Is Organic Certification Right For Your Operation?

Consumer interest in organic food continues to increase, making organic farming a growing opportunity for many Pennsylvania farmers. But what exactly does organic certification mean and is it worth the effort to become certified? If it is, how do you get started? This article will break down the federal certification process and help you evaluate whether organic production is right for your farm or business. 

Deciding whether or not to be certified 

Organic certification requires additional attention to record-keeping, regulations, and details that may be absent from non-certified operations. Therefore, it is important to evaluate if certifying a farm or business is right for you.

Some farms follow organic practices but forgo certification because their market does not require it, or they do not want the extra burden of record-keeping and certification costs. Others might become certified because the market they sell to requires it. It is also possible to have "split-operations" where some areas of the farm are certified, and others are not, but these operations require extra attention to prevent contamination of organic crops or livestock by non-allowed substances. A few exceptions exist for who must be certified, including farms and businesses who gross less than $5,000 in organic sales per year.

Summarizing the benefits and challenges of organic farming

What is organic certification?

Organic certification allows a farm or processing facility to sell, label, and represent their products as organic by ensuring that agricultural products have been produced in accordance with the USDA National Organic Program (NOP) regulations. Organic certification verifies that practices meet the regulations and can offer new marketing opportunities for farm products. USDA regulations recognize four organic product categories including crops, livestock, processed products, and wild crops.

For any agricultural product to be sold or represented as certified organic:

• No prohibited substances can be used prior to or after certification.
• The operation must undergo an annual on-site inspection and be certified with an accredited agency.  
• An Organic Systems Plan must be maintained.
• Complete production and sales records must be retained for a minimum of five years.

It is unlawful to use the organic seal or sell products as organic without abiding by the federal regulations and being certified. Offenders who knowingly mislabel products will be fined and automatically charged with lying to government agents.

Transitioning to organic production 

The NOP requires that land and animals are managed according to organic regulations before organic certification can be granted.

• Cropland must be managed organically for 3 years.
• Slaughter livestock must be managed organically from the last third of gestation.
• Dairy animals require 12 months of organic management. 
• Poultry must be under continuous organic management from the second day of life.

It is important to contact a certifier before transitioning to organic so that you understand what practices and substances are allowed. Certifying organizations are familiar with the NOP List of Allowed and Prohibited Materials and many offer review services and approved lists for their members. In addition, the Organic Materials Review Institute (OMRI) is a private organization that reviews materials intended for use in organic farming that they find to be compliant with NOP regulations. However, a certifier's list takes precedence over the OMRI product list, so always check with them before using any new product or material to be sure that it is allowed in organic production. If a prohibited substance is used, the transition period restarts.

Keep records and receipts that clearly describe all farming practices and inputs used during the transition period. Documentation is needed to ensure that land or animals have been free of prohibited substances before being eligible for certification.

What to expect during the certification process

There are five basic steps to achieve organic certification.

1. Farm or business applies to an accredited certifying agency.
2. Certifying agent reviews application and assigns an inspector to eligible operations.
3. Inspector conducts a thorough, on-site assessment of the operation.
4. Certifying agent conducts a post-inspection review, including the inspector's report, to verify compliance and consistency with application.
5. If eligible, the certifying agent issues an organic certificate to the operation and products can be sold using the organic label.

All certified organic operations must go through the review and inspection process annually to maintain certification.

Choosing a certifier 

Although the main responsibility of a certifier is to ensure that organic integrity is maintained throughout production and handling, they should also be considered an ally to the organic operation. Certifiers can help to navigate NOP rules and regulations and develop an Organic Systems Plan, identify an inspector, and provide templates for record-keeping. Establishing a relationship with the certifier early in the transition will help you stay informed about changes in requirements that may occur.

When choosing a certifier, consider the fee structure, quality of customer service, level of involvement in the community, and whether the certifier offers benefits such as publications or educational events. Currently, Pennsylvania Certified Organic is the only accredited certifier based in Pennsylvania, but any USDA-accredited certifier may be used. Other organic farmers can also be helpful in identifying an accredited certifying agency.

Costs

Certification fees are due annually to the certifying agency. Costs associated with certification and annual inspections vary depending on the certifier, size of the operation, and gross farm sales. Costs might range from around $700 to $3,000 for small and medium-sized farms. They typically include an application fee, a site inspection fee, and an annual certification fee. Cost-share programs are sometimes available to ease the burden of certification costs. Indirect costs associated with potentially lower crop yields during the transition phase and any new equipment purchases should also be considered.

Developing an Organic Systems Plan (OSP)

The application process differs slightly among certifiers, but it will always include the development of an Organic Systems Plan and a site inspection, which must be approved by the certifier. The Organic Systems Plan serves as an outline of operations and describes in detail:

• Practices to be performed (including frequency)
• A list of each substance to be used (detailing composition, source, and location of use)
• Monitoring practices and procedures
• Description of recordkeeping system
• Description of management/handling practices used to prevent commingling with prohibited substances and non-organic products
• Any other information deemed necessary by the certifying agent

The Organic Systems Plan acts as a contract between the farmer and the certifying agent and must be updated and reviewed each year. Organic Systems Plan templates can be helpful and are available from most accredited certifiers.

Record Keeping 

The audit trail is a fundamental part of organic regulation. It establishes traceability and upholds the reputation of the organic label. Certifiers may offer recordkeeping forms but there is no standard format required except that they must be readily understood and contain necessary information to demonstrate compliance with organic requirements. Receipts and records including application dates and rates for all materials, seeds purchased, and practices used in the operation, crop yields and sales, including information about imported and exported products must be documented and saved for at least 5 years. The importance of keeping thorough records cannot be overstated.

Sample recordkeeping forms can be obtained from most accredited certifiers or other sources such as the National Center for Appropriate Technology (NCAT) Sustainable Agriculture Project.

Site-Inspections

Site inspections allow the certifying agent to verify that the farm is managed according to the Organic Systems Plan and adheres to federal regulations. The inspector will examine production and input records, facilities, equipment, and fields and ask questions about management practices. The inspector will also look at buffer zones that protect the farm from chemical drift from non-organically managed land. After the inspection, the inspector will submit a report to the certification agency, which will determine if certification should be awarded. The certifying agent will grant certified USDA organic status if management complies with the NOP regulations and completes all steps of the application process. At this time, the certified operation can use the organic seal and collect price premiums that may be offered for certified organic products.

Summarizing organic certification

The regulatory nature of the organic certification process requires attention to detail and recordkeeping that many producers might not be used to. Identifying the right certifying agency and other organic farmers to offer support can help ease some of the burden. Although organic certification is not right for everyone, many farmers and business operators find it to be enjoyable and rewarding.

The Penn State Extension's Organic Crop Production Guide provides thorough information about organic certification and agronomic crops. It was used as a reference to summarize information about the organic certification process.