Most
Common Mistakes
Made by certified crop operators and/or certification applicants
Compiled by Jim Riddle*
Certifier relations:
- Getting
a product or practice approved by a certifier, but not getting the approval
in writing, and then misunderstanding the "approval".
- Failure
to submit requested documentation to the certifier (such as prior land use
forms, non-GMO letters, adjoining land use forms, water test results,
etc.)
- Not
understanding and/or not complying with certification requirements (minor
non-compliances) from the previous year.
- Failure
to complete required paperwork on time, or at all.
- Not
registering with the state organic program, if applicable.
- Failure
to pay certification and/or inspection fees.
Non-approved inputs:
- Use of
non-approved substances (incl. treated seeds), due to negligence and/or
not understanding the requirements.
- Use of
non-approved substances, due to trusting an input supplier who gave
assurances that the material was "approved" for organic farming.
- Failure
to inquire about the GMO status of inputs, especially inoculants and Bt
products.
- Not
having documentation of non-GMO status of inputs, including seeds,
inoculants, and Bt products.
- The
farmer does not correctly calculate the amount of time from the last date
of prohibited inputs used - and the required 36 months have not passed.
The farmer then wrongly thinks that the present year's crop will be
saleable as certified organic, when it is not certifiable.
Documentation
of approved inputs:
- Failure
to obtain adequate documentation for purchase of approved inputs.
- Failure
to document attempts to source organic seeds.
Record
keeping:
- Lack of
adequate detail or clarity on field maps and/or use of inaccurate maps.
- Field
maps which do not show acres, field numbers, and/or adjoining land uses.
- Not
keeping field activity records up to date.
- Failure
to keep seed and input labels and receipts in an organized and accessible
manner.
- Failing
to keep records for contracted services, such as planting, spraying,
harvesting, and/or trucking.
- Failure
to keep bin records up to date.
- Not
recording field numbers on harvest and/or storage records.
- Not
using lot numbers or not using a consistent lot numbering system.
- Not
providing adequate documentation to buyers when organic products are sold.
- Not
keeping records of steps taken to inspect and clean transport units.
- Not
maintaining adequate records for operations with both organic and
conventional production.
Organic
plan:
- Failure
to follow the operation's organic plan.
- Filing
"renewal" farm plans with entries marked "No Change",
when there have been significant changes, such as new leased or purchased
fields, discontinued leases, sub-divided fields, new crops, new inputs,
changes to field numbers, changes to lot numbering system, etc.
Commingling
and contamination:
- Failure
to properly clean harvesting equipment and/or storage units, resulting in
commingling or contamination of organic crop.
- Failure
to segregate crops harvested from buffer zones.
- Lack of
cleaning logs for spray equipment that is also used for prohibited inputs.
- Work
area contamination for post harvest handling (e.g. washing vegetables,
cutting vegetables, packing
vegetables, etc.)
- Mislabeling
or mishandling of crop by mistake by workers who are not fully informed of
organic certification requirements.
- Misapplication
of prohibited materials by workers who are not fully informed of organic
certification requirements.
- No GMO
drift management plan - not knowing where the nearest GMO fields are
located.
- Failure
to inform highway departments and/or other authorities that land adjacent
to organic fields should not be sprayed (or sign no-spray agreements when
these are available).
- Failure
to post no-spray signs when and where these would add protection.
*Based on
information provided by members of the Independent Organic Inspectors
Association and the OTA's Organic Certifiers Council. Compiled January 18,
2002, by James A. Riddle, Organic Independents, Winona, MN, USA.
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