Written by Rob Wallbridge
Editor’s note: Rob is great to talk with on Twitter, always opening our minds to new possibilities and challenging all of us (organic, conventional, and otherwise!) to rethink our stances and choose the best information possible. When he tweeted that his organic farm was being inspected, I asked him to share with us what the process was like and what it means for his farm. I’m so glad he did. This is a great glimpse into what USDA organic certification really means. Enjoy! -Anastasia
Today was our farm’s annual organic inspection. An inspector had called a couple of weeks ago to set up the appointment while she was in the area. I spent a few hours last night trying to make sure that all the necessary files and documents were updated. Having worked as an inspector and having helped dozens of farmers through the certification process, I was pretty confident in my preparations but still a bit anxious. I’d never met this particular inspector before, and although the procedure itself is relatively standardized, each person brings their own perspective and particular focus to the job. For this reason (and others), certification bodies tend to assign different inspectors to each farm over a period of time. This would be the 4th new inspector to visit my farm over the course of the past 10 years – I’ve had the same inspector for the past two years, and once before that, so I’d become accustomed to her style. This is going to shake things up a bit – which is undoubtedly a good thing. Here’s how it went…
I meet her in the driveway as she climbs out of her car. After saying hi and asking about the drive, I ask, “where would you like to start?” Some inspectors like to get the paperwork out of the way first, but I always liked the context of having seen the real thing before the records.
“I always like to start in the fields,” she replies. “Do you have a map? I’d like to orient myself.”
I pull a field map out of my records binder and show her where we’re standing in relation to the diagram on the paper, as well as which fields are growing which crops. “OK, I need to see here, here, and here,” she says, pointing to the areas on the map where my farm borders neighboring properties, as well as a drainage ditch that runs along the back of our cleared land. With a little over 30 acres to cover, we strike off on foot – most farms require driving to reach all the land to be inspected. Along the way, we chat about the weather, the challenges of dealing with excessive rainfall, how things are growing, my cover crop plans, pest problems, marketing and more. It’s small talk, but it’s also her way of assessing my knowledge and what she should expect to see when she looks at the crops. As we pass the fields where things are growing, she makes notes – they’ll be compared against my production plans and field records once we’re back inside. She notes the soil conditions, plant growth, a few signs of insect damage on some cabbage and kale, and comments that a lot of farmers have been complaining about the weed pressure this year. I think it’s her roundabout way of asking “do you normally have this many weeds?”
As we pass an overgrown area that I’ve let go fallow due to its poor-quality, erosion-prone soils, I’m a little apologetic: “I keep thinking I should just plant this back to trees,” I comment. “It’s doing a good job feeding the bees,” she observes, nodding towards the nearby hives. Later, she’ll note “biodiversity” as one of the strong features of the farm. She’s pleased with our buffer zones, too – with forest behind us, a beef farmer’s hay field to one side, and an abandoned farm on the other side, we’re at a very low risk of contamination from prohibited substances! On many farms, buffer zones would need to be measured out, other mitigation measures discussed, and the records for dispersal of any crop harvested from buffer zones would need to be reviewed – we’ve got it easy.
Things get a bit more serious as we circle back to the buildings and enter the greenhouse. After the hubbub of spring planting, it’s mostly empty now, but I’ve still got some transplant mix, soil amendments, and seeds for fall planting stored there. There’s also an unplugged refrigerator in the corner, crammed full of leftover vegetable seeds, cover crop seeds, soil amendments, and pest control products. Some of it is a couple of years old – the result of “just in case” purchases or experimental trials that didn’t pan out. No matter – all of it is checked and added to her list. While I try to make everything fit back into the rodent-proof storage, she notes a cupboard nailed to the back wall over a table creaking under the weight of accumulated odds and ends: “I’m just going to check this out,” she calls over her shoulder as she marches towards it. “Go ahead,” I reply, cringing a little. “Sorry about the mess – it’s mostly irrigation parts and supplies.” It’s days like this I wish I were a tidier, more organized farmer – there are no secrets from the organic inspector!
Having satisfied herself that she’d seen all there was to see outside, we head inside to the dining room table covered with files, binders, and envelopes. We each fire up our laptops, and she starts asking questions. I’d filled out a questionnaire in March wherein I detailed the crops I expected to grow, where I was growing them, which inputs I had planned for use, and more. Of course, nothing in farming works out quite according to plan, so I’ve already revised those records and printed out new copies for the certification body’s files. She checks over these documents, compares them against the notes she’s made in the fields, and verifies a few more details.
Next, it’s the list of inputs – seeds, fertilizers, mulches, pest control – both what I said I was going to use, and what she’s found on-site. I hand over a stack of invoices from a file I’ve been compiling – I try to copy everything as it comes in – the theory is that I don’t need to search through 3 months of receipts to find it later, and I’m not out of luck if an inspector happens to visit while my files are at the bookkeepers (unannounced inspections are also part of the certification process).
“Where’s the invoice for your transplant mix?” she asks after a few minutes.
“Hmmm…should have been there…maybe forgot to copy it…” I mumble as I leaf through the file. It’s nowhere to be found, so I dig into the accounting files, and produce it a few minutes later. The best laid plans…
Soon there’s another issue: “The receipt from the farmer who sold you seed potatoes doesn’t provide proof of their organic certification,” she states. I get on the phone and leave a message asking him to fax me a copy of his organic certificate, but it’s mid-morning, and I’m not optimistic: if I don’t get it in the next hour or so, it will be noted as a non-compliance on the inspection report, and I’ll have to follow-up with the certification body before they’ll issue my organic certificate. Luck is on my side: the fax machine rings a few minutes later and grinds out the potato grower’s organic certificate.
Next, I’m asked to provide justification for the soil amendments I’ve applied this spring, and proof that they’ve come from organically-approved sources. The supplier invoice simply notes “custom fertilizer blend approved for organic use” but doesn’t provide more detail. I reach into my “soil management” file and pull out the soil test analysis and recommendations from an agricultural consultant, as well as a printed copy of my email correspondence with an agronomist from the fertilizer supplier.
Then we’re on to sales and production records. This part I like – for all of my disorganization outside, I’ve managed to create a pretty tidy system of record-keeping on my computer. The inspector reviews sales records from the previous year’s farmers’ markets and wholesale accounts, making sure that the products I’ve sold and their volumes match what was planted. It’s a relatively simple matter on large-scale farms producing a limited variety of crop or livestock products, but more of a challenge for a diversified fresh vegetable operation like ours. But by looking at the crops planted, she can predict a pattern to my sales income, and then verify that against my monthly sales records.
Next she audits two specific crops: she randomly picks garlic and strawberries, and asks me for all the records pertaining to their production and marketing. Using the search option in my Outlook Calendar, I pull up my daily records showing when each crop was planted, weeded, fertilized, irrigated, and harvested. Then I flip over to my sales spreadsheets and show when and where each harvest was sold. It would be impressive, except it doesn’t look like I recorded when I planted the strawberries in the spring of 2011… I do know that they were planted a day or two after the plants were delivered, so I look up that invoice, and we’re able to verify that although they were not organic plants (none are commercially available), they were planted well over 12 months before they were harvested, which makes my 2012 harvest eligible for organic certification.
It’s now approaching the 3-hour mark, but the inspector seems satisfied. She asks me if I have questions for her, or if I think there’s something she’s overlooked. I glance at the chaos of files and papers strewn around me and admit that I think we’ve just about covered everything. Then she remembers to ask me for the bacteriological analysis of the water I use to wash vegetables, and I delve into another file to retrieve a copy of that. Finally, she hands me a sheet of paper that summarizes her findings and observations. Thankfully, we’ve been able to resolve all the issues as they arose, and the final comments are all positive. I gladly sign it, she hands me a copy, and jumps back in her car, off to repeat the process at another farm.
My head is spinning a bit, but I’m pleased – I’m over that hurdle. The inspector’s report will now go back to the certification body, where a committee will review my complete file and the inspection report, before making a decision on how to issue certification. They can issue a certificate outright, make certification pending the resolution of certain issues, or cancel it altogether. Knowing that my initial application didn’t generate any concerns and that the inspector didn’t identify any deficiencies, I have good reason to be optimistic. I’ll know for sure in a few weeks!
Written by Guest Expert
Rob Wallbridge is an organic farmer in Western Quebec, Canada. He is also a father, extensionist, writer, speaker, and rabble-rouser. He advocates for high-quality organic food and informed communities in agriculture and beyond.
The process of organic farm inspection seems very mysterious – it’s so nice to have a full picture of what it means. Thank you so much, Rob, for taking the time to write this for us!
Better hide those containers of Roundup/glyphosate herbicide. Lots of organic farmers are complaining it doesn’t work as well as it used to. Superweeds will stop your certification!
Thanks for walking through the process. I really didn’t know what all the annual inspections include, just know that they are reason to search files and get info together. Congrats on a favorable first step.
Oh sarcasm… Although I hear some organic farmers have been hitting the antibiotics hard for orchards:
In almost 20 years of experience, the only comment I’ve heard from an organic farmer regarding the use of glyphosate on their farm was a tongue-in-cheek complaint from a woman who complained she could no longer use it to control weeds on the stone walkway in front of her house. (I suggested that a heavy dose of white vinegar would accomplish the task.)
However, if you do have a valid complaint about a violation of the organic standards, the procedures and policies are outlined here:
By the way, my answer to “Superweeds” is the “Super A” in the photo above!
It’s nice being a farmer who has all his options open and who doesn’t have to worry about “inspectors” crawling around his place. If it works, I use it.
I’ve worked on an organic farm, and I attended workshops on organic orcharding, and the whole thing strikes me as rather asinine. Do I spray for apple borer, or watch the trees get infested and then try to dig the larvae out with a pocket knife and wire? That’s a no-brainer. I spray because I care.
The fact is, if the organic propaganda machine hadn’t convinced a sizable portion of the public that “conventional” farmers are “poisoning us and our children,” there would be little market for it.
Glyphosate works just fine on the weeds along my stone walls.
Thanks for this Rob. I have been through a few of these myself and you captured the process and emotions very well. During one of my inspections I too had to have somebody get a document to me right away (it was a Bill of Lading I couldn’t locate a copy of)!
My impression has been that the inspectors are pretty rigorous and even though there’s no way they can audit everything it is this “pick something at random and show me the details approach” that lets them know if you have your act together. I actually appreciate it when they go into these details and can see that we are doing things well.
The comments you made about biodiversity and having good buffers is one I don’t think most people appreciate about organic system plans. The law requires us to describe how an organic farm is going to make space for non-cultivated species. It is interesting to look at the roadsides and ditches on my farm compared to my neighbors, who all tend to spray field edges.
Hi Rob. I’ll continue from where we left off on Twitter. I had asked you if you felt this was worth the effort, and you asked me to clarify. What I was thinking was that this obviously is a pretty rigorous process (Thanks for describing it; I’ve not seen anything like this before). I realize most, if not all, farming operations go through some level of certification/inspection at some point, but this is very encompassing of the whole operation. It would appear that you invest a non-trivial amount of time, money, equipment, and personal anxiety into achieving this. I assume there must be an economic payoff. Are there other advantages to certification? After all, if it were just personal conviction, you could just follow the methodology without bothering with the certification, bookkeeping, inspections and bureaucratic hassles while still meeting your personal satisfaction.
I have a lot of other questions, but I’ll stop with an additional thought that had occurred to me. Most of the GM Label laws we’ve seen include clauses requiring maintaining records determining sources of non-GM materials, which many producers and retailers find burdensome. Given that the laws are typically heavily conceived and promoted by organic producers/retailers, I was thinking that this might be part of the disconnect: The organic community is used to this type of regulation, while the conventional side is less so. Just a thought.
Thanks again for the insights 🙂
Hi Bill (now I don’t have to think of you as “pdiff” any more!). Thanks for the insightful comment. Obviously, organic certification and the associated paperwork and oversight isn’t for everyone. For me, there are a few advantages which, in my mind, outweigh the costs.
Firstly, there is an economic payoff: being certified organic allows me to earn a premium for my product that does offset the cost of certification. Being certified also gives me access to markets that non-certified “organic” growers and conventional growers cannot access. It also gives my customers an added degree of confidence, knowing that I’m held to a specific set of standards, and not just what I’ve personally decided is “organic” for me.
Secondly, the level of record-keeping involved gives me tools and information I can use to manage my farm more efficiently and more profitably. Being “forced” to keep records lets me do a better job tracking my cost of production, my returns on labour, my yields, and which of the crops I grow are most profitable, just to give a few examples. It also gives me lots of information to aid in planning from year to year.
Thirdly, although I grouse a bit in the post above about the anxiety and discomfort of having an inspector poking around, I do actually appreciate having another “set of eyes” on my farm: seeing things through someone else’s eyes, and having someone who’s been on a wide variety of farms asking questions about my operation gives me fresh perspective and new ideas about how I’m doing things. Again, it helps me be a better farmer.
Your final comment about the labeling law disconnect is an interesting one. I do know that the level of paperwork and regulation is increasing for all farmers, particularly as food safety and quality assurance programs spread across various sectors. In Canada, the dairy industry has implemented a quality assurance program that had many farmers quite upset about the level of record-keeping required, but it’s still generally less than is required for organic certification. My perspective is that these types of requirements are not going to go away, and the farmers who harness the information they’re collecting to improve their business management will come out ahead.
Feel free to ask more questions anytime!
What,if anything, would you do differently if you didn’t have to worry about certification?
I suppose the bureaucratic hassle/tolerance is a balance. I asked because I’ve seen people and consumers locally here turn away from “Organic” at times in favor of “locally produced”. This could obviously overlap Organic, but is not stringently regulated. Specifically, I am thinking of several up and coming chefs and their restaurants along a corridor we call the Inland Empire (basically a swath running from Boise to Spokane). Initially, they were all about Organic as a practice and selling point, but eventually found the USDA Organic designation really had little meaning for what they wanted, cost more, and was hard to verify/trust. More importantly, they found that customers responded much better to “local” food, which they could sell as fresh, community based, etc. Some of their producers responded and new ones came into their markets sans the O certification. I’m curious if you think you might be tempted to back away from certification if sufficient economic incentive/dis-incentive came along and you could still maintain your own peace of mind with what you were doing on the farm (This, of course, is ignoring the other factors you mention above, re: record keeping, other “eyes” etc).
What do you think about recent events where a survey has indicated up to 70% of Washington State’s organic apple producers may drop out of the O market because of the NOP’s decision to forbid the use of anti-biotics for fire blight control? Can you envision a point where the regulations become unworkable for you or do you feel like you have enough control/input into the regulation process to prevent that from happening?
Thanks for you patience in answering 🙂 I’m getting a much better insight here.
Bill, can you point me to the apple growers survey you mentioned?
It came across on twitter the other day:
Direct link (the tweet is mangled): http://www.scoop.it/t/mpmi/p/4005090906/news-concern-grows-over-fire-blight-treatment-options-among-organic-producers-after-oxytetracyclin-antibiotic-ban-2013
“the level of record-keeping involved gives me tools and information I can use to manage my farm more efficiently and more profitably”
Interesting that you put it that way. All of the conventional farmers I know keep records that probably aren’t much different from what you need for the organic certification. If they didn’t, they probably wouldn’t stay in business very long. They might grouse about the idea of being forced to keep records, but it probably wouldn’t be much different from what they already do.
What that means for GM labeling, I don’t know. Farmers keeping meticulous track of which parts of their fields need more nitrogen and how much yield they got from different seed varieties doesn’t have anything to do with what happens to the grain once it gets to the silo.
Yes, I’d agree that documentation for producers would not be as much of an issue, but was more thinking of smaller processors that we typically see at farmers markets etc. They most likely must already document (and perhaps pass inspection for) safety purposes, but they probably don’t watch every small ingredient source they use, e.g. sugar or spices, etc. How such thing would work with products like honey, where bees forage freely over several miles, I can’t even imagine 🙂
Thanks for all the comments – I’m just getting back to a real keyboard after a few days on the road.
I’m quite committed to the certified organic label as a reasonable way of verifying a pretty comprehensive set of principles. There’s always room for improvement, but I’ve yet to see anything better. “Local”, of course, designates nothing but a relatively undefined notion of proximity. Which, if interpreted correctly, has value in terms of freshness and community, but really says nothing about how the food was grown, unless one subscribes to some kind of xenophobic fallacy that “undesirable” practices only occur somewhere else far, far away. The ability for a buyer to build a relationship with a local producer may create the opportunity for a type of “personal verification,” but it’s hard to compare that with an inspection by a trained professional. I know that the “USDA Organic” label has come under fire, but to ascribe its shortcomings to everyone operation under its jurisdiction hardly seems logical or fair. (It’s a bit like believing that if my neighbor gets stopped for speeding, my whole community is full of speeders.)
I guess the bottom line is that for me, certification offers a solid foundation for a relationship with my customers that I can build upon using whatever other tools/strategies I wish to employ.
Yes, this issue has been hugely controversial within the organic community. I’ve heard excellent arguments from both sides, and I don’t feel that I have the expertise to pass judgement one way or the other (though right now I’m inclined to support the ban). I will say that what producers say they’ll do right now, when the change is fresh and the lobbying is intense, and what they’ll actually do when the rubber hits the road, could be very different things.
Having worked both as an inspector and as an advisor to farmers seeking certification for almost 15 years now, I’ve yet to meet a farmer whose conventional record-keeping system was adequate for organic certification purposes. The younger generation and those who have adopted electronic systems are much better-positioned, but as you hint at, Anastasia, most conventional farmers are used to a commodity marketing system, so going beyond field production records is a new concept.
That’s not the case for everyone, of course – there are well-established “identity-preserved” (IP) markets for some products. I’m most familiar with the export market for IP soybeans destined for Japan (also non-GMO, of course); there are well-defined standards and protocols in place.
Organic certification also covers small processors: depending on how they want to label their products, they must address the source for every small ingredient they use (including, for example, the vitamins added to milk and the cultures added to cheese). (FYI, Bill, there are also standards for organic honey that address their foraging behaviour.)
I don’t want to turn this into a debate over labeling, but from my perspective, we do need to keep in mind that we aren’t re-inventing the wheel. The biggest problem is that our bulk commodity system is not set up to handle any type of segregation. As I’ve argued before, the most realistic outcome of any labeling regulation would be a “may contain” label on practically every processed food item, along with new opportunities for small to mid-sized handlers and processors to fill a niche demand for products that could meet the labeling standards. Speaking strictly from a self-interested perspective, I as an organic producer should probably oppose GMO-labeling, as it is just as likely to further fragment the “non-mainstream” market as it is to steal market share from the big guys.
Great question! In terms of growing practices, I wouldn’t change anything. I’d save the few hours of time I spend preparing for the inspection and having it take place, and there would be fewer copies of various records and invoices floating around, but that’s really about it.
Yeah, sorry to diverge into the label issue. I think you are correct on the “may contain” outcome, though. Thanks again for the thoughtful replies 🙂 . The internet seems to be short on those .
Rob: I understand that you pulled out the soil test analysis for your inspector. But when did you pull out the pesticide-residue analysis to verify that you’re not using prohibited pesticides?
Well, Mischa, the field tour pretty much verified that, better than any test could! 🙂
Seriously, however, I did enquire once about having my soil (and water) tested for pesticides. The water lab guy laughed and told me I couldn’t come close to being able to afford it. Basic wide-spectrum detection tests for soils (which would be insufficient to determine the exact substance or level of contamination) would cost me hundreds of dollars. In the absence of any suspicion of fraud, and given the broad range principles and practices covered in the scope of certification, I fail to see any justification for routine residue testing on all farms.
A broad-spectrum pesticide residue test costs just $100. You paid 10-times that for your audit-based inspection, plus you had to spend all that time keeping meticulous records throughout the year.
I organized the first “Sample Collection and Testing Seminar” for the International Organic Inspectors Association. If the lab guy you spoke to laughed at you, how does he stay in business?
As I’ve stated, I keep meticulous records so I’m a better farmer, not just to satisfy audit requirements.
Please tell us the date of the seminar you organized, provide a current link to an accredited lab offering a broad-spectrum pesticide analysis for $100, and explain how such a test would distinguish between incidental, environmental contamination and deliberate application of a prohibited substance. Thank you.
The seminar I organized was for the International Organic Inspectors Association (IOIA), through Enviro-Test Labs out of Winnipeg. It was called “Field Sampling for Pesticide Residue,” and was held in Moose Jaw SK in the Spring of 2003.
For accredited Canadian labs I recommend Saskatchewan Research Council Analytical Labs or Bodycote Testing Group.
As for distinguishing between “incidental, environmental contamination” – referred to as spray drift – and “and deliberate application of a prohibited substance” – referred to as fraud – I have performed numerous tests on organic farms over the years and have never detected ANY prohibited residues. None! So the whole argument about spray drifting onto organic farms turns out to be false. I’d be happy to share some of my results with you.
What this means is that if a prohibited pesticide is detected in an organic crop, it forms the basis for a necessary investigation into possible fraud. Something to think about after the CBC reported that a whopping 40% of the certified-organic food sold in Canada is contaminated with prohibited pesticide residue.
Sadly, there is no field testing of organic crops in Canada.
So if no one does any testing in Canada, why were you asked to organize a seminar on the topic? The truth is that field testing does occur, when fraud is suspected.
Secondly, your testing and your claims with regard to the results of that testing does not constitute a valid data set. The CBC report was based on data from the Canadian Food Inspection Agency, and officials with that government agency clearly explained the difference between pesticide residues that would be considered incidental (from a variety of sources, not limited to fields) and that which would be considered possible fraud. The distinction was very clear.
With all due respect, Mischa, I’ll choose to believe the scientists and the government body responsible for overseeing these things.
There is no field testing in the Canadian or American organic sector. When fraud is suspected, end-product (post-harvest) testing is sometimes done. But there is no testing in the field when prohibited substances are still detectable. If I am wrong, please show a list of lab results from organic farms that were tested by USDA or CFIA-accredited organic certifying agencies.
thank you very much for taking us through the whole process. the article is very eye opening
This is a very informative blog. i hope that all researchers can display such information for the benefit of the society
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