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

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Chronological Thread  
  • From: road's end farm <organic101 AT linkny.com>
  • To: Brigette Leach <avalonfarmshomegrown AT earthlink.net>, Market Farming <market-farming AT lists.ibiblio.org>
  • Subject: Re: [Market-farming] Market-farming Digest, Vol 46, Issue 1/NAIS
  • Date: Sat, 4 Nov 2006 09:42:07 -0500


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 grown.

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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