What is an Organic System Plan?
The Organic System Plan (OSP) is a detailed description of how an operation will achieve, document and sustain compliance with organic standards. The application submitted to a certification agency is generally considered your OSP. It is a living document that must be updated as changes occur.
Can I label my product as organic simply because I use organic practices?
No, using the term organic without being certified or having an exemption is against the law and fines could apply. For additional information refer to USDA Do I Need to be Certified Organic.
Isn’t organic certification expensive?
No, a beginning farmer typically ends up paying under $200 to become certified through NOFA-NY due to the USDA Organic Certification Cost Share Program. The program reimburses producers and handlers for a portion of their paid certification cost. Once certified organic your eligible reimbursement would be up to 75% of your certification cost each year to a maximum of $750 per certification scope – crops, livestock, wild crops and handling.
Are NOFA organic standards different than other certifiers?
No, NOFA-NY Certified Organic follows the same standards as other certifiers in the United States. Organic regulations are mandated by the National Organic Program through the USDA. Our agency is known for bringing high integrity to the organic process.
Can I be certified organic if I produce organic and non-organic products?
Yes, this is referred to as a split operation. A key component of this type of operation is to have sound documentation and management practices that prevent contamination and commingling. You may refer to organic standard 205.201 for more information on this type of operation.
Do I really have to wait three years for my land to be certified organic?
Depends, if evidence can be provided indicating no prohibited products have been applied to field(s) during the last three years your land may be eligible now or for earlier transition.
When should I apply for certification?
Typically, applications are submitted the year land qualifies for organic certification. We do offer a land transition program, but transition fees are not eligible for cost share reimbursement.
Do I have to go through a different certification process to certify different parts of my farm? E.g. vegetables, poultry, pigs, etc.?
No, you do not have to get separate applications or go through different processes. You can certify different parts of your operation with the same application, we will provide the needed additional forms. Should you want to add a component to your certification the yearly certification fee will increase $25 for livestock and $50 for on-farm processing.
Do you certify operations outside of New York State?
Yes, we certify operations in bordering states such as Pennsylvania, New Jersey, Massachusetts, and Connecticut.
May I label my certified organic products as Non-GMO?
Organic certification and "certified organic" statements are sufficient to substantiate a claim that a certified organic food is non-GMO and/or was not produced using excluded methods. However, many operators choose to make additional non-GMO claims.
The phrase “non-GMO,” when used on NOP-certified product labels, is understood to mean that the product was produced without the use of genetic engineering. This is consistent with the organic regulations.
“Non-GMO” is an accurate statement because it declares a product is produced without the use of GMOs. Unlike the term “GMO-free,” the term “non-GMO” does not claim that the product is 100% free of GMOs
What is the transition period for a Dairy operation?
The transition period for a dairy herd is one year. This is a one-time opportunity for a conventional dairy operation to transition their entire herd to organic production. Once the transition begins, no more conventional animals may be brought to the farm.
During my dairy transition can I feed my herd non-organic feed?
No, 100% organic feed is required for the entire one-year transition period. However, feed harvested from fields in their third year of transition (T3) that are included in the Organic System Plan may be used as part of the 100% organic feed requirement during the transition. All T3 crops must be fed up or removed from the farm before the end of transition.
Are animals with docked tails allowed in the transition program?
Yes, animals with docked tails may enter the transition program, but from the start of transition on, tail docking is prohibited.
Does manure spread on organic fields need to be from organically certified animals?
No, manure just needs to be absent of any prohibited products.
Can I apply raw manure on my vegetables at any time?
No, organic standard 205.203 states raw manure may only be incorporated into the soil not less than 120 days prior to the harvest when the edible portion comes in direct contact with soil surface or soil particles. Crops with no direct contact to soil particles require manure incorporated into the soil not less than 90 days prior to harvest.
Would conventional fields located across the road be considered adjoining land to my organic field?
Yes, if you are growing organic crops next to your neighbor’s and there is a road as the only “barrier” then a buffer may need to be established or we would need to know the growing practices of your neighbor’s field. This is especially important if you both are growing corn since most conventional corn is genetically modified (GMO) and there is a high likelihood of cross contamination from pollen. We also recommend letters be sent to neighbors, the highway department and health departments notifying them of your organic status and asking them not to spray on/around your land.
How do I prove that nothing has been applied to my land? Do I have to send a soil test?
If you have managed the land for the past 3 years, you have to complete our initial field history form documenting any inputs that have been used, seeds used and crops grown for the past 3 years. If you lease the land, or have recently acquired it, a new field affirmation has to be completed and signed by the previous land owner or manager. Soil tests are only necessary if you plan to use micronutrients as a soil amendment.
If I have treated wood on my property, do I have to remove it?
No, if it has been installed for at least 3 years, it does not have to be removed, and there does not have to be a buffer between it and any livestock. If treated fence posts have been installed in the last 3 years, then a buffer to prevent the animals from reaching it would have to be installed.
I can’t find any organic stock for fruit perennials (strawberries, blueberries, etc.). Am I able to use non-organic stock?
Yes, you can use non-organic stock, just as long as you have made adequate attempts (documented search of 3 suppliers) to source organic stock, and documented this.
Is there a specific organic standard stating the age to dehorn organic calves?
No, however, organic standard 205.238 does state “Performance of physical alterations as needed to promote the animal’s welfare and in a manner that minimizes pain and stress”. Dehorning is allowed, but must be done in a humane manner. We recommend doing it as young as possible.
Can you give vaccines to organic livestock?
Yes, allowed medical treatments include vaccines, vitamins, minerals, herbal remedies, electrolytes and probiotics. Health care products must be approved prior to use and are to be documented on your Organic System Plan Livestock Medication & /Health Care Record. (Link to PDF)
Can livestock keep its organic status if treated with antibiotics?
No, any animal treated with antibiotics, or another prohibited material, will lose its organic status and is to be removed from organic production. However, you may not withhold treatment from a sick animal in order to preserve its organic status – organic standard 205.238(c)(7). Treatments, including antibiotics if needed, must be used to return an animal to health, and all medical treatments must be recorded.
What are the livestock living space requirements?
Current regulations do not have specific livestock space requirements. Regulations address the condition of the living space that provide year-round outdoor access, exercise, fresh air, shade, shelter and direct sunlight. Living conditions are to promote the health and natural behavior of the livestock.
Why is the Animal List important?
The list allows for verification of animals from birth to sale or removal, which ensures the integrity of the Organic System Plan. Certifiers can easily verify whether an animal qualifies for slaughter status or only for dairy production, which is helpful when animals are sold between certified operations or to processors. NOFA-NY has forms available to help you complete your Animal List, when applying for certification. Animal Lists are then entered into the computer system and printed for producers to update each year with new replacements or culled animals. Sales records are verified at inspection each year. DHI or other records are accepted as an alternative, providing all necessary information is listed.
How do I keep track of Dry Matter Intake ?
The NOP requires all ruminants over 6 months of age to receive a minimum of 30% Dry Matter Intake (DMI) from pasture on average for the entire grazing season (at least 120 days each year). NOFA-NY has designed Feed Ration Verification Forms (FRV) to help both the producer and NOFA-NY determine if this requirement is being met. The FRV helps us calculate the percentage of feed from pasture and also verify feed fed on farm, which can be useful when performing feed audits. All areas of the FRV should be filled in as accurately as possible showing animal numbers, weights, hours outside, milk production, estimated pounds of feed per animal or group and is broken up by month and animal groups (milkers, dry cows, bred heifers and young stock; beef over 1 year and beef under 1 year of age, etc.). The office can calculate the percentages as long as the pertinent information is filled in by the producer. If these forms do not meet the specific age groups producers manage their animals in, they can easily be altered by the producer to show their specific groups (dry cows managed with bred heifers, all groups managed together, etc.). If crops other than indicated are fed, these categories can be altered as well. Accurate feed weights/amounts fed (or close estimates) are necessary.
Do I only have to meet the organic standard if producing organic craft beer and/or cider?
No, all organic alcohol beverages must meet both Alcohol and tobacco Tax and Trade Bureau (TTB) and USDA organic regulations. Specific labeling requirements apply to both organizations. Additional information can be found on Fact Sheet USDA Labeling Organic Malt Beverages. (Link to PDF)
Am I allowed to keep organic and non-organic ingredients in the same storage area?
Yes, if adequate measures are taken to provide clear distinction between the organic and non-organic ingredients. Storage practices should also be in place to prevent commingling or contamination risk for organic ingredients.