Continued from Page 4

show land use history of three years

without prohibited materials? Do you

practice crop rotation to conserve soil,

build organic matter, manage pests and

nutrients, break pest cycles and enhance

biological diversity? Are you committed

to searching for and using commercially

available organic seed and planting

stock? Does your pest management

rely on preventive practices, biological,

mechanical and physical controls, using

allowed materials, with appropriate

restrictions, and only when all other

efforts are insufficient to prevent or

control pests?

Do you raise livestock as organic

according to regulations? Do they

receive 100 percent organic feed

and allowed supplements? Does

your animal health care focus on

practices preventative, using only

allowed vaccinations, biologics

and medicines? Do livestock living

conditions include adequate pasture for

ruminants? See: Pasture for Organic

Ruminant Livestock: Understanding

and Implementing the National

Organic Program (NOP) Pasture


Do living

conditions include outdoor access for

all animals (any confinement duly

justified), with fresh air, clean water,

direct sunlight, shade, shelter, bedding,

opportunities to exercise, move freely,

minimize stress and allow for natural

behaviors, as appropriate to the species?

Does your recordkeeping system

include a clear audit trail to track

production from seed and source

through production practices, harvest,

storage, transport, processing and

sale? Can you assure prevention of

commingling of organic production

with any non-organic products? Do

you take appropriate measures, during

production and after harvest, to prevent

contamination by prohibited materials,

heavy metals, nutrients and pathogens?

Can you describe ways you maintain or

improve the natural resources of your


Are there any significant barriers to

organic compliance for your operation?

Do your production systems face any

significant challenges, such as pests or

FREE online tutorials

on soil health, produce safety, and more

How can ATTRA help you?

Trusted technical assistance for your ag challenges

diseases, that could

not be addressed

with compliant


practices and

materials allowed

for use in organic

production? For

example, USDA

organic regulations

prohibit use of antibiotics

on organic livestock, yet

require a livestock producer

to treat sick animals humanely,

even if it means using a prohibited

medication. Under these circumstances,

the individual treated animal would

lose its organic status, but as long as

there is an adequate system in place

to identify and segregate that animal

from the organic herd, the rest of the

operation can remain certified organic.

Your organic system plan lists all the

materials planned for use, including any

prohibited materials that may be needed

in order to restore an animal to health,

along with a description of procedures

to be followed if an animal were to be


What about the Paperwork?

While organic certification requires

recordkeeping and audit trail

documentation, recordkeeping is

simply a good business practice. A

majority of records required for organic

certification benefit any agricultural

business, regardless of certification

status. A good recordkeeping system

can facilitate completion of tax returns,

enterprise cash flow budgeting, loan

applications, as well as compliance with

other federal regulatory requirements

related to environmental health and

food safety. For example, the Food

and Drug Administration Food Safety

Modernization Act (FSMA) requires

traceability for fresh produce. USDA’s

Food Safety and Inspection Service

requires inspection, grading and

labeling of livestock products. You

can increase efficiency in your overall

business management by developing

your recordkeeping systems that serve

multiple purposes.

Producers and processors alike recount

how the records they kept for organic

certification enabled them to track

practices, ingredients or products; to

identify patterns, follow correlations,

and the clarify causes. Records can help


Organic Farmer April/May 2019

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