2.3 Steps in the Certification Process

Organic certification is meant to assure consumers that the farmer followed all requirements of the USDA organic regulations. The farmer works with the certifier and inspector through several steps during the certification process. Veterinarians may find it helpful to understand the certification process to communicate readily with organic and alternative farmers. This section will provide an overview of the certification process for livestock farmers and ranchers. More information can be found in 7 CFR 205.400 and Chapter 3 of the USDA Guide for Organic Producers [PDF].

Determine eligibility of the land and livestock

A farmer can apply for organic certification of pastureland after 36 months of documented practices showing no prohibited materials were applied. Farmers and ranchers must document all land use and material applications during the three-year transition period. This land requirement is crucial for organic livestock farmers and ranchers since their animals must only eat organic feed, and ruminant livestock must graze organic pasture. One exception is for dairy farmers who are allowed to feed a ration of their forage or feed from organically managed land during its final year of transition (i.e., during the 12 months before the sale of milk and milk products) so that the land and dairy herd together are completely transitioned in 3 years.

The origin of livestock is also a crucial component of a farmer’s eligibility for organic certification. Organic livestock must be under continuous organic management from the last third of gestation, including organic milk and milk products from dairy animals.^[1]. One exception to this requirement is that poultry and edible poultry products must be under continuous organic management no later than the second day of life.

Application process

Farmers may apply for certification to any ACA they choose. The certification process typically takes 3 to 6 months to complete, so farmers should apply before the end of their transition period. The farmer submits the required documents with the application, such as a farm map, field histories, and the Organic System Plan (OSP).

The OSP is an essential tool for the farmer to describe their farm. The OSP describes:

• Farm practices, record-keeping system
• Management practices
• All substances that may be used (also known as the Materials List)
• Estimates of projected organic yields and sales
• Physical barriers are used to prevent commingling and contamination of organic and prohibited substances (which is a crucial consideration for split operations. [DVMs should pay close attention to what is included in the Materials List since it consists of all potential feeds, insecticides, and health care products that might be used on the farm. If an unlisted product needs to be used, the certifier must first be contacted to approve it and add it to the OSP. If this process isn’t followed correctly, the certifier may revoke certification and/or prohibit an animal from being slaughtered under organic status. However, it is important to remember that organic regulations require sick animals to be treated with organically approved methods and/or conventional treatments, “even if doing so jeopardizes the animal’s organic status” (§205.238). More details on treating organic and alternative animals can be found in the chapter on livestock treatments, see Chapter 4.

The certifier reviews the application and determines whether additional documentation is necessary. Applications may be denied, delayed for further clarification, or approved for inspection. An inspector then performs inspections.

The organic inspector represents the ACA and is trained to maintain confidentiality. They inspect every organic farm yearly to look for violations, verify the OSP is accurate, and examine the farm’s records. More information on record-keeping can be found in the “Practice Management and Treatment chapters. The inspector asks questions, visits each area, assesses the livestock’s health and living conditions, and performs an exit interview with the farmer. As an independent third party, the inspector cannot provide advice on farming practices or overcoming certification barriers.

Once the inspection is complete, the inspector writes a report and sends it to the ACA for their review. The reviewer considers the seriousness of each issue identified on the farm and determines if there are issues that must first be addressed before the farm is considered in compliance for certification. The farmer receives a letter from the ACA with a range of notices, including:

• issuance of the Organic Certificate,
• notice of non-compliance (with correctable actions identified), or
• denial of certification or proposed revocation.

Once the ACA issues the Organic Certificate, the farm remains certified until the farmer

• renews or surrenders the certification or
• it is suspended or revoked by the certifier.

Organic farmers and ranchers must either renew or surrender their certification every year. If not renewed, certification will be suspended. The renewal process involves:

• Updating the OSP
• Signing an operator agreement
• Paying an annual fee
• Undergoing a yearly inspection

Also, among other activities to strengthen enforcement and reduce fraud, as of March 19, 2024, they will require certifiers “to conduct unannounced inspections of at least 5% of the operations they certify” (NOP Strengthening Organic Enforcement March 20, 2023, Final Rule).

More information about non-compliance can be found in 7 CFR 205.660—663.