1. Making the Transition Cissy Bowman, CEO, Indiana Certified Organic
Organic Farming
Making the Transition
Cissy Bowman, CEO, Indiana Certified Organic
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2. Bringing Land into Organic Production
What is organic transition/conversion?
What do you need to do to get certified organic?
Is organic right for you?
Why go organic?
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3. “Transition” means:
Transition refers to the 3 year period in which an operation is managed in accordance with the organic regulations, prior to its being certified.
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4. “Organic” means:
Raised or handled under an Organic System Plan as agreed upon and approved by you and a USDA Accredited Certifying Agent.
There is one consistent organic organic standard in the US: CFR 205
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5. CFR § 205.202 Land requirements
Any field or farm parcel from which harvested crops are intended to be sold, labeled, or represented as "organic," must:
(a) Have been managed in accordance with the provisions of §§ through ;
(b) Have had no prohibited substances, as listed in § , applied to it for a period of 3 years immediately preceding harvest of the crop; and
(c) Have distinct, defined boundaries and buffer zones such as runoff diversions to prevent the unintended application of a prohibited substance to the crop or contact with a prohibited substance applied to adjoining land that is not under organic management.
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6. § Allowed and prohibited substances, methods, and ingredients in organic production and handling
To be sold or labeled as organic, the product must be produced and handled without the use of:
Synthetic substances and ingredients, except as provided in the National List
Nonsynthetic substances prohibited in the National List
Nonagricultural substances used in or on processed products, except as otherwise provided in the National List
Nonorganic agricultural substances used in or on processed products, except as otherwise provided in the National List
Excluded methods, except for vaccines, Provided, That, the vaccines are approved in accordance with the National List
(f) Ionizing radiation, as described in Food and Drug Administration regulation, 21 CFR ; and
(g) Sewage sludge.
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7. § 205.203 Soil fertility and crop nutrient management practice standard
The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion.
The producer must manage crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials.
The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.
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8. Animal and plant materials include:
Raw animal manure
Composted plant and animal materials
Uncomposted plant materials.
Note: The use of raw manure and compost are restricted to certain conditions and methods.
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9. A producer may apply
A crop nutrient or soil amendment listed on the National List of synthetic substances allowed for use in organic crop production;
A mined substance of low solubility;
A mined substance of high solubility, provided that the substance is used in compliance with the conditions established on the National List
Ash obtained from the burning of a plant or animal material, provided, that the material burned has not been treated or combined with a prohibited substance or the ash is not included on the National List of nonsynthetic substances prohibited for use in organic crop production
A plant or animal material that has been chemically altered by a manufacturing process provided that the material is included on the National List of synthetic substances allowed for use in organic crop production
Note: The use of these materials must not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.
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10. The producer must not use:
Any fertilizer or composted plant and animal material that contains a synthetic substance not included on the National List of synthetic substances allowed for use in organic crop production;
Sewage sludge (biosolids) as defined in 40 CFR Part 503; and
Burning as a means of disposal for crop residues produced on the operation: Except, That, burning may be used to suppress the spread of disease or to stimulate seed germination.
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11. § 205.204 Seeds and planting stock practice standard
(a) The producer must use organically grown seeds, annual seedlings, and planting stock: Except, That,
(1) Nonorganically produced, untreated seeds and planting stock may be used to produce an organic crop when an equivalent organically produced variety is not commercially available, Except, That, organically produced seed must be used for the production of edible sprouts;
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12. Nonorganic Seeds and Planting Stock
(2) Nonorganically produced seeds and planting stock that have been treated with a substance included on the National List of synthetic substances allowed for use in organic crop production may be used to produce an organic crop when an equivalent organically produced or untreated variety is not commercially available;
(3) Nonorganically produced annual seedlings may be used to produce an organic crop when a temporary variance has been granted in accordance with § (a)(2);
(4) Nonorganically produced planting stock to be used to produce a perennial crop may be sold, labeled, or represented as organically produced only after the planting stock has been maintained under a system of organic management for a period of no less than 1 year; and
(5) Seeds, annual seedlings, and planting stock treated with prohibited substances may be used to produce an organic crop when the application of the materials is a requirement of Federal or State phytosanitary regulations.
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13. § 205.205 Crop rotation practice standard
The producer must implement a crop rotation including but not limited to sod, cover crops, green manure crops, and catch crops that provide the following functions that are applicable to the operation:
(a) Maintain or improve soil organic matter content;
(b) Provide for pest management in annual and perennial crops;
(c) Manage deficient or excess plant nutrients; and
(d) Provide erosion control.
Rotations may be customized to fit your region, crops and soils.
Work with your certifier and your NRCS office to assess the best rotation practices for your operation.
Prescribed rotations do not always fit your operation.
Temporary variances may be granted under the right conditions and with proper documentation of the reason for the variance.
Contact your State Dept. Of Ag. for information on conditions that may lead to the granting of a Temporary Variance.
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14. § 205.206 Crop pest, weed, and disease management practice standard
(a) The producer must use management practices to prevent crop pests, weeds, and diseases including but not limited to:
(1) Crop rotation and soil and crop nutrient management practices, as provided for in §§ and ;
(2) Sanitation measures to remove disease vectors, weed seeds, and habitat for pest organisms; and
(3) Cultural practices that enhance crop health, including selection of plant species and varieties with regard to suitability to site-specific conditions and resistance to prevalent pests, weeds, and diseases.
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15. Pest Problems
(b) Pest problems may be controlled through mechanical or physical methods including but not limited to:
(1) Augmentation or introduction of predators or parasites of the pest species;
(2) Development of habitat for natural enemies of pests;
(3) Nonsynthetic controls such as lures, traps, and repellents.
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16. Weed problems may be controlled through:
(1) Mulching with fully biodegradable materials;
(2) Mowing;
(3) Livestock grazing;
(4) Hand weeding and mechanical cultivation;
(5) Flame, heat, or electrical means; or
(6) Plastic or other synthetic mulches: Provided, That, they are removed from the field at the end of the growing or harvest season.
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17. Disease problems may be controlled through:
(1) Management practices which suppress the spread of disease organisms; or
(2) Application of nonsynthetic biological, botanical, or mineral inputs.
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18. When these practices are insufficient to prevent or control crop pests, weeds, and diseases, a biological or botanical substance or a substance included on the National List of synthetic substances allowed for use in organic crop production may be applied to prevent, suppress, or control pests, weeds, or diseases: Provided, That, the conditions for using the substance are documented in the organic system plan.
The producer must not use lumber treated with arsenate or other prohibited materials for new installations or replacement purposes in contact with soil or livestock.
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19. Do I need to be certified?
Except for operations exempt or excluded, each production or handling operation or specified portion of a production or handling operation that produces or handles crops, livestock, livestock products, or other agricultural products that are intended to be sold, labeled, or represented as "100 percent organic," "organic," or "made with organic (specified ingredients or food group(s))" must be certified.
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20. Exemptions from certification
A production or handling operation that sells agricultural products as "organic" but whose gross agricultural income from organic sales totals $5,000 or less annually is exempt from certification and from submitting an organic system plan for acceptance or approval under § but must comply with the applicable organic production and handling requirements and the labeling requirements of CFR 205.
The products from such operations shall not be used as ingredients identified as organic in processed products produced by another handling operation.
Be aware that the Small Farm Exemption does not allow you to sell into markets that offer certified organic products. Only certified organic products may go into certified organic processed products.
This includes livestock feed—pasture, hay and feed grains.
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21. Am I ready for transition?
Do I have land that is eligible for certification or that can be put into transition?
Do I have the resources in place to convert?
What are my reasons for entering transition?
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22. Eligible Land
Prohibited practices and materials must not be used for 3 years on land to be certified
All or part of a farm can be organic
Cash crops can be raised and sold during transition. (In some cases a premium price is offered for transitional crops.)
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23. Identify Resources
You will need knowledgable resources for advice, inputs, seeds, finances, soil quality, markets, etc.
Transition is easiest if you have community support and motivation—Find other organic farmers and learn from them!
This conference is an excellent place to identify resources.
IL has a fairly large and growing organic community—a great place to be located if you are entering organic markets.
Ask around—find out whom the other growers are using as resources and how they feel about them.
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24. Why go Organic? Common reasons include: Premium for organic crops
Desire to protect and balance ecosystems
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25. Realities of Organic Farming
Production practices must maintain or improve the natural resources of the operation, including soil and water quality.
Organic farm management is labor and management intensive.
Yields may be comparable to conventional systems.
Cost of production is affected by labor and management however premiums are usually received for organic crops.
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26. The Organic System Plan
The roots of organic farming and certification are based in the philosophy of building and protecting soil and water quality and the creation of balance of the natural systems on the farm. This is reflected in the regulatory requirement for an organic system plan (OSP): §§
While you are in transition, and when you get certified, your OSP is your quality assurance that you are operating under organic methogs. Use assistance from ATTRA or other educational organizations that are experienced in organics to make sure you have the best available help in creating your OSP.
Ultimately you and your certifier agree upon your OSP. It is never too early to talk to a certifier.
Some operations decide to have an inspection in their transition years so they have a critique of their OSP. Whereas this is not required, it is often helpful.
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27. § 205.201 Organic production and handling system plan.
The producer or handler of a production or handling operation, intending to sell, label, or represent agricultural products as organic must develop an organic production or handling system plan that is agreed to by the producer or handler and an accredited certifying agent. An organic system plan must meet the requirements set forth in this section for organic production or handling.
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28. An organic production or handling system plan must include:
A description of practices and procedures to be performed and maintained, including the frequency with which they will be performed;
A list of each substance to be used as a production or handling input, indicating its composition, source, location(s) where it will be used, and documentation of commercial availability, as applicable;
A description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed, to verify that the plan is effectively implemented;
A description of the recordkeeping system
A description of the management practices and physical barriers established to prevent commingling of organic and nonorganic products on a split operation and to prevent contact of organic production and handling operations and products with prohibited substances.
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29. § 205.103 Recordkeeping by certified operations
A certified operation must maintain records concerning the production, harvesting, and handling of agricultural products that are or that are intended to be sold, labeled, or represented as organic.
Such records must:
Be adapted to the particular business that the certified operation is conducting;
Fully disclose all activities and transactions of the certified operation in sufficient detail as to be readily understood and audited;
Be maintained for not less than 5 years beyond their creation; and
Be sufficient to demonstrate compliance with the Act and the regulations in this part.
Recordkeepins is critical to your OSP. Organics is not based on residue analysis, but on quality assurance to a method of production.
The organic integrity of your farm will be viewed as much from records as from whatever the inspector sees on the farm.
Recordkeeping does not have to be complicated. Just keep everything!
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30. Penalties for Non-Compliance
Any operation that knowingly sells or labels a product as organic, except in accordance with the Act, shall be subject to a civil penalty of not more than $10,000 per violation.
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31. Finding and working with a certifier
The certifier must be a USDA Accredited Certifying Agent (ACA).
All certifiers standards are the same.
Differences in certifiers include procedures, cost, legal entity structure, types of services offered and access to markets.
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32. Certification and First Inspection—When do I need it?
Prior to the first sale of a crop to be labeled “organic.”
Inspection should be performed when the inspector can see active production of the first crop you intend to sell as organic.
You do NOT need to be inspected until you are ready for certification.
Do not wait until you are sure you have a market! Remember: your first “organic” crop is planted prior to the end of the 3 year transition period.
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33. What to Expect
An on-site inspection of your OSP, records and field histories, as well as a visit to your organic land and facilities associated with organic production and storage.
The inspection is arranged by your certifier.
No conflicts of interest must exist between you, your certifier or your inspector.
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34. Cost of Certification
Varies widely from certifier to certifier—from several hundred dollars to thousands
May include “user fees”—a fee based on a percent of your gross organic sales
May be reimbursed in part by state or federal cost share. (Info is available from your state Dept. of Ag.)
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35. Labeling Organic Products
Do not print labels without your certifier’s approval!
§ Use of the term, "organic."
Any agricultural product that is sold, labeled, or represented as "100 percent organic," "organic," or "made with organic (specified ingredients or food group(s))" must be:
(a) Produced in accordance with the requirements specified in § or §§ through or §§ through and all other applicable requirements of part 205; and
(b) Handled in accordance with the requirements specified in § or §§ through and all other applicable requirements of this part 205.
Labeling mistakes can cause problems. Make sure to have your label reviewed by an expert!
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36. Helpful Resources Other organic producers Buyers, co-ops
New Farm and other publications
Educational Conferences
USDA National Organic Program
ATTRA
Organic Farm Research Foundation
OFARM/MOFC
Universities, Extension
Trade and Educational Organizations
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37. Indiana Certified Organic
For More Information
Indiana Certified Organic
phone/fax
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