Commingling and contamination prevention

Your records should detail how you plan to prevent the commingling of organic and non-organic products and protect organic products from contact with prohibited substances.

Recordkeeping systems will depend on the size and scope of your operation. For example, if you have a split operation, where only some of your fields are organic, you will need a separate set of records for your organic crops. You must track organic crops from seed to farm departure, ensuring nothing has commingled with non-organic crops or prohibited substances.

What do I need to document for equipment usage?

In general, we’ll review your post-harvest handling procedures, all of the equipment used, and clean out protocols. An equipment cleaning log verifies that your crop(s) did not come into contact with any prohibited materials, non-organic crops (if applicable), or cleaning residue. It provides confirmation that equipment was cleaned and purged between non-organic usage and organic usage to prevent commingling.

What is a clean truck affidavit?

If using trucks for transportation and shipping, you must keep truck sanitation records to show proper cleaning to prevent contamination of your organic crops.

How do I document my buffer zones?

Your OSP must demonstrate steps taken to create adequate crop buffers to prevent contamination from potential pesticide drift or runoff from neighboring lands. All buffer zones must be clearly marked on your farm map. Signed agreements with neighbors, municipalities, and other organizations bordering your land should be provided here as well.

Do split and/or parallel operations need to keep extra records?

If you produce organic and non-organic crops, you will need clear traceable records to demonstrate the prevention of commingling and contamination. Documentation may be in the form of a harvest log, lot numbers or other recordkeeping that plainly traces crops from seed to harvest to storage, transport or sale.

What do I need if my water is supplied by an irrigation district?

If your water is supplied by an irrigation district that adds prohibited substances to the water — e.g., algicide — you must provide documentation to show clear communications and confirmation with the irrigation district regarding its calendar for substance additions. Additionally, you must have clear records to demonstrate there was no on-farm irrigation on those days.

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