Organic: Certification Section I

As promised, as part of our series documenting our transition to organic certification, I will be posting much of the text and documentation that we’ll be submitting to the certifier. The goal in doing this is to provide an example for other farmers considering certification, and to provide more information for customers about how and why we run our business the way we do. I expect to post all of this information on our website proper over the winter, but I have not done that design work yet and so will rely on the blog for now. Tonight I offer up our response to Section I, which asks us to briefly describe our background in farming and reasons for choosing organic methods. By my standards, the following text is brief, though I understand if not all readers make it to the bottom. Just wait until I get to the more detailed sections of the application!

Our background in farming

We both grew up in rural areas, with families that gardened and preserved food. We met while working toward graduate degrees in geology in the same department, and were drawn together partly by our shared love of food, cooking, & local foods/farmers markets. After graduate school, we moved to Virginia to work at Shenandoah National Park, and became involved with a nearby sustainable CSA farm. Joanna worked there regularly opposite her 1/2 time SNP job, and Eric (full time) helped out as often as he could.

We had already decided that when we settled down, we wanted to live a homestead-style life, with a single income and a homemaker growing/raising most of our food (similar to how we grew up). Working at Waterpenny Farm exposed us to more of the realities and possibilities in farming for a living (not just for ourselves) and inspired us to seriously consider that as a life choice. A new job opening for Joanna led us to move to mid-Missouri, where the cost of living was far lower, the niche for direct-market farmers was much wider (compared to the East Coast), and a better job made single-income living while starting a farm possible. We moved onto our current land in mid-2006 and founded Chert Hollow Farm. We have sold produce at market for the last two years (2007, 2008) and are regularly expanding our production areas and farm offerings.

Our choice of organic management practices

There has never really been any choice in that matter. We were both raised in families that strongly valued conservation and respect for natural systems, and carried those values into our initial career pursuits in research and educational geology. Our training and research in geomorphology, and human effects on landscapes, strongly influenced our belief in sustainable land management. Our interest in food and cooking led us to learn about food production practices and their environmental & political ramifications, and the more we learned the faster we transitioned our food choices toward local/sustainable/organic options. Working at Waterpenny Farm solidified those beliefs with experience, as that farm used all sustainable methods and felt very strongly about the long-term sustainability of their soil, land, and environment. This was our initial practical exposure to “organic” methods, supplemented by a heavy diet of research and reading (we are scientists, after all).

With regards to our current farm, we believe very strongly in sustainability, independence, and freedom. We want to limit our reliance on inputs, resources, and factors that we cannot control and do not approve of, such as manufactured fertilizers and pesticides. Organic methods provide a means to that end by emphasizing closed loops, natural methods, and long-term benefits over short-term efficiencies. We value our independence and property rights, and organic certification gives us a stronger tool to defend ourselves from off-farm threats such as government spray programs. Although we have significant philosophical concerns regarding the implementation of the government organic program, we feel it is important that our beliefs and methods are recognized (especially in Missouri), and certification is the only way we will be noticed by those who make policy. We also feel that organic certification will help us become better farmers by forcing us to question, analyze, and describe our plans, methods, and inputs. Much of the record-keeping and planning needed for certification are things that farmers like us could benefit from, and we might as well get the full benefit of the work.

In summary, we believe strongly in Thomas Jefferson’s ideal of the educated, self-sufficient, politically active farmer. Organic methods lead us toward environmental and economic sustainability, and organic certification grants us a political voice. Together, those goals represent our vision for the future.

Organic: Outline of Certification Requirements

We are now actively writing and compiling our official application for organic certification, and it is a thick task. I’m grateful for my experiences in assembling a teaching portfolio for my Masters in Education degree, and in preparing a large (2″ thick) final report for the major project I was responsible for during my National Park Service time. The practice in organization and assembly is now serving me well, as is Joanna’s equivalent academic and professional experience.

There are eight parts to our certification application, as laid out by MOSA. I will summarize them here, and plan to post the text/details of each one as it is completed. The goal through this series is to help customers and non-organic farmers to better understand the requirements and standards of organic, and what better way than to read along as we develop and refine our documentation? MOSA makes many forms available online, and I will link to those where I can for those who are truly interested. As you read through this very long post, perhaps you will start to understand why “organic” is more expensive, especially when it comes to small farms. If I put a dollar value on the time I spend on certification paperwork, it would be frightening. We can apply for cost reimbursement from Missouri for the actual certification charges, but not for our time.

Section 1: General Information
This includes basic contact information, location of/directions to farm, and definition of farm/product types (crops, dairy, meat, etc.). It also asks us to lay out our background in farming and reasons for choosing organic production methods. While most of that information is laid out already on our web site, it’s an enjoyable challenge to boil it all down into a concise and thorough summary.

Section 2: Farm and Crop Description
This is a meaty one. Under this heading, we need to submit Three Year Field Histories for all production areas, including every variety of seed we planted and grew, all inputs used, and so on. Like a lot of the organic program, forms like this are really aimed at large-scale producers with only a few varieties, not diversified small farms. So what may not be too bad for an organic corn grower or large-scale tomato operation becomes massive for an heirloom vegetable farm growing around 100 varieties interplanted throughout the season. Organic is one-size-fits-all, which is one of the complaints small farmers have about it, especially since we can’t delegate staff to take care of this like the big folks. Also, since we have been on this land since mid-2006, we are working to contact the previous owner in order to get a Prior Land Use Declaration (PLUD) from him certifying that no prohibited substances were used on the land during the first half of 2006.

Section 3: Seeds, Seedlings, and Planting Stock
In this section we declare ahead of time every seed or transplant we intend to use during the upcoming (certified) growing season. No GMO or treated seed is allowed, and non-organic seed is only allowed if we can prove that we conducted a reasonable search for an organic version by completing the Organic Seed Search Form. Given our dedication to growing sometimes rare heirlooms, I think we’ll be using that form a lot.

Section 4: Soil Fertility and Conservation Management Plan
In this section we document and describe our strategies for handling these issues and document all inputs used on-farm (fertilizers, pest controls, mulch, etc.). Specific categories to be described include compost production, manure use, natural resource management, and biological diversity. This includes getting verification letters from suppliers of off-farm products such as manure, straw, and hay certifying that their products are acceptable for organic production.

Section 5: Crop Management Plan
In this section we document and describe our plans and methods for crop rotation, weed management, and pest & disease management.

Section 6: Plan for Maintenance of Organic Integrity
In this section we document and describe our approach to preserving our organic status, i.e. preventing contamination of our fields, harvests, equipment, and facilities. This includes describing buffer zones or other methods that protect our fields from off-farm sprays and inputs (like other farms or government/utility spray programs), equipment management & cleaning, harvest methods, crop storage & handling, product transportation, and marketing methods. This section is not too difficult, as we are certifying all of our products, thus eliminating concerns about mixing organic and non-organic products. If, for example, we were not certifying the orchard and planned to sell those fruits outside our certification, we would have to spend a lot more time carefully keeping those products separate and documenting how. Keeping cleaning logs will be a new challenge, though.

Section 7: Record Keeping Requirements
In this section we document and describe the methods by which we document and describe our methods. Do we keep good records of field activities, inputs, compost & manure management, seed purchasing, harvest & sales, land management, cleanliness, etc.? How do we manage our records (paper copies, online, etc.) It’s really just establishing what records we need to keep to fulfill Sections 2-6; I would have made this Section 2 in order to make the point up front.

Section 8: Affirmation
In which we promise to tell the truth, the whole truth, and nothing but the truth so help us USDA.

We are also preparing full maps of the farm and each individual growing area, documenting and labelling all production zones. In theory, we ought to be able to track any given product from seed to sale, knowing that this tomato came from a plant started Z, transplated Y into bed X, fertilized or otherwise handled W, harvested V, sold U, and so on. Again, something that is sensible in concept and very valuable to the customer and to food safety concerns, but much more practical for large, low-variety farms and very onerous for small, high-diversity farms.

So that’s it. All you have to do to sell a certified organic product is compile all that information for three years, submit it in proper form, sit back & watch the money roll in. Those darned organic farmers sure are gouging the gullible yuppies, aren’t they?

Organic: choosing a certifer

The first step to certification, at least for us, was choosing a certifier. This is the agency/company/group accredited by the USDA to conduct inspections and issue certifications. There are a truly dizzying variety of options out there, from large global corporations (such as OneCert or QAI) to private associations (such as CCOF) to non-profits (such as MOSA) to, in some cases, state agencies (as in Iowa).

There are really two options here for certification: government or private sector. Which is preferable depends partly on your political philosophy. A government program is typically far cheaper for the producer, but this of course is subsidized by taxpayer dollars and is in effect a preferential treatment of an industry. Private sector certification allows for competition and choice, but I have a serious concern about this method: the latent potential for ethical violations.

Consider: a private certifier relies on income from succesful certifications. It will not make money by NOT certifying farms. In a marketplace with lots of options, even a strict certifier has the real potential to be subtly outcompeted by a more compliant certifier. I am not accusing any specific entity of anything, just noting that the system is set up for abuse. Organic farmers are businesspeople, not saints, and there’s plenty of talk over who is easier to work with and who is a hard case. I’ve been told at least once, “Oh, you don’t want to use ____, they’re way too strict.”. Hmm. There’s a real gray area there between good service, and too good service. There’s enough room for abuse as it is (one inspection a year is not going to catch the bottle of Roundup hidden in the basement for emergencies).

Although I tend to prefer keeping government out of private business, to me a government organic certification program is closer to a Health Department or Fire inspection than a subsidy or mandate. It’s simply using a government office to efficiently and equitably conduct a certain level of certification for a customer-recognized standard (like LEED or Energy Star on the green front). In Missouri, it’s a moot point for now, as the state cut its nascent organic certification program in 2005. So we have no choice but to look on the open market.

Cost is another issue here. Private certification seems to cost around $700 the first year for a small produce farm, and will likely be more like $500/yr after that. Under Missouri’s old program, certification cost $100. Now, through appropriations in the Farm Bill, Missouri does offer a cost-share program that will in theory reimburse organic farmers for up to 75% of their certification fees, up to $750. That probably does take less government to manage, at least at the state level, but trends a lot closer to a straight-out subsidy when compared to a basic state certification program, at least to my eyes. I’m not all that comfortable taking a straight payout subsidy for my farm.

In any case, given our limited philosophical options, we chose to certify with the Midwest Organic Services Association (MOSA), based in southwestern Wisconsin. I first ran across their operation at the fantastic MOSES organic conference last winter. I had a long talk with one of their certifiers and came away very impressed; I’ve made several subsequent phone calls to their office to ask questions about the certification process, and each time have been instantly placed in contact with a knowledgeable staffer who was happy to spend half an hour answering detailed questions for a complete stranger. Every interaction I’ve had so far supports my impression of a solid, small, focused organization. So we’re giving them a try. We just feel more comfortable with the certification equivalent of a local small business whose focus is directly on what we do in the region we do it in. I’m sure I’ll have more to say about MOSA as the process continues…

Organic: the $5,000 exemption

This series is likely to feature a number of my complaints with the National Organic Program, which I consider a very imperfect system. At some point I will write a cogent analysis of why we’re certifying anyway, but not at 4:00 in the morning. Right now I’d like to highlight one oddity: the $5,000 exemption:

“Producers who market less than $5,000 worth of organic products annually are not required to become certified, though they have the option of doing so. These operations must still adhere to the federal standards for organic production, product labeling, and handling.”

Frankly, I find this absurd. I suspect it is a well-meaning attempt to soften the cost burden of certification for smaller operations, but I think it dilutes the meaning of the word. Certification is too much work, bother, and expense (especially for independant small farms) to allow its value to be undercut by exemptions. If the goal is to buffer costs for small operations, set up some form of cost-share program (Missouri dabbles in this) .

That second sentence is just silly; if there’s no certification, there’s no control on what methods the grower might be using while taking full advantage of the expected price and image benefits that the “o” word conveys. In addition, given that a core customer base for organics are people with chemical allergies, this exemption seems downright dangerous to me. Granted, followers of this exemption are not allowed to use the official USDA seal, but I suspect that fine distinction is lost on most consumers, who in any case have no way of knowing how much money a farm stand makes each year.

There are many other euphemisms that non-certified growers can use to convey their methods (organic methods, sustainable/no-spray, etc.) that are not so easily confused with an actual certified operation. We’ve been using “transitional organic” to make clear that we are not certified but are working toward it. I’ve been pleased at how many people stop and ask what that means; educated consumers are the foundation of a functional market economy. Why trade education for confusion? In my first year selling, I was asked by several people (growers included) why I didn’t just take the exemption and write “organic” on my sign. My answer was simply that I didn’t feel it was right, and would disrespect and undercut the actual certified organic growers at market. I still feel that way.

Organic is far more than “no-spray” or “naturally grown”. As I’ll discuss later, real certification involves demonstrating long-term commitment to fully sustainable methods integrated throughout the farm, not just withholding chemicals. Despite all its faults, that seal and that word means something to those small farmers who earn it, and I want it respected across the board, no exceptions.

New series: certifying organic

Over the next month, we will be working to complete our application for organic certification. I’ve written once already about one specific challenge to achieving official organic status, but I expect to have much more to say as we move through the process. I suspect that most folks don’t really know what actually goes into organic certification; we certainly didn’t until we started reading up on it in preparation for attempting it. Suffice it to say that certification is time consuming and involves LOTS of documentation. The binder above is our official certification application packet, approximately 2″ thick.

Now that the growing season is mostly over, my goal for now is to shift the focus of this blog toward covering and discussing the steps we take in assembling our certification application, so that readers, customers, and potential organic growers can learn from our experiences and gain a better appreciation of the benefits and problems associated with organic. Hopefully the series is of interest.
For those deeply interested in the topic, this publication from the National Sustainable Agriculture Information Service (oddly acronymed ATTRA) gives an excellent overview of the history, context, and outline of the National Organic Program.

Avoiding killer hay

Two of our top fall projects involve continuing to establish our permanent no-till beds in the main field, and completing our application for organic certification. While there is more to write about both these topics than I can possibly fit into one blog post, I want to discuss an interesting, challenging, and newsworthy way in which the two interact.

I first wrote about our intention to farm using organic no-till methods back in May. We are following the example set by Patrice Gros of Foundation Farm in northern Arkansas, as described on his website. Mulching is key here; thick layers of hay/straw keep the soil moist, encourage earthworm and microbial activity, prevent weed growth, and improve soil nutrition and structure. This is especially true when used in conjunction with manure or other natural fertilzers. Using this method correctly involves a lot of manure, hay, and straw.

The trick here, especially for us as we move toward organic certification, is to make sure all hay, straw, and manure are safe and approved for organic production. If you assumed that these are all safe because they are natural materials, you’re wrong. Some hay fields are sprayed with herbicides in an attempt to improve the hay; these herbicides have very long residence times and can damage or kill vegetable plantings if treated hay is used as mulch, even months later. Growing For Market magazine documented an especially devastating incident (article not available online) in which a Virginia vegetable farm (the one we got our start at, incidentally) lost somewhere around $80,000 in produce from using sprayed hay as mulch. They had used the same supplier for years with no problems, until one year the grower randomly decided to spray the fields and didn’t tell them. Among other hard-learned lessons, the farmers noted that had they been a certified organic farm, they would have been required to check whether their mulch had had anything applied to it.

So far we’ve done that, sourcing our straw and spoiled hay intended for mulch from growers that will sign paperwork indicating that nothing has been applied to the material. As for manure sources, long-term we hope to have enough goats, chickens, and other livestock to supply much of our own needs on-farm, but until then we need to use off-farm sources. We get a lot from a trusted goat operation north of us, who have nice piles of old, partially composted manure/bedding mix that is dynamite fertilizer. We also had a neighbor offer us some nice horse manure from their barn, which offer we happily accepted.

Then we read this in the latest print edition of Mother Earth News. You really ought to read the full article, but the gist is that several Dow herbicides marketed to hay growers have been found to have such long residence times that they retain their potency even through the gut of the animal and into the manure. In other words, the sprayed hay is fed to horses, they digest it, and defecate. Months or even years later, that manure still contains enough active herbicide to kill vegetables and other plants if the manure is applied to a garden or farm bed. Yikes doesn’t cut it.
So now, in order to achieve our certification (much less piece of mind), we have to track down all the hay sources that our manure providers might have used and ask them if they can sign paperwork certifying that their hay has not been sprayed. We also have to dispose of twenty bales of grass hay that I imprudently bought off of Craigslist about a week before we read the long-life herbicide article (they had been intended for the goats, not mulch). Starting to understand why organic is more expensive?

This really brings credence to a comment I once read (but can’t cite a source for) that organic ought to be the default standard, and everyone else ought to have to certify and state all the chemical and other inputs they put into growing the food. It’s basically the difference between the European and US models of consumer safety. As I understand it, in the EU you have to prove that an ingredient or chemical is safe before you can use it. In the US you have to prove that it isn’t safe before you can ban it. I would love to see food packages in grocery stores with labels that declared every pesticide, herbicide, hormone, and other unnececsary input used; talk about consumer education in a free-market system…

Practically, of course, that wouldn’t work very well in agriculture as opportunities to cheat would be far too common. As it is, organic certification is hardly a comprehensive guarantee of the intended principles (that’s another long upcoming post). But right now it’s all we’ve got, and we’re doing our best to jump through all the hoops that it takes to simply grow natural vegetables in a chemical world.