For farms

#Requirements

Your recordkeeping system demonstrates where promise and practice meet for compliance. The annual inspection reviews every aspect — from weed management to contamination prevention — of organic crop production. Our ability to easily audit and trace all certified organic crop products maintains the integrity of your operation and enables quick action if issues occur.

Note

If you have a split operation — organic and non-organic — you will need a distinct set of records for your organic crops to demonstrate that they meet organic standards. You’ll also need to demonstrate how organic and non-organic products do not commingle.

You must maintain documentation — your Organic System Plan outlines recordkeeping strategies, management, and storage — that demonstrates all requirements are being met. Each operation’s recordkeeping systems will be different. However, a few core requirements must be minded.

Recordkeeping basic requirements

  • Records are easily accessible on-site for inspection
  • Documentation must be adapted to reflect your operation
  • All records must be clear and auditable

Alert

All records related to your organic product need to be stored for at least five years.

What records do I need to keep?
The records listed below are examples of records that can be used to demonstrate compliance with the recordkeeping requirements in the USDA National Organic Program regulations.

  • Harvest records
    Fields harvested from, dates, crop types, amounts harvested and transported from the field
  • Purchasing records
    For all materials used in crop production such as seeds, transplants, fertilizers, pesticides, etc.
  • Material(s) records
    Material applied, application location, date of application, and the amount/rate of application
  • Activity log
    Chronological journal, calendar, or account of on-farm activities (e.g., field prep, harvest, etc.)
  • Compost time and temperature logs
  • Equipment clean out logs
    For field equipment, storage, transportation, etc.
  • Planting records
    Rotations, crop plantings, cover crop plantings, etc.
  • Shipping records
    Bills of lading, receiving logs, delivery receipts, etc.
  • Transactions with co-packers
    Certification information for co-packers and records of all transactions
  • Sales records
    Farmers’ market load lists, produce stand inventory lists, grower statements, invoices, records of deliveries to owned facilities for all products, including brokered or resold products

#Crop audit

Organic inspectors are required to conduct at least one complete audit trail exercise at each inspection. The audit trail evaluates your recordkeeping system as well as activities for traceability and compliance.

For crop producers, a complete and thorough audit trail enables a product — e.g., broccoli for retail sale — to be traced from seed to sale. Your recordkeeping system should act as a connected web. An inspector will be able to easily review a crop and its management practices, materials, equipment, harvest, transport and more.

Depending on your operation and production needs, you might choose an online program or handwritten logs. Integrating recordkeeping into the daily routine and culture of your farm is key to success. It should be clear that updating and tracking information on your farm is well-managed and easily done.

Seed-to-harvest recordkeeping
Creating a flowchart system enables you the ability to update your recordkeeping system regularly. The process of noting seed purchased and used alongside harvest information will present a clear picture of your operation’s activities.

Supplemental logs
In addition to seed-to-harvest data, it is important to keep detailed harvest logs, greenhouse activity logs, weed management logs and other plant/harvest actions. In addition, you will need to keep receipts and labels for all seeds and materials, including invoices, sales logs and shipping records.

No matter what system you use, it is important to ensure that your recordkeeping:

  • Is easy to update regularly
  • Is well understood by all employees, even those not responsible for data entry
  • Is clear and well-organized for inspectors and certifiers
  • Documents a full, linked chain between activities, materials and touchpoints without gaps
  • Demonstrates clear relationships that match on-the-ground realities — e.g., the number of seeds of a crop — with reported activities — e.g., the amount of that crop harvest

Resource

Learn more tips and tricks for organic recordkeeping in Lessons Learned: Organic Recordkeeping for a Crop Audit.

#Seed sourcing

The USDA National Organic Program requires farmers to use certified organic seeds and planting stock.

There are some exceptions where use of untreated, non-GMO non-organic seed and planting stock is permitted only if a certified organic equivalent is not commercially available in the appropriate form, quantity or quality. You must provide thorough documentation — also known as a commercial availability search — of a search using at least three different seed sources without finding an organic equivalent.

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=RF9NVURtV2lDEDlQb0h6DDR0dih5DkxvT2hU_19>.

Documenting form, quantity or quality
For an inspector and certifier, a commercial availability search confirms that seed or plant stock was not available:

  • In the right form (e.g., seed size and treatment)
  • In the right quantity (e.g., amount needed)
  • Of the right quality (e.g., poor germination rate, days to maturity, weeds in the planting mix)

In addition, you’ll need documentation of seed supplier information and receipts at your inspection.

Alert

There are a few exceptions to allowable non-organic seeds and planting stock. Farmers producing edible organic sprouts must use organic seed stock.

Basics for seed search recordkeeping

  • Document your search
    You must record the date of your seed or plant stock availability search, the suppliers reached, and your communication history — e.g., emails, faxes, etc. — for your inspection. A search must be conducted and recorded for each non-organic seed or plant stock variety planted. You must perform a new search annually, even if you are using leftover seed documented as commercially unavailable from a previous year.
  • Organize and make accessible all purchase records
    Save and organize all of your receipts, labels, and packets of both certified and non-certified seeds for the past five years. In addition, have commercial availability search documentation available for all non-organic seed used.
  • Request a non-GMO statement
    Request a supplier statement affirming all non-certified organic seeds are non-GMO — if a GMO version is commercially available — and are not treated with prohibited substances.
  • Implement a recordkeeping system
    Find a recordkeeping system that works for you. Keep it updated and be consistent in how you document and organize information.

Resource

Learn more about organic recordkeeping in our webinar, Recordkeeping: Tips, Tricks and Questions Answered.

#Materials

Documentation of materials is a critical part of your recordkeeping system. An inspection will review the materials used, how they are used, and determine the compliance of your certification.

Documenting materials
You will need clear and up-to-date records for every material used in your organic production. An inspector and certification reviewer will work to determine the compliance of each material as outlined by the USDA National Organic Program (NOP) guidance.

One simple approach is to file each receipt — with dates — and label — with the brand name, manufacturer and ingredient list — in chronological order in a binder.

Mapping applications
Using maps — with color codes, material codes, etc. — is a useful way to document material(s) used on your farm. You and an inspector will be able to trace application of materials for compliance and your future production plans. All maps must include what material you applied, the date of application, and the quantity applied.

Compost production records
You must maintain compost production records — the NOP offers a sample worksheet — for all on-farm compost. Records should include material types and quantities, as well as logs of temperature readings and turnings, to ensure compliance with the NOP’s compost standards.

Resource

Learn more tips and tricks for materials recordkeeping in our Lesson’s Learned Series: Recordkeeping for Organic Materials.

#Commingling and contamination prevention

All certified organic operations “must implement measures necessary to prevent the commingling of organic and non-organic products and protect organic products from contact with prohibited substances.”

Your Organic System Plan (OSP) should detail how you plan to address these issues — or demonstrate that all equipment is for organic crops only — for post-harvest handling procedures, equipment usage, and equipment clean out protocols. Records must demonstrate compliance with commingling and contamination prevention requirements.

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.

Documentation should include:

  • Equipment cleaning log
    The equipment cleaning log verifies that your produce 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.
  • Split and parallel operations
    If you produce organic and non-organic crops, you will need clear traceable records to demonstrate 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.
  • Clean truck affidavits
    If using trucks for transportation and shipping, you must keep truck sanitation records to show proper cleaning to prevent contamination of your organic crops.
  • Borders and buffers
    Your OSP must demonstrate steps taken to create adequate crop buffers to prevent contamination from potential pesticide drift or runoff from neighboring lands. Signed agreements with neighbors, municipalities, and other organizations bordering your land should be provided here as well.
  • Water
    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.

Sample equipment cleaning log:

Resource

#Field activities

Recording field activities is an open journal of what happens daily on your farm.

The creation of a field activities log — a notebook, binder of individual daily pages, calendar system, or online spreadsheet — provides clear and thorough documentation of what happens in the field(s). Some of the activities that should be included are seeding or transplanting, weed management, cultivation, harvesting, pest control activities, compost production and more.

Tip

Consider leaving binders at individual field sites to promote ease of use, collection and compilation.

The field activity log supports other records you keep like harvest logs, planting logs and equipment clean out logs.

#Harvest and production

Harvest records are a key part of our audit trail. You will need to demonstrate what, how much, when and where you harvested crops on your farm. Additionally, you must document storage and transportation post-harvest. The creation of a harvest log will address these major questions during an inspection or certifier review.

Sample harvest log:

Special considerations
Your harvest log will be customized to your operation. You may want to incorporate additional recordkeeping requirements here, or maintain them separately.

Other documentation to consider:

  • Harvest equipment must be documented for usage and clean out schedule/process
  • Storage of harvested crops must be documented for container clean out, location and more
  • Transportation of harvested crops must be documented for clean out, commingling prevention, schedule and more

In all cases, creating an easy-to-follow recordkeeping system — e.g., using harvest lot numbers — will enable an inspector and certifier to ensure compliance.

Resource

Learn more tips and tricks for organic recordkeeping in Lessons Learned: Organic Recordkeeping for a Crop Audit.

#Sales

Sales records are the final step in your audit trail. These records, combined with your harvest logs, will enable your inspector to verify that the amount of organic product you are growing and harvesting match the amount you are selling.

Here are some of the types of records you may need to keep:

  • Grower statements
  • Farmers’ market load lists
  • Produce stand inventory lists
  • Records of delivery to processing facility
  • Invoices
  • Sales summaries from wholesalers or processors

The recordkeeping system — e.g., lot numbers for sales and harvest logs — used should allow for full traceability of all crops sold back to the beginning of field activities and production.

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