What the organic grain inspector wants to see

Benjamin Clark, a former employee on a large Montana organic grain farm, now an organic farm inspector, provided perspective on organic grain certification at a Maine Grain Alliance meeting.

Clark is a staff inspector for the Maine Organic Farmers & Gardeners Association (MOFGA) Certification Services. MOFGA Certification Services provides USDA-accredited organic certification in Maine, New Hampshire and Massachusetts.

The National Organic Program (NOP) requires that organic farms provide specific records to their inspector during the annual inspection. The farmer uses these records to demonstrate that the farm is meeting the organic standard.

“Recordkeeping can be overwhelming. It can be complicated, but it doesn’t actually have to be,” Clark said. According to him, grain farms can actually be among the easiest farms to certify.

First, write an Organic System Plan.

The first step of organic certification is to submit an Organic System Plan (OSP) to a certifier. The point of the OSP is to document each process on the farm. This is because organic certification certifies process rather than product.

Clark said, “It would be unreasonable for us to test every single tomato, cucumber, bushel of wheat or whatever for pesticide residue.”

In the OSP, a grower documents how they will maintain the organic integrity of the grain crop as it transitions from seed to field to storage and then eventually the market.

The OSP is submitted to the certifier who then schedules a yearly annual inspection. The inspector’s job is to verify that what is documented in the OSP is actually what’s happening on the farm.

Next, share records at the inspection.

An inspector, like Clark, will want to see a lot of records during the inspection. The NOP does not stipulate what exact records are required; it simply specifies that the farm’s records verify compliance. This can be a relatively simple process on a grain farm.

“You are purchasing seed. You’re planting that seed. You’re harvesting it. You’re storing it. And then you’re selling it,” Clark said, “so that’s like five separate events that you would just need to have noted.”

The farmer needs to verify that they bought organic seed, planted it on organic land, harvested an organic crop and then sold it as organic.

Seed receipts, field histories (including receipts for any purchased inputs), harvest records and sales receipts will provide the verification.

The 13,000-acre Montana grain farm Clark worked on tracked this information in small notebooks kept in trucks, tractors and combines. Each operator was responsible for recording their name, date of operation, field name, the crop, total acreage of activity and the activity. Combine operators recorded the number of bushels unloaded, yield calculations and which storage vessel the combine unloaded into.

At the end of the season, the farm manager compiled the records into a master document to be used during their organic inspection. There are also computer programs specific to grain farming that can be used to track production.

The inspector then uses these records to conduct two audits: a mass balance audit (also known as an in/out audit) and a trace-back audit. The mass balance audit proves that the grower actually produced enough grain to justify their sales.

“If you sold $2 million worth of grain into the marketplace, we want to see $2 million of grain produced on your farm,” said Clark.

The trace-back audit verifies that the grain crop can be traced from its final sale back to its initial planting, with records proving compliance with organic regulations throughout the crop’s lifecycle.

Clark said it’s important for organic grain growers to know the exact capacity of each grain storage vessel. He said, “Knowing how much crop you have on hand and how much crop you produced and how much crop is in storage is going to make all of these audits be super easy.”

Finally, understand parallel production and buffers.

Parallel production refers to a farm that is selling both organic and conventional crops. On a grain farm, this is fairly common if the operation is transitioning additional acreage over time.

Recordkeeping becomes more complex when farms are handling both organic and conventional crops simultaneously.

For example, any equipment used to handle conventional crops must undergo cleaning procedures before handling organic crops again. This applies to combines, trucks, augers and storage bins. Farms must maintain clean-out records showing when equipment was cleaned between handling conventional and organic crops.

“You’re not getting in there with bleach and a toothbrush, but what you do want to say is ‘Look, I did what I could to make sure that whatever crop I handled with this equipment, there was no residue left that could contaminate the organic crop that I then went and harvested,’” Clark said.

Most farms used compressed air and/ or brooms to meet the requirement. On the Montana farm, they kept checklists and logbooks at each piece of grain handling equipment to record clean-outs.

Recordkeeping also becomes more complicated when organic grain crops are grown close to conventional ones. According to the NOP, organic farms must maintain buffers, and the buffers must be clearly documented in the mapping and recordkeeping systems. This demonstrates to the certifying agency that the farm is protecting their organic crops from surrounding non-organic acreage.

by Sonja Heyck-Merlin