2020 Starting an Organic Grain Farming Operation – Clayton Blagburn Presentation
Starting an Organic Grain Farming Operation – What You Need to Know Program held Thursday, Jan. 30, 2020 at the University of Nebraska Eastern Nebraska Research and Extension Center. Organic Certification- From Application to Certification Decision presented by Clayton Blagburn, Certification Specialist - OneCert Organization Inc.– Lincoln, NE.
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[00:00:21.919]I'd like to introduce Clayton Blagburn,
[00:00:24.550]he works for OneCert.
[00:00:26.640]And OneCert is a certification agency
[00:00:30.787]out of Lincoln, Nebraska.
[00:00:33.410]And he's been involved in the organic industry
[00:00:36.755]since he started working at OneCert in 2017.
[00:00:42.630]He's a certification specialist.
[00:00:45.270]And he's involved with certified operations
[00:00:48.870]and takes called from prospective clients.
[00:00:52.320]His area of expertise is handling and processing operations.
[00:00:58.263]And he's ready to talk about the certification process
[00:01:01.300]and what it all involves there.
[00:01:05.520]So, Clayton, welcome, and thanks for coming today.
[00:01:09.760]All right, thank you Gary.
[00:01:11.170]Can everyone hear me fine?
[00:01:14.020]Okay, I'll speak up then.
[00:01:15.650]I'm here to talk about organic certification.
[00:01:19.570]Mainly how to apply for certification, what that looks like,
[00:01:23.250]what happens after we get your application,
[00:01:26.917]and on through the process here.
[00:01:31.920]Presentation I've got it broken into two parts,
[00:01:34.770]I'll first talk about the logistics of certification
[00:01:38.228]and the general requirements.
[00:01:40.890]And then we'll go into
[00:01:41.810]what an organic system plant actually is,
[00:01:44.010]what do the regulations say that you need to spell out.
[00:01:48.035]That goes along with the OneCert forms,
[00:01:51.410]I'll go regulation, form, regulation, form,
[00:01:54.895]they tie together nicely that way.
[00:01:57.584]I'll talk about notice of non compliance,
[00:01:59.800]what to do when you get one,
[00:02:01.650]if you're certified
[00:02:02.540]you're likely gonna get one at some point,
[00:02:05.120]no need to worry.
[00:02:06.160]And then hopefully that gets us some questions.
[00:02:09.230]Hoping to answer more than I create,
[00:02:11.870]but we'll see how that goes.
[00:02:13.860]I do also want to talk about crop rotations,
[00:02:16.940]I know that's something that came up
[00:02:19.240]throughout the last talks.
[00:02:20.770]There was some valid information
[00:02:22.150]but maybe a bit misleading.
[00:02:24.330]So I wanna go through that.
[00:02:26.550]A little bit here about OneCert,
[00:02:28.160]we're a local certification agency.
[00:02:30.433]I took some numbers, you can see here,
[00:02:33.630]all of our clients, just some crops here in the region.
[00:02:37.330]Sam Welsh is our president,
[00:02:38.880]he is at the NOP training now,
[00:02:41.520]just accepting a couple of these awards here.
[00:02:44.790]The integrity data quality award,
[00:02:47.550]and the directors award for investigating fraud
[00:02:51.620]with other certifiers.
[00:02:52.720]So if you're trying to pull something over someone,
[00:02:54.870]probably choose a different agency.
[00:02:59.570]12 employees about five of us are specific to producer.
[00:03:04.820]I deal with handling,
[00:03:06.240]but I am involved with the inputs committee with OneCert
[00:03:10.080]and other certifiers have a working group
[00:03:13.940]discussing commercial availability of flavors.
[00:03:16.770]So I am pretty privy to how to interpret regulations.
[00:03:24.100]Here we go with the basics of certification.
[00:03:26.850]Five steps, this is from the program handbook,
[00:03:30.500]a good resource, at 2601,
[00:03:34.200]so you need to come up with a plan and describe it.
[00:03:38.760]That's step one there.
[00:03:40.320]Implement your OSP and we will review it
[00:03:43.970]with the application
[00:03:46.170]to see if it complies
[00:03:47.440]once we determine you may be able to comply,
[00:03:51.460]you'll be inspected.
[00:03:53.090]We'll review your report
[00:03:54.700]and determine if you can get certification.
[00:03:57.920]That's it in a nut shell.
[00:04:00.380]I like this part I saw in Dave's speak about
[00:04:05.250]you gotta have a reason for it.
[00:04:08.340]Here it is your production practices,
[00:04:10.610]maintain and improve resources.
[00:04:14.740]That's a pretty good reason,
[00:04:15.740]I know Genesis is pretty sound with that.
[00:04:18.745]The Lord put the man in the garden to care for it
[00:04:21.850]and maintain it.
[00:04:23.130]So whatever your reason may be,
[00:04:25.020]that's at least a good one there.
[00:04:27.780]Here's the general requirements.
[00:04:30.190]You've gotta comply with the act and the regulations.
[00:04:34.340]So to break that down,
[00:04:35.960]I've got some visual representations,
[00:04:38.530]here's the act, here are the regulations.
[00:04:41.140]They're two different things.
[00:04:42.540]One brings up the law establishing marketing
[00:04:47.250]and that you have to follow the regulations.
[00:04:50.230]To follow, here they are.
[00:04:52.150]These are what you have to go through
[00:04:55.340]in order to comply.
[00:04:56.850]Emphasis here on number F.
[00:04:59.477]I talked about non compliances,
[00:05:01.390]this is a pretty big easy one
[00:05:03.960]to write someone a non compliance for.
[00:05:05.680]You did not immediately notify your certifying agent
[00:05:08.279]of any application or change in your certification.
[00:05:17.930]So you know, if you have to change your seeds last minute,
[00:05:20.408]we're more than willing to work with you,
[00:05:23.591]but if we find something at inspection,
[00:05:25.990]there's gonna be a problem.
[00:05:31.410]Here we go with the transition period.
[00:05:33.870]Jumping right in, I wanna get a feel for the room,
[00:05:37.570]has anyone applied for certification or is certified?
[00:05:42.855]Okay, a few people.
[00:05:44.670]Is anyone transitioning, or think they have transitioned?
[00:05:49.090]Okay, so the rest of you.
[00:05:50.140]A lot of you maybe are just thinking about it here
[00:05:52.880]for some information.
[00:05:55.650]Clarify here, the three years,
[00:05:58.290]that's 36 months.
[00:05:59.590]So if you can document that your last application date
[00:06:02.550]was on June 2018,
[00:06:05.060]then you can harvest and sell crops
[00:06:07.700]after June 2021 for sale as organic.
[00:06:11.574]So the key part here
[00:06:13.250]is documenting that last application date.
[00:06:16.360]If you're the owner, manager of the land,
[00:06:18.050]that's a little easier.
[00:06:19.810]It gets more complicated from there.
[00:06:23.483]Does CRP enrollment
[00:06:26.154]qualify as applications?
[00:06:30.979]Well what do you mean by that?
[00:06:31.880]If you're taking land out of CRP...
[00:06:35.063]What is CRP?
[00:06:37.130]Oh, conservation resource-
[00:06:39.090]Okay, yeah if you haven't,
[00:06:42.103]it's prohibited substance,
[00:06:45.290]if you haven't applied prohibited substances.
[00:06:49.000]Well if you didn't spray the tree,
[00:06:50.210]you know kill the trees, I can tell you they were
[00:06:52.430]killed obnoxious weeds like musk thistle.
[00:06:54.820]If you never sprayed it with anything you're okay.
[00:06:58.020]Yeah I just don't know
[00:06:59.445]what the documentation is gonna be, that's why I was asking.
[00:07:02.321]If you could just show that you were in the CRP program
[00:07:05.100]that prohibits any-
[00:07:06.370]So that gets into record keepings,
[00:07:08.360]I will touch onto that.
[00:07:10.290]But you know documentation, you basically need to write down
[00:07:13.460]what you do every day,
[00:07:14.540]that's the gist of that.
[00:07:17.387]And what you buy.
[00:07:19.400]Here you can read through the application.
[00:07:29.490]So you know one thing,
[00:07:30.770]all of our forms are available online,
[00:07:37.420]The wording in there is complete your application
[00:07:39.750]three months prior to certification.
[00:07:42.740]Before your harvest,
[00:07:44.420]so you have to be inspected,
[00:07:46.060]there's some timing issues there.
[00:07:48.260]Renewals for all of our existing clients are due March 31st.
[00:07:52.370]So if you're looking at getting an application in
[00:07:54.530]for this year, you should do it now.
[00:07:57.090]So we can start looking at things.
[00:07:59.430]The way OneCert does it,
[00:08:00.730]we have, an initial review is broken down into completeness
[00:08:04.510]and then someone will dig into compliance.
[00:08:07.327]But they're gonna review all of your inputs, et cetera.
[00:08:10.800]We do need to know if you were previously certified,
[00:08:13.680]we're required to follow up with the other agency
[00:08:16.280]to make sure you've corrected anything.
[00:08:19.360]And then from there, we can schedule the on-site inspection.
[00:08:23.310]The purpose of the
[00:08:25.010]we'll review it to the key words here
[00:08:27.070]may be able to comply,
[00:08:28.490]so you tell us what your plan is,
[00:08:31.600]we'll look at your plan,
[00:08:33.470]and then send out an inspection
[00:08:35.950]to make sure you're following your plan.
[00:08:38.689]It's not a consulting visit,
[00:08:40.480]they're definitely gonna ask questions,
[00:08:42.040]provide information, clarification,
[00:08:43.990]but they're not gonna tell you
[00:08:45.960]how to overcome barriers to certification.
[00:08:48.650]That's something that we can't do
[00:08:49.830]as a certifier as well.
[00:08:51.180]That's in the regulations.
[00:08:53.510]So when the inspector shows up,
[00:08:55.480]they're gonna define the rules,
[00:08:56.790]out line activities, answer some questions,
[00:08:59.520]and then when it's all over,
[00:09:01.315]they will have another interview with you
[00:09:03.770]to communicate any non compliances,
[00:09:06.120]they'll request some information if needed.
[00:09:12.100]Timing, you know, you're gonna have to be there,
[00:09:14.060]that's a given.
[00:09:15.622]Your crops are gonna need to be in the ground,
[00:09:17.540]so land activities need to show that you can comply.
[00:09:21.603]And here there is a bunch of things
[00:09:23.890]that are core producers that I pulled
[00:09:26.110]from an instruction, I believe.
[00:09:29.320]Some information that you might need to know
[00:09:31.450]before you go into it.
[00:09:36.040]So the inspector will write a report based on the,
[00:09:40.140]we'll give them your plan,
[00:09:41.980]and they review the plan
[00:09:43.280]and see if you were actually following it,
[00:09:44.800]and they'll let us know how you're doing,
[00:09:47.120]so if everything is fine, and hopefully it is,
[00:09:50.550]you will get your certification.
[00:09:53.190]Maybe there's some conditions for it,
[00:09:54.990]we call those minor issues,
[00:09:56.980]so things like you're missing a document,
[00:09:59.907]you were missing a log,
[00:10:01.860]or something minor needs to be added to the OSP.
[00:10:05.860]Non compliance is something a little more major.
[00:10:09.830]Maybe that requires a corrective or preventative action plan
[00:10:13.807]that can be followed up with next year,
[00:10:16.340]maybe it's even more serious than that,
[00:10:19.220]and we have to go through
[00:10:23.121]which is not something anyone wants to do, really.
[00:10:29.670]So here, we're looking at our timeline.
[00:10:33.130]This is what OneCert does;
[00:10:34.660]right now we're going through input, review
[00:10:36.860]and re-review, so.
[00:10:38.700]We have a database of all our inputs.
[00:10:42.550]If you guys know Omri,
[00:10:43.860]they have a bunch of inputs you can use.
[00:10:47.450]So we're going through, we're contacting manufacturers.
[00:10:50.130]If things were listed, if things were dropped,
[00:10:52.020]we're going for those.
[00:10:52.980]We're contacting manufacturers
[00:10:55.880]to try and get inputs listed.
[00:10:58.370]We're getting new clients, reviewing applications
[00:11:00.570]to see changes.
[00:11:02.260]Right now the producer reviewers are making sure
[00:11:04.500]that the farmers know what they can use
[00:11:06.690]in their field come May.
[00:11:08.680]Another date to point out here, September 30th;
[00:11:11.650]we like to have new clients decision made by the 30th
[00:11:14.810]so you can apply for cost share.
[00:11:17.630]That's, you can get up to 75%, up to $750 back
[00:11:22.880]from your certification fees
[00:11:24.700]if you apply by September 30th.
[00:11:27.181]That's through a couple marketing services
[00:11:30.710]I'm googling that online.
[00:11:33.780]You should be able to find it.
[00:11:39.200]So here's a little recap,
[00:11:41.720]a person seeking certification must comply
[00:11:44.300]and understand the requirements,
[00:11:45.950]that's what I'm here to help you guys understand today.
[00:11:49.150]You've got to establish and implement
[00:11:51.200]an organic system plan, and then apply.
[00:11:54.220]Pay your dues, allow an inspection,
[00:11:56.510]and again immediately notify your certifying agent
[00:11:59.978]this goes back to don't use anything
[00:12:04.460]that wasn't approved,
[00:12:05.600]and don't do anything before we know about it.
[00:12:08.810]Or you could risk your certification
[00:12:10.580]is the thing.
[00:12:14.350]A certifying agent, we also have requirements.
[00:12:16.650]We must understand the requirements as well
[00:12:18.710]and have applicable expertise.
[00:12:21.300]We've got reviewers across the country,
[00:12:24.524]we have to understand how every farmer's working,
[00:12:29.180]how people are working in a region,
[00:12:31.000]and how your specific farm is working, so,
[00:12:33.640]there's a lot for us to consider
[00:12:35.480]when making a decision for your farm.
[00:12:38.030]We review applications and we communicate results.
[00:12:41.700]There's notice letters, certification letters,
[00:12:43.950]email, phone calls,
[00:12:45.674]there's a lot of ways we'll follow up with people.
[00:12:50.040]That concludes logistics and how to be certified.
[00:12:53.950]I know I might have ran through that.
[00:12:57.050]And regulations are next.
[00:12:58.600]Do we have any questions about that process
[00:13:02.570]of maybe when to apply, et cetera?
[00:13:07.465](man speaking faintly)
[00:13:16.410]So we do not certify transitions,
[00:13:18.610]so 2020 to next year you can apply
[00:13:21.370]probably after this season, so.
[00:13:24.196](man speaking faintly)
[00:13:27.180]Yeah, so if you're gonna do it that year.
[00:13:29.040]You know you could even do,
[00:13:31.500]I suggest, you know that's a great question,
[00:13:33.330]if know in two, three years you wanna be certified,
[00:13:36.100]make your plan now.
[00:13:37.380]Go online and get your packet.
[00:13:39.150]Start making it now, start following it.
[00:13:41.860]And that should answer questions
[00:13:44.150]and make it a little easier when you do want to apply.
[00:13:48.758](man speaking faintly)
[00:14:04.370]Usually do a year.
[00:14:05.560]So we don't do transition.
[00:14:09.095]So I need to keep my records open
[00:14:10.778]from all of my last application,
[00:14:12.963]and then apply.
[00:14:14.140]I think we do have a partial fee.
[00:14:17.190]So the minimum fee for producers is $1000.
[00:14:20.410]I think there is a partial fee for transition
[00:14:24.130]if you want us to review your things,
[00:14:27.043]you know if you're worried
[00:14:28.310]and just want us to look over your plan
[00:14:30.760]before you get certification,
[00:14:32.680]so then you can have a little more assurance that way
[00:14:34.790]when it does come time.
[00:14:37.923](man speaking faintly)
[00:14:49.012]Gary, would you give them the mic?
[00:14:52.579]Because we're recording this
[00:14:55.100]and unless it goes through the microphone,
[00:14:57.341]the people that'll listen to this eventually,
[00:15:00.040]which might be all of you again won't hear the questions.
[00:15:06.241]I've got an alfalfa field
[00:15:07.550]that I haven't done any application with since 2017,
[00:15:12.150]and I'm hoping to sell organic corn this season.
[00:15:15.960]So is that considered transitional or...
[00:15:19.833]Yeah so if you've been managing the land
[00:15:22.190]and can show you haven't applied anything,
[00:15:26.098]this goes into records, you know,
[00:15:28.300]it could be something as simple as a calendar on the wall
[00:15:31.080]where you write down what you did that day.
[00:15:33.220]So, I mean,
[00:15:35.210]if you can show where you've been applying things
[00:15:37.300]and where you haven't been applying things,
[00:15:39.666]we may have to take your word for it on some things,
[00:15:45.550]But I mean I could get certified
[00:15:47.520]with you and be selling organic crop this fall then?
[00:15:51.110]Yeah 2017, if that's how I had my,
[00:15:54.260]yeah so it's 36 months.
[00:15:55.900]And then after that you can sell.
[00:15:58.560]Well I didn't know,
[00:15:59.393]you said something about you didn't do transitionals?
[00:16:02.410]Yeah we don't certify transitional,
[00:16:04.472]I know I think QAI might do that,
[00:16:08.210]but we don't certify transitionals.
[00:16:11.380]And I wouldn't be considered
[00:16:12.500]a transitional, I'd be...
[00:16:14.560]Yeah so if you're,
[00:16:15.990]you could be potentially eligible
[00:16:18.629]and you could apply pretty soon if you wanted to get in.
[00:16:22.824]Gotta share that kind of thing.
[00:16:32.280]My crop insurance person
[00:16:35.366]wants me to be certified by July 15th.
[00:16:38.787]I've heard that too, I heard it-
[00:16:40.860]So how does that work?
[00:16:42.150]I heard it March though.
[00:16:44.912]That ones pretty tough.
[00:16:46.520]So I mentioned OSP approval letter.
[00:16:49.380]I know with cost share,
[00:16:50.430]some of our existing clients,
[00:16:51.840]when they apply for cost share,
[00:16:53.840]they're able to get that or with saying I have paid,
[00:16:56.963]and I have an OPS approval letter,
[00:17:00.513]and I was previously certified,
[00:17:01.720]so sometimes that's enough.
[00:17:03.740]You may need to find a new insurance provider,
[00:17:06.130]you may need to try and work with them.
[00:17:08.690]We do say the OPS approval letter
[00:17:11.910]that says you appear to comply,
[00:17:13.992]you're going to be inspected.
[00:17:17.890]That's about all we can do, you know.
[00:17:26.610]How long is a certification good for?
[00:17:29.690]That's a good question,
[00:17:30.610]certification does not expire.
[00:17:33.388]I'll cover that later on,
[00:17:34.810]but certification continues in effect
[00:17:37.019]until you surrender or suspend it or are revoked.
[00:17:41.670]So the certification has an annual renewal date on it,
[00:17:47.600]so that's the date you have to pay your fees
[00:17:50.490]and apply for the next year.
[00:17:51.730]But the certification does not expire.
[00:17:55.440]It does in the Europe and India,
[00:17:59.060]but USDA does not.
[00:18:05.460]So say you have a farm
[00:18:06.430]with three fields,
[00:18:07.650]do you have three certifications,
[00:18:09.160]or just one certification per farm?
[00:18:12.863]It goes to a person.
[00:18:15.850]So, if you are the sole proprietor,
[00:18:18.440]and you have three fields,
[00:18:20.010]and you're managing those fields,
[00:18:22.230]then those would all three be yours.
[00:18:25.400]It gets into legal entity and who's managing.
[00:18:29.668]So if you have a tricky situation,
[00:18:32.200]that's where it becomes important,
[00:18:34.220]it's where you really describe it
[00:18:35.480]and talk to us about it.
[00:18:40.170]Maybe a couple more and then I want to go into regulations.
[00:18:44.530]Yeah just real quick,
[00:18:46.150]you talked about yearly fees,
[00:18:48.660]what are we looking at?
[00:18:49.570]So initial application sounds like about $1000,
[00:18:52.190]maybe a bit more, not too much.
[00:18:54.070]What are we looking at yearly then?
[00:18:55.810]So our fee schedule, it's based on
[00:18:58.150]your gross sales.
[00:19:00.430]So you come in with an estimate
[00:19:02.670]or at the lowest $1000
[00:19:04.660]and then however much you made the last calendar year
[00:19:07.860]will put you in a bracket.
[00:19:10.430]$1000 or upwards from there.
[00:19:13.229]And that covers your inspection, anything else.
[00:19:17.710]The only extra fee we have for producers,
[00:19:20.420]you're allowed as many listed inputs as you want,
[00:19:23.490]but you get three unlisted inputs for free.
[00:19:28.210]'Cause we have to contact the manufacturer,
[00:19:30.010]look at all the ingredients,
[00:19:31.470]it can become a headache fast.
[00:19:32.960]So any more than three unlisted, we will charge extra.
[00:19:38.980]Follow up question to the earlier one,
[00:19:41.790]could a certification be transferred
[00:19:43.590]from one operator maybe
[00:19:45.940]to another person who takes over an operation?
[00:19:48.400]No, certification does not transfer,
[00:19:50.330]that's actually specified in the-
[00:19:51.880]So is there a required
[00:19:54.140]three-year transition waiting?
[00:19:58.560]no, the new person would need to apply
[00:20:01.330]for their own certification.
[00:20:03.270]You can use the previous certification
[00:20:05.890]as verification that nothing prohibited was applied,
[00:20:08.600]but you would have to go through your own application.
[00:20:13.950]I think that's a good place,
[00:20:15.550]we'll jump into some regulations,
[00:20:17.830]and then hopefully I can answer more questions,
[00:20:20.210]I know some of them
[00:20:23.450]went into this.
[00:20:27.840]So what is an organic system plan?
[00:20:30.270]Here is a long list of things you have to do.
[00:20:34.970]It's basically a description,
[00:20:36.880]like I said earlier, you tell us what you're doing,
[00:20:39.770]we'll review it,
[00:20:41.150]and the inspector will see is that how it actually goes,
[00:20:45.823]So a list of all your substances, inputs,
[00:20:49.590]monitoring, management, record keeping,
[00:20:52.660]and then of course any additional information
[00:20:55.250]that we may need.
[00:20:57.640]The OneCert organic system plan
[00:20:59.760]is divided into five sections
[00:21:01.700]with the regulation identified at the top.
[00:21:03.660]So if you're reading through the questions
[00:21:05.470]and you're not sure what we're getting at,
[00:21:07.280]you have something to go back to.
[00:21:09.960]I wanna, you know, emphasize this.
[00:21:12.070]Each farm is unique with different soils, climates, crops,
[00:21:15.321]philosophies behind your management,
[00:21:17.850]we're interested in learning about your farm
[00:21:20.370]and how you plan to manage it.
[00:21:22.730]So, you need to answer the questions completely.
[00:21:26.070]And the regulations do, you know,
[00:21:30.370]lend themselves, they're not always so specific,
[00:21:32.830]which, you know, can be to your benefit.
[00:21:38.160]And again you can always get that online
[00:21:40.480]at any time, it's free, the crops packet.
[00:21:46.170]So organic seeds,
[00:21:48.120]your slide might be a little different than this one
[00:21:50.510]after a couple, being a fly on the wall
[00:21:52.740]in a couple producer meetings;
[00:21:54.390]it's a can of worms.
[00:21:56.200]So, 204A, the producer must use organically grown seeds.
[00:22:02.290]We should all just stop there
[00:22:04.000]and make it easier for ourselves.
[00:22:06.400]'Cause then we get into interpretation,
[00:22:08.456]what is commercial availability, et cetera.
[00:22:12.700]And there's also the issue of I can't tell you what to grow.
[00:22:17.110]So, it becomes a headache,
[00:22:18.940]some of these meetings circle around for 40 minutes.
[00:22:23.770]But you know here,
[00:22:25.650]use organic seeds, if they're not available commercially,
[00:22:29.260]which is dependent on quality, quantity and form,
[00:22:33.310]so if there's no mention of cost there,
[00:22:35.380]you can't say organic version was too expensive,
[00:22:39.580]sorry, that doesn't cut it.
[00:22:43.710]With your commercial availability,
[00:22:45.260]we don't only wanna know what you searched,
[00:22:47.870]but also how you're going to,
[00:22:49.300]what are you gonna do next year,
[00:22:50.650]how are you gonna continue to search?
[00:22:52.590]Are you writing contracts with producers
[00:22:54.680]to grow organic seeds, et cetera?
[00:22:57.540]I included a couple seed databases here.
[00:23:01.570]The AOSCA, and then Pick a Carrot is a website
[00:23:06.250]with that information.
[00:23:07.860]I believe I pulled from these best practices,
[00:23:10.673]accredited certifier agency's best practices,
[00:23:14.210]which is a group of all the certifiers,
[00:23:22.560]All right, here is another one,
[00:23:24.450]crop rotation practice standards.
[00:23:26.290]So, Joel accurately stated
[00:23:29.286]that the practice standards do not mention
[00:23:38.470]based on this it seems you could do corn, soy, corn,
[00:23:41.870]but I do wanna point out something,
[00:23:44.150]some information I'm not seeing
[00:23:45.490]in a lot of the information out there.
[00:23:48.710]There is a definition for crop rotation,
[00:23:51.700]I'd like to read that.
[00:23:53.380]So it is the practice of alternating the annual crop
[00:23:56.460]grown on a specific field in a planned pattern or sequence
[00:24:00.690]in successive years.
[00:24:02.400]So that crops of the same species or family,
[00:24:07.530]are not grown repeatedly without interruption
[00:24:09.930]on the same field.
[00:24:11.710]So there's a lot to take in there.
[00:24:14.220]Some room for interpretation,
[00:24:15.890]but to me it's pretty clear,
[00:24:19.020]not the same species consecutive years.
[00:24:22.360]Perennial cropping systems employ means
[00:24:25.020]such as alley cropping, intercropping, and hedge rows
[00:24:28.260]to introduce biological diversity.
[00:24:34.233]I also understand the act was written in 1995,
[00:24:38.510]and GPS and cropping technology has also improved.
[00:24:42.770]So what is field?
[00:24:45.800]Can you use rows?
[00:24:47.485]There is a big gray area,
[00:24:49.890]hopefully a can of worms I don't wanna open right now.
[00:24:55.190]But I did include the OneCert crop rotation policy.
[00:24:59.110]The main thing is justification.
[00:25:02.000]Here's where having your plan
[00:25:03.790]during the transition year period is important.
[00:25:06.910]If you think you can do corn, soy, corn, soy cover crop,
[00:25:10.130]then use your transition period to show us
[00:25:13.890]that that improved your soil.
[00:25:16.400]If you come in and say
[00:25:18.180]I wanna do corn, soy, corn, soy, cover,
[00:25:20.760]we might say that doesn't look like it applies
[00:25:22.930]or you know complies.
[00:25:26.560]So just something to keep in mind.
[00:25:28.781]And also, you know, these folks doing research
[00:25:31.310]have grad students, undergrad students being able
[00:25:34.230]to keep their books for them,
[00:25:35.860]I don't think you guys have quite as many resources
[00:25:38.370]as an extension professor.
[00:25:40.560]So something also to keep in mind
[00:25:43.110]as you try and justify your crop rotation practices.
[00:25:52.570]So here, I got section one,
[00:25:54.550]this is the OneCert forms.
[00:25:57.618]Section one, you know, we wanna know about your seeds,
[00:26:01.040]planting style, we have an appendix for that
[00:26:03.500]for you to list everything out,
[00:26:04.730]that's done annually.
[00:26:06.560]We wanna know about your soils, your waters,
[00:26:08.500]how are you using it?
[00:26:09.430]Where is it from?
[00:26:10.360]Be monitoring it.
[00:26:12.090]We ask for your plan and your land buffers.
[00:26:16.860]Here's one of those things where
[00:26:19.290]you can describe your buffer on paper,
[00:26:21.050]but we don't really know if it's okay
[00:26:22.870]until you're inspected.
[00:26:25.150]So, that's one of those things
[00:26:26.550]you're gonna have to talk to the inspector about.
[00:26:28.990]How you justified your buffer zone.
[00:26:31.540]Field history, annual field plan,
[00:26:33.570]this is where you get into documenting,
[00:26:36.180]when the last prohibited substances were applied
[00:26:38.590]and that comes with the application,
[00:26:40.560]so here again, your farm is unique.
[00:26:43.410]We wanna know about how you're doing things
[00:26:46.400]and to see if it complies.
[00:26:47.810]That's the takeaway.
[00:26:50.440]Also here, equipment, that's section four,
[00:26:52.490]I moved it in, it makes sense to go here.
[00:26:55.840]You know, list your equipment, storage.
[00:26:58.430]Do you own the equipment, are you leasing the equipment?
[00:27:01.130]Are you using on-farm bins, is it your cousin's bin?
[00:27:04.020]We wanna know all these things
[00:27:06.780]and you know we have to decide what needs to be inspected,
[00:27:17.340]Here we go into soil fertility.
[00:27:20.300]One thing I wanna point out about these.
[00:27:23.420]A, B, C are must, you must do these things.
[00:27:27.510]And D are things you may do.
[00:27:29.520]And D is where you're gonna get into these
[00:27:32.140]national list items.
[00:27:34.270]I keep pointing to the Omri material list,
[00:27:37.058]but this is a good encyclopedia
[00:27:39.870]of you know what the national list is.
[00:27:50.140]And so again, you're moving towards
[00:27:53.280]only A, B, C, and eventually phasing out of D,
[00:27:58.470]and that's something we wanna consider in your plan.
[00:28:01.380]Maybe you're at D and we can allow it,
[00:28:03.510]but what about next year,
[00:28:04.810]what about a few years from now.
[00:28:06.230]How are you going
[00:28:09.760]to use less inputs?
[00:28:12.405]It's something that Joel brought up,
[00:28:13.290]you know practices are much better than your products.
[00:28:16.950]And then E here is something not to use.
[00:28:19.900]No sewage sludge, et cetera.
[00:28:23.630]Here is the OneCert form, section two,
[00:28:27.500]just some examples of the questions,
[00:28:29.270]you know some of it's fill-in-the-blank,
[00:28:31.070]some of it's check boxes,
[00:28:33.380]some of it, like I've mentioned,
[00:28:35.240]is an appendix you have to fill out separately.
[00:28:38.320]So you know what are your deficiencies?
[00:28:40.160]How are you monitoring?
[00:28:42.450]Manure can be something,
[00:28:43.840]what is your source, how are you apply it?
[00:28:45.850]It is composted?
[00:28:47.110]You know there's rules for all these things.
[00:28:50.440]And we need to see how you comply.
[00:28:54.830]Again, Keith mentioned in one of his questions,
[00:28:58.367]how are you trying to get to equilibrium?
[00:29:00.920]When do you eventually get to equilibrium?
[00:29:02.590]And that's something again we're looking here.
[00:29:05.060]You must manage, you know may use mechanical
[00:29:08.930]and so on and so forth.
[00:29:11.250]C here, I do wanna include more,
[00:29:13.976]it looks like that's all that's allowed,
[00:29:15.930]but C, weed problems can be controlled through mulching,
[00:29:19.640]mowing, grazing, weeding, cultivation,
[00:29:22.180]those are a lot of things that Joel talked about,
[00:29:23.930]so you guys should have resources for what y'all are doing
[00:29:28.130]and be able to describe it well.
[00:29:30.990]The main point of going through all these regulations,
[00:29:33.220]I know it's a lot,
[00:29:34.080]but this is the language we're looking for.
[00:29:37.740]So I'm giving you some language to use for you to tell
[00:29:41.820]when you make your application.
[00:29:44.590]Again, here's our forms,
[00:29:45.730]here you can read the instructions
[00:29:48.290]for our input request form.
[00:29:50.910]So when we're looking at inputs
[00:29:52.310]we basically wanna know all the ingredients in it,
[00:29:54.850]in your fertilizer.
[00:29:55.880]It can either be listed in Omri,
[00:29:58.220]that makes it easier for us,
[00:29:59.470]but if you know you gotta friend making compost,
[00:30:03.400]we're gonna wanna know what is everything he put in,
[00:30:06.390]you know what are his feed stocks, et cetera.
[00:30:17.160]Here we go with record keepings.
[00:30:18.970]So here first and foremost,
[00:30:20.350]they must be adapted to your particular business.
[00:30:23.460]I've said many times, every farm is different,
[00:30:26.040]every person is different,
[00:30:27.750]and people like using different technologies.
[00:30:29.960]Maybe you have a notebook in your tractor,
[00:30:32.070]maybe you have a calendar on the wall,
[00:30:33.480]maybe you can use your smartphone.
[00:30:35.550]It doesn't matter as long as you describe what you're doing
[00:30:38.332]and it can be readily audited, understood,
[00:30:42.460]something that's verified, you know.
[00:30:45.070]I said I was gonna plant this much on this day,
[00:30:47.260]so the inspector can see, okay your log says
[00:30:49.970]you planted this much on this day,
[00:30:52.405]that's a good path forward to be certified.
[00:30:57.130]Save records, you know, seeds, inputs, field preparations,
[00:31:01.060]some examples here.
[00:31:02.750]And you know, include details like amounts, locations,
[00:31:06.560]varieties, et cetera.
[00:31:09.760]Here's a bunch more examples,
[00:31:12.020]a headache to look at,
[00:31:13.490]but here's the key
[00:31:14.620]this phrase here.
[00:31:16.720]Documentation of activities is key
[00:31:18.990]to showing us that what you're doing
[00:31:21.350]is what you said you would do on your OSP,
[00:31:24.140]and this goes back to
[00:31:26.340]immediately notifying your certifying agent of any changes.
[00:31:29.690]So you said you were gonna doing something,
[00:31:31.210]I'm gonna plant corn this year,
[00:31:33.760]it didn't work out, I need to plant soy,
[00:31:35.650]let us know so that an inspector doesn't go out
[00:31:38.520]and say hey, they've got soy in their field.
[00:31:42.060]That doesn't look good.
[00:31:46.890]The national list,
[00:31:50.131]it's quite a long list of things to go through,
[00:31:53.710]but you know I've got some resources at the end,
[00:31:56.760]again there's Omri.
[00:31:58.490]These are things allowed, prohibited,
[00:32:01.170]and this is what we look at
[00:32:02.964]if we have an input.
[00:32:05.020]To say what are the ingredients,
[00:32:06.200]are they on the list?
[00:32:07.033]There's also restrictions on the list.
[00:32:10.560]You can only apply it in certain amounts,
[00:32:12.480]or the production of the input has to be a certain way.
[00:32:20.220]Here is the packet, I did this for you guys,
[00:32:23.670]did some homework.
[00:32:24.510]I said that I was a handling,
[00:32:26.450]I needed to get familiar with producers.
[00:32:28.290]I requested a packet for myself,
[00:32:30.130]you just need name and email.
[00:32:32.720]Crops packet there.
[00:32:34.580]And you can also get sent a copy of the regulations.
[00:32:37.270]This is free to do, I suggest you do it.
[00:32:40.830]And to reduce the shock factor,
[00:32:42.900]there's gonna be 19 attachments, here they are.
[00:32:48.250]So it's quite a bit to go through
[00:32:50.421]and like I said, there's the OSP form
[00:32:53.610]and there's some appendixes.
[00:32:55.590]Some of this is information,
[00:32:57.270]you know the instructions and the cover letter,
[00:32:58.970]that's something that we actually write
[00:33:01.310]and update every year.
[00:33:02.900]So it's a good idea to maybe just spend some time
[00:33:05.900]to read it all first and get started.
[00:33:08.410]This is a good thing to do during your transition,
[00:33:11.000]instead of when you've decided okay,
[00:33:12.450]I've transitioned, oh my gosh,
[00:33:14.950]now I have to fill out all these forms,
[00:33:16.900]you have three years to prepare.
[00:33:23.040]So, as we wrap it up a little bit,
[00:33:26.250]before we go into questions,
[00:33:27.510]notice of non compliance, I included this here.
[00:33:30.210]You know, this is just something we have to do.
[00:33:32.940]I deal with this quite a bit.
[00:33:34.250]It's not something I wanna do,
[00:33:35.450]it's something I have to do.
[00:33:36.980]If we find that you're to be in noncompliance,
[00:33:40.044]you'll get a notice either in a formal nonc,
[00:33:44.480]there's a minor issue with certification,
[00:33:46.410]sometimes I will follow up with things over the email.
[00:33:51.210]It just depends on how I'm feeling sometimes,
[00:33:53.060]but nonc is the way to go.
[00:33:55.130]Describe what it was,
[00:33:58.220]and then there's some steps to go through, resolutions,
[00:34:01.690]even more so if it goes through,
[00:34:03.930]there's appeal and et cetera.
[00:34:05.390]It can be quite a headache.
[00:34:07.090]But here's a good matrix,
[00:34:09.533]and a good place to draw the line.
[00:34:11.850]So, we have minor issue, noncompliance,
[00:34:15.240]and these are more serious.
[00:34:16.550]So a minor issue,
[00:34:19.100]if you're a new client,
[00:34:20.180]we can grant your certification with a minor issue,
[00:34:23.770]just something like hey, you left out a log
[00:34:27.470]or you said, you know, you need to update,
[00:34:30.070]you forgot to put a tractor on your list,
[00:34:31.910]something like that
[00:34:32.960]that can be readily resolved.
[00:34:35.380]Notice of noncompliance,
[00:34:36.560]something that needs a corrective or preventative action.
[00:34:42.030]And with that, something that can be verified.
[00:34:50.150]And you know then it gets more serious from there.
[00:34:53.200]Whether it's a willful violation.
[00:34:58.290]So what to do when you get a nonc.
[00:35:00.830]Read it carefully.
[00:35:02.520]It's important to know what you're responding to.
[00:35:07.560]So you have to know what you've violated
[00:35:09.160]in order to fix it.
[00:35:11.410]Identify the cause, a preventative plan,
[00:35:14.110]and some evidence that can go with it.
[00:35:16.560]Something that can be verified at the next inspection
[00:35:19.220]or someone at a desk can look at and say yes,
[00:35:22.900]I can see you've addressed this.
[00:35:27.670]Here's where I wanna end while I take some questions,
[00:35:30.530]resources to point out.
[00:35:32.050]So the regulations, you can get them online,
[00:35:34.340]a Google search of ECFR205 will take you there.
[00:35:38.710]The NOP handbook, there's a lot of information there.
[00:35:43.960]It's pretty good for certifiers,
[00:35:45.610]but you guys also need to know
[00:35:47.740]what we're expecting of you.
[00:35:49.800]The integrity database is a list
[00:35:52.407]of all the NOP certified operations.
[00:35:57.170]Material review institutes,
[00:35:58.730]so Omri is free,
[00:36:01.970]they have a book even two or three times thicker than this
[00:36:06.080]just listing all of the manufacturers
[00:36:09.000]and improved products,
[00:36:10.010]you can search that online.
[00:36:12.490]W-S-D-A, WSDA, Washington State,
[00:36:15.290]they also have a free resource available.
[00:36:17.890]Then there's PCO, CDFA, Pennsylvania certified,
[00:36:23.590]They have some for members.
[00:36:25.983]Also, you know, we touched on seed,
[00:36:29.000]there's a list of organic seed suppliers here.
[00:36:31.831]I mentioned the ACA, accredited certifiers,
[00:36:34.760]this is a group of all certifiers.
[00:36:37.860]So OneCert, QAI, LCIA, everyone, PCO.
[00:36:41.281]And you know we have working groups
[00:36:44.520]discussing different hot topics through out the year
[00:36:47.030]to try and get consensus and consistency.
[00:36:51.490]You can imagine it's pretty easy to interpret something
[00:36:54.200]in multiple different ways,
[00:36:55.310]so that's a way we can stay consistent.
[00:36:58.530]Here for those of you that are transitioning,
[00:37:01.420]a lot of the information I took from here.
[00:37:03.880]This interactive video is really good.
[00:37:06.270]This is something I did my first few weeks;
[00:37:09.870]takes about 30 minutes.
[00:37:11.890]It's like those stories where you let the character
[00:37:14.350]make their own decision and you can go back
[00:37:17.050]and make the right decision later,
[00:37:18.340]so it's pretty good, has a lot of good information.
[00:37:25.970]Agricultural marketing services,
[00:37:27.710]there's a lot of information.
[00:37:29.610]I think I wanna stop here on this resources page
[00:37:32.160]and get some questions maybe about regulations,
[00:37:34.920]how much time?
[00:37:38.490]Oh maybe 15 minutes,
[00:37:39.820]but that'd be max,
[00:37:41.130]but a question I have is, you know,
[00:37:43.080]talking about certification or transition,
[00:37:46.170]like he talked about,
[00:37:47.540]you know he can get certified this year right away,
[00:37:49.790]but what if a guy has,
[00:37:52.233]you know he was conventional farming this year,
[00:37:55.880]so he didn't have anything on til, well I could say,
[00:37:59.440]I don't know we'll just say August of 2019.
[00:38:04.620]Do they need a certification plan from somebody,
[00:38:07.670]you said you don't do that.
[00:38:09.350]Do other companies do that,
[00:38:10.480]or do you even need it?
[00:38:12.680]So transition certification,
[00:38:14.460]is that what you're talking about or?
[00:38:16.611]Or do you just mean your products in transition
[00:38:20.553]you're a snob that way,
[00:38:22.120]but I mean just, they wanna go to organic,
[00:38:25.520]they're not worried about the in between time
[00:38:28.010]as far as getting an extra price for their product,
[00:38:31.830]but I guess, you know,
[00:38:33.500]does somebody else do the transitioning thing
[00:38:36.100]if they wanted to do that?
[00:38:38.770]I think QAI does transition.
[00:38:41.700]So here's where the law gets into marketing,
[00:38:44.590]the USDA seal is a marketing thing,
[00:38:47.100]you have to follow the regulations to get into it.
[00:38:51.730]So that's where,
[00:38:52.800]and then the regs say you have to have your transition
[00:38:56.540]period and follow the plan.
[00:38:59.940]'Cause I didn't know if you needed to
[00:39:01.460]right away go into it.
[00:39:07.240]Okay got some other questions?
[00:39:21.270]I have a question,
[00:39:22.330]I'm currently certified,
[00:39:24.010]and I'm having troubles with the government
[00:39:28.070]with my certifier
[00:39:30.810]that I'm NOP certified,
[00:39:32.810]but I still have to do something for the government
[00:39:35.910]that is exactly the same paperwork
[00:39:38.564]as what I'm doing for my certifier,
[00:39:40.800]so why isn't the certifier basically talking
[00:39:44.170]to the government and telling the government
[00:39:46.020]that I am certified instead of having to make me do
[00:39:49.090]even more paperwork when I have to go in and get my
[00:39:53.560]I don't know what they need it for,
[00:39:54.660]it's for, we don't get any big benefit
[00:39:58.390]from the government for doing it,
[00:40:01.290]as far as I know,
[00:40:02.350]but like I say, are you following what I'm saying?
[00:40:04.970]Because I have my certificate from my certifier,
[00:40:11.063]well then the government doesn't know I have a certificate,
[00:40:14.420]or even if they do have the knowledge
[00:40:16.910]that I have a certificate,
[00:40:18.040]which my certifier is NOP certified,
[00:40:21.970]they do not
[00:40:25.250]allow me to use my certification for my paperwork.
[00:40:30.440]They need a new organic plan
[00:40:33.029]and it has to look a little bit different,
[00:40:35.850]or it does look enough different to the government to,
[00:40:38.573]is there any bridging the gap here on this sort of thing?
[00:40:42.520]It sounds like you're talking about
[00:40:43.850]a state organic program, are you in California or?
[00:40:46.307]No, no, I'm here in Nebraska,
[00:40:51.730]No, it's ridiculous,
[00:40:53.310]it just upsets me every time,
[00:40:55.350]it's like oh geez, I just got done with my paperwork,
[00:40:57.760]but now my FSA office is wanting more paperwork
[00:41:03.720]and I don't know if it's just my FSA office,
[00:41:05.580]I don't think it is.
[00:41:06.539]Is this for cost share or?
[00:41:08.773]No, it's over and above the cost share.
[00:41:11.490]I just did the cost share thing,
[00:41:13.210]but then they needed me
[00:41:14.360]to do another whole organic system plan.
[00:41:18.500]But like I say,
[00:41:19.650]an organic system plan is an organic system plan
[00:41:23.000]and I already do it,
[00:41:25.090]and I can't even just send a copy of my certificate,
[00:41:30.330]it's ridiculous but.
[00:41:32.202]I didn't know if you had any answers to that.
[00:41:34.080]This has happened every year
[00:41:35.872]or this is a new problem?
[00:41:36.801]Yes, it happens every year.
[00:41:37.880]Where Nebraska's wanting you
[00:41:42.010]to register in their own...
[00:41:47.110]yeah I'm not sure how to answer that,
[00:41:48.927]I don't think the state has its own accreditation.
[00:41:55.110]It's a national-
[00:41:56.837]Is there a reason you need to apply for this?
[00:41:59.190]Is it just to make sales as organic?
[00:42:01.210]Or is this-
[00:42:02.043]Joel and Jim, I don't know,
[00:42:02.950]are you following what I'm saying?
[00:42:04.670]Do you have the same hoop that you have to jump through or
[00:42:08.046]this doesn't apply to you maybe?
[00:42:13.539](man speaking faintly)
[00:42:19.370]You're not, does your certificate work
[00:42:23.440]at the government agency, at the FSA?
[00:42:27.613](man speaking faintly)
[00:42:39.914]I just, my question was is why aren't they communicating
[00:42:43.172](laughing) the certifier to the government.
[00:42:46.730]So certifiers aren't state.
[00:42:49.320]We're not, OneCert is a third party accreditation service,
[00:42:53.440]we are accredited by the USDA to enforce the regulations,
[00:42:57.120]we're not part of the government,
[00:42:59.496]so there is some separate things.
[00:43:01.650]You know like with the insurance question,
[00:43:03.470]we're not an insurance company,
[00:43:04.880]we're a certification company,
[00:43:07.110]so there's only so much we can do
[00:43:09.594]if the state requires it.
[00:43:11.810]I mean even with the seeds,
[00:43:13.050]it went back to if the federal government
[00:43:16.060]is requiring you to use treated seeds,
[00:43:18.660]then organic can't really step over that.
[00:43:21.990]Or you know, mosquito problems in Texas,
[00:43:25.073]the state comes in and sprays.
[00:43:27.430]There's different situations like that
[00:43:30.330]where we don't overstep.
[00:43:36.700]Where does your organic certification
[00:43:40.530]agency stand on
[00:43:44.350]pumping water out of the river for irrigation?
[00:43:52.595]I'm not sure about that.
[00:43:55.820]That's a pretty specific question,
[00:43:57.300]I think it would depend again on
[00:44:00.390]are you maintaining soil improvement, water quality
[00:44:04.200]in doing so.
[00:44:08.060]and it depends on the region.
[00:44:09.860]If people are doing that in the region,
[00:44:11.170]and it's the thing to do,
[00:44:12.970]then that could be allowed.
[00:44:14.870]A lot of, I hate to give you these answers,
[00:44:17.000]but even with clients that I talk to on the phone
[00:44:19.830]that are certified
[00:44:23.468]and they explain something and I say okay fine,
[00:44:25.358]I'm gonna need that in writing,
[00:44:27.350]and then I can review.
[00:44:28.370]You know, give me that in writing,
[00:44:30.220]submit the supporting documentation,
[00:44:32.691]and then with all the information I can make a decision.
[00:44:36.367]And again here you know with the steps to certification,
[00:44:40.270]many of you are at step one or two,
[00:44:42.220]so anything that I might tell you
[00:44:44.390]isn't me making a decision,
[00:44:46.630]you guys are still at the first steps.
[00:45:02.770]So we currently use a lot of cover crops
[00:45:05.120]and have for 10 years plus.
[00:45:08.440]Are all acres available to be certified organic
[00:45:12.090]even if there's water running off
[00:45:14.990]a neighbor's onto yours, or what's?
[00:45:19.910]Yeah that's where the buffer zone comes-
[00:45:22.192]Okay and what would the buffer zones be?
[00:45:24.830]That depends on your operation,
[00:45:26.430]you know I can't say, there's not a standard way
[00:45:31.170]of reducing weeds for everyone.
[00:45:34.250]So that's a case situation
[00:45:36.190]and even that kind of question
[00:45:37.820]would depend on the inspection.
[00:45:40.280]You know, you tell us something,
[00:45:41.590]but the way things look on paper and on the computer
[00:45:44.910]isn't always how they look in the field.
[00:45:48.210]So, with that buffer,
[00:45:50.564]even if they're treating their land,
[00:45:53.150]if it's a certified place
[00:45:54.610]or if you can get them to not spray there,
[00:45:57.480]then maybe you don't need a buffer,
[00:45:59.540]but you know do you have a buffer,
[00:46:02.580]is it being contaminated,
[00:46:03.690]how are you transferring that over to conventional.
[00:46:07.820]Did that get your question?
[00:46:09.717]I think so.
[00:46:18.230]Clayton will be around,
[00:46:20.440]so trying to catch up a little bit,
[00:46:22.440]let's give him a hand
[00:46:23.620]and then we'll move on.
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