This Tuesday, Courtney Tchida of Cornercopia sat down with Brenda Rogers of MCIA in a lovely air-conditioned conference room of Hayes Hall to for part two of the organic certification inspection. Last Thursday was the farm tour, this Tuesday was the records tour.
Looking at her formidable black binder, Ms. Rogers opened by noting that last year, Cornercopia was cited for using biocontrols not included in their OSP (organic production system plan). Courtney confirmed that they did not use any controls this year. Ms. Rogers then noted that she had not received documents regarding the high tunnel. Courtney made a note to turn them in. Subsequently, Ms. Rogers noted that Cornercopia had sold seedlings. Yes, Courtney replied, but not as certified organic.
Thus the pattern for the meeting was set. Ms. Rogers perused the OSP, made check marks, and occasionally asked clarifying questions. The first area of review was seeds. Ms. Rogers went through page after page of seed records, stopping to double-check each nonorganic entry in the master list against the nonorganic seed list, which included the companies who did not carry organic versions of the desired varieties. The list was daunting, but Courtney’s clear organization made it a breeze. “This is almost too fast,” Ms. Rogers said.
She went on to ask questions about the likelihood of greenhouse staff interfering with seedlings, the status of unplanted strawberries, previous soil tests, the rotation plan, and soil fertility. A brief discussion ensued about compost requirements. Courtney had been applying raw compost (plant material) to fields at the end of the season to avoid monitoring the carbon-to-nitrogen ratio, temperature, and age of their compost heap. Ms. Rogers clarified that those requirements are only for compost containing animal products, not including plant material-based worm castings, which are, in her words, “just like magic."
The questions continued: what about chickens, wildlife, spraying, water testing, straw from the poultry barn, disease control, buffer zones, reuse of berry boxes, equipment cleaning? Courtney got dinged on that last one – she did not have records of the mower being power washed between fields. “I’ll have to get those from Mike,” she said, making a note.
Courtney was also missing hard copies of sales records, and while she went back to her office to print some samples, Ms. Rogers turned to me and politely asked what I was doing there. I gave her the run down of my recent activities and hopes for the future, then fired some questions at her (for a change) about her time with the MCIA (lengthy), who she inspects (vegetable gardeners), how much of Minnesota she covers (from Norman to Big Stone to Pine to St. Louis - look here if you need a refresher on the counties of Minnesota), and when she inspects (May to September, generally).
Courtney returned with the sales records. Ms. Rogers glanced through them and the harvest records, and was satisfied. She reviewed the few points needing follow up and then it was over.
After Ms. Rogers left, Courtney revealed her secret to success: they’d been going through this process for six years now, the first three during the transitional period, when meeting every single requirements isn’t as big a deal (except for the application of prohibited materials to land, which would set you back to month 0 of 36). With plenty of time to work out the kinks, this year’s inspection was “pretty painless,” Courtney said.
So there you have it: a ground-level look at how a certifying agency applies the National Organic Program’s rules and regulations. Discuss.
Photo from the UMN website.
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