Transcript USDA Accredited Certifying Agents and Substance Use in

USDA Accredited
Certifying Agents and Evaluation of
Substance Use in Organic Production
Jessica Morrison
Quality Systems Manager
Substance Program Manager
Organic 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.)
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)
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
• 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 Ingham
Soil Foodweb Oregon
Email: [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