2 Steps of the certification process

Organic certification is meant to assure consumers that the farmer followed all requirements of the USDA organic regulations. During the certification process, the farmer works with the certifier and inspector through several different steps. Veterinarians may find it helpful to understand the certification process so they can 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.

Determine eligibility of the land and livestock

A farmer can apply for organic certification of pastureland after a 36-month period of documented practices show no prohibited materials were applied. Farmers and ranchers need to document all land use and applications of material during the three-year transition period. This land requirement is a crucial concept 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 prior to 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 it is recommended that farmers apply before the end of their transition period. The farmer submits several pieces of documentation with the application, such as a farm map, field histories, and the Organic System Plan (OSP).

The OSP is an important tool for the farmer to describe their operation. The OSP essentially describes the farm practices, recordkeeping system, management practices, all substances that may be used (also known as the Materials List), estimates of projected organic yields and sales, and physical barriers used to prevent commingling and contamination of organic and prohibited substances (which is an especially important consideration for split operations). Veterinarians should pay close attention to what is included in the Materials List since it includes 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 the product and add it to the OSP. If this process isn’t followed correctly, the certifier may revoke certification and/or prohibit an animal to be slaughtered under organic status. However, it is important to keep in mind 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 the treatment of organic and alternative animals can be found in “Treatments and practices for organic and alternative livestock”.

The certifier reviews the application and determines whether additional documentation is necessary. Applications may be denied, delayed for further clarification, or approved for inspection. Inspections are then performed by an inspector.

The organic inspector is a representative of the certifying agency and trained to maintain confidentiality. They inspect every organic farm each year to look for violations, verify the OSP is accurate, and examine the farm’s records. More information on record-keeping practices are available in subsequent chapters, “Practice management considerations for working with organic and alternative livestock clients” and “Treatments and practices for organic and alternative livestock clients”. The inspector asks questions, visits each area, assesses the health of all livestock and their living conditions, and performs an exit interview with the farmer. As an independent third-party, the inspector is not allowed to provide advice on farming practices or overcoming certification barriers.

Once the inspection is complete, the inspector writes a report and sends it to the certification agency 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 will receive a letter from the certifier with a range of notices, including:

• issuance of the Organic Certificate;
• a notice of noncompliance (with correctable actions identified); or
• denial of certification or proposed revocation.

Once the Organic Certificate is issued by the certifier, 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 are required to 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, and undergoing an annual inspection. Also, among other activities to strengthen enforcement and reduce fraud, as of March 19, 2024 the NOP 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).

Further information about noncompliance procedures can be found in 7 CFR 205.660 – 663.