What Service Providers Must Know About Organic Rules and Regulations

What Service Providers Must Know About Organic Rules and Regulations

Summary

Our project will develop a collaborative team of agricultural trainers, including extension specialists, organic certifiers, and farmers, to develop a two day training workshop about organic production, certification and regulation. This is a “train the trainer” program. We will work with the experts from NCAT who developed the materials for organic training and agricultural specialists from several institutions to develop a curriculum for training service providers who work directly with farmers. This is a comprehensive program to train the trainers. We will implement the training program through workshops in Florida, Kentucky and the Virgin Islands at both 1862 and 1890 institutions. This program will be the first to use the training materials developed through NCAT’s SARE National Initiative grant entitled “Sustainability and Compliance Tools for Organic Farmers”. Our project will therefore serve as pilot test for NCAT’s materials and will link two SARE grants, enhancing the benefits of each.

To date, we have assembled the teams in each state that will be responsible for the development and implementation of the training program. We have developed an outline for the training curriculum and have assigned team members specific modules to develop. We are developing the evaluation tools for the training. We have scheduled a pilot training for the materials that we are developing in July, 2004.

Objectives/Performance Targets

The following were the objectives of this proposal.
Objective 1: Develop Multi-Disciplinary, Multi-Institutional Training Teams. Our first objective is to develop a team of trainers in each state. These teams will include state Extension specialists, representatives of certifying agencies and experienced organic producers. These teams will take responsibility for developing and implementing training for field personnel in each state. The desired outcome is that each state will have a functional team of experienced and knowledgeable trainers. The desired behavior is that these teams will provide leadership for training programs in organic production in each state.

Objective 2: Develop a Two-Day Comprehensive Training Program for Field Personnel. Our second objective is for the three teams to work together to develop a comprehensive two-day training program in the regulations covering organic production and certification for field personnel. The desired outcome is a training program for field personnel from the Cooperative Extension Service, other USDA field agencies, collaborating state agencies, and organic certifying agencies (public or private). The desired behavior is that this training program is incorporated into the formal in-service training programs provided by Cooperative Extension Service, other USDA field agencies, collaborating state agencies and training for organic certifiers offered through both the public and private sector.

Objective 3: Deliver Training to Field Personnel. Our third objective is to deliver the training program to at least 125 individuals who work directly with farmers. The desired outcome is field service providers understand and are able to communicate the regulations regarding organic production in the United States to agricultural producers. The desired behavior is that field service providers develop training programs about the requirements for organic production for farmers and that they provide timely, accurate information to growers about the requirements for organic production on an individual consultation basis.

Objective 4: Finalization of Training Curriculum Distributed through NCAT’s ATTRA Project. Develop a comprehensive training program that can be used by other land grant institutions or other agriculturally related parties in organic regulations and certification. The training curriculum would utilize ATTRA’s materials developed from the SARE funded national initiative entitled “Sustainability and Compliance Tools for Organic Farmers“ and the materials developed from this project to provide a comprehensive training curriculum on the NOP final rule. NCAT’s ATTRA project will be responsible for distributing these materials to interested parties.

Accomplishments/Milestones

Accomplishments for Objective 1: Develop Training Teams. Rose Koenig and Mickie Swisher from the University of Florida, Marion Simon from Kentucky State University and Carlos Robles from the University of the Virgin Islands have identified teams of five to eight individuals to participate in the project. The training teams include members from Cooperative Extension Service, USDA, accredited certification organizations, non-governmental organizations and experienced organic farmers. Team leaders participated in a number of conference calls to orient the group to the objectives of the project and assign tasks. Teams were assembled by the team leaders and invited to participate in a meeting to determine the training curriculum and orientation. The teams met in-person on January 26-27th in Gainesville, Florida.

Accomplishments for Objective 2: Develop Training Program. The training teams met on January 26-27, 2004 to discuss the development of the training program. The general outline for a core curriculum that will be used in all training sessions was discussed and the group was divided into work teams that were responsible for different modules of the core curriculum. Additionally individual states will develop supplemental curriculum that is specific to their needs. The core curriculum will cover the following modules and include the information noted in the outline developed as an output from this session and subsequent conference calls.

What Service Providers Must Know about the Organic Rule and Regulations
Training Modules

Module 1: Overview of organic production

Goal: Agents will understand the history and current status of the organic industry and the basic requirements for certification

Principles:
a. Definitions, including other production systems such as sustainable, biodynamic, etc for clarity
b. History of the organic method of production
c. Economics/market share/price differentials
d. Certification personnel and procedures, accreditation of certifying agents
e. Things change and disasters happen – variances and possible changes
f. State organic programs

Materials and resources
Certification forms
Lists of certifying agencies
Cost share – where

http://www.ers.usda.gov/publications/aib777/ - Economic Research Service (USDA) publication on growth in the organic foods market in the US

Washington State University - Useful Web Sites & Printed Materials on Organic Farming
(Date 3/18/03)http://ext.wsu.edu/noas/LINKS/books.html
Organic Materials Review Institutehttp://www.omri.org/
USDA National Organic Programhttp://www.ams.usda.gov/nop/index.htm
The New Farm (Rodale Institute) On-Line Magazine http://www.newfarm.org/
National Sustainable Agriculture Information Service http://attra.ncat.org/

Reference to the Rule
§ 205.2 Terms defined
§ 205.100 What has to be certified.
§ 205.101 Exemptions and exclusions from certification
§ 205.290 Temporary variances
§ 205.300 Use of the term, "organic
§ 205.301 Product composition
§ 205.310 Agricultural products produced on an exempt or excluded operation.
§ 205.311 USDA Seal.
§ 205.400 General requirements for certification.
§ 205.401 Application for Certification
§ 205.402 Review of application

§ 205.403 On-site inspections.
§ 205.404 Granting certification.
§ 205.405 Denial of certification.
§ 205.406 Continuation of certification
§ 205.500 Areas and duration of accreditation of certifying agents
§ 205.501 General requirements for accreditation.
§ 205.502 Applying for accreditation.
§ 205.503 Applicant information.
§ 205.504 Evidence of expertise and ability
§ 205.506 Granting accreditation.
§ 205.507 Denial of accreditation
§ 205.508 Site evaluations
§ 205.509 Peer review panel
§ 205.510 Annual report, recordkeeping, and renewal of accreditation
§ 205.607 Amending the National List.
§ 205.620 Requirements of State organic programs.
§ 205.621 Submission and determination of proposed State organic programs and amendments to approved State organic programs.
§ 205.622 Review of approved State organic programs
§ 205.640 Fees and other charges for accreditation
§ 205.641 Payment of fees and other charges.
§ 205.642 Fees and other charges for certification.
§ 205.660 General information on compliance
§ 205.661 Investigation of certified operations.
§ 205.662 Noncompliance procedure for certified operations
§ 205.663 Mediation.
§ 205.665 Noncompliance procedure for certifying agents
§ 205.668 Noncompliance procedures under State organic programs
§ 205.672 Emergency pest or disease treatment.

Module 2: The Farm Plan

Goal: Agents will understand the physical features necessary for a farm to be certified

Principles:
a. Necessary field history and the information required for this
b. Which crops or products are to be produced and whether they are organic, transitional
or conventional
c. Special requirements for ‘mixed’ (organic and conventional) farming, in general
(specifics may be included in other modules)
d. Inclusion of processing, livestock, etc. and how it affects the required information
e. Paperwork requirements for certification relating to farm plan

Materials and resources

Reference to the Rule
§ 205.103 Recordkeeping by certified operations.
§ 205.202 Land requirements

Module 3: Planting stock – seeds and transplants

Goal: Agents will understand what planting materials are acceptable for use in organic production and where to find sources of planting stock

Principles:
a. Definitions – treated, untreated, GMO, organic seed, organic transplants
b. Acceptable seed treatments (i.e. compounds applied to seeds or physical treatments
applied to seed)
c. What constitutes ‘fair effort’ for certified organic production?
d. On-farm transplant production and the facility requirements (greenhouse construction,
soil/media, water source and application, pest control)
e. Paperwork requirements for certification relating to planting stock

Materials and resources

Reference to the Rule
§ 205.204 Seeds and planting stock practice standard

Module 4: Soil and water quality and crop fertility

Goal: Agents will understand the reason as well as the methods for maintaining soil quality, crop fertility, and water quality in organic production.

Principles:
a. Healthy soil, healthy plant concept
b. Methods and importance of monitoring soil and water quality
c. Amending the soil
1. Crop rotation
2. Crop residues/green manures
3. Manure requirements and acceptable usage
4. Compost use and production
5. Acceptable fertilizers
6. Concepts of soil health and/vs. fertilization
d. Water use and application
e. Required evidence of soil and water conservation
f. Paperwork requirements for certification relating to soil and water quality and
fertilization

Materials and resources

Reference to the Rule
§ 205.105 Allowed and prohibited substances, methods, and ingredients in organic production and handling
§ 205.203 Soil fertility and crop nutrient management practice standard.
§ 205.205 Crop rotation practice standard
§ 205.600 Evaluation criteria for allowed and prohibited substances, methods, and ingredients.
§ 205.601 Synthetic substances allowed for use in organic crop production.
§ 205.602 Nonsynthetic substances prohibited for use in organic crop production

Module 5: Crop Management

Goal: Agents will understand the mechanisms and methods available to organic growers for the control of insects, weeds and diseases.

Principles:
a. Definitions – A, R, and P designations of pest control materials
b. Importance of and methods for monitoring pest presence and populations
c. Crop rotation for pest control
d. Use of mulches – acceptable types and usage
e. Acceptable methods of pest control
1. Physical
2. Biological
3. Chemical
f. Emergency measures for pest control
g. Paperwork requirements for certification relating to pest control

Materials and resources

Reference to the Rule
§ 205.105 Allowed and prohibited substances, methods, and ingredients in organic production and handling.
§ 205.206 Crop pest, weed, and disease management practice standard.
§ 205.600 Evaluation criteria for allowed and prohibited substances, methods, and ingredients.
§ 205.601 Synthetic substances allowed for use in organic crop production.
§ 205.602 Nonsynthetic substances prohibited for use in organic crop production
§ 205.607 Amending the National List.

Module 6: Organic Integrity

Goal: Agents will understand the importance of and methods for maintaining organic integrity in production, handling and transportation of products.

Principles:
a. Definitions – organic integrity, commingling, etc.
b. Requirements for buffers, signage, monitoring, etc. for adjoining lands
c. Requirements for sharing of equipment with conventional production
d. Provision for prevention of commingling during harvest, post harvest handling and
transportation of product
1. Harvest containers
2. Packaging
3. Storage facilities
4. Transport
e. Paperwork requirements for certification relating to maintenance of organic integrity

Materials and resources

Reference to the Rule
§ 205.105 Allowed and prohibited substances, methods, and ingredients in organic production and handling.
§205.200 General – Organic Handling and Processing
§ 205.201 Organic production and handling system plan.
§ 205.271 Facility pest management practice standard.
§ 205.272 Commingling and contact with prohibited substance prevention practice standard.
§ 205.307 Labeling of nonretail containers used for only shipping or storage of raw or processed agricultural products labeled as "100 percent organic," "organic," or "made with organic (specified ingredients or food group(s))."

Module 7: Livestock

Goal: Agents will understand the concept of organic production of livestock and the specific requirements of certification for livestock producers.

Principles:
a. Types of livestock
1. Dairy vs. slaughter herds
2. Other livestock
b. Conversion of herds
1. Production of breeder stock
2. Handling of replacement stock
c. Feeds and feed supplements and additives
d. Health care and pest control
e. Housing and living conditions
f. Manure management
g. Organic processing on-farm or through another agency
h. Marketing
i. Paperwork requirements for certification relating to livestock production

Materials and resources

Reference to the Rule
§ 205.236 Origin of livestock.
§ 205.237 Livestock feed
§ 205.238 Livestock health care practice standard.
§ 205.239 Livestock living conditions.
§ 205.603 Synthetic substances allowed for use in organic livestock production
§ 205.604 Nonsynthetic substances prohibited for use in organic livestock production
§ 205.607 Amending the National List.

Module 7: Handling and Processing

Goal: Agent will understand what activities constitute handling and processing and how these affect the certification, labeling and marketing of organic products

Principles:
1. Labeling and terminology
2. Types of processing
3. Ingredients
4. Use of logos and seals
5. Requirements for export
6. Use of wild crops for sale as organic
7. Water use and quality
8. Organic integrity
9. Monitoring and quality assurance
10. Equipment and sanitation
11. Packaging, storage and transport
12. Pest management
13. Record keeping

Materials and resources

Reference to the Rule
§ 205.200 General – Organic Handling and Processing
§ 205.201 Organic production and handling system plan.
§ 205.207 Wild-crop harvesting practice standard.
§ 205.270 Organic handling requirements.
§ 205.271 Facility pest management practice standard.
§ 205.301 Product composition
§ 205.302 Calculating the percentage of organically produced ingredients
§ 205.303 Packaged products labeled "100 percent organic" or "organic."
§ 205.304 Packaged products labeled "made with organic (specified ingredients or food group(s))."
§ 205.305 Multi-ingredient packaged products with less than 70 percent organically produced ingredients.
§ 205.306 Labeling of livestock feed.
§ 205.307 Labeling of nonretail containers used for only shipping or storage of raw or processed agricultural products labeled as "100 percent organic," "organic," or "made with organic (specified ingredients or food group(s))."
§ 205.308 Agricultural products in other than packaged form at the point of retail sale that are sold, labeled, or represented as "100 percent organic" or "organic."
§ 205.309 Agricultural products in other than packaged form at the point of retail sale that are sold, labeled, or represented as "made with organic (specified ingredients or food group(s))."
§ 205.311 USDA Seal.
§ 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as "organic" or "made with organic (specified ingredients or food groups(s))."
§ 205.606 Nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as organic or made with organic ingredients.
§ 205.607 Amending the National List.
§ 205.670 Inspection and testing of agricultural product to be sold or labeled "organic.”
§ 205.671 Exclusion from organic sale.

In addition to the core curriculum, each state will include activities and materials that address issues of special importance to the state’s producers. The Florida team is working on additional modules for citrus, rice, sugarcane and other important commodities. The Kentucky team likely will work on additional modules for livestock. The Virgin Islands will concentrate on a more basic understanding of the organic industry and regulation. Each state team will assume responsibility for the components specific to that state.

Evaluation

We will evaluate changes in knowledge and expertise of field personnel through a pre- and post-test. The test will evaluate changes in knowledge and expertise in the regulations covering organic production in the United States. The pre-post test method is commonly used for measuring changes in knowledge, which is calculated as a percentage change in correct responses to the questions.

We will use a standard instrument developed by the Institute of Food and Agricultural Sciences to evaluate the overall quality of the training program. This standard instrument provides a good overview of the participants’ perception of the overall quality and value of the training, including training materials. It was developed by specialists in evaluation at the University of Florida and is extensively used by Florida Cooperative Extension Service.

We will use Likert-like scales to measure participants’ attitudes about (1) the importance of providing advice to organic or potential organic farmers and (2) their confidence in their ability to do so. Likert-like scales are a well established social research tool. They are based on a set of phrases that range from strongly negative to strongly positive. Examples would be: “I am very confident that I can provide growers with useful information about the regulations covering organic production,” or “Providing information about organic production to farmers is not very important.” Each respondent indicates his/her agreement with each phrase on a scale of 1 to 5 where 1 means strongly disagree and 5 means strongly agree. We are measuring two variables and therefore we will use two Likert-like scales, although the phrases will be intermingled into one instrument when we conduct these evaluations. Participants will respond to the Likert-like scales before and after the training. Changes in composite raw scores pre- and post-training will provide a measure of change in attitude and confidence on the part of participants.

We will develop a web-based instrument to evaluate the degree to which trainees used the information provided during the training in their work. All participants will be provided with the web site for the instrument by e-mail. Three separate announcements will be made, in accordance with standard procedures for mail-out questionnaires. A web-based questionnaire is for all purposes a mail questionnaire. Responses will be anonymous. The program for web-based instruments generates a random number assigned to each respondent when the form is completed and submitted.

During the meeting in January, the teams reviewed rated questions proposed for some of the evaluation materials by Dr. Swisher and a graduate student. The participants also submitted questions that they felt were important for evaluation tools. The survey instruments are currently being refined and further developed by Dr. Swisher and a graduate student. These materials will be tested in the pilot training in July.

When the common core curriculum and state component curriculum are developed, a pilot training program will be conducted in Fort Pierce, Florida. This training has been scheduled for July 26-28, 2004. This will be the test for the training materials, overall curriculum and evaluation materials. The participants at this pilot program will be selected to include individuals with varying degrees of experience with organic production, ranging from very little to extensive experience. The pilot workshop will be used to make changes in both the NCAT training materials and in the overall curriculum design.

Accomplishments for Objective 3: Deliver the Training. None at this time

Accomplishments for Objective 4: Finalization of Training Curriculum Distributed through NCAT. None at this time.

Impacts and Contributions/Outcomes

The following contributions and outcomes have been accomplished to date for this project:

1. The three institutions/states involved in the project have identified and assembled a team of individuals who will help develop and implement the trainings.

2. The teams have met in-person and developed an outline for the training curriculum.

3. Committees have been assigned modules for the training that they will be responsible for developing by June 2004.

4. State teams are working on modules that are specific for the needs of their state.

5. Evaluation tools are being developed for the training program.

6. A date for the pilot training has been set and all materials necessary for the test training will be assembled by July 1, 2004.