By Ed Maltby, NODPA Executive Director
The current initiative to standardize the Organic System Plan (OSP), an essential part of the certification process, in order to bring a more uniform approach to the role of the OSP in assessing compliance with the Organic regulations, was initiated with a call to action from Dr. Jenny Tucker, Deputy Administrator of the National Organic Program (NOP) at the 2024 National Organic Standards Board Meeting (NOSB) where she challenged the community: “This is a chance for the industry to step up and lead the way-can we rise to meet it?”
Since the beginning of the NOP, there have been requests from producer groups and others for a common OSP to make it easier for producers and certified operations to complete the forms and have more choice about which certifiers to use. We always assumed that the NOP would oversee all aspects of a common OSP as they do with the regulations and auditing of certifiers. The reasons for a common OSP are tied to the many examples of certifiers interpreting the regulations differently, including diferent questions and forms in their OSP's, for example, the pasture requirement, origin of livestock and hydroponics, and requiring different information from producers. Examples of this are a detailed list of livestock that some certifiers wanted and others ignored and information required for selling organic livestock. This has created a division among the organic community and an inconsistent and unfair playing field between different certified operations. There has been differing opinion among certifiers regarding the necessity of a universal OSP. Some prefer to maintain their autonomy due to their affiliation with parent non-profit organizations or their own mission, while others have appropriately included additional requirements in their OSP to address varying scopes and regional conditions, and for some it comes down to dollars and cents.
The NOP has clearly said that they cannot mandate a common OSP that all certifiers must follow, and they do not have the staff capacity or the budget to develop and update a template for an OSP that they can approve and post on the USDA NOP website. Jenny Tucker’s appeal in 2024 was to encourage an individual or company or group of individuals to develop an OSP that the NOP could approve and publish on their website. Anybody could use the complete template and certifiers could choose to use either the whole template or parts of it, to improve their OSP and to bring them into compliance with the NOP audit requirements.
Connie Carr, consultant,an associate at Wolf and Associates, Inc., and Chief Certification Liaison at Quick Organics, was previously at Oregon Tilth for 24 years, the last 12 years as the Certification Director. She is well respected within the organic certification community and has used her expertise to assist many certification organizations. Connie took up Jenny Tucker’s challenge and has been working with many partners and the NOP to develop an OSP that could be applied universally across many regions and scopes. Partners involved in the process include Wolf Associates, Organic Trade Association, Accredited Certifiers Association, California Certified Organic Farmers (CCOF), Rodale Regenerative and other certification specialists. Ms. Carr is working with Quick Organics, which now has the plan as part of their digital software platform, to simplify and optimize the sometimes-complex process of completing an OSP that can be used by farmers, certifiers, and agents. This subscription platform, like many others and very similar to standard accounting programs like QuickBooks, achieves this by digitizing record-keeping, providing comprehensive compliance tools, and offering resources aimed at minimizing paperwork and reducing stress. I don’t imagine that there are any producers who do not find the certification paperwork requirements stressful! Many certifiers now have their own platforms and have developed their own software that allows producers to complete paperwork online and/or receive pre-filled applications with their most current information.
CCOF has been piloting this new OSP for nearly a year and the Rodale Regenerative project has suggested to certifiers that their certified operations use this OSP rather than the certifier’s own OSP. In Fall 2025, National Organic Coalition, Organic Farmers Association (OFA), NODPA and Western Organic Dairy Producers (WODPA) were able to view the draft of the OSP and offer comment and suggest edits. Apparently, the livestock OSP is the most complicated, so the NOP was keen to have input from certified livestock producers, especially dairy. My reply to those that ask why the livestock requirements are so complicated is that the NOP and certifiers could not stop fraud without some specific and detailed regulations that would be legally successful in any non-compliance. An example is the case against Aurora Dairy in 2008 about adequate access to pasture which is nutritious, and another example comes from an Inspector General investigation in 2013 which found that three of the six certifiers interviewed were allowing producers to continuously transition additional conventional cattle to organic production, which effectively permitted "organic factory dairy farms" to lower production costs and potentially create an unfair market for small family farms that were following a stricter interpretation. The other three certifiers prohibited this practice, highlighting a lack of uniform enforcement across the industry. The NOP were unable to enforce any non-compliances until the regulations were changed, and certifiers were afraid of being sued because they didn’t have the backing of the NOP.
NODPA, WODPA, and OFA formally requested a meeting with the NOP in December 2025 in order to clarify the circumstances regarding the OSP being developed by Connie Carr in collaboration with the NOP. This request was prompted by ongoing confusion about the process and expectations of what was being called a Common OSP. We met with Jenny Tucker and Robert Yang, NOP Director, Accreditation Division, and they agreed to delay announcing or rolling out their version of an OSP template until March or April to allow for more feedback, review and comments by livestock producers. Jenny Tucker emphasized that while these OSP templates will receive approval from the NOP, their use will not be required for all certifiers. The new templates, which will be made available on the USDA website, are set to replace the current versions that have been in use for 13 years. They will be provided as downloadable Word documents at no cost through the NOP website. The OSP will not be directly tied to Quick Organics, or any digital platform or company, so there would be no license fee for certifiers and producers if they wanted to use the complete document or parts of it. It is still not clear who will keep them up-to-date and be responsible for their compliance after initial publication. NOP/USDA does not have the money or resources to do so.
The approval by NOP of this OSP template will be an incentive for certifiers to adopt it or parts of it to lessen their potential difficulties during an NOP audit. Certifiers might also receive this OSP from individuals who either downloaded it as a Word document from the NOP website, or as a PDF from Quick Organics or other digital software subscription platforms. Certifiers will have a number of different options when presented with the USDA OSP:
There is no requirement that the certifier accepts the USDA OSP. Hopefully the most likely outcome is that the process will be seamless for most producers who currently use their certifiers OSP digital software. Producers are used to dealing with updates and certifiers are used to training their inspectors and desk auditors on how to implement any changes. The decision will be made by certifiers about which OSP they will use and how to update it.
Producers may decide to use Quick Organics or other subscription services to manage their information. They should ensure that their agreement with that subscription service maintains their control of their data and information, rather than the subscription service having that control to use either, individually, or by aggregate to help fund the service company.
The OSP used by certifiers will be audited with every NOP audit and it will be up to the certifier to make any changes that the NOP audit requires. Quick Organics or other non-certified platforms will not be audited by the NOP but will have to respond to what changes their clients are instructed to make by the NOP.
Concerns arise about what happens next, especially with the USDA template. The OSP’s are often updated every year to make sure that the questions being asked receive answers that are clear and cover the intended question. They are also updated to cover new risks, emerging issues, and in response to regulatory changes. It is unclear how a USDA OSP template would be updated. The NOP will not be doing it annually, if at all, unless they find more staff and have an increased budget to support a $71.6 billion industry. Would there be a part of ACA that would receive and vet the asked-for changes? Would a separate body review changes? How will they be able to incorporate feedback from multiple certifiers and other organic community members in a way that works for most people? Will NOP approve the updated version?
One of the fears of a Comon OSP is that it would devolve into a “check the box” type of OSP that doesn’t let operations describe what they are doing and tell their story based on their operation. If certifiers are asking narrative questions, the wording of the question can be very important. Experience shows that open-ended questions can sometimes garner answers that don’t adequately answer the question. At that point the certifier must go back to the operation for clarification and to further explain the question. The certifier will probably also change the question to get a clearer response.
The OSP may be downloadable for free from the USDA website, but it does not make it any easier for those that don’t have good electronic connections or have religious/cultural restrictions on using the internet. They will still be assessed an extra fee by certifiers. The USDA web-based template may well be redundant within a year if there is no process for updating it and therefore cannot be used as a downloadable independent OSP.
If every certifier adopted the new template and the ACA oversaw presenting updates to the NOP, would that lead to more consolidation between certifiers? A very powerful central system for data storage could be set up by a digital software program that would be efficient and cost-saving with economies of scale. It would allow for more consistent training for inspectors, plus allowing producers to move from one certifier to another more easily. It would also solve the financial difficulties that many certifiers are facing. Unfortunately, increasing consolidation has, historically, had adverse effects on the small to mid-size operations (both farms and handlers). It could also place a lot of power within the leading certifiers to decide on what is organically certified and how it is inspected. Examining the rise of hydroponics reveals how it came to be included under organic farming: After several certifiers approved it as organic and its popularity and economic importance grew, it became impractical to revoke organic certification from users of the system. Hydroponic products are now approved for organic certification status by many certifiers, and recognized in the domestic and international markets as organic without any formal approval by the NOP.
Posted: to Industry News on Sat, Jan 10, 2026
Updated: Sat, Jan 10, 2026
