Maintaining Organic Certification

Maintaining organic certification requires ongoing commitment, documentation, and dedication to organic practices. Every year, the certified organic farm or facility must pay to go through a review and inspection process. The farmer should continuously update the organic system plan (OSP) and any modified practices. They will also review the farmer responses to any corrections of minor noncompliance issues previously identified by the certifying agent.

A certifier will review your updated OSP, production, harvesting, and handling records, and other certification materials annually. The actual organic operation will also undergo an inspection to ensure organic regulations are being maintained. If the certifier determines the operation is still organic compliant, the farm will be issued an updated certificate.

Certified Organic Crop Records to Maintain

The following list is from the Maine Organic Farmers and Gardeners Association (MOFGA) website.

Certified organic crop producers are required to keep the following records for at least 5 years (as applicable for the business): 

  1. Seed/Seedling/ Perennial/Planting Stock Records 
    • Documentation/protocol of effort to procure organic seed/ planting stock, this can include but not limited to printed correspondences from seed companies regarding requests, inventory, availability, etc.  
    • Verification from a seed supplier that non-organic seed is not genetically modified. This is only necessary for seeds that have commercially available GMO seeds (e.g. corn, soybeans, sugar beets).   
    • For seed savers: harvest records showing production of organic seed. 
    • Verification that pelleting materials are NOP compliant. 
  2. Material Application Records 
    • Date, input or implement, rate, location, and source for the following: 
      • Soil amendments, including fertilizer, compost, etc.
      • Pesticide/herbicide products.
      • Manure application records (this should include date of manure application and date of first harvest yield/ kind of crop from that field).
      • Crop production aids, including mulches, foliar sprays etc. 
  3. Production Records 
    • Crop rotation records, especially if this information is not apparent from the field history forms. 
    • Field activity records. Protocols/records on cultivation practices, weeding and planting dates. 
    • Compost production records are required if feedstocks contain manure or animal parts and the finished product is applied during the growing season on crops intended for human consumption. Records include sources and feedstocks, temperature data and turning dates
    • If equipment is used on conventionally managed land: equipment clean out log including date, method and who cleaned out the equipment. 
    • 1 year transition records for perennials. 
  4. Harvest, Storage and Sales Records 
    • Audit trails are essential paper trails that allow products to be traced to the farm/field of origin. Inspectors will examine your records to verify that this link can be made on paper. Audit trail requirements vary depending on the scale and complexity of the farm operation. Producers should work with their certification specialists on an audit trail system that verifies their compliance with the regulation. 
    • Examples of records needed to demonstrate farm traceability include but are not limited to: 
      1. Direct sales through CSA, farm stand, and/or farmers’ markets:
        • A daily receipts log of sales showing crops sold 
        • CSA share records 
        • Harvest records (if different from sales records). For crops grown and harvested from multiple fields at the same time of the year, records that differentiate between fields must be kept. 
      2. Wholesale to local co-ops, stores, restaurants
        • A log book and/or dates invoices to document product sales. 
        • Wholesale containers labeled with farm name and a lot number or date. 
        • Harvest records (if different from sales records). For crops grown and harvested from multiple fields at the same time of the year, records that differentiate between fields must be kept. 
      3. Wholesaler to processors or distributors: 
        • Sales invoices with lot numbers
        • Wholesale containers labeled with farm name and a lot number or date. 
        • Inventory records for stored product.
        • Harvest records. Harvest records must indicate the field of harvest. Lot numbers should link to the field where the crop was grown and the date of  harvest 
    • If organic product is bought in from other farms, the following must be kept: amounts of crop(s) bought in, amounts of “bought in” crop(s) sold, verification that bought-in products are certified organic or not sold as organic
  5. General Recordkeeping
    • If land has been owned or leased for less than 3 years, a landowner affidavit must be in place to verify  no non-organic practices have taken place in that 3 year period. 
    • Accurate and complete field histories and maps exist (including buffer areas). 
    • Soil test documentation to confirm soil health and inform fertility application decisions. 
      • Note: soil tests are reimbursable through the cost share rebate. Water and tissue analysis reports. 
    • Receipts for all inputs (including seeds, seedlings and perennials and custom applicator invoices) are kept and available at inspection. 
    • Documentation of gross income reported for the last and current year.
    • Product labels have been reviewed and approved by certification specialist. 
    • Records to document the protocols in place to avoid commingling and contamination in operations that handle both conventional and organic crops.  These records may include equipment cleaning logs for pesticide tanks, tractors, boxes, etc.  Records may also include post-harvest handling standard operating procedures, product labeling, etc.  

Resources

USDA publication, Organic Documentation forms that are required for record-keeping
USDA publication, Documentation Forms for Organic Crop and Livestock Producers, which explains how records are kept and other requirements.