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The USDA National Organic Program (NOP) requires that you must develop practices and systems to prevent organic products from contacting non-organic products and coming into contact with prohibited substances.

Commingling is defined as the contact of organic products with non-organic products; contamination is when organic products come in contact with prohibited substances.

How do I assess potential contamination risk areas on my farm?

It’s critical to examine your operation’s practices to identify needs for practices and procedures to prevent contamination and commingling issues.

There are several scenarios that you might flag as a risk area for commingling or contamination of your crops. In particular, split operations that handle both organic and non-organic crops are generally at much higher risk. A few sample processes that would be a red flag for an inspector and certifier can include, but are not limited to:

• Co-storing organic and conventional crops in the same space
• Reusing containers that store both organic and non-organic crops
• Custom hire or contract harvesting, seeding, input application, etc.
• Storing or applying prohibited materials on or near your operation
• Using equipment on both organic and non-organic land or crops

What are the labeling requirements for containers used to store or transport nonretail/bulk products?

Nonretail containers used to ship or store certified organic agricultural products must:

1) Display the identification of the product as organic and

2) The production lot number, shipping identification, or other unique information that links the container to audit trail documentation.

Do I need to use a certified transporter?

No. You don’t need to use a certified organic transporter provided your product is sealed and clearly labeled prior to transporter receipt. It cannot be repackaged, relabeled or processed in any way — including use of restricted atmospheric controls — throughout the time of transport.

What do I need to know about on-farm crop storage?

If you store your crop(s) on-site, you’ll need to implement practices to prevent your crop(s) from commingling or becoming contaminated with non-organic products or prohibited materials.

What do I need to know about off-farm crop storage?

If you are using an off-farm location for crop storage, you must use a certified organic facility for your crop(s).

Are there any exceptions for using an uncertified storage facility?

It’s possible an uncertified storage site may be eligible to be used, provided (1) products are in sealed and tamper evident packaging prior to the facility’s receipt of delivery; (2) products remain in the same package or container at the facility; (3) products are not repacked or re-labeled while under control of the facility; and, (4) the storage facility successfully completes an Independent Storage Information Sheet & Off-Site Storage (IS) form. The use of off-site storage locations must be disclosed in your Organic System Plan (OSP).

Am I allowed to store crops in a treated wood building on my farm?

Crops may be stored in a treated wood building only if not coming into contact with the treated wood. You must provide and document an appropriate barrier — distance, storage bins, etc. — and observe additional requirements for treated wood as needed.

Check out our quick tips video about preventing contamination with crop storage:

Using farm equipment in organic production (e.g., harvesting, handling, milling, etc.) for both conventional and organic crops elevates the risk for contamination.

What will be reviewed for equipment contamination prevention?

In general, we’ll review your post-harvest handling procedures, all of the equipment used, and clean out protocols. It is important that you maintain records to demonstrate compliance with commingling and contamination prevention requirements.

What should go into an equipment contamination prevention plan?

Your Organic System Plan (OSP) must detail management practices, physical barriers, and all other measures used on your farm to prevent commingling of organic and non-organic products and contamination from prohibited substances. A few things to consider when developing your prevention plan(s):

• Identify all areas of potential contamination or commingling
• List all pieces of equipment used for both organic and non-organic crops
• Document preventative equipment cleaning processes (e.g., pressure washing, etc.)
• Purge equipment — run organic batches diverted to non-organic sales — prior to use
• Apply practices on leased/borrowed equipment, even if they are used only for organic crops
• Document preventative equipment cleaning processes (e.g., pressure washing, etc.)

Check out our quick tips video about preventing farm equipment contamination:

For organic farms, a buffer zone is an area between certified organic production and non-organic land. Buffer zones provide a dedicated area to prevent contamination. You’ll monitor firsthand how to gauge the effectiveness of your buffer zone in protecting your crops.

Buffer zones should be clearly indicated on the required Farm Map.

Where do I need to have a buffer zone?

If there is any risk of contamination from adjacent properties or activities (e.g., pesticide sprays, roadway drainage, etc.) that pose a threat to crops you intend to be “sold, labeled or represented” as organic, you need a buffer sufficient to prevent contamination.

What do farm buffer zones protect certified organic crops from?

Buffer zones protect your certified organic crops and land from prohibited substances (e.g., unapproved synthetic pesticides) and excluded methods (e.g., GMO cross-pollination).

How big does a buffer zone need to be?

There is no standard size for buffer zones. The only requirement is that a buffer zone does its job. Size matters, but so does your planting and management plan (e.g., plant type, the height of a hedgerow, plant density and bioswales). Factors such as common wind patterns, land slope, chemical application activity and stormwater drainage patterns all will inform how you set up your buffer. We may perform pesticide or GMO residue testing of organic crops to verify that buffer zones are adequate. Simply put, it must be adequate to prevent contamination from prohibited substances.

Can I harvest crops from a buffer zone?

Crops can be grown in a buffer zone but they may not be sold or represented as organic. We may perform pesticide or GMO residue testing of organic crops to verify that buffer zones are adequate. You’ll need to follow your contamination prevention plans and clean out for equipment used in buffer zones and any crops harvested and stored.

Check out our quick tips video about buffer zones:

Treated wood (lumber) is not allowed for new installations or replacement when in contact with soil or livestock.

Is a pre-existing building or fence made with treated wood allowed?

For organic crop and livestock producers with pre-existing buildings or fencing constructed of treated lumber, these structures may be exempt and will not need to be removed.

What do I need to do if I have treated wood on my farm?

Crop and livestock contact with treated wood must be prevented at all times, even in cases of pre-existing treated wood.

Am I able to use treated wood in any scenario on my farm?

Using treated wood products for construction on your certified organic land will result in a noncompliance and potential loss of certification for the impacted parcel, crop, and/or livestock.

Treated wood is prohibited for use when:

• Building a pasture farrowing hut, a cattle feed bunk or a shelter
• Building feed or crop storage areas
• Fencing (e.g., posts, etc.) in livestock pastures, holding, or confining areas
• Supporting (e.g., posts, plant stakes, hoop houses, etc.) on-site structures

What if the treated wood will not be not near organic production areas?

Treated wood that is isolated from organic production — such as wooden building materials that are not in direct contact with either livestock or crops — might not be prohibited, but could be restricted in its applications. OTCO requires a buffer zone to prevent contamination. For example, you may need a barrier of some sort between the post and its surroundings. There is zero allowance for any wood treated with creosote.

Farmers are eligible to produce both organic and non-organic crops on their operation, provided they are able to clearly demonstrate that there is no commingling or contamination of organic crops.

What is a split-operation farm?

On a split-operation farm, the organic crops grown are different from the non-organic crops. This reduces the possibility of confusion and potential for mix-ups of organic and non-organic crops.

What is a parallel operation farm?

A parallel operation farm produces the same crops as both organic and non-organic.

Do split-operation and/or parallel operation farms require special actions?

The risk for contamination or commingling of certified organic crops is higher. These farm types must be vigilant, incorporating buffer zones, follow well-documented processes for equipment cleaning, and maintain clear plans for crop handling, storage and transport.