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!