USDA Accredited Certifying Agents and Evaluation of Substance Use in Organic Production

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USDA AccreditedCertifying Agents and Evaluation
ofSubstance Use in Organic Production

• Jessica Morrison
• Quality Systems Manager
• Substance Program Manager
• Organic Certifiers, Inc., Ventura, CA

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Organic Certifiers, Inc.

• Accredited California Organic Program 1996
• Accredited USDA April 29, 2002 first round
• Accredited ISO65 / IFOAM September 2005
• MAFF (Japan) TM-11 Recognized
• EU Equivalent under ISO65
• CAAQ Accredited (Quebec)
• Accreditation to Canadian Standards NOW

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Scopes of Certification Offered

• NOP Crop, Livestock, Wildcrop,
  Handling/Processing
• IFOAM/ISO65 Crop, Livestock, Wildcrop,
  Handling/Processing, Smallholder Group
• AND
• Substance/Brand Name Inputs

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Certifying Agents in US

• California 11
• United States 55
• Finding one thats right for you. Make calls, do
  your homework. (www.ams.usda.gov/nop)
• This is going to be a long-term decision.
• Assure you can work well with and get the service
  you want from the certifying agent you choose..
  ..

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You Certified or Transitioning

• General Misunderstandings
• You cant use synthetics
• You cant use raw manures
• You CAN use anything that is OMRI approved
• You CAN use anything that is WSDA approved
• Or, more importantly..
• You CANT use anything that is NOT
• OMRI or WSDA approved

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You Certified or Transitioning

• NOT TRUE
• Each Certifying Agent has its own internal
  policies and protocols for growers. CHECK WITH
  YOUR AGENT!
• Raw manures? Specific Restrictions NOP
  205.203(c)(1)
• Additionally, re raw manure, check with your
  buyers, packers for further food safety
  restrictions

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Other Countries

• Factory Farm Manure / Compost
• Antibiotics / GMO/GE Feedstock
• Further restrictions on substances
• Gib, Lignin Sulfonates (chelating agent), Humic
  Acid, Potassium Bicarbonate, Copper, etc.
• WHERE IS YOUR CROP BOUND?

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Certifier Substance Review

• Is the farmer currently certified?
• Period of growing organically? (transition)
• Are ALL materials intended for use listed in the
  Organic System Plan? (fert, pest, disease, weed)
• Has the farmer provided labels and msds on all
  products intended?

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Certifier Substance Review

• Is the farmer using natural, nonsynthetics not
  previously reviewed by a CB or other agency?
• Chicken/dairy/other manure (composted?)
• Compost recordkeeping
• Organic matter for soil health? (mulch,
  greenwaste, disking weeds, crop residues, etc.)

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USDA National Organic Program

• FARMING PRACTICES
• USDA National Organic Program 7 CFR Part 205
• 205.100 205.105 (Applicability)
• 205.200 205.206 (Organic Production Handling
  Requirements)

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USDA National Organic Program

• The National List of Allowed and Prohibited
  Materials
• 205.600 Evaluation Criteria for allowed and
  prohibited substances, methods ingredients
• 205.601 Synthetics Allowed
• 205.602 Prohibited Nonsynthetics

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USDA National Organic Program

• SUBSTANCE MUST BE INCLUDED IN YOUR OSP.
• IF IT DOES NOT APPEAR ON THE ALLOWED LIST, ITS
  PROHIBITED.
• IF IT DOES NOT APPEAR ON THE PROHIBITED LIST,
  ITS ALLOWED.
• DO NOT MAKE A MISTAKE THAT COULD COST YOUR
  CERTIFICATION. CALL YOUR CERTIFIER.

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Review Programs

• Organic Materials Review Institute (OMRI)
• Washington State Dept. of Agriculture
• Organic Certifiers, Inc.
• others
• Letter from the NOP regarding 3rd party reviews
  may be accepted by other certifying agents. What
  does it mean?

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Organic System Plan

• Critical to the business of organic farming and
  eligibility
• Must contain a description of all practices to
• Enhance fertility / organic materials
• Prevent weeds
• Prevent disease
• Prevent pests
• MORE IMPORTANTLY..

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Organic System Plan

• The OSP (Organic System Plan) MUST under
• NOP Section 205.201(a)(2)
• Contain a list of each substance to be used as a
  production or handling input, indicating its
  composition, its source, location(s) where it
  will be used, and documentation of commercial
  availability, as applicable..

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Crop Production Materials

• The certifying agent verifies practices for
  fertility, weed control, pest control, disease
  control.
• THEN
• Assesses proposed materials intended for use
  against practices and applicability for use.
• Products must be used in the manner intended?
  Are there creative uses? Are they allowed give
  the SPECIFIC SITUATION?

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Fertility / Soil Quality

• Whats the status of your soil? Regular Soil
  Testing? Petiole Testing?
• Known results can help a farmer improve soil
  quality to aid uptake of readily available
  nutrients and save money
• Organic materials (mulch, compost, manure, mined
  substances i.e., gypsum)
• Innoculants
• Emulsions, compost teas, etc.

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Fertility / Soil Quality

• Micronutrients RESTRICTED FOR USE ONLY WITH A
  DOCUMENTED SOIL DEFICIENCY (NOP 205.601(j)(5) and
  (j)(6)
• Magnesium Sulfate, Soluble Boron, Sulfates,
  carbonates, oxides or silicates of zinc, copper,
  iron, manganese, molybdenum, selenium cobalt.
• This is why regular soil testing is not only
  recommended, in some instances its required by
  the certification agent. Its also why OMRI and
  WSDA listed products might not be ok for you!

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Pest/Disease/Weed Control

• USDA NOP Section 205.206
• Crop Pest Weed and Disease Management
• Rotation, soil crop nutrient management
• Sanitation (remove disease, weed seeds, habitat)
• Cultural Practices to promote health, selection
  of plant species (site specific)

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Pest/Disease/Weed Control

• Pests may be controlled first through mechanical
  or physical methods (205.206(b))
• IPM (predators, parasites)
• Nonsynthetic controls such as lures, traps
  repellents
• Weeds may be controlled by first trying mulching
  (biodegradable materials), mowing, grazing, hand
  weeding, flame/heat or plastic (no pvc, no
  plowing)

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Pest/Disease/Weed Control

• Disease may be controlled by first trying
  management practices to suppress the spread of
  disease, applications of nonsynthetic biologics,
  botanicals, minerals
• ONLY THEN

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Pest/Disease/Weed Control

• NOP 205.206(e) states When practices provided
  for in paragraphs a-d are insufficient to prevent
  or control (pest,weed,disease), then a biological
  or botanical substance OR a substance included in
  the National List may be applied. PROVIDED that
  the conditions for using these substances are
  documented in the Organic System Plan

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Petiole and Soil Testing

• Timing is everything
• Sustainable and organic farmers see NPK and other
  nutrients as part of a bigger whole and attempt
  to balance fertilization with soil amending and
  correct biology.
• Place to start
• Dr. Elaine Ingham
• Soil Foodweb OregonEmail info_at_oregonfoodweb.com
  

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Soil Testing

• Texas Plant Soils Lab Co2 vs CEC extraction
• Find a good lab which provides accurate tests of
  soil as it is in the ground at your operation,
  not heat treated or otherwise altered.
• http//www.txplant-soillab.com
• Some use a Carbon Dioxide (CO2) extraction while
  other use automated systems such as C.E.C.
  percent base saturations

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Importance of testing properly

• An analysis should include other tests which
  affect nutrient uptake, such as soil texture,
  humus content, nitrates, free carbonates, total
  salts, amount of soluble salt cations. These
  tests are important for making the most accurate
  soil fertilizer recommendations possible. The
  Co2 extraction mimics the natural action of the
  plant roots. Available Potash - Magnesium -
  Calcium, especially soluble Calcium are
  determined.

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Questions and Answers

• Some Information
• jessica_at_organiccertifiers.com
• www.ncat.org
• www.cdfa.org
• www.ams.usda.gov/nop
• www.organiccertifiers.com
• www.ccof.com / www.qai-inc.com
• www.omri.org / www.wsda.gov

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Substance Review Programs

• Like OMRI / WSDA -- not regulated/NOP Accredited
• OC is the only company in US accredited to review
  and certify substances under our ISO65/IFOAM
  Accreditation.

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Process for Approval/Certification

• Application from manufacturer
• Product information, composition disclosure
• CONFIDENTIALITY AGREEMENT
• Rigorous inspection and onsite audit prior to
  approval
• Ingredient source verification/process validation
• Annual update required, annual inspection