Brian Baker, Organic Materials Review Institute
Jim Riddle, University of Minnesota
Organic standards require that operators maintain and improve the quality of natural resources. Practices to achieve this goal must be part of a management plan. Every certified organic producer is required to develop a production or handling system plan, also known as the Organic System Plan (OSP).
The OSP serves several purposes for an organic farm.
- The OSP is a forward-looking management tool that takes into account future states and conditions. As such, it helps the farmer anticipate challenges and make rational decisions, rather than react to crises.
- The OSP is a description of the human and natural resources that a farm has as its productive capacity. When implemented, the OSP can help a farm more fully develop its potential and use available resources more efficiently and effectively.
- The OSP is an economic tool. A well-constructed OSP can help an operator budget for the coming season’s expenses and income, and sustainably fulfill the potential to be viable both economically and ecologically.
- The OSP serves as a legally binding contract between the certifier and the certified operation. Once a certifier approves an OSP, the farmer has a written guarantee from the certifier that those practices and materials are acceptable. Not following the OSP can result in denial or loss of certification.
Agricultural professionals who work with certified organic clients have to work within the OSP. Advice and recommendations will need to fit within the OSP in order to not jeopardize organic certification. Operators often seek advice after other options in the OSP are exhausted. Before an agricultural professional can give any advice to a certified organic operator, the professional should find out if the recommended practice will fit into the OSP. Even if a material is registered for a certain crop and complies with organic standards, application outside the OSP can still cause problems with certification. While it is possible to amend the OSP, it is better to think ahead.
The National Organic Program (NOP) final rule (United States Department of Agriculture [USDA], 2000) requires that an Organic System Plan include:
- Practices and procedures to be performed and maintained;
- A list of each substance to be used as a production or handling input;
- Monitoring practices and procedures to be performed and maintained;
- A description of the record keeping system;
- Practices and physical barriers established to prevent commingling with conventional food and contact with prohibited substances; and
- Any additional information needed to document NOP compliance.
1. Description of Practices
Farmers need to describe explicitly how they plan to manage their resources. The OSP should document any soil and water conservation practices intended. An OSP could include a description of tillage practices, irrigation methods, planting of hedgerows, stream buffers, drainage, manure handling practices, composting facilities, and crop rotations.
Livestock operations should describe how nutritional needs will be met, preventive strategies used or planned for use to maintain animal health, how access to the outdoors will be provided to animals, how the land where animals are kept will be managed, any physical alterations used or planned for use, and measures implemented to reduce stress.
Descriptions should include the tools, inputs, and equipment to be used or planned for use; the estimated frequency of practices; and the methods to be used to carry them out. Agricultural professionals can assist in the preparation of OSPs by providing farmers with an inventory of tools, inputs, and equipment available; the best available practices for the field conditions in the region; and estimates or models to help farmers optimize the timing of their practices.
2. List of Substances
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, is required in the OSP. In general, the composition and source of materials requires specific information on brand name products. All ingredients in farm inputs need to comply with the NOP Rule.
The planned locations for the application of fertilizers and pesticides must be described or recorded on a farm or field map. As a management tool, the OSP can help to prepare budgets and improve the efficiency of input applications. Precise descriptions of planned inputs help to document material purchases and applications during inspections. The NOP Rule restricts substances not included in the OSP. If a material not listed on a producer's OSP is considered for use, the certification agency must be contacted in advance, and the OSP must be amended to include information on the new substance and its intended use.
In general, any substances permitted as pesticides may be applied only if they are contained within the OSP and other preventative measures prove ineffective. Therefore, it is crucial that all inputs used during a season are included in the OSP prior to their application and the conditions for their application are clearly documented. Unanticipated production problems that result in the application of restricted materials will require revision of the OSP, and may result in difficulties during inspection, if not well documented.
Livestock operations must document feed ingredients, health care products, and production aids in the OSP. The OSP should include the projected sources of organic livestock feed and all feed supplements. Operators should be able to predict how much feed and forage will be produced on the farm, the dietary contributions of pasture and range, how much feed will need to be purchased, and what backup sources are available in case of crop failure, drought, or tight future market conditions. Farms that use non-organic feed additives and feed supplements must document the specific nutritional needs to be met by these non-organic feed ingredients and describe why organic sources are insufficient to meet these needs. The OSP should also document any vaccinations, inoculants, animal drugs, or treatments that will be used in anticipation of common health problems or endemic diseases.
3. Monitoring Practices
Maintaining the quality of the environment and meeting certain application standards requires that the operation describe how to measure and document compliance with required practices. For example, operations that make compost need to describe how they will monitor temperatures and record the number of times that the compost is turned. A number of synthetic substances require testing, either for a deficiency before a given nutrient can be applied (e.g., micronutrients), or for environmental degradation after the substance is applied (e.g., potassium chloride or copper fungicides).
If biopesticides, botanicals, or allowed synthetic substances are applied, the OSP should include a description of the minimum pest thresholds used to determine if and when specific crop protection materials will be applied, and describe how pests will be scouted. If copper fungicides are used, the OSP needs to document how and when soil accumulation of copper will be measured.
Livestock operations should provide information on how nutritional needs are met and how health care is maintained. For example, the OSP would include fecal examination schedules to document the need for internal parasiticides.
4. Recordkeeping System
Certification is based not only on compliance with the standards, but also on the ability to document compliance. The OSP must contain a description of the recordkeeping system, and a list of recordkeeping documents used or to be used. Operators must demonstrate how they are able to produce what they market as organic. During an audit, an operator must track the product all the way back to the field and how the field was managed for at least three years prior to production of the product.
Every input applied to soil, crop, or animal needs to be documented, with detailed information on the ingredients and brand names. Field operations, planting and harvest dates, yield records, sales, and chains of custody are all important documents for crop certification. Each animal must be tracked in a livestock operation, except in the case of poultry where recordkeeping is required for each flock. The recordkeeping system must record:
- All feed, including all feedstuffs, additives, and supplements;
- All animal drugs, treatments, biologics, remedies, and parasiticides administered;
- All alterations made and the steps taken to reduce stress, pain, and suffering in conducting those alterations; and
- The final sale or other fate of every animal, up to an animal’s sale for slaughter, sale of that butchered animal’s meat products, or death.
A handling operation’s recordkeeping system must account for organic agricultural commodities that are purchased, brokered, or otherwise handled on commission, as well as a record of every action that occurs at the processing facility related to the product, including equipment cleaning and pest control activities.
5. Contamination Prevention
Any operation faces potential loss of certification due to contamination resulting:
- From the mixing of non-organic and organic products (commingling); or
- From the contact of organically grown crops, organically managed soils, organically raised animals, or organic products with prohibited substances.
An operator needs to be able to demonstrate that the operation takes reasonable precautions to prevent contamination by prohibited substances from occurring. Operations that grow organic and non-organic crops are of particular concern. If contamination of a crop is subsequently discovered, a well-designed OSP and clear documentation can help establish that contamination was the result of circumstances beyond the farmer’s control. Unavoidable residual environmental contamination should not result in loss of certification of an operation, although a specific crop may lose organic status if the level of contamination exceeds 5% of the EPA tolerance.
6. Additional Information
The certifying agent may require additional information about certain aspects of the operation. If a grower has any doubt about a practice or procedure that the certifying agent may question, it is best to include it in the OSP. This can help resolve any doubts about the status of a practice and its acceptability in an organic system before the inspection. The ATTRA workbooks and compliance lists offer helpful further guidance for developing OSPs, and the ATTRA forms offer a suggested format (Kuepper et al., 2007). Most certifiers have their own formats.
References and Citations
- United States Department of Agriculture. 2000. National organic program: Final rule. Codified at 7 C.F.R., part 205. (Available online at: http://www.ecfr.gov/cgi-bin/text-idx?SID=a6a0935ddf00e166695f4c2138bd58d8&mc=true&node=pt7.3.205&rgn=div5) (verified 18 March 2010).
- Kuepper G., H. Born, and L. Gegner. 2007. Organic system plan (OSP) templates for certifiers [Online]. ATTRA National Sustainable Agriculture Information Service. Available at: http://attra.ncat.org/organic.html#overview (verified 18 March 2010).