USDA Accredited Certifying Agents and Evaluation of Substance Use in Organic Production Jessica Morrison Quality Systems Manager Substance Program Manager.

USDA AccreditedCertifying Agents and Evaluation of

Substance Use in Organic Production

Jessica MorrisonQuality Systems ManagerSubstance Program ManagerOrganic Certifiers, Inc., Ventura, CA

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

Scopes of Certification Offered

• NOP – Crop, Livestock, Wildcrop, Handling/Processing

• IFOAM/ISO65 – Crop, Livestock, Wildcrop, Handling/Processing, Smallholder Group

AND

Substance/Brand Name Inputs

Certifying Agents in US

• California – 11• United States – 55• Finding one that’s 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.. ..

You – Certified or Transitioning

• General Misunderstandings– You can’t use synthetics– You can’t use raw manures – You CAN use anything that is “OMRI approved”– You CAN use anything that is “WSDA approved”Or, more importantly…..– You CAN’T use anything that is NOT OMRI or WSDA approved– ………

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

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?

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?

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.)

FARMING PRACTICES

• USDA National Organic Program 7 CFR Part 205

• 205.100 – 205.105 (Applicability)• 205.200 – 205.206 (Organic Production &

Handling Requirements)

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

USDA National Organic Program

USDA National Organic Program

• SUBSTANCE MUST BE INCLUDED IN YOUR OSP.• IF IT DOES NOT APPEAR ON THE ALLOWED

LIST, IT’S PROHIBITED.• IF IT DOES NOT APPEAR ON THE PROHIBITED

LIST, IT’S ALLOWED.

DO NOT MAKE A MISTAKE THAT COULD COST YOUR CERTIFICATION. CALL YOUR CERTIFIER.

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?

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……..

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…..

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?

Fertility / Soil Quality

• What’s 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.

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 it’s required by the certification agent. It’s also why OMRI and WSDA listed products might not be ok for you!

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)

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)

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……

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

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 InghamSoil Foodweb OregonEmail: [email protected]

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

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.

Questions and Answers

• Some Information:• [email protected]• 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

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.

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