cows in field

Organic Certification from the Inspector’s Perspective

An Interview with Arden Landis

Arden Landis, left, at a recent NODPA Field Days

By Sonja Heyck-Merlin

How and why did you decide to be an inspector? What training do you have?

I decided to become an inspector because I was an organic farmer both in crops and dairy for 15 years. After I left farming, I completed two training sessions, one for crops and one for livestock, with The International Organic Inspectors Association. Following that, I completed two apprenticeships with two different certifying agencies in which I job shadowed other inspectors and observed what they did during their inspections. I continue to participate in yearly trainings through either webinars or on-site training with specific certifiers.

How many certifiers do you work for? Is there a difference in how they each function?

I work for four independent certifiers as an independently contracted inspector. They all follow NOP regulations. The format of the inspections is similar as far as attempting to fulfill the same goals, but the questions are all different. There is also different paperwork for each agency. Some are more narrative and others are more check-list oriented. Some tend to ask more questions and duplicate information; others get it done in a more efficient manner. The agencies I inspect for all working really hard to get it right. I feel like they are working hard to maintain the integrity of the National Organic Standards.

Do you find that the certifier that reviews your inspection report is knowledgeable and includes your comments and assessment in their reports?

I feel that they are knowledgeable. In general, they look at my report and at that time they make their decision based on what I report. Typically, my comments are not incorporated. If I see something negative on the farm, I make a comment, and sometimes I will see those in a final report.

What are your thoughts on the certification process, especially from
an inspector’s point of view?

One of the things I have observed is that agencies make their money by the farmers paying them to certify them. If farmers find one agency provides better services than another, that is where they go. Some agencies are very efficient at determining if specific products are allowed in organic production. Some have more tedious paper work.

If I see one real problem in the whole process, it is that the agencies make their money off the farmers they certify. They don’t want to lose farmers. If a certifier is too tough, farmers find out and they will move from one agency to another. I don’t know how you’re going to get around this. It is just the reality of the situation.

From your experience, is their consistency in how dairy producers document the requirements under the Access to Pasture Regulations?

The agencies all have different forms and formats but the goal is the same- to prove that a certain percentage of DMI comes from pasture. There is little consistency in how farmers document the pasture requirements. Some are really good at record keeping and some are really poor. Sometimes you have to use your imagination to figure out what they are doing.

What techniques do you use to verify the data they provide to ensure compliance?

It depends on the time of the year I get to the farm. Sometimes I can visually assess what the pastures look like and determine that the farmer’s records match the conditions of their pastures. If I am doing an inspection at the end of the grazing season, I look closely at their records. As a farmer, I have a good sense for typical yields from both pastures and hay fields. I know how much tonnage is available and I make sure the available dry matter intake is consistent with what the farmer says he is feeding his cows. Sometimes it can be difficult to wrap your head around if a farmer is actually meeting the standard. I take the information given to me by the farmer and combine it with my skilled observations. The better the records the easier it is to determine if there are any issues of concern.

How important do you feel it is to have the following to record and
verify pasture consumption?

Unannounced inspections?
Unannounced inspections will definitely help with verifying pasture consumption.

Inspections during the grazing season?
Inspections during the grazing season are important but it doesn’t always happen.

A spreadsheet showing the grazing record which has automatic calculations to assist with calculating dry matter intake?
A farmer can put any numbers in there if their relying on spreadsheets.

A daily grazing record that shows where the different classes of livestock are grazing?
I think daily grazing records are really important and I ask for them. I like to see records. I want to see where the cows are being grazed and how often they are being moved.

A record of the pasture mix and a history of reseeding?
That’s helpful and beneficial but it’s not the most important thing. That information should also show up on the field records.

A unique record for each animal that you can use to spot check which animals are in which class and whether they reflect their record accurately for age, etc.?
I think that would make things pretty complicated.

Do you have any more thoughts on how farmers are doing at proving the adequate amount of dry matter intake from pasture?

The biggest thing I see as an inspector is that farmers do a pretty good job recording what they are feeding their milking cows. They are having a harder time with their records for dry cows, bred heifers, and young stock. I like to see records from all groups of animals. If I show up at a farm in July, I want to see grazing records from the start of the grazing season of the current year up to the day when I get there.

I also want to point out that grazing and grazing records have nothing to do with scale or size. I have seen 25-30 cow dairies where the grazing records were terrible. I have also inspected larger farms that are clearly meeting the grazing standard. Grazing issues and recordkeeping is not size oriented. Just because it’s a small dairy doesn’t ensure that the farmer is doing a good job pasturing and keeping up with the necessary paperwork.

Any thoughts on how to improve the certification process of large dairies?

I think the one thing you need are people that understand dairy and grazing and understand what it going on. I have real concern for these big dairies; I don’t know how they’re doing it. Their grazing plans would have to show that there is enough land to get a minimum of 30% DMI from pasture. Take for instance a herd of 5,000 Holsteins producing 65-70 pounds of milk per day. There dry matter demand is roughly 50 pounds, so 15 pounds needs to come from pasture. Multiply that out by 5,000 cows and figure out how many tons they need and then look at typical yields per acre. After a bit, you might come to realize that something isn’t working.

They should have a system in place both visually and on paper. It would also be pertinent that the inspector goes there and sees that there are cows out grazing.

Any suggestions for improving the certification process of organic dairies?

Require a minimum time of grazing experience of at least one year. No buying of organic cattle and putting them on certified organic land and then becoming a certified organic dairy. There are too many organic dairy farmers that lack the experience for grazing cows and managing grass for grazing when they become certified organic.

Require farmers that want to be certified organic to become educated in understanding how to record DMI calculations and maintain adequate records of their grazing management. Pass a test on the requirements that need to be understood for DMI calculations and recordkeeping.

The inspectors that inspect organic dairies should have dairy and grazing experience and knowledge.

Continue to develop ways that restrict the movement of organic cattle out of organics and being replaced by non-organic cattle. Accurate livestock inventory lists and animal identification are needed to be maintained.

The NOP needs to start upholding the organic regulations. Their audits of the accredited certifying agencies need to be consistent and following the same organic standards that they expect the organic inspectors to follow when they are completing organic inspection.

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