MODULE 5

CONSIDERATIONS BEFORE CERTIFICATION

Coverage:
5.1 Why consider certification?
5.2 Marketing opportunities with organic certification
5.3 Conversion Period
5.4 Communicating with certifiers
5.5 Roles of certifiers and consultants, and criterial for their selection
5.6 The application
5.7 Examples of types of records
5.8 Inspection: preparation and what to expect
5.9 How to renew organic certification
5.10 Split/parallel operations
5.11 Organic Control Points (OCP)
5.12 Key Takeaways

5.1 WHY CONSIDER CERTIFICATION?

Organic agriculture is a fast-growing sector worldwide. Farming organically allows producers to

incur many economic and social advantages compared to farming conventionally. However, a
farmer may be growing organic crops or raising organic livestock, but without organic certification
he/she may not be able to sell his/her products in the market. Organic certification is needed to get
market access and premium prices through enhancing consumer’s trust in the authenticity of the
organic product . Thus, each producer needs to be certified for compliance with the requirements
of a certain organic standard depending on the requirements of the target market. For example, in
case a farmer or an entrepreneur who will like to sell organics in the United States, they must be
certified for compliance with the USDA National Organic Program (NOP) standards and
regulations requirements. Similarly, certification of the compliance with the requirements of the
EU standards and regulations will be required when the product destination is EU market.

Becoming certified organic helps producers and handlers [1]:

a. Receive premium prices for their products
b. Access fast-growing local, regional, and international markets
c. Access additional funding and technical assistance
d. Market products to consumers
e. Support local economies

5.2 MARKETING OPPORTUNITIES WITH ORGANIC CERTIFICATION

The global organic market continues to grow worldwide. The research company Ecovia
Intelligence estimates that the global market for organic food reached 97 billion US dollars in
2017. Organic crops are grown in every country, but demand for organics remains concentrated.
The North America and Europe generate almost 90% of the organic food sales though these two
regions account only 25% of the organic land area. Although domestic organic markets are
growing, but organic production in Asia, Latin America and Africa is largely for the export
market.

The United States is the leading market with 40 billion euros, followed by Germany (10 billion
euros), France (7.9 billion euros), and China (7.6 billion euros). In 2017, many major markets
continued to show double-digit growth rates, and the French organic market grew by 18 percent.
The Swiss spent the most on organic food (288 Euros per capita in 2017). Denmark had the highest
organic market share (13.3 percent of the total food market). The Swiss spent the most on organic
food (288 Euros per capita). They are followed by the Danish at 278 Euros per capita and the
Swedish at 237 Euros per capita. Interestingly, USA citizens only spent 122 Euros per capita on
organic products, although their country has the largest organic market.

Organic certification is the requirement for export of organics to advanced markets like the North
America, European Union, and Japan, as well as high-end domestic markets. Driven by increasing
consciousness of consumers about the quality of food they buy and how that food was produced,
the demand for organics is projected to continue expanding in the foreseeable future in both
domestic and export markets. Third party certification of individual operations is required for
selling products as ‘organic’ in most global markets but that is costly. Therefore, The low-cost
organic certification systems like third party group certification and participatory guarantee
systems (PGP) are gaining popularity among the small famers and products certified for these
systems are finding increasing acceptance in the high-end markets. Since organic certification is
the only tool for quality assurance of organic products for the consumers especially when distance
between the producer and consumer is long as in case of international trade among countries,
certification will continue to open up new opportunities for the organic producers as it leads to
product differentiation with high value, high market demand, premium price, and greater market
access.

5.3 CONVERSION PERIOD

Conversion periods is also called transition period. Requirements of the IFOAM- Organics
International and the US NOP for the conversion period are prescribed below.

5.3.1 IFOAM

The section “4.2 Conversion Period (Plant Production) of the IFOAM- Organics International’s
“Standard for Organic Production and Processing” [2] is reproduced as follows:

General Principle
A conversion period enables the establishment of an organic management system and
builds soil health and fertility.
Requirements:
4.2.1 All the requirements of this standard shall be met for the duration of the conversion period.
4.2.2 The start of the conversion period shall be calculated from the date that an application has
been received and agreed to by the control body.

Regional or other exception

The conversion period may be calculated retroactive to the application only on the basis of
sound and incontrovertible evidence of full application of the standard for a period at least as
long as 4.2.3.

4.2.3 The length of the conversion period shall be at least:

a. 12 months before sowing or planting in the case of annual production
b. 12 months before grazing or harvest for pastures and meadows
c. 18 months before harvest for other perennials.
4.2.4 Crops harvested less than 36 months after the application of a prohibited input to crop or
soil shall not be used or sold as organic.
4.2.5 Plant products may be used or sold as “in-conversion” provided that they have undergone
a 12-month conversion period.

5.3.2 USDA -NOP

Changing from conventional to organic production is a regulated process. Organic “certification”

requires that crops do not receive any synthetic chemicals including fertilizers or pesticides for
three years prior to the harvest of the crops. [3 ]For example, to sell this year’s rice harvested on 1
November 2019, as organic would require that the land received no synthetic chemicals since 31
October 2016. While the transition to certification time period is three years, the number of crops
that need to be sold as transition crops could be two. For this example, crops grown in 2017 and
2018 must be grown using organic methods but cannot:
a. sell, label, or represent the product as “organic”
b. use the USDA organic or certifying agent’s seal
Some lands, such as fallow or pasture lands, may be immediately certified if three years have
already passed.

5.4 COMMUNICATING WITH CERTIFIERS

For successful conversion from traditional production to organic and to avoid any risk in the
process, it is important for the producer to contact a certifier during the transition time. He/she
should not wait until his/her land qualifies for certification. Getting connected with a certification
agency while producer is transitioning his/her land/animals helps ensure he/she is completing all
the necessary steps to achieve his/her certificate before his/her first organic harvest. The certifier
can send you regulatory information, guide your application, and help you through a successful
transition process. You can also use the agency’s certification forms to set up your record-keeping
system. [4]

During transition, certifier can be a valuable asset to make sure you don’t inadvertently undermine
your own steps into organic agriculture. The certifying agents may not be able to answer your
specific questions about organic production, but they can answer inquiries about whether specific
inputs are allowed or prohibited.

Farmer may need to share the following record and documents with the certifier (Table 5.1).
Therefore, it is advisable for the farmer to maintain such records and documents as much as
possible when planning for the conversion.

Table 5.1. List of Records (this is not a complete list of records. The certifier will inform the
producer about the actual record and documents required for certification). [4]

A. Crop Production B.Livestock Production

− Seeds & Transplants − Origin of livestock record
− Material application records (e.g. − Feed records
fertilizers and soil amendments, pest − Animal health care records
control products, crop production aids, − Livestock living conditions and pasture
All invoices and receipts) records
− Production records − Production records
− Field history − All invoices and receipt
− Harvest & storage
− Sales records
− All invoices and receipts

C. Handlers and Processors:

Receiving record, processing and storage record, shipping records, etc., and all invoices and
receipts

For ease of certification, producer should provide correct answers to all questions/queries of the
certifiers. He/She should also provide to the certifier all the requested record and documents.

5.5 ROLES OF CERTIFIERS AND CONSULTANTS AND CRITERIA FOR THEIR

SELECTION [5]

Organic certification can be challenging for new entrants into the organic farming. Therefore,
certifiers’ role at different steps of organic certification is critical.

5.5.1 ROLES OF CERTIFIERS

The certifiers play important roles throughout the process of certification as given below [5]:

Step 1. Application and Fees

 a. An operation that wants to become certified first contacts a certifier. In response, the
certifier provides information about its application process and certification fees.
b. If the operation decides to proceed with that certifier, it completes an application, which
includes organic system plan (OSP).
c. The certifier should make its application forms, including any OSP forms and fee
schedules, readily available.
d. The certifier is responsible to provide an estimate of fees to the applicant. For this purpose,
he/she can provide a published fee schedule provided a reasonable person could use the
information to estimate the total cost of certification and inspection for its operation.

Step 2. Review of the OSP [5]

a. The certifier reviews the application for completeness and determines if the OSP appears
to comply with the regulations.
b. The certifier must clearly communicate to the applicant in a timely fashion whether the
application appears complete and whether the OSP appears to comply with the regulations.
Based on the application review, the certifier can take one of the three actions as given
below:
i. In case the initial review shows that the applicant appears to, or may be able to, comply
with the regulations, then the certifier schedules an onsite inspection (see Step 3).
ii. In case the application does not include enough information for the certifier to
determine whether the operation may be able to comply with the regulations, then the
certifier is to request more information from the operation before scheduling the onsite
inspection.
iii. In case the operation fails to provide or willfully withholds significant information,
then the certifier shall take appropriate compliance actions.

Step 3. Inspection [5]

a. Once the certifier’s initial review determines that the operation may be able to comply
with the regulations, the certifier appoints an inspector, who schedules an onsite
inspection.
b. The inspector completes an onsite inspection of the operation to evaluate the
implementation of the OSP and the operation’s compliance with the certain organic
standard. The purpose of the onsite inspection is to:
i. Assess whether the operation complies or has the ability to comply with the
regulations;
ii. Verify that the OSP accurately reflects the operation’s activities; and
iii. Ensure that prohibited substances have not been applied.

c. For conducting inspection process smoothly, the inspector should conduct an opening
meeting to discuss the inspection plan. The NOP considers opening meetings to be a best
practice for all inspections.
d. The inspector will review each production unit, facility, and site where the operation
produces or handles organic products.
e. The inspector will prepare an inspection report.
f. Once the inspector finishes the inspection report, he or she sends the report to the certifier
for review.
 g. The certifier will evaluate the inspector’s findings when making a final certification
decision.
h. It is important for certifiers to appropriately assess the inspector’s level of expertise and
ability, both during the hiring process and as part of regular performance evaluations.
Organic inspectors play a vital role in ensuring organic integrity. Their visits to organic
farms and processing facilities are often the most direct contact that certifiers have with
organic operations.

Step 4. Review of Inspection Report [5]

a. The certifier assesses the inspection report, the OSP, the results of any analyses conducted,
and any additional information provided within a reasonable period of time. The review of
the inspection report may lead to different paths, each of which may require additional
evaluations or decisions. After evaluating whether the operation appears to comply with
the organic regulations, the certifier makes one of the following four certification
recommendations:
i. Certification, if the operation is fully compliant;
ii. Certification with conditions, if there are minor, non-violative issues;
iii. Notice of Noncompliance for correctable violations; or
iv. Combined Notice of Noncompliance and Denial of Certification for non-
correctable violations.

b. The certifier may conduct additional onsite inspections to verify continued compliance
with the regulations. These inspections may be announced or unannounced, as deemed
appropriate by the certifier.

Note: The final review of the inspection report and the certification decision steps may be
performed by the same person, but that person may not be the inspector.

Step 5 – Certification Decision [5]

a. The certifier determines which of the following actions is appropriate to the operation.
i. If the operation complies or is capable of complying with the regulations, the certifier
issues an organic certificate.
ii. If the operation does not comply with the regulations, then the certifier issues adverse
actions.
b. Once certified, the operation’s certification remains in effect until it’s surrendered, suspended,
or revoked. The certifier, or the competent authority may initiate adverse actions, up to and
including suspensions and revocations.
c. However, to continue its organic certification a certified operation must submit at least once
per year an application for annual renewal of certification along with the an updated OSP and
fees to its certifier. If the operation fails to submit its annual update and/or fees, the certifier
issues a Notice of Noncompliance.

5.5.2 ROLES OF A CONSULTANT

Inspections are not consulting visits. A certifiers or certifier’s inspectors may ask questions, collect
and provide information, explain the regulations or the certifier’s requirements, and identify
conformities and nonconformities for a specific standard. However, accredited certifiers or
certifiers’ inspectors must prevent conflict of interest by not giving advice or providing
consultancy services to certification applicants or certified farmers on how to overcome the
identified barriers such as nonconformities. The services of a consultant may be useful to address
these and other issues relating to organic production and marketing. [6]

Organic production practices are knowledge and management intensive [6], and both new entrants
and certified growers can benefit from consultant expertise. A consultant can assist growers in:

a. providing information and clarification regarding organic standards and certification

procedures and applicable laws and rules without any restriction
b. providing specific advice to meet compliance requirements for a certain organic standard and
regulation.
c. developing organic system plan
d. drafting and implementing plans on crop management especially nutrient management,
irrigation management, and IPM, which have a prominent place in most certification program
standards.
e. completing paperwork required for a certification audit, especially by creating, keeping, and
organizing records of production practices used on the acreage to be certified.
f. Identifying appropriate markets and marketing strategies.

5.5.3 CRITERIA FOR SELECTION OF A CERTIFIER AND CONSULTANTS

Producer-to-certifier relationship combined with quick response time and sensible paperwork is
critical for a successful certified organic business. That is why a producer should be careful in
selection of a certifier.

Producer may consider the following points when selecting a certifier:

a. Certification Body
i. Explore the agencies active in your area and choose the one that best meets your needs.
ii. Working with the same agency as other local farms may save producer money on
organic inspections.
iii. Be sure the certifying agency you choose is accredited in the scope(s) of production—
crops, livestock, wild crops, postharvest handling including processing, etc.) — that
you are pursuing.
iv. Certification agency is reputed for supporting organic producers and eagerness to assist
them in continuing to make their organic endeavors unique and true to their mission.

b. Certifier (individual)
Select a certifier who:
i. is familiar with your region, the fertility input suppliers, and organic feed suppliers,
etc., that are providing products to organic farmers.
 ii. is willing to guide producer through the certification process.
iii. can be contacted at any time with any questions or concerns regarding their organic
certification.
iv. is known for making simple and easy solutions for certification.
v. is competent and experienced in the subject in line with your organic farming plan.

c. Consultant
Producer may consider selection of a reputed consultant with specialization and good
experience in the type of organic farming/organic business, he or she would like to get certified
or further improve the certified organic farm. Other criteria remain the same as for the certifier
(individual) above (b).

5.6 THE APPLICATION

Don’t leave any areas of your application blank. Write “not applicable” on sections that don’t
apply to your operation. The certification agency will not process an incomplete application and
may send it back to you, which would delay your process. Your certification agency can answer
questions that arise as you complete your application. [4]

While filling in the application forms, applicant/operator will need to answer questions relating to
the following subjects:
a. What is an Organic Systems Plan?
b. Organic Production: A Systems Approach
c. Inputs
d. Labeling
e. Special Note

a. What is an Organic Systems Plan (OSP)?

The organic system plan is the cornerstone of any application for certification and the jumping off
point for conversion to organic practices. The certifiers may provide customized template
guidelines depending on the type of operation (crop production, livestock production, a mixed
farming) to develop organic system plans and provide a starting point for newly accredited
certifiers to develop customized templates for prospective producers. [7]

b. Organic Production: A Systems Approach

System-level decision-making for crop production is a hallmark of organic farming. Organic
certification requires soil improvement, whole farm planning, and adherence to approved input
lists based on the premise that the agroecology of insects, diseases, weeds, and soil microbes is
highly interrelated. Altering any part of this ecology changes the environment in which the farmer
operates. Organic farm management requires a holistic approach to crop nutrient and soil fertility
management; pests, weed and disease management; and soil moisture management, among others,
not least because economies may be realized from multiple management strategies. Organic
farmers must consider the complementarity of practices when choosing among options. [7]

i. Crop Pest, Weed, and Disease Management: [7]

 In all the important organic regulations/standards such as the EU ‘organic regulation’, the
National Organic Program of the USA, the guidelines of the Codex Alimentarius, and the basic
standards of the IFOAM – Organic s International, plant protection is strictly regulated.
Organic plant protection follows a clear hierarchy: primarily, plant health is maintained by
preventative measures. Only if these methods are insufficient, plant protection products may
be used. However, only a very limited range of substances is authorized (substances of plant
or animal origin, micro-organisms and a few other substances).
Management practices (e.g., crop rotation, soil and crop nutrient management practices;
sanitation measures; and cultural practices) in combinations with physical, mechanical, or
biological means must be used for pests, weeds, and diseases management in an organic
regime.

ii. Soil fertility and crop nutrient management: [7]

The organic 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 nutrition and soil fertility through crop rotations, cover crops,
and application of plant and animal materials.

The producer must not use:

− any fertilizer or composted plant and animal material that contains synthetic substances
not included in the list of a specific standard “Synthetic Substances Allowed for Use in
Organic Crop Production”.
− Sewage sludge (biowaste)
− Burning as a means of disposal of crop residues produced on the farm.

iii. Seeds and Planting Stock Practice: [7]

The producer must use organically grown seeds, annual seedlings, and plant stocks with due
regard to the exceptions prescribed in the standard.

iv. Crop Rotation Practice: [7]

Producers must implement a crop rotation including but not limited to sod, cover crops, green
manure crops and catch crops that improve soil organic matter, provide for pest management
in annual and perennial crops, manage deficient or excess nutrients, and provide soil erosion.

The management of nutrients in organic farming systems presents a formidable challenge, as

the use of synthetic chemical fertilizers is not permitted. Therefore, organic must optimize a
range of soil, crop rotation and manure management practices to ensure a nutrient supply which
will guarantee optimum crop yields and minimize losses to the environment. [7]

For plant protection combine complementary insect, disease, nematode, and weed
management strategies, which may include right crop variety, crop rotation, nutrient
management, pest control through homemade infusions, and mechanical and biological
control.

c. Inputs
Several inputs are used in organic farming such as inputs for improving soil fertility; inputs for
managing pests, diseases and weeds; inputs for storage, etc. Remember the three rules when
applying inputs in an organic operation.
i. Use preventive measures as much as possible to protect crops from pests, weeds and
diseases; nutrient deficiency, etc.
ii. Use inputs which are allowed in the specific organic standard/regulation; and
iii. Use inputs approved by the certifier. It is advisable to get certifier approval of inputs prior
to their use in an organic operation.

d. Labelling
‘Organic’ is a labeling term that indicates that the food or other agricultural product has been
produced through approved methods, which meet the specific requirements of the specific organic
standard, which must be verified by an accredited certifying agent or certification body before
products can be labeled as ‘organic’. According to the USDA-NOP requirements, “Organic can
be used to label any product that contains a minimum of 95 percent organic ingredients (excluding
salt and water). Up to 5 percent of the ingredients may be nonorganic agricultural products that
are not commercially available as organic and/or nonagricultural products that are on the National
List.1. [8]

The IFOAM-Organics International requirements of labeling a product as ‘Organic’ are

prescribed in section 8.0 of the IFOAM Standard for Organic Production and Processing. [9]

e. Special Note:
i. Applicants/producers of organic certification are advised to:
ii. Read the application materials carefully.
iii. In case some materials are not clear, ask your certifier for the explanation/clarification
iv. Accomplish all the fields of application accurately.
v. Prepare all the information materials and documents required by the certifier and attach
those to the application.
vi. Keep one copy of the accomplished application form and all documents attached with
you for your record.
vii. Submit application to your certifier
viii. After the application review, the certifier may request the producer for additional
information and documents
ix. The producer is obliged to provide all information and documents requested by the
certifier. However, in case some information or documents are not available, producer
must talk with the certifier to find the appropriate solution.
x. Remember trust between the producer and the certifier is critical.

5.7 EXAMPLES OF TYPES OF RECORDS

Recordkeeping is required for organic certification. The purpose is to track all of your farming
activities, from field preparation and planting to the crops you harvest and sell. This checklist
describes the types of records you must keep as part of your organic certification. There are no
requirements about how you record the information, but it must be done in some kind of written
format that organic inspectors will be able to understand. In some cases, we have sample forms
to assist you. In other cases, you will need to maintain original documents such as receipts, etc.
[10]

Recordkeeping Checklist for Organic Growers is given below [10]:

a. Keep records of all the planting materials (seeds, annual transplants, planting stock, etc.), and
input materials (fertilizer, compost, soil amendments, planting mixes, etc.) you use.
For example:
i. Receipts for purchases
ii. Production records for transplants or input materials you produce yourself
iii. Harvest records for seed you saved from your own production
b. Keep records of what you plant, when you planted it, and where it was planted. Sample forms
for ‘seed and stock panting record’; ‘activity log’; etc., can be helping.
c. Keep track of what fertilizers, pest control materials, and other input materials you use, how
much you use, and when and where you used them. Sample forms for ‘input record’, ‘activity
log’, etc., can be helping.
d. Keep track of what you harvest, how much you harvest, and where you harvested it from.
Sample form for ‘harvest record’ can be helping.
e. Keep track of how your crops are handled once they leave the field. This sample form for
‘activity log’ can help you if you do the handling yourself.
f. If you send your crops to another certified organic operation for handling or processing, keep
records of what you sent, where you sent it, when you sent it, and what you received as the
outcome. For example:
i. The handler’s current organic certificate
ii. Delivery or receiving documents for your delivery to the handler
iii. Invoices, pack-out summaries, or other final statements for the finished product
g. Keep track of what you sell, how much you sell, who you sell it to, and how much money you
received. For example: invoices, sales receipts, sales summaries
h. If you sell at Farmers’ Markets, track how much of each product you take to each market and
how much you brought home unsold. This sample form ‘Market Load List’ can help.

5.8 INSPECTION: PREPARATION AND WHAT TO EXPECT

For this section readers are referred to Module 6, where this subject is covered in detail.

5.9 HOW TO RENEW ORGANIC CERTIFICATION

Once an operation is certified, that should not allow its certification status lost. For this purpose, a
certified operation needs to get annual renewal of the certification. The annual update adds new
information to the existing OSP. Main steps in renewal process are given below [5]:

a. A certified operation must submit an updated OSP and fees to its certifier at least once per year
to continue its organic certification.
b. If the operation fails to submit its annual update and/or fees, the certifier issues a Notice of
Noncompliance.
c. The annual update must include a summary statement outlining any changes to the OSP that
were made during the last year, as well as any changes planned for the coming year. If the
certifier requires supporting documentation to verify these changes, then the operation will
provide it.
d. The annual update only needs to describe changes to the operation; it does not need to reiterate
information that was previously submitted. If the certifier requires the operation to resubmit
all information, including that which has not changed, then it is putting an unnecessary burden
on the operation, and the NOP may issue a Notice of Noncompliance (to the certifier) as a
result.
e. Operations must also notify its certifier of any ongoing changes that may affect its compliance
with the regulations. If an operation plans to add new products, fields, operations, or labels to
its OSP, then the certifier must first approve these changes and issue an updated certificate.
f. A request to add new fields, animal species, or facilities would require an additional onsite
inspection.
g. After the inspection is complete, and the certifier has reviewed both the annual update and the
inspection report, the certifier chooses one of the four certification decisions below and
communicates this decision in writing to the operation.
i. Continuation of certification, if the operation is fully compliant, including the issuance
of a new certificate;
ii. Certification with conditions, if there are minor, non-repetitive, non-violative issues;

iii. Notice of Noncompliance for correctable violations. A Notice of Noncompliance

allows the operation to submit a response with proposed corrective actions, typically
within 30 days of the date of issuance. The certifier must evaluate the corrective actions
to determine whether the operation complies with the regulations and take one of the
four certification decisions described here (i, ii, iii, & iv).
iv. Combined Notice of Noncompliance and Proposed Suspension or Revocation for non-
correctable violations, including willful or fraudulent violations.

h. As with the initial certification decision, the decision to continue certification may include new
conditions for minor, non-violative issues. However, if an operation shows evidence of a
repeated minor issue, the certifier should elevate the violation to a Notice of Noncompliance.

5.10 SPLIT/PARALLEL OPERATIONS

There are two categories of operations that produce both organic and conventional crops:
1. Split-operations
An operation that produces or handles both organic and nonorganic agricultural products. Here
organic crops grown are different from the non-organic crops produced
2. Parallel operations
Farm produces the same crops as both organic and non-organic
Farmers are eligible to produce both organic and non-organic crops on their operation. However,
it is critical that they are able to clearly demonstrate and document that no commingling or
contamination of organic crops can occur with non-organic crops or prohibited conventional
materials. If an operation is or intends to have, either split or parallel production, consider the
following points:

1. Organic crops and land have a sufficient buffer zone to prevent cross-contamination
2. Equipment/tools used on organic and non-organic crops/land meet contamination and
commingling prevention (cleaning) requirements
3. Proper handling for storage, transport, and sale (e.g., avoid commingling, clear labeling, etc.)
4. Separate and clear records for organic and non-organic production/sales

5.11 ORGANIC CONTROL POINTS [11]

The organic control points (OCP) are the points (in the organic chain) where contamination and
commingling could occur resulting in a loss of organic integrity. Production and handling
operations need to identify and address their commingling and contamination risks, or organic
control points, in their OSP. [11]

All organic or split production or handling operations must clearly describe their specific
management practices that prevent commingling or contamination in their OSP. All certifiers are
responsible for verifying that certified operations have sufficient management practices in place
to prevent the commingling and contamination of organic products with nonorganic products and
prohibited substances. [11]

The OSP should specifically address the operation’s organic control points and the preventative
measures employed to avoid the loss of organic integrity. Depending on the type of operation,
examples of organic control points can include organic and adjoining non-organic areas, receiving
and storage areas for inputs and ingredients, processing equipment used for organic and non-
organic products, adjacent lands and their associated land management practices (e.g., pesticide
applications or use of genetically modified crops), and receiving areas for feed and inputs such as
soil amendments. [11]

During inspection, certifiers should assess the risks, and verify the adequacy and actual
implementation of the described practices and procedures to ensure that preventive commingling
and contamination activities are carried out and consistently documented. Preventive practices
may include physical boundaries, buffer zones, separate receiving, and manufacturing areas for
organic products, clean-out procedures, training of organic and non-organic personnel, or
completely separate and different storage, packaging or packaging transportation systems.
Evaluation of records and onsite inspections may also include the review of non-organic activities
and areas of the certified operation to verify compliance with the commingling and contamination
prevention provisions of the NOP regulations. [11]

Detailed list of organic control points (OCP), according to the NOP, for: a) both all organic
operations and split operations, b) crop and pasture operations, and c) livestock operations, along
with other relating regulations, is available in the USDA-AMS NOP document ‘Guidance
Commingling and Contamination Prevention in Organic Production and Handling.’ [11]

5.12 KEY TAKEAWAYS

a. Organic crops are grown in every country, but demand for organics remains concentrated. The
North America and Europe generate almost 90% of the organic food sales though these two
regions account only 25% of the organic land area.
b. Third part certification is required for export of organics to advanced markets like the North
America, European Union, and Japan, as well as high-end domestic markets. New models of
certification like third-party group certification and participatory guarantee systems, which are
a bit less costly and are thus suitable for small farmers.
c. For successful conversion from traditional production to organic and to avoid any risk in the
process, it is important for the producer to contact a certifier during the transition time.
d. Organic certification must be done by an accredited certifying agent or certification body
before products can be labeled as ‘organic’.
e. System-level decision-making for organic crop production is a hallmark of organic farming.
d. Farmers are eligible to produce both organic and non-organic crops on their operation.
However, it is critical that they are able to clearly demonstrate and document that no
commingling or contamination of organic crops can occur with non-organic crops or prohibited
conventional materials.
e. The organic control points are the points (in the organic chain) where contamination and
commingling could occur resulting in a loss of organic integrity. Production and handling
operations need to identify and address their commingling and contamination risks, or organic
control points, in their OSP.
f. Organic certification can be challenging for new entrants into the organic farming. Therefore,
certifiers’ role at different steps of organic certification is critical.
g. The certifier determines which of the following actions is appropriate to the operation: a) If
the operation complies or is capable of complying with the regulations, the certifier issues an
organic certificate. b) If the operation does not comply with the regulations, then the certifier
issues adverse actions.
h. Once an operation is certified, that should not allow its certification status lost. For this
purpose, a certified operation needs to get annual renewal of the certification through
submitting application, updated OSP, and certification fee.
REFERENCES

1. USDA/AMS (2019) Organic Certification - Benefits of Organic Certification.

https://www.ams.usda.gov/services/organic-certification/benefits
2. IFOAM-Organics International (2014), Section 4.2 Conversion Period (Plant Production) the
“Standard for Organic Production and Processing.” In “The IFOAM Norms for Organic
Production and Processing- Version 2014 (Version 2014 edited in 2018).
https://www.ifoam.bio/sites/default/files/ifoam_norms_july_2014_t.pdf
3. Chase, C.; K. Delate, and Ann M. Johanns (2009), Making the Transition from Conventional
to Organic. In: Ag Decision Maker, Iowa State University Extension, Bulletin File A1-26
https://www.extension.iastate.edu/agdm/crops/pdf/a1-26.pdf
4. MOSES- The Midwest Organic and Sustainable Education Service - (2005), The Guide Book
for Organic Certification, 7th edition published in 2016, Midwest Organic and Sustainable
Education Service. Authors: Harriet Behar, Lauren Langworthy and Jennifer Nelson. Editor:
Audrey Alwell. https://mosesorganic.org/publications/guidebook-for-certification/
5. USDA-AMS NOP (2018 ), Instruction on the Organic Certification Process. NOP 2601 The
Organic Certification Process, Rev 03, 13 Sep 2018.
https://www.ams.usda.gov/sites/default/files/media/2601.pdf
6. Matteson, Patricia and Chloe Nelson (2015), Sustainability and Organic Certification
Programs offer Opportunities to Growers and Their Consultants. Crops and Soils Magazine,
Jan-Feb. 2015. https://www.organicspecialists.com/Downloads/Matteson-CropsSoils-Jan-
Feb-2015.pdf
7. Organic and Your Health (2019), Organic Farming Methods/Techniques.
https://organicandyourhealth.com/tag/organic-crop-nutrient-management/
8. USDA- AMS. Organic Standards. Organic Standards.
https://www.ams.usda.gov/grades-standards/organic-standards
9. IFOAM-Organics International (2014), Section 8.0 Labeling in the “Standard for Organic
Production and Processing.” In “The IFOAM Norms for Organic Production and Processing-
Version 2014 (Version 2014 edited in 2018)
https://www.ifoam.bio/sites/default/files/ifoam_norms_july_2014_t.pdf
10. 10. CCOF (California Certified Organic Farmers). Recordkeeping Checklist for Organic
Growers https://www.ccof.org/sites/default/files/05%20Recordkeeping%20checklist%20for
%20Growers.pdf (Accessed on 23 September 2019)
11. USDA-AMS NOP (2011), Guidance Commingling and Contamination Prevention in Organic
Production and Handling, NOP 5025 Commingling & Contamination Rev 01, 22 July 2011,
pages 1-4. https://www.ams.usda.gov/sites/default/files/media/5025.pdf