by ANNA RABHAN
We’ve all seen the two bags of lettuce sitting side by side in the grocery store, one with the little green and white symbol that says “USDA Organic” and one without. Most of us make our decision based on cost and what we perceive as the benefits (or lack of benefits) of eating organic foods. The problem is that that perception is many times based on the limited understanding that an organic food was grown without synthetic pesticides and fertilizers. A better understanding of what’s really involved in getting USDA Organic certification could help us, the consumers, make informed choices.
The definition and purpose of USDA Organic certification is fairly simple. All that “USDA Organic” symbol really means is that it meets the set of standards the U.S. Department of Agriculture, specifically its National Organic Program, has set for farms, wild crop harvesting, or handling operations that want to sell their products as organically produced. It was a long road to establishing a system of regulation, but as of October 2002, all certifiers and all producers, processors and handlers who want to market their products as organic are required to be in full compliance (www.attra.ncat.org/attra-pub/organic_certification.html).
So what does “full compliance” mean? A good way to answer that question is to come along for the ride as St. Johns County farmers Francisco Arroyo and Vivan Bayona work to certify KYV Farm (www.kyvfarm.com). There are a mind-blowing number of regulations and requirements that vary according to an almost-as-mind-blowing variety of factors – one of them being what kind of production operation you want to certify – but it’s basically a five-step process.
First, the farmer has to choose a certifier. These third-party organizations, whether state agriculture departments or private entities, must be accredited by the National Organic Program to ensure that they understand and are using the same national standards. Cost was a major factor in KYV’s choice. “There are two certifiers in Florida right now,” Francisco says. “The one guy got really expensive because he charged you for every visit, every extra item that you label, and this other guy that I’m using, since he’s new, he’s giving me a flat fee rate, which is good.” His decision went a little faster because of the limited number of certifiers in the state. In California, there are currently 11 certifiers. Some only certify handlers, some only certify certain kinds of production operations, and so on. The farmer also has to weigh considerations such as the reputation of the certifying organization as part of the decision. “At least the guys here in Florida are very reputable,” Francisco says, “because there are some certifiers in California that lost their accreditation because of the way they were doing business.”
Once the certifier has been chosen, the farmer requests an application packet and pays the application fee (the first of many, many fees) if there is one. Fortunately, KYV was able to get help from someone with a lot of experience. “If you do this by yourself, it can be overwhelming,” Francisco says. A small sample of the information the farmer might have to provide includes soil fertility planning, weed and pest management practices, storage and handling routines, soil and water tests, farm maps, crop and input histories, strategies for preventing contamination by prohibited substances and non-organic products – the list goes on. “All my equipment has to be listed,” says Francisco, “and I have to keep two sprayers if I’m going to have conventional and organic acreage, even when I spray the same biologicals on both. That’s an expense we’re going to have to have.” Upon submission of the application, the farmer might sign a licensing agreement with the certifier and pay another fee. The certifying agency then reviews the application and requests any additional information it may need. This is called the “completeness review.” If that information includes more soil tests and the like, the farmer pays the fees for those tests. There may also be a charge for re-submitting the application. KYV just finished this step.
After the certifier decides the application is complete, they send out an inspector for the on-farm inspection. The inspector is there to verify that the farm actually does operate according to the information in its application. Everything down to the last shovel is inspected, and risks for contamination by prohibited substances or commingling with non-organic products are assessed. The inspector reviews records of management practices, seed sources – in short, everything. The meticulous record keeping required has also necessitated another major expense for KYV. “We’re going to change the CSA management tool,” Francisco says. “We’re going to go with [Internet-based] Farmigo. They have a section in the program I can use to record all of my inputs and everything I need to provide for the inspector every year.” He’s hoping their inspection will happen by the end of April.
One specific, basic requirement that seems to stop a lot of growers from pursuing certification is, as explained by the National Sustainable Agriculture Information Service, that “prohibited substances (synthetic fertilizers and pesticides, etc.) must not have been used on the land for three full years preceding harvest of the first organic crop.” That’s one reason KYV uses organic practices on all 80 acres, not just the 20 they’re hoping to certify. “Little by little, I think we’re going to be able to move some of that land into organic,” Francisco says. If the inspector is contracted by the certifying agency, there may be an additional fee the farmer pays for the inspection or the cost may have been included in what the farmer initially paid the agency. The inspector and farmer sign an inspection affidavit, and the inspector reviews any non-compliance issues identified with the farmer before finally submitting his or her report to the certifier.
The last step is the final review. The certifier reviews the application and inspection report and can take one of four steps: approve certification, meaning that the farmer can begin marketing his or her products as organic and using the USDA Organic seal; request more information; notify the producer of noncompliance, meaning that certification will be granted if certain things are done or changed; or deny certification. The farmer can then anticipate yearly certification renewals, each requiring reinspection.
It’s worth noting that the fees mentioned were general possibilities, and there’s a good reason specific dollar amounts are absent. The fee structure for the certification process can be ridiculously complex. In addition to the administrative fees mentioned, there can also be additional fees based on any combination of acreage, annual sales, type of crop, type of processing or handling that goes on – you get the idea. So unless a farmer finds a certifier willing to charge a flat rate like KYV has, one really can’t say, “It costs X amount of money to get certified.” It is apparent, however, from looking at examples of fees charged that it is quite costly. That’s one reason why many farmers, even ones who already use organic practices like Francisco, don’t pursue certification and why, of the ones who do, many only certify a portion of their acreage. “Once you pass the 20-acre mark, the price [for certification] increases considerably,” says Francisco.
In considering getting certified, the farmer who already uses organic practices has to balance whether his or her customers are comfortable or want assurance with the costs of being able to market products as organic (which may have to be passed on to the consumer) and the hassle of getting, and staying, certified. Francisco analogizes, “People know what we do, but some people really need that piece of paper. It’s like your bachelor’s degree; you can have 15 years of experience but if you don’t have your bachelor’s degree, you don’t get paid for it.” So the next time the choice of organic, certified organic or conventional presents itself, you can make it armed with a better understanding of how that USDA Organic label got there and what it means.
The Organic Adventurer
by ANNA RABHAN