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NOFA-NY Certified Organic, LLC
2008 Guidance Manual
Introduction
The information contained in this document is NOFA-NY Certified Organic LLC's Guidance to the USDA National Organic Program's National Organic Standards (NOS). The Guidance is referenced back to specific sections of the regulations. Like other federal government programs, the regulations were created to fulfill the Federal Organic Foods Production Act, which was passed in 1989. The regulations were first published in the Federal Register on December 21, 2000, a publication of the federal government, and can be found there, as well as in the Code of Federal Regulations (available at county-seat libraries) and on the web at the NOP's website at www.ams.usda.gov/nop.
This manual is meant to help producers have a reference point to some areas of the Rule that may not be clearly defined. This is guidance that the program stands behind and recommends certified operations follow.
Table of Contents
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1b. |
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6. |
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7. |
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8. |
SEEDS AND PLANTING STOCK, RESOURCING AND MANAGEMENT RECOMMENDATIONS |
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11. |
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13. |
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14. |
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14a. |
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14b. |
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15. |
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16. |
STANDARDS AND LABELS FOR CROPS WITH NO SPECIFIC USDA STANDARDS (MAY 2, 2002) |
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GUIDANCE FOR HARVESTING, PACKAGING, STORAGE OF ORGANIC CROPS |
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All applicants for certification must develop an Organic System Plan, which covers all aspects of agricultural production and handling/processing. This plan is written by the applicant and reviewed and approved by the Review Committee. The certification application, when considered in conjunction with on-farm records, will constitute the organic system plan.
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Intent: |
A statement of understanding and intent to follow the practices described in these Standards |
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Method: |
A description of the organic management plan for farms, including soil tests; crop information, including seed and transplant sources; production history; soil development plans and crop rotations. Farm maps, identifying all fields, greenhouses and other production areas, plus storage, processing and handling facilities are an integral part of an organic farm plan. Livestock producers will be required to include an animal inventory and health management plan. |
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Documentation: |
A system of record keeping that shows that the applicant is indeed carrying out the practices for organic production and processing. Examples include soil tests, crop plans, field maps, amendments & pest controls used, receipts, harvest records, records of medical treatments to livestock, manure Management practices and purchased feed records. |
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History: |
Documentation of the management practices used on the farm for the previous 3 years. |
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Affidavit: |
A signed affidavit stating that the information supplied is accurate, true and complete. |
The purpose of the Organic Farm Plan is two fold: to assist the applicant and the Certification Program. For the applicant, the Organic Farm Plan provides a flexible, useful, and affordable tool for developing a sound resource management system on the farm. The process of developing the Organic Farm Plan allows the farmer to plan and evaluate their farm management practices and make tangible improvements in the farming operation. For the Certification Program, the Organic Farm Plan provides essential information for assessing the applicant's compliance.
(b) The Organic Handling & Processing Plan must include a general description of the handling/processing operation, including processing procedures; schematic diagrams of the facility; flowcharts showing movement of organic products through the facility; ingredient information and verification procedures for organic ingredients, and separation policies for certified and non-certified products. The Organic Handling Plan should also identify areas of production that could jeopardize the organic integrity of the product.
Guidance for Federal Rule § 205.201:
The NOFA-NY Certified Organic, LLC application for certification, in conjunction with on-farm records, records, will be considered the organic production and handling system plan.
2. Basic Units of Certification
The field, animal, sugar bush, and facilities (For example: barns, greenhouses, processing facilities) are the basic units of certification. The field and sugar bush should have clear boundaries and their entirety must be subject to the applicant's described management plan. Maps of all fields are required. It is left up to the applicant to divide the operation into fields for certification and record keeping purposes. All fields, sugar bushes, greenhouses must be identified with a name, number or letter. If certification problems arise, a field or parts of a field may be decertified. All livestock must be tagged for identification. Poultry flocks must have identification numbers.
Additional fields should only be added to your certification at the time of annual renewal. New applicants, or repeat applicants requesting to add new fields to their existing certification, should provide the crop history, soil amendment history, and pest control history for the previous three years for all fields to be certified.
Applicants continuing their certification, and adding new fields or new enterprises, may not consider the crop from the new field or the new enterprise certified until the inspection and Review Committee determination has been completed. Applicants may not advertise such new enterprises as certified until the Review Committee has made a determination. Crops from new fields must be segregated from certified crops until certification is completed.
In the case of partial farm certification, the NOFA-NY Certified Organic, LLC Program will require information to be supplied regarding the use of land, types of practices used, crops including if genetically engineered crops are being grown, livestock produced, and labeling of non-certified products.
3. Farm/Field/Facility Diagrams
The Farm Map is an integral part of the Organic Farm Plan. Farm map(s) should show the location, orientation (N, S, E, & W) and identification of each field / sugar bush to be certified. A farm map is necessary so that the Review Committee can obtain a clear picture of your farm and also understand what effect, if any, the adjoining land use will have on your farm.
Farm maps submitted to the Certification Program should be 8 ½ x 11 in size and should include the layout of all fields/sugar bushes to be certified, including borders, hedgerows, roadways, power lines, railroad tracks, fallow areas, buffer zones and proximity to buildings, creeks, etc. These maps may be hand drawn, but in all cases the map must clearly represent the fields / sugar bushes to be certified. Due to the poor quality of ASCS maps, the Certification Program does not accept these maps.
It is suggested that these maps can be used to "trace" a new map for use in the Certification Program. Fields / sugar bushes should be clearly identified with either a number or letter for identification purposes which should correspond to the number or letters used on the application form. Greenhouse locations should be identified on the farm map. The use of any adjoining land, whether owned by you, or belonging to neighbors must also be included.
Terms such as "conventional farm land", "woods", "swamps","organically managed land", "neglected", "residential", should be used to describe adjoining land. For farms comprised of a large number of fields / sugar bushes, spread over many miles, a "master map", indicating location of field / sugar bush areas in relation to the home farm must also be provided. This is in addition to individual and specific field / sugar bush maps which are also required.
Farm maps of maple production should also include information specific to the operation such as the roads in sugar bush, main collection lines, and collection tank locations, approximate number of taps on lines, pump locations and sugar house location. A diagram of the sugarhouse, indicating processing and storage areas is also required.
In poultry operations, a diagram of the housing facility, indicating overall size, size of floor area allocated to birds, size & location of internal divisions, storage areas, along with the location of the managed pasture areas [if used] or location of paddocks to facility should be included. The use of adjoining land must also be included.
Farm maps for dairy & livestock operations should also include a detailed map of the farmstead, including locations of barns, paddock areas, feed storage areas including grain bins, bunks and silos.
Processing Facility Diagrams must include schematic drawings of the facility. All areas of the facility should be identified, including incoming product areas, processing areas, storage areas, shipping areas, and location of cleaning systems. In addition, a product flow chart should also be submitted.
For each operation certified by NOFA-NY Certified Organic, LLC, one individual must be designated responsible for contact and communications with the Certification Program, meeting NOFA-NY Certified Organic, LLC certification requirements, informing the Certification Program of management changes, and providing records.
Other individuals may also be involved. The designated person must be able to provide access to all information regarding record keeping and technical aspects of the operation, and access during the inspection to all facilities and fields.
In the case of absentee ownership, the site manager must be designated as the contact person. The manager must be responsible for contact with the Certification Program and have access to all information regarding record keeping, audit trail information and technical aspects of the operation. The NOFA-NY Certified Organic, LLC Certification Program office must be notified of changes in site manager personnel.
Failure to notify the Certification Program office of managerial changes may jeopardize continued certification. If the Certification Program feels managerial changes are resulting in lack of accountability for the certification process, additional inspection visits to verify compliance with practices and audit trail requirement may be necessary. The costs of these inspection visits will be billed to the applicant.
Fields to be certified must be under the management of the applicant. Certification of rented land is permitted, providing the applicant has day-to-day management control of the field. Certified farmers are expected to replenish and maintain fertility and organic matter by providing optimal conditions for soil biological activity. It is not an acceptable organic practice to simply exploit existing soil nutrients in a manner that, over time, systematically depletes and exhausts the fertility of the soil.
Certified farmers must develop a management plan that will maintain or improve soil fertility, soil structure, organic matter and biological activity that is consistent with the nutrients removed by tillage and crop harvest. Certified farmers should also strive to maintain fertility and organic matter levels that will ensure a high quality, nutritious crop. Certified farmers should develop an active management plan which includes weed control strategy, pest control strategy, monitoring of pH levels, monitoring soil trace element levels, replenishing soil fertility sources, crop rotations, timely harvest of crops and cover cropping if applicable.
Guidance for Federal Rule § 205.203:
Producers should strive to leave the soil exposed as little as possible. When not growing a commercial crop, green manures, cover crops, and mulches should be used to increase soil biological activity, prevent erosion, fix nitrogen, recycle nutrients, increase soil organic matter, increase water penetration, and improve soil structure.
Spreading manure on frozen ground or snow can contribute to run-off contamination and is not encouraged.
Short term piling or composting of manure is encouraged as an alternative to spreading on frozen ground providing pile location is suitable. All storage and field applications should be within NYS DEC regulations to avoid environmental pollution.
It is recommended that Fifteen tons per acre (or less) of raw manure, Five tons per acre (or less) of chicken manure be spread on fields. Incorporating manure directly after spreading reduces volatilization of nitrogen.
Production of an allowed composted material begins with the selection of appropriate feedstock. The producer's first responsibility is to identify the source of the feedstock used in the composting system. Only allowed plant and animal materials may be included in the composting process. Allowed materials cannot be contaminated with prohibited materials, and should be incorporated in quantities suitable to the design of the composting system.
Soil Testing & Tissue Analysis
Benefits of soil tests may include improved ability to manage fertility, reduced costs of fertility management and increases in yields. Farmers are encouraged to know their soils. Soil testing is one tool of fertility management. Analysis should include major and minor nutrients, pH, Cation Exchange Capacity, and organic matter. Farmers should submit samples to a reliable laboratory. Particular problems may necessitate tissue analysis to monitor nutrient uptake by the crop.
Farms certifying vegetable and field crops for the first time should submit available soil tests from the previous three years. Samples should be taken during the current year's growing season.
6. Crop Rotation Recommendations
Guidance for Federal Rule § 205.205:
Crop Rotation is defined as the practice of alternating the annual crops grown on a specific field in a planned pattern or sequence in successive crop years so that crops of the same species or family are not grown repeatedly without interruption on the same field. Perennial cropping systems employ means such as alley cropping, intercropping, and hedgerows to introduce biological diversity in lieu of crop rotation.
Ideally an organic crop rotation system would contain crops from different plant groups, that are seeded at different times and that have different nutrient demands. An organic field crop rotation plan should include row crops, legumes/sod crops and small grains. Production of annual vegetable crops should also include crop rotations.
Using different crops with varying nutrient requirements assist in breaking weed cycles and in building soil fertility. NOFA-NY Certified Organic, LLC strongly recommends not planting the same row crop 2 years in a row unless the rotation is clearly broken by a cover crop. The producer should take pictures of the green matter to be plowed down from the cover crop.
7. Audit Trails for Certified Operations
In order to maintain the integrity of livestock, crops or products labeled as NOFA-NY Certified Organic, LLC. Organically Grown or NOFA-NY Certified Organic, LLC. Certified Organically Grown & Processed, NOFA-NY Certified Organic, LLC. Program recognizes the importance of providing a clear, documented audit trail of all inputs used in your farming or processing operation.
NOFA-NY Certified Organic, LLC. also recognizes the importance of a clear and documented audit trail of the harvest and sale of crops, livestock or products from Certified fields and/or facilities to the purchaser. All applicants for NOFA-NY Certified Organic, LLC certification are required to develop and maintain an audit trail record keeping system.
A complete audit trail is comprised of, but not limited to, documents such as the farm map, purchase records for field inputs and purchased feeds, Applied Amendments / Spray Record form, livestock health and medication records, harvest records, and sales records that track crop, livestock or product from field or facility to the purchaser. In livestock operations, all animals must be identified with either plastic or metal tags. Tattoos are also acceptable. Flock numbers must identify poultry.
To be complete, an audit trail should be able to trace any given product from its origin, whether it be field, sugar bush, herd, etc., to the point of sale. For those selling at farmers' markets, records of inventory brought to the market and a record of daily sales totals must be maintained.
Farms marketing through CSA projects must also maintain harvest and distribution records. Farms producing both certified and non-certified crops must maintain complete audit trail records for both certified and non-certified crops. Your audit trail system will be reviewed at the time of inspection. Failure to maintain an audit trail system will jeopardize Certification. Audit trail records are required to be retained for 5 years.
Guidance for Federal Rule § 205.103:
Split operations should maintain audit trail records for both the organic and non-organic production systems. Examples of audit trail records are listed below. Many of the examples are part of the annual certification application; others should be maintained by the farmer/handler/processor. Not all records in the list are relevant to all operations.
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(1) |
Farm / Facility Diagram
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(2) |
Input Records |
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Expense Records |
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(ii) |
Applied Amendments/Spray Records |
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Shipping Records |
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Expense Ledger, Checkbook, Checks |
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Transaction Certificate |
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Custom Work Transactions
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(3) |
Seedling and Transplanting Records |
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Purchase Records for Seed |
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Information indicating whether seeds are organic/non-organic/treated |
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Field History for seedlings and transplants
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(4) |
Field Records |
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Field History forms |
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Field Maps |
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(iii) |
Application/Custom Work Records |
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Soil, Water and/or Crop Tests
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(5) |
Harvest Records |
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(i) |
Field Identification for each given crop |
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(ii) |
Machinery Cleanout Logs |
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(iii) |
Date of Harvest |
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Amount of Crop Harvested |
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(v) |
Sap Collection Records/Syrup Production Records |
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(vi) |
Sales Records if sold from field |
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(vii) |
Weigh Slips |
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(viii) |
Transportation Records |
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(ix) |
Storage Records |
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(x) |
Records of any Post Harvest Handling or Processing |
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(xi) |
Inventory of Product brought to public or farmer's markets |
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(xii) |
CSA Distribution Records
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(6) |
Livestock / Poultry Records |
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Breeding and Birthing Records |
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(ii) |
Hatching Records |
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(iii) |
Feed Records (including source and feed rations) |
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(iv) |
Health and Medication Records |
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(v) |
Tagging and Identification Records |
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(vi) |
Milk Pickup & Quality Reports |
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(vii) |
Egg Collection Records |
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(viii) |
Loss/Cull Records |
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(ix) |
Access to Pasture Records
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Processing Facility Records |
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Schematic Drawing of Facility |
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Production Flow Chart |
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(iii) |
Delivery Records |
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Incoming Bill of Lading |
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Receiving Records |
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(vi) |
Equipment Cleanout Logs |
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(vii) |
Packaging Reports |
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(viii) |
Daily Operations Reports |
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(ix) |
Inventory Records of both Raw & Finished Product |
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(x) |
Outgoing Bill of Lading |
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(xi) |
Pest Control Log
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(8) |
Sales Records |
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(i) |
Records of what is sold as organic and as non-organic |
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(ii) |
Sales Invoices |
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(iii) |
Farmer's Markets Daily Sales Totals |
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Shipping Records |
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(v) |
Transaction Certificates |
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(vi) |
Organic Transaction Monitor Forms |
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(vii) |
Income Ledger |
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(viii) |
Lot Numbers |
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Guidance for Federal Rule § 205.105:
Certified organic producers are required to report use of all materials. Applicants receive an Applied Amendments/Spray Record Form, which is used to list all amendments/sprays used during the year. A completed copy of the Applied Amendments/Spray Record form must be submitted to the Certification Program prior to annual information update in the following year.
8. Seeds and Planting Stock, Resourcing and Management Recommendations
Guidance for Federal Rule § 205.204:
If the producer cannot obtain organically grown seed because a particular variety is not commercially available, the producer should keep records of the effort to locate sources of organic seeds such as letters, phone logs of discussions with suppliers, or catalogs on hand for the inspector to review. It is recommended that at least three suppliers be checked to determine if a particular variety is not commercially available.
You cannot determine your own emergency for use of non-certified transplants. You must contact the Certification Program and request a variance from the USDA AMS Administrator. Use of non-certified transplants, without variance approval, is prohibited.
Microbial inoculants are permitted for use on seeds, providing that they are not derived from genetically engineered materials (excluded methods). Seeds produced with excluded methods (genetically engineered) are prohibited. Seeds with clay based palletizing, which do not contain synthetic materials, or excluded methods, may be used.
9. Materials for Use in Organic Production
When management practices are insufficient to prevent or control pests 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, Section 205.601 through 205.607, may be used by operations certified by NOFA-NY Certified Organic, LLC.
Guidance for Federal Rule § 205.206:
The Program suggests farms dispose of agricultural plastic at their local landfill until such time that recycling programs are offered for these classes of plastic. When recycling programs are offered, farms should recycle these plastics. Burning or on-farm burying of agricultural plastic is prohibited.
The Federal rule allows dual use of spray equipment, therefore the purchase of used sprayers is allowed, provided proper cleaning procedures are performed and documented. This cleaning should include the replacement of nozzles, tubing and screening. Farmers are encouraged to try to obtain a history of what substances have been used in the sprayers in the past. The Program has information on recommended procedures for cleaning spray equipment.
This prohibition applies to lumber used in direct contact with organically produced and handled crops and livestock and does not include uses, such as lumber for fence posts or building materials, that are isolated from production. The prohibition applies to lumber used in crop production, such as the frames of a planting bed, and for raising livestock, such as the boards used to build a farrowing house, or bunk silo.
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Notify neighbors of the organic status of the applicants farm, either verbally or in writing;
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Notify the utility company, in writing, of the organic status of farm, and request no spraying be done, if utility has a right of way or transmission line on the organic farm; a follow up by phone should be done in subsequent years;
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Notify state or local highway departments, in writing, of the organic status of farm, and request no spraying be done, if spraying is done along roadside frontage; a follow up by phone should be done in subsequent years;
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Notify local health department, in writing, of the organic status of farm, and request no spraying in the event of pest or disease control; a follow up by phone should be done in subsequent years.
Organic farmers should
make every effort to be aware of, and to prevent all possible sources
of such contamination of fields, irrigation water and facilities.
Applicants should:
Copies of all letters must be sent to the Program office, and also retained by you.
The term split operation refers to an operation that produces or handles both organic and non-organic agricultural products. Split Operations allow for the possibility of confusion or fraud that could result in non-certified products being mislabeled and sold as Certified Organic. It is the responsibility of the grower to submit management plans that prevent co-mingling.
Split Operations utilizing the same planting, cultivation and harvesting equipment must clean out equipment prior to use on organic fields and crops. Records of equipment cleaning must be documented on a Cleanout Log and maintained in your records. Planting equipment should be free of residue of seed treatments and chains should be removed from fertilizer boxes prior to use for planting organic crops.
12. Genetically Altered Materials, Plants & Crops
The use of genetically
engineered materials (see definitions: excluded methods) is
prohibited under the National Organic Standards. This includes
all genetically engineered food crops and other agricultural products
including, but not limited to:
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Transgenic Seed |
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Plants and seed bred to produce BT toxins |
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Herbicide tolerant plants |
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Bacteria that prevent frost damage |
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(5) |
Bovine growth hormone (rBGH) or bovine somatotropin (rBST) |
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(6) |
Vitamins derived from genetically engineered sources |
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(7) |
Enzymes derived from genetically engineered sources |
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(8) |
Seed & forage inoculants derived from genetically engineered sources |
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(9) |
Food processing materials derived from genetically engineered sources |
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Vegetable meal fertilizers, such as alfalfa & soy meal, produced from conventional crops |
13. Land and Buffer Zone Recommendations
Guidance for Federal Rule § 205.202:
A minimum 50 ft. buffer zone is recommended where a certified field adjoins conventionally managed lands, including both farmland and residential areas. Buffer zones should be under the management control of the certified farmer.
A minimum of a 250 ft. buffer zone is recommended if an air blast sprayer is used on the adjoining non-certified land.
A minimum of a 660 ft. buffer zone is recommended if planting an organic crop next to the same species genetically engineered crop. If wind or insect pollination can occur, testing may be required to ensure the crop has not been genetically contaminated.
A minimum of an 800 ft. buffer zone is recommended if adjoining non-certified land is aerially sprayed.
Buffers can include windbreaks and living barriers such as a dense hedgerow. A dense hedge row less than 50' may offer better protection from contamination than a 50' open buffer zone. These Standards prohibit a field's buffer zone to be planted to the same crop, with the exception of hay and pasture fields.
Crops grown in the buffer zone area may not be marketed as certified organic, or used for feed or bedding for certified livestock or dairy cattle.
The buffer zones above are based on research results and are provided to ensure that the organic crop is not contaminated. A reduction of the buffer zone size recommendations should be requested on a case-by-case basis. Justification for a different buffer zone should be provided in the application/request and approval will be granted as part of the certification review committee decision on the farm. Additional information and testing may be required.
A farmer who maintains organic production in accordance with these Standards, on non-certified fields (i.e. transition fields, adjacent to certified fields) is exempt from a buffer zone provided no prohibited substances are used since January 1 of current year.
It is the responsibility of the organic farmer growing corn and soybeans to verify with neighbors whether GMO crops of same species are being grown on adjoining land. Farmers will be asked to provide documentation from the neighbor about the crops being grown. Applicants using seed and forage inoculants should obtain letters from the manufacturer that these are not derived from genetically modified ingredients, or production techniques.
14. Transition to Organic Production and Certification
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Implement organic management practices for fields, including crop rotation requirements
- Develop appropriate housing and pasture for dairy animals,
including young stock.
- Implement pasture and outdoor access in the winter for all
animals over 6 months old
- Discontinue the use of antibiotics, hormones, and dry cow treatments
- Search out and implement the use of alternative health care practices
(a) General Information on the Transition Recommendations
Farms wishing to pursue organic certification are advised to obtain a copy of the National Organic Program's National Organic Standards early in their transition process. To qualify for certification fields may not have had synthetic herbicides, pesticides, or fertilizers applied during the previous three years prior to harvest of the agricultural product. During the 3-year transition period since last use of prohibited materials, all Standards requirements must be followed. This includes the use of appropriate seeds, crop rotation systems, use of appropriate soil amendments, and use of pest and weed control practices and materials. Biological or botanical substances or a substance included on the National List of synthetic substances allowed for use in organic crop production, Section 205.601 through 205.607, may be used by operations in transition to certification.
First year applicants must be able to demonstrate through record keeping that the Standards requirements have been met in the previous three years. First year applicants must follow all National Organic Program Standards, including the requirement to use only materials approved for use by National Organic Program's National List. Use of non-approved materials will result in either refusal to accept the application or denial of certification.
A producer who is transitioning his/her land to organic production may apply for official transition status through NOFA NY Certified Organic, LLC at any time during the three- year transition period. Applying for transition status is optional and will in no way effect the official certification decision once land is eligible. The transitional status is similar to actual certification with complete paperwork and an on-site inspection.
If a farm decides to apply for official transition status, the certification office can issue a letter to insurance companies, FSA office, or other agencies as requested by the applicant, stating that the farm is officially transitioning their land to organic production through our organization. For each subsequent year, the Organic Farm Plan will need to be updated and inspection must take place (for verification purposes) in order to maintain continual transition status.
(b) Dairy Transition Recommendations
The certification of organic milk production involves both land and livestock management. The NOFA-NY Certified Organic, LLC Certification Program realizes the difficulty in the transition of a dairy operation to Certified Organic Production.
With the publication of the USDA Organic Rule, NOFA-NY Certified Organic, LLC new dairy herd transition time is now one year. The one-year transition period will allow farmers to become familiar with alternative health care practices, organize record keeping systems, and generally become familiar with organic production and certification requirements.
**Transition is a one-time whole distinct herd conversion. All of the animals that you wish to convert to organic must be on the farm at the beginning of transition. This is a one time opportunity for a conventional Dairy operation to transition their herd to organic production. All animals must be on farm at the beginning of the one year transition.
The one-year transition feed requirement is: 100% organic feed for a full year. Feed harvested from fields in their third year of transition that are included in the Organic Farm Plan may be used as part of the 100% organic feed requirement.
All other Certification requirements must be followed during the one-year transition period, including health care practices.
***Transition is defined as following all National Organic Standards completely***
Organic dairy farms are required to provide animals with managed pasture with edible forage throughout the grazing season. The use of antibiotics and hormones is prohibited. All certification requirements must be followed during the 1-year transition time.
The process of the NOFA-NY Certified Organic, LLC Organic Dairy Certification is a multi-step process. Farmers wishing to convert to organic production must first apply for Transition Status with the Program. During the sixth month of the transition period, the application for full certification is completed.
In order to begin the Transition process, a sufficient amount of land that is certifiable or in its third year of transition (T-3) must be available to provide adequate supplies of pasture and forage to meet the 100% organic feed requirement. Even with an organic premium, it is not always economically feasible for farms to purchase large amounts of organic forages and organic grains. To begin the Transition process, we use as a guide, a minimum of 1.5 acres of total certifiable land for each 1000# animal unit, or 90% of your fields.
All non-certifiable fields should be in transition at the start of the one-year dairy herd transition. It is understood that if a farm has non-certifiable fields, there must be a plan developed for separation of crops from non-certified fields, and a plan showing what these crops will be used for.
To Prepare for Transition Dairy Farms Should:
It is advisable for each producer to secure in writing, a market for one's organic milk. NOFA-NY Certified Organic, LLC is not involved in the marketing of organic products. Since transition to organic production is expensive and time consuming, it is in the best interest of each farm to secure a market before beginning the process.
It is important to familiarize yourself with the National Organic Standards. The first step in the process is to purchase an application packet and fill it out. Included with the application packet will be a Dairy Transition Questionnaire, which must be submitted with your application. **Please note: The date your application is received in the office is the date your transition officially starts; provided you are in compliance with the Organic Regulations at that time.
15. Livestock Production Recommendations
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Herd health plan, including medication record;
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Purchased animal records; and livestock sales record;
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Details of your herd identification system, including birth date or purchase date; this system cannot change within the certification year;
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Complete audit trail records, including harvest records, purchased feed records, and milk testing and shipping records.
Guidance for Livestock Production:
All producers must practice good husbandry techniques and provide their livestock with adequate housing and feeding facilities. Animals should not be over crowded, each animal should, at a minimum, be provided enough space to prevent abnormal behavior and be provided with daily outdoor exercise, weather permitting. Adequate supplies of clean water must be available for all livestock. Adequate clean and dry bedding, appropriate for the species is required. If bedding is consumed, then the bedding must be organically grown. The use of crops from buffer zones, newspaper or paper sludge products for bedding are not recommended.
Procedures such as castration, dehorning and removal of extra teats are permitted but must be performed at a young age, using the most humane methods available. Producers should avoid painful, disruptive procedures. Docking of calves or cows' tails is prohibited. The NOFA-NY Certified Organic, LLC Program will permit a farm that has cows with docked tails to enter the Certification Program. However; tail docking of replacement animals (both farm raised or purchased) is prohibited. Trimming of the beaks of poultry should be limited to a dimes width.
Pasture, dry hay and forages should be incorporated into the finishing ration of organic slaughter stock; the use of a grain-only finishing ration is prohibited for organic slaughter stock.
Calves on organic dairy farms must be fed organic whole milk, organic forages and grains.
The use of preservative treated lumber in the construction of animal feeders and bunk silos, where the feed comes in contact with the wood, is prohibited. Use of preservative treated wood in construction of new bunk silos is prohibited.
Good sanitation practices and adequate ventilation can prevent many problems. Many producers have used fly parasites for control of flies around barn areas with good results. Synthetic pesticide use in dairy facilities is prohibited.
All farms using agricultural plastic bale wrap, silage bags, etc., should develop a disposal plan. The Certification Program suggests farms dispose of agricultural plastic at their local landfill until such time that recycling programs are offered for these classes of plastic. When recycling programs are offered, farms should recycle these plastics. Burning or on-farm burying of agricultural plastic is prohibited.
All dairy animals to be marketed as organic beef must comply with all Standards for meat production, including the stock source requirements, organic feed requirements and medication limitations, from last third of gestation.
In addition to the certification application, farmers are required to maintain the following as part of their audit trail system:
Historically, Somatic Cell Count Reports and Bacteria Counts have been used as a measure of animal health. Over the long term Organic dairy farmers with good herd health plans, good sanitation and ventilation and pasture nutrition should meet Somatic Cell Count Level and Bacteria Count levels as established for payment of the milk quality premium. Annual averages must be kept below 400,000 SCC and 50,000 SPC. Farms having higher averages must implement a plan to reduce the count. The above counts are recommended for dairy cattle; dairy sheep will have a higher count.
Good sanitation practices in the barn, in the milking parlor and in the milk room, will limit problems and thus reduce use of synthetic cleaners.
Iodine based pre-milking dips, udder wash or wipes, and post-dips may be used if ingredients are in compliance with section 205.603 of the National List.
Equipment cleaning and sanitizing materials may be used provided ingredients are in compliance with section 205.603 of the National List.
Hydrated lime is prohibited for daily use in barns, 205.603 (b) (4).
Calves under 6 months should be provided with adequate space such as box stalls, tie stalls, loose housing or calf hutches. Due to feed contamination calves must not be tied in the manger area.
Animals over six months of age must be provided with daily access to outdoor exercise areas for the non-grazing season, weather permitting.
Poultry must be provided with meaningful outdoor access. Outdoor access must allow birds the opportunity to exhibit their natural behavior, have access to fresh air and direct sunlight, weather permitting, at the earliest age suitable for the type of bird. The poultry house should provide 1.5 square feet of floor space for chickens, and/or 3 square feet of floor space per turkey, for use during time of inclement weather. The use of cages is prohibited inside poultry houses.
The Certification Program encourages the use of rotated pastures and paddocks, whenever possible, for animal health and welfare reasons. Pasture should not be continuously grazed without rest. We recommend .75 acres of pasture per 1000# animal unit. Farmers seeking adjustment in the acres/animal unit requirement may submit a written management plan describing their system.
Ruminants must be provided with edible pasture throughout the grazing season.
Farmers are encouraged to begin pasturing of young animals as soon as possible. Animals from 6 months of age to one year must be provided with pasture and /or daily access to outdoor exercise areas. Animals over 1 year of age must be provided with access to pasture during the grazing season.
Short-term confinement for organic slaughter stock, with access to outdoor exercise area, is permissible for the finishing of slaughter stock.
Plans for temporary confinement must be described in the Organic Production System Plan and be approved by NOFA-NY Certified Organic, LLC.
Part (a) of Section 205.236 takes precedence over all other sections resulting in the requirement that once a farm is certified, all animals should be raised organically, following these Standards, including calves and all other young stock. Feeds from transitional fields and prohibited health care practices may not be utilized for any animals.
16. STANDARDS AND LABELS FOR CROPS WITH NO SPECIFIC USDA STANDARDS
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a bench system when all plant material is in pots, flats or bags and growth medium is renewed periodically;
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An in-ground system when plants, including those not for sale, are grown in grade or raised beds, not in pots, flats or bags. This requires the usual 3-year interim since last use of prohibited substances.
As Posted on the USDA Organic Program Website May 2, 2002:
National Organic Standards do not currently exist for apiculture, greenhouse, or mushroom production. Until USDA publishes National Organic Standards for such production methods, producers using such methods may continue to produce and label their products as organic, under the following conditions:
National Organic Program Scope
Producers and Handlers of any agricultural commodity or product, whether raw or processed, including any commodity or product derived from livestock, that is marketed in the United States for human or livestock consumption may seek certification under the National Organic Program (NOP) as an organic producer or handler. Please note, the term consumption is not limited to products that are used for food. To qualify for certification, the producer or handler must comply with all applicable production, handling and labeling regulations under the National Organic Program including the requirements concerning the use of natural and synthetic substances (the National List). To label a product as"100 percent organic," organic or made with organic (specified ingredients) the producer or handler must be certified by an accredited certifying agent.
Guidance for Federal Rule Greenhouse Production:
All greenhouse production practices, including the growing medium and pest & disease control must be in accordance with these Standards. Greenhouse production Certification is on a whole greenhouse basis.
A greenhouse is defined as any permanent, enclosed plant environment, with or without heat sources, including cold frames, on otherwise non-certified land. Example: tunnels on certified fields are not considered greenhouses, while your basement could be.
Production is considered:
In the construction of new greenhouses, growers need to avoid use of prohibited substances in their construction, including lumber treated with arsenate or other prohibited materials.
Takeover of an existing greenhouse must have prior approval of the Review Committee. An affidavit is required from the previous owner/operator pertaining to the practices and substances used during the past three years. Based on the past practices used, the waiting period may be a 3-year period, and / or may include replacement of plastic glazing and other materials.
A Certified greenhouse may co-exist with a non-certified house, as long as crops marketed from both are clearly distinguishable. Example: a nursery may certify one of several greenhouses for selling Certified Organically Grown transplants, but the pots and containers should be visibly different and clearly labeled. If certified and noncertified plants are produced in the same greenhouse, they must be clearly identified and segregated.
Guidance for Cut Flower Production:
All cropping practices must follow §§205.000-205.207 and §§205.300-205.311 of the federal rule plus greenhouse cut flower growers must follow the NOFA-NY Certified Organic, LLC greenhouse guidance standards. All post harvest materials to be used must be listed on the National List.
Guidance for Mushroom Production:
All mushroom production practices must be in accordance with these Standards. These include standards for crop production, woodlot management, and maintenance of a comprehensive audit trail.
When management practices are insufficient to prevent or control pests 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, Section 205.601 through 205.607, may be used by operations certified by NOFA-NY Certified Organic, LLC.
In split operations (i.e. producing both certified and non-certified mushrooms) production areas must be environmentally isolated to prevent cross contamination. Suggestions are to have production areas separated by permanent structures. Ventilation systems shall ensure that prohibited materials do not drift from non-certified area to certified areas. Individual rooms or areas used for mushroom production cannot have been treated with any material listed as prohibited by these Standards prior to inoculation of the growing medium and through the entire growing period.
Compost, substrate, spawn and dowels, must be produced according to these standards, and not contain materials that are prohibited for use under these standards.
Growing logs must be harvested consistent with good, sustainable woodlot management. The area that logs will be harvested from must be documented as free from treatment with prohibited substances for the previous three years. Producers who purchase logs must obtain an affidavit from the seller stating that no prohibited substances have been applied to the log harvesting area for at least three years.
The laying yard for the inoculated mushroom logs must be certified as a field. Outside growing areas should be protected from drift and are subject to the same buffer requirements as all certified fields.
Guidance for Maple Syrup Production:
All maple syrup production practices must be in accordance with these Standards. These include standards for woodlot management, and maintenance of a comprehensive audit trail.
When management practices are insufficient to prevent or control pests 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, Section 205.601 through 205.607, may be used by operations certified by NOFA-NY Certified Organic, LLC.
We encourage Maple Syrup producers to observe good forest management practices and refrain from over tapping of trees or the tapping of diseased trees or trees in decline.
Tapping should be based on the health and vigor of the tree determined by examination in both the winter and summer to view the leaf canopy. Tapping of trees greater than 10" in diameter at breast height; one additional tap for each 4" increase in diameter of tree is recommended.
Vacuum pumps are permitted to be used, with monitoring of the pressure levels at the tap. Producers should maintain as low a pressure as possible. Freshening of tap holes with use of same size drill is permitted.
The use of Para formaldehyde and other tap hole pellets in any tapped trees is prohibited.
Thinning of excess or diseased trees should be done on a regular basis to promote canopy development and general health of the sugar bush.
In Certification of Maple Syrup, the sugar bush is considered a field and all applicable standards apply to the management of the sugar bush. Only sap collected from a Certified sugar bush may be used in production of Certified Maple Syrup. If the sugar bush is located on rented land, a written rental or tapping agreement from the landowner, indicating year round compliance to National Organic Program's National Organic Standards must be included with application.
Inspection of maple syrup producing fields and facilities will be done during the tapping and production season for maple syrup.
Since the production of maple syrup is considered processing, the re-packaging of NOFA-NY Certified Organic, LLC syrup, with the intent to label as certified organic by NOFA-NY Certified Organic, LLC syrup, may only be done in certified facilities. A schematic diagram of the sugarhouse indicating processing and storage areas must be submitted.
Non-synthetic defoaming agents, including certified organic milk and certified organic vegetable oils should be used. This provides insurance that they most likely do not contain genetically engineered materials. Synthetic defoaming agents are prohibited unless included on the National List.
Filtering may be done with use of settling tanks, traditional cone or flat filters (paper, wool, orlon or nylon), or pumping through food grade diatomaceous earth filters. Other synthetic filtering media is prohibited unless included on the National List.
Cleaning of equipment may be done with a water flush, or with chlorine materials, if used as specified in the National List of materials.
A Reverse Osmosis machine may be used. If synthetic materials are used in the storage of this equipment, and these are not listed on the National List, it is required that every effort be made to clean & rinse these machines thoroughly before they are used for organic maple syrup production. A management plan for the use of this machine must be described in the application. Cleanout logs must be maintained.
Irrigation Water
In recent years, the ground and surface waters of New York State have been recognized as containing pollutants, notably nitrates and some of the widely and long used herbicides such as Atrazine. The water, whether for irrigation, stock, or washing fruits and vegetables, might contain prohibited substances, depending on a particular farm and its up-stream neighbors, previous use, or ground and surface water flow. Many of these materials are not tested for in the usual NYS Department of Health surveys, so often property owners aren't aware of the problems.
We recommend that producers and processors investigate sources of water for potential problems. These include up-stream land use (agricultural and industrial), neighbors with well problems, NYS Health Department information, and Soil and Water Conservation District Information. If there is any possibility of contamination we recommend that the water be tested for suspected pollutants. We realize that this is an additional expense to the farmer / processor, but also a responsible action to ensure the quality of products. The Review Committee can ask that water sources be tested.
Wash Water for Crops
Water used for washing of crops, including sprouts, must be documented to be potable. Municipal water sources are exempt from test requirement; all other water sources should be tested for coliform bacteria. An annual potable water test is required to be submitted with the application.
Guidance for Harvesting, Packaging, Storage of Organic Crops:
Harvest, storage and market delivery should assure maximum freshness and nutritional quality of food products. Harvest, storage and shipping of all certified organically grown products should be with the least possibility of contamination. If contamination should occur, with the producer's knowledge, he/she shall notify the Review Committee immediately in writing and shall not market that contaminated product labeled as certified organic.
Equipment
Crops should be harvested at proper maturity and in appropriate weather conditions. Equipment used for harvesting both certified and non-certified crops should be thoroughly cleaned prior to the harvest of the certified crop. In the case of field crop harvesters it is recommended that the equipment be thoroughly cleaned; then harvest 50' - 75' of the certified crop and purge this amount of crop. The clean out of equipment should be documented on an Equipment Clean Out Log.
Cooling
Perishable products need immediate cooling and careful handling to avoid injury. Acceptable storage conditions include regular, cooled, or controlled atmosphere (CA, to be so marked). Manual and mechanical control of temperature and humidity is permitted, as is ice, or cold water-cooling depending on water source.
Storage
Storage areas for certified organic crops should be a dedicated area that is clearly labeled, especially if conventional crops are also stored at same location. Microbial inoculants are permitted for use on forages, providing that they are not derived from genetically engineered materials (excluded methods).
Pest Control in Storage
See Section 205.271, Facility Pest Management
Packaging Materials
See Section 205.272, Commingling and Contact with Prohibited Substance
The following constitute the principle objectives of NOFA-NY Certified Organic LLC's program:
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To replenish and maintain long-term fertility by providing optimal conditions for soil biological activity.
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to produce high quality, nutritious food and feed.
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To reduce pollution that may result from farming and processing systems.
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To encourage "closed cycle" farming systems using local resources & nutrient recycling.
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To enhance biological cycles within the food production system.
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To maintain genetic diversity in an agricultural system and its surroundings, including protection of native plant & wildlife habitats.
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To encourage non-exploitive treatment of farm workers.
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To create conditions for livestock that ensures them a life free of undue stress, pain and/or suffering.
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To maximize farmers' monetary returns and satisfaction for their work.
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To maintain the land in healthy condition for future generations.
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For more information call 607-724-9851 or certifiedorganic@nofany.org
Copyright © 2007 Northeast Organic Farming Association of New York, Inc. All rights reserved.
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