The MOFGA Certification label assures consumers that products have been produced with approved methods and that prohibited substances, such as almost all synthetic pesticides, have not been used.

How Does the Certification Process Work?

First, an operation submits to MCS its annual paperwork. This is reviewed in the MCS office to verify that practices comply with USDA organic regulations. A reviewer might then have some questions for the producer, or for the inspector to ask the producer.

Once the review is done, the farm or processing operation is ready for inspection. Every organic operation must be inspected each year.

MCS works with a core group of contract and employee inspectors. Scheduling inspections can be a puzzle. We always prioritize new applicants. We assign batches of inspection folders to inspectors based on geography (Could an inspector do two inspections a day without having to drive far?), inspectors’ expertise (those without dairy farm experience, for example, are not asked to inspect dairy farms), inspectors’ availability, and so on. Since MCS certifies about 500 clients using about nine inspectors, doing all inspections during the growing season can sometimes be a challenge.

The inspector’s job is to verify that the operation’s written plan accurately reflects the operation on the ground and that the farmer is following the plan. Many of our inspectors are trained by the International Organic Inspectors Association (IOIA), the professional organization of organic inspectors. Its rigorous training teaches inspectors to look critically at all aspects of an operation. Inspectors are important to MCS because they are typically the only people on site annually to verify organic practices.

What Happens at an Organic Inspection?

When I do an inspection, I usually call the producer a couple of weeks beforehand to set up a mutually agreed upon time for the visit. (However, per federal requirement, 5 percent of our inspections are done unannounced.) I call the producers again the day before to confirm the inspection and to ask them to get their records ready. When I do an organic farm inspection, I usually like to see the fields first so that I understand the farm operation before I see the farm records. Also, most farmers are more comfortable in the fields than with records, so this is a good way to break the ice.

I get the maps and field histories (which record the planned management practices for each field) from my inspection folder. The MCS office provides the inspection folder and includes the farm’s annual update, maps, and previous years’ letters and inspection report. I ensure that the information provided corresponds with reality. I also look for such things as buffer zones from neighboring farms. I ask many questions about pest management, soil fertility and other factors. I also look at input storage, equipment, preparation areas, etc., to make sure everything meets the organic requirements. During the field inspection I take notes to compare later against production plans and field records. I also note soil conditions, plant growth, signs of insect damage, and weed pressure.

When farmers have questions, I am allowed to explain the organic regulations but am not allowed to provide advice on how to farm or how to overcome any barriers to certification. This separation between farmer and certifier maintains the independent, third-party nature of the inspection.

When I am satisfied that I have seen everything outside, I ask to see records – usually inside on the kitchen table. I start completing the inspection form on my laptop while asking for records showing that the farmer sourced and searched for organic seeds. I ask to see planting records, lists of inputs, invoices, sales and production records, etc., and work on an audit trail and mass balance. Checking mass balance means ensuring that the amount of material that came into the system balances with the amount that left the system; e.g., the amount of carrots sold matches the amount planted. People often say that organic certification involves a lot of recordkeeping. That is true, but many of these records are needed for tax purposes anyhow. Our certified farmers often tell us that because of our recordkeeping requirements, they became better farmers, as they use the records in their farm management.

When I am finished looking at the records, I usually ask if the farmer has any questions for me, and I make sure that I have an answer for all the questions that came from the initial review done in the office. Then I ask for a couple of minutes to organize my thoughts and to make sure I have everything I need. After that I do an exit interview in which I summarize my findings. I record this summary on a sheet of paper and have the farmer sign it.

Then I jump back into my car to write up the inspection report, which describes my observations and findings. I submit the report to MCS, which reviews it. As long as no issues arise and the operation complies with the organic regulations, the producer will receive a copy of the report and a letter saying the producer is certified. The letter typically lists suggestions for improvement. If serious concerns exist, an operation receives a noncompliance notice.

A typical inspection can last about two hours for simple farms, such as a blueberry operation, to two days for complicated processors or dairy operations. Every organic farm, packing facility, processor and distributor involved between farm and market is inspected each year to verify compliance with USDA National Organic Program regulations.

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