Organic Materials Compliance

1. Organic Materials Compliance
Materials for Organic Production, Handling, and Processing:
Planning for Compliance with USDA’s National Organic Program
A Publication of ATTRA - National Sustainable Agriculture Information Service • 1-800-346-9140 • www.attra.ncat.org
By Ann Baier and The USDA’s National Organic Program regulates the use of substances and materials for farming, handling,
Lance Gegner and processing. This publication discusses three basic steps to ensure that materials use is compliant
NCAT Agriculture with organic standards and certification. First, understand the regulations relevant to your operation.
Specialists Next, create an Organic System Plan with your certifier. Finally, keep records of your purchase and use
of all materials. Following these steps will help ensure compliant use of materials, and avoid any use of
© 2008 NCAT a prohibited material or incorrect use of a restricted material—which could necessitate an additional
three-year transition process.
Contents Materials that are used to produce and
Three Steps to Ensure handle organic crops under the USDA’s
Organic-Compliant Use National Organic Program (NOP) must
of Materials for Organic be selected for compliance and used in the
Photo: Rex Dufour
Production and
Handling context of organic principles for farming
Step One........................2 and handling practices.
Become familiar with
National Organic The NOP regulations describe organic
Program regulations farming systems as those that maximize
about materials for your
type of operation. cycling of nutrients through crop rota- Beneficial insect hedgerow along organic field edge.
Step Two ......................4
tions, cover crops, and green manures.
List every material you The systems are designed to conserve soil, Certified organic producers and handlers
use or plan to use in the improve soil health, enhance biodiversity, must use only materials that are approved for
Organic System Plan with use according to the standards to which they
supporting
and prevent pest problems. Organic farm-
documentation as ing is not simply the substitution of nat- will be certified. Therefore, the first step is
required, and obtain ural materials for synthetic ones. It is a to understand the standards relevant to one’s
approval from your operation. Prior to using any material, certi-
organic certifier of this whole-systems approach.
Plan before you use any fied operations must include in their Organic
material. Organic producers and handlers first must System Plan (OSP) a list of all materials they
Step Three ....................7 be able to describe and document how their use or plan to use. They must have the OSP
Document every input operations apply organic principles and approved by their organic certifier.
material purchase and implement proactive strategies to prevent
use, and keep those problems. Then they verify and document Finally, organic producers and handlers must
records for a minimum of
five years. compliant use of materials employed for keep records of the purchase and application
specific purposes within those operations. of all materials. This three-step process will
enable the producer or handler and their cer-
Whether a material is allowed or not tifier to evaluate materials for their intended
depends on the context. Some types of specific use, and to ensure their compliance
ATTRA—National Sustainable
materials are integral to maintaining an with relevant standards.
Agriculture Information Ser- organic system. Others may be used only
vice is managed by the National when cultural, biological, mechanical, or Non-compliance can jeopardize certifica-
Center for Appropriate Technol-
ogy (NCAT) and is funded under physical methods are insufficient. This tion status. Use of a prohibited material or
a grant from the United States paper discusses some basic steps to ensure violation of a restriction (annotation) on
Department of Agriculture’s
Rural Business- Cooperative that the materials proposed for use are com- the use of a material can set an operation
Service. Visit the NCAT Web site pliant with organic standards and certifica- back three years to begin the transition
(www.ncat.org/agri.
html) for more informa- tion to NOP standards. process again.
tion on our sustainable
agriculture projects.

2. Three Steps to Ensure Organic-Compliant Use
To help ensure compliant use and documentation of materials for organic
production and handling, follow these essential steps:
STEP ONE —
Become familiar with NOP regulations about
materials for your type of operation.
The regulatory texts of the National Where in the Standards can I
Organic Program standards are find the rules about materials?
R
available on USDA’s National Organic
ead the Program website: Sections 205.105 and 205.600-606, the
Rule: www.ams.usda.gov/nop/indexIE.htm National List of Allowed and Prohibited
In general, Substances, are the main places to find
To view the production and handling stan- information about allowed and prohib-
Natural Materials
dards, go to the above page. Under General ited materials. However, there are also spe-
are allowed (unless Information, click on Regulations to bring cific regulations within the standards for
they are prohibited); up a new window. Then under Regulatory certain materials. For example, applica-
Synthetic Materi- Text, click on Electronic Code of Federal tion of raw manure is addressed in section
als are prohibited Regulations. It is important to review the 205.203(c)(1); production of manure-based
full set of regulations in order to find and compost in 205.203(c)(2), and other materi-
(unless they are
understand the key parts that apply to your als used for soil fertility in 205.203(d).
allowed). Then, pay operation.
attention to
The General Rule for Organic
annotations. What do the NOP Standards say Crop and Livestock Production:
about Input Materials? Or: Natural materials are allowed.
Why isn’t the answer simple? Synthetic materials
Several sections of the National Organic are prohibited.
Program regulations (the “Rule”) describe
which materials are allowed for what pur- For organic crop and livestock production,
poses and under what circumstances. Sec- the Rule clearly states that natural materi-
tions of the Rule that address materials als are allowed unless specifically prohibited,
allowed for specific purposes can be found in and that synthetic materials are prohibited
the paragraphs that discuss crop production, unless they are specifically allowed.
livestock production, and handling (process-
ing). Several materials are listed with anno- The Exceptions:
tations that limit or restrict products to spe- Allowed Synthetic Materials
cific uses within these broader purposes. For
example, hydrated lime may be used as an The following sections list the exceptions to
ingredient in Bordeaux mixture for disease this general rule. Section 205.601 lists syn-
management on fruit trees—when other pre- thetic substances allowed for use in organic
ventative practices are not enough and its use crop production. This list includes sub-
is consistent with Rule section 205.206(e). stances such as fish extracts for fertilizer,
But hydrated lime cannot be used as a soil chlorine for washing vegetables (discharge or
amendment. effluent water concentration below drinking
Page 2 ATTRA Organic Materials Compliance

3. Organic calves on pasture on LaMacchia Ranch, Gonzales, California, owned and managed by Frank and Irene LaMacchia. Organic livestock
operations use compliant practices and materials to manage their fields and pastures as well as their animals’ health. Photo: Ann Baier
water standards), and copper sulfate for crop Materials lists for organic
disease control. Section 205.603 lists syn-
thetic substances allowed for use in livestock
processing and handling Related ATTRA
production, and includes materials such as are organized differently. Publications
iodine, vaccines, vitamins, and minerals. For organic processing and handling, the National Organic
lists of materials that are allowed for use Program Compliance
The Exceptions: are in separate sections of the National List Checklist for
(205.605 and 205.606). These lists are orga- Producers
Prohibited Natural Materials nized differently than crop and livestock National Organic
Sections 205.602 and 205.604 list nonsyn- lists, in that they name specific allowed Program Compliance
thetic (natural) materials prohibited for crop and restricted materials. Section 205.605 Checklist for Handlers
and livestock production, respectively. lists non-agricultural substances allowed for Organic Farm
use in or on processed products labeled as Certification & the
While each of these lists is fairly short, it “organic” or “made with organic ingredients” National Organic
is important to become familiar with the (product claims). The National List section Program
prohibited materials as well as the allowed 205.606 lists non-organically produced agri-
materials. cultural products that are allowed as ingre-
Organic Crop
Production Overview
Just as some of the synthetic materials are dients in products labeled as “organic” or
“made with organic ingredients.” NCAT’s Organic Crops
restricted by annotations, some of the pro- Workbook – A Guide
hibited natural substances have exceptions You can list a material or product planned to Sustainable and
that permit their limited use. for use in your Organic System Plan (OSP) Allowed Practices
with relative confidence by verifying that it NCAT’s Organic Live-
is allowed. stock Workbook –
A Guide to Sustainable
and Allowed Practices
Organic System Plan
(OSP) Templates for
In the hedgerow shown on page one, a Certifiers
Monarch butterfly larva and aphids feed
on narrowleaf milkweed, as the chrysalis Organic Certification
sparkles like a jewel. This native perennial Process
hedgerow was planted at Fong Farms in
Woodland, California, to attract beneficial Preparing for an
organisms. The aphids, larva and chrysa- Organic Inspection:
lis represent diversity on the farm. They Steps and Checklists
also serve as non-pest alternate hosts for
parasites and predators that are feeding on And many more listed
farm pests. The field in the background is at www.attra.ncat.org/
planted with organic alfalfa. organic.html
Photo: Rex Dufour.
www.attra.ncat.org ATTRA Page 3

4. STEP TWO —
List every material you use or plan to use
in your Organic System Plan (OSP)
with supporting documentation as required,
and obtain approval from your organic certifier of
this Plan before you use any material.
Verify the precise identity of Check whether the material or
any material you plan to use, product you plan to use is
including the product brand currently listed or registered
name, formulation, and on one or more of the
C
reate an manufacturer/source of every approved lists of Brand Name
Organic material in your Organic or Generic materials.
System System Plan. Always use the most current information
Plan with a list of Avoid the common mistake of confusing the available. The websites of OMRI and WSDA
compliant materials manufacturer of a product (who made it) listed on page six are best to verify any claim
that you plan to use. with the distributor or supplier (who sold it of listing. A very recent printed guide is next
Your certifier must to you). It is the identity of the manufacturer best. It is the organic producer or handler’s
that is important in determining whether a responsibility to verify any claim of listing
approve this Plan.
product is allowed. Whether you bought it for compliance by checking it against cur-
from the local hardware store or the farm rent lists on the website. When in doubt,
supply is unimportant. contact your certifier to determine the sta-
tus of any material that you are considering
for use.
Find out if your organic
certifier has a list of approved If the material/product you are
brand name materials, or interested in using is not on a
whether they honor other lists. current approved list, follow
Many certifiers recognize the Organic Mate- your certifier’s instructions to
rial Review Institute (OMRI) and/or the verify its compliance.
Washington State Department of Agricul- Work with your certifier to evaluate the
ture (WSDA) products lists (see direct links material by providing supporting documen-
and explanation of these lists below). In this tation (product label, Material Safety Data
case, certified clients can refer to these cur- Sheet–MSDS, manufacturer’s statement,
rent lists of acceptable brand name mate- and/or ingredient list with all ingredients
rials. Some certifiers maintain their own including inert ingredients). You and your
internal lists instead of, or in addition to, certifier will need sufficient information
OMRI and WSDA. about the product and its production pro-
cess to assess whether the material is allowed
under the standards.
The NOP issued a memo to Accredited Certification Agencies on March 5, 2008
regarding “Verification of Materials” and documentation of such:
http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5066877
Page 4 ATTRA Organic Materials Compliance

5. Maintain your OSP to be current Verify materials use in the
and accurate by reviewing and context of the OSP.
updating it regularly. In addition to materials, the OSP must
also include a description of your produc-
The Organic System Plan is essentially a con-
tion practices and procedures, monitoring,
tract that includes written plans concerning
recordkeeping system, and prevention of
all aspects of agricultural production or han-
commingling and contact with prohibited
dling (NOP Section 205.201). Any materials
materials, and any other information as spec-
used or planned for use must be in current
ified in Section 205.201. This other infor-
compliance.
mation provides the context under which a
You should review and update your Organic material may or may not be allowed for use.
System Plan at least annually or as changes
Even if a given input is on a list that the cer-
are made. Keep a copy for yourself and sub-
tifier recognizes—whether WSDA, OMRI,
mit any updates promptly to your certifier,
or even their own list of materials—a certi-
as required by 205.400(f).
fier may still deny the use of a material in
M
the context of the OSP.
any
certifiers
agree
Excerpts from OMRI’s website and publications explain their work. that OMRI Products
Lists are invaluable
The Organic Materials Review Institute (OMRI) is a tools to help find
501(c)(3) nonprofit organization that specializes in the review
compliant materials.
of substances for use in organic production, processing, and
handling. OMRI’s services are directed to all aspects of the Find the most
organic industry with a primary focus on the decision mak- current lists on their
ers who deal with the compliance status of generic materials website:
and brand name products. With the OMRI Generic Mate- www.OMRI.org.
rials List and OMRI Products List, OMRI provides guid-
ance on the suitability of material inputs under the USDA
National Organic Program standards.
How products are reviewed
OMRI reviews applications from input suppliers for products in crops, livestock, and
processing. To assess compliance with the National Organic Program Rule, OMRI
requires product applications to contain all the relevant public and proprietary
information regarding product ingredients, formulations, and manufacturing
processes. OMRI operates under a rigorous confidentiality policy to guard against
disclosure of proprietary product information to unauthorized individuals.
As a nonprofit organization, OMRI is able to offer an independent, third-party
review of products that can balance the need for confidentiality in reviewing
proprietary formulations with the necessity to ensure that products comply with the
National Organic Program Rule.
The review process consists of two steps: review and recommendation by OMRI
staff, and decision-making by an independent Review Panel. All products are
reviewed according to published policies and standards.
www.attra.ncat.org ATTRA Page 5

6. B) Washington State Department of
Materials Lists Agriculture Materials List
A) The Organic Materials Review http://agr.wa.gov/FoodAnimal/Organic/
Institute (OMRI) Products List MaterialsLists.htm
www.omri.org/OMRI_datatable.htm The Washington State Department of
OMRI’s primary reference manuals are Agriculture (WSDA) registers several brand
the OMRI Products List (brand name name materials for use in organic production
materials, available on their website) and handling. WSDA provides the following
and the OMRI Generic Materials List explanation of their brand name lists:
(available for purchase on their website). “In order to comply with National Organic
These resources help interpret the NOP’s Standards, producers and handlers must
National List and enable producers and use substances in compliance with National
processors to determine under what cir- Organic Program requirements (7 CFR Part
cumstances a material or product is allowed 205). WSDA Organic Food Program has
W
for use in organic production. OMRI lists evaluated the products on the Brand Name
ash- are updated quarterly, and users should be Material List (BNML) and determined that
ington sure they are using the most current version they comply with the National Organic
State of the list. The most current product listings Standards.
Department of can be found on OMRI’s website.
WSDA does not imply any guarantee or
Agriculture also OMRI’s services are valuable to facilitate endorsement of any of the products listed
evaluates understanding of materials and products on the BNML. In addition, manufacturers
materials and that are consistent with the National List, of these products are not required to list
maintains a list of even though OMRI is not officially accred- their products on the BNML. Therefore,
allowed brand ited by the NOP. Inclusion on the OMRI this is not a comprehensive list of brand
name products. Products List must be renewed every year name materials that meet organic standards.
by the manufacturer. Some products may be Please refer to the National List of Allowed
listed one year and not the next. Reformula- and Prohibited Substances for further
tions can render a product non-compliant. information regarding materials for use in
Alternately, a reformulation can bring a pre- organic food production.”
viously non-compliant product into compli-
ance. In some instances, a producer will be C) Your Certifier’s List
required to document the lot number of a Ask about whether one exists and how you
product in order to verify its compliance. can access its information.
Note: The program is voluntary and many
The U.S. Environmental Protection registrants of NOP-compliant products
Agency (EPA) has issued a notice for have chosen not to identify their
how pesticide registrants can obtain products as such. For more information,
EPA approval to identify products that visit the EPA’s website:
comply with the NOP Rule for organic www.epa.gov/oppbppd1/biopesticides/
production and handling. regtools/organic-pr-notice.htm
Page 6 ATTRA Organic Materials Compliance

7. STEP THREE —
Document every input material purchase and use,
and keep those records for a minimum of five years.
Input purchase records may include receipts ATTRA’s Record Keeping & Workbook draft
or invoices, delivery tags, and receiving by Ann Baier and Holly Born
logs. Input application records must include http://attra.ncat.org/downloads/organic_ Be Careful!
Material (Brand name/formulation), Manu- cert/recordkeeping_budgeting.pdf.
facturer/source, Crop, Location, Frequency, Prior to using
Rate and Quantity, Purpose (e.g. fertilizer, ATTR A’s workbooks, checklists, sam- any substance
pest control), and Date Applied. ple forms, and other guides for organic in an organic
certif ication including documenta- operation,
Your certifier may provide forms to facilitate tion forms for livestock, field crops, mar- carefully
documentation of input applications. Several ket farms, and orchard, vineyard, and evaluate the
types of sample documentation forms are berry crops can be downloaded for free at status of
also available from ATTRA: http://attra.org/organic.html. the material
according to the
National List
and the Brand
Name Material
List.
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forms for tracking
input use. One exam-
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icationassistance.php
www.attra.ncat.org ATTRA Page 7

8. Special thanks for input and review from:
James Wynn and Brian Baker
Organic Materials Review Institute (OMRI)
Miles McEvoy and Katherine Withey
Washington State Department of Agriculture
(WSDA) Organic Program
Jim Riddle
University of Minnesota.
Organic Materials Compliance—
Materials for Organic Production, Handling, and
Processing: Planning for Compliance with USDA’s
National Organic Program
By Ann Baier and Lance Gegner
NCAT Agriculture Specialists
© 2008 NCAT
Karen Van Epen, Production
This publication is available on the Internet at:
www.attra.ncat.org/attra-pub/organicmaterials.html
or
www.attra.ncat.org/attra-pub/PDF/organicmaterials.pdf
IP313
Slot 312
Version 081808
Page 8 ATTRA