Organic Industry Part II: Certification & Accreditation Process

By Cecelia Taylor

If you’re thinking of entering the organic food business, the following article will give you a better understanding of what it means for a product to be “organic” and how food producers and handlers can become organic-certified.

The U.S. Department of Agriculture (USDA) defines “organic” as a labeling term that denotes products produced under the authority of the Organic Foods Production Act. The main guidelines for organic production are to use materials and practices that enhance the ecological balance of natural systems and that integrate the parts of the farming system into an ecological whole.  For a primer on the organic food businesses, read part one of this series, Understanding the Organic Food Industry.

How to Become a Certified Organic Producer or Handler

Organic certification is the process where a producer or handler is approved by an Accredited Certifying Agent (ACA) as being in compliance with theNational Organic Program (NOP) regulations. Only after a producer or handler has been certified are they legally authorized to sell, label, or represent products as being “certified organic”.

Outlined below is a summary of the Department of Agriculture’s five step process on how to become a certified organic provider or handler.

1. Application

If you are a producer or handler interested in becoming organic certified, you will need to contact an accredited certifying agent (referred to as an ACA or certifying agent) to begin the application process. Consult the list of organic certifying agents provided by USDA to find one in your area. The certifying agent will provide you with the application and information on any fees associated with your organic certification.

One of the most important parts of the application process is preparing your Organic System Plan (OSP). An Organic System Plan should include:  

• A description of practices and procedures to be performed and maintained, including the frequency with which they will be performed.
• A list of each substance to be used as a production or handling input, indicating its composition, source, location(s) where it will be used, and documentation of commercial availability, as applicable.
• A description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed. A description of the record-keeping system implemented to comply with the requirements established by the NOP.
• A description of the management practices and physical barriers established to prevent the mixing of organic and nonorganic products and to prevent contact of organic production and handling operations and products with prohibited substances.

2. Review of the Organic System Plan

Once you’ve submitted your application, the certifying agent reviews it for completeness and determines if your plan complies with the NOP regulations. The certifying agent also verifies that all inputs and ingredients listed in the Organic System Plan comply with the NOP regulations. Certifying agents base their review of materials on different resources that provide a list of materials already reviewed for use in organic production.

If your application appears to comply with the organic standards, the next step is an in-person inspection with the certifier.

3. Inspection

Upon approval of the application and the Organic System Plan, an inspection is scheduled. Inspections are not consulting visits, so do not expect inspectors to provide any advice or guidance. The purpose of the onsite inspection is to:

• Assess whether the operation is in compliance or has the ability to comply with the NOP regulations.
• Verify that the Organic System Plan accurately reflects the activities of the operation.
• Ensure that prohibited substances have not been applied.

An inspection of a production unit, facility, or site that produces or handles organic products includes, but is not limited to the following:

• Evaluation of the Organic System Plan that the producer or handler maintains on-site. This evaluation assures that the producer or handler has an up-to-date plan, is implementing the plan, and that the plan is compliant with the NOP regulations.
• For organic crop producers – evaluation of soil management, adjoining land use, buffers, land history, production capacity of the land, seeds and planting stock used, crop rotation practices, pest control practices, harvest, labeling and shipping.
• For organic wild crop harvest producers – evaluation of designated harvest areas, sustainable harvest practices and procedures that ensure an adequate audit trail.
• For organic livestock producers – evaluation of soil management, adjoining land use, buffers, land history, seeds and planting stock used, health care practices, origin of livestock, livestock living conditions, evaluation of conditions for temporary confinement of livestock, and pasture management practices.
• For organic handlers – evaluation of receiving, processing, pest control, storage, labeling and shipping as well as practices to prevent commingling and contact with prohibited substances.
• Verification of the production or handling capacity of the operation.
• Reconciliation of the volume of organic products produced or received with the amount of organic products shipped, handled and sold.

Upon completion of the inspection, the inspector conducts an exit interview. At the exit interview, the inspector communicates any compliance issues and may request additional information. The inspector will provide a receipt for any samples taken and once finished, the inspector sends the report to the certifying agent for review.

4. Review of Inspection Report

Next, the certifying agent evaluates the inspection report, the Organic System Plan, the results of any analyses conducted, and any additional information provided from the producer or handler.

The certifying agent assesses the level of compliance and makes one of the following certification recommendations:

• Certification
• Certification with conditions
• Noncompliance
• Denial of certification

During the certification process the certifying agent may conduct additional announced or unannounced onsite inspections to verify continued compliance with the NOP regulations.

5. Certification Decision

Though processing times vary, the USDA attempts to provide a response within a reasonable period of time. 

The certifying agent may issue certification with conditions for minor, non-volatile issues (for example, establishment of adequate buffer zone, development of compliant labels).

Once certified, the operation’s certification remains in effect until surrendered by the operation, or suspended or revoked by the certifying agent, the State organic program, or the Administrator of the USDA Agricultural Marketing Service.

Renewing Certification & Annual Update

 Anyone interested in obtaining an organic certification should keep in mind it is an ongoing process. Once certified, the organic producer or organic handler is responsible for the following activities to maintain their certification.

An operation must annually submit to their certifying agent:

• An updated Organic System Plan,
• Any fees owed,
• Updated contact information,
• An update on the correction of any previously identified minor noncompliance’s, and
• Other information as deemed necessary by the certifying agent

Resources:

• NOP Program Handbook
• NOP Draft Guidance Documents