[Market-farming] Market-farming Digest, Vol 46, Issue 1/NAIS

road's end farm organic101 at linkny.com
Sat Nov 4 09:42:07 EST 2006

On Nov 3, 2006, at 11:02 PM, Brigette Leach wrote:

>  Rivka,
>  How does record keeping as it pertains to organic standards provide 
> trace back?  I'm talking about situations other than when you might 
> have sold directly at the market. Of course those individuals know, or 
> they assume they know, where and how that product was grown.

Exact details will vary from operation to operation, and to some extent 
according to certifying agency. The principles are the same: everything 
bought from you needs to be traceable back to the field in which it was 

I don't do livestock; I do fresh market vegetable and fruit crops. I 
keep records of every input to a given field (seed sources, transplant 
sources, soil amendment sources, dates and rates of applications and 
planting, etc.); of planting plans, so I can show what was planted in a 
given field; of harvest records; of sales records.

In the case of farmers' market sales, I note what I took to market and 
what came back unsold, so that I have records to show, for example, 
whether I sold snap peas at that market; how much of that crop I sold; 
and what field(s) they were harvested from, on what date. The final 
customer, as you say, is in that case buying direct from me. There is 
no practical way to confirm the customer's memory of whether they 
bought those peas from me or from someone else; at least unless I had 
no peas at market on that date, or far fewer than the customer says 
they bought; which I would have records to show.

In the case of sales to a food coop or other wholesale sales, I keep a 
copy of invoices. The purchaser also keeps invoices. The invoices 
include my address, and also the name of my organic certifying agency 
and my certification number. Procedures for identifying the product 
within the store undoubtedly vary from store to store, but the store is 
also supposed to have records that let them identify from which 
source(s) the organically grown peas on their shelves on a given date 
came from. When I sold through a wholesaling cooperative, we coded each 
case with a date and farm identification code, so that the case could 
be traced back to the specific grower.

I believe that livestock are generally identified by ear tags, except 
poultry by flock; but I don't raise livestock and don't know what forms 
of ID are acceptable. I'm sure that if you want to spend the money to 
identify your livestock with GPS tags you could do so. But as long as 
you can identify them clearly, there's no need to pay for such systems; 
unless the individual farmer sees a need on her/his specific operation.

How is this different from NAIS? In several ways. One obvious one is 
that it's voluntary, more or less; though now required if you want to 
use the word "organic" and to sell over $5000 yearly. Certainly it 
would not apply to anyone growing only for their own use, or to 
livestock kept as pets or transportation.

Another major difference is that there is considerable leeway as to how 
you keep the records. Organic farms are inspected at least yearly; the 
inspector checks that you are keeping records, and that the inspector 
can make sense of them. But you can keep them in your computer, in a 
notebook written in by hand, on preprinted forms, or whatever; and in 
any format that does make sense. NOFA-NY, at least, only cares that 
they'll work: that if there is a problem traceback will be possible. 
(Some certifiers may have set forms and specific requirements as to how 
to deal with them. I've gotten certification statements for straw I 
purchased, certified through OCIA, that had been sent by the grower to 
the certification agency, who then sent copies of them to me. But most 
growers have several agencies active in their area to choose from; so 
you can choose a certifier based partly on whether their record keeping 
requirements fit your operation. OCIA I believe certifies mostly large 
wholesaling field crop operations; NOFA is more likely to certify 
highly diversified direct-marketing small farms.)

And another significant factor is that most of these records are kept 
by the farmer. They are checked by the private inspecting agency. They 
don't go to the federal government, to be kept on record who knows how 
long in what fashion, unless this becomes necessary to resolve an 
actual problem (in which case, of course, they could and would be 
supplied to whatever department of health or other agency actually 
needed to deal with them.)

This is an awful lot of record keeping; and it is often a royal 
nuisance (especially that list of amounts of everything that went to 
and came back from market, done in a rush while packing for market and 
in a state of exhaustion on return). But I have found that the records 
required are very useful to me in doing the next year's planning; which 
has pretty much reconciled me to them. My memory as to whether purple 
beans sold better than yellow wax, for instance, turned out to be 
unreliable; but the written record was there to inform me. Clear input 
records are also highly useful; I can easily tell what I actually did, 
and check this against results.

>  Do you have examples of the inequitable treatment and enforcement 
> against smaller operations while exceptions are made for larger 
> enterprises?
I gave several in an earlier email on this subject.

NAIS as proposed would be another one: small producers would be 
required to tag every animal, large producers would not be.

-- Rivka; Finger Lakes NY, Zone 5 mostly
Fresh-market organic produce, small scale
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