The Final Rule of the USDA’s National Organic Program (NOP) is the
legal standard for organic food production in the United States.
This rule requires that every certified organic farm have an “organic production
plan,” sometimes called an “organic farm systems management plan” or simply,
an “organic plan.”
In plain terms, an organic plan describes how the farm has been,
and will be, managed. The plan is put together by the farmer and must be
approved by the organic certifying agency that the farmer selects.
Besides fulfilling a requirement for organic certification, the organic
plan can be a very helpful tool for farm management. Writing it forces
the farmer to collect, compile, and think about a wide range of production
and stewardship information. Of course, the plan also helps the certifier
figure out if the farm is in compliance with federal regulations.
According to section 205.201 of the organic rule, an organic plan
- A description of practices and procedures to be performed and maintained,
including the frequency with which they will be performed;
- A list of each substance to be used as a production or handling
input, indicating its composition, source, location(s) where it will be
used, and documentation of commercial availability, as applicable;
- A description of the monitoring practices and procedures to be
performed and maintained, including the frequency with which they will
be performed, to verify that the plan is effectively implemented;
- A description of the record keeping system implemented to comply
with the certification requirements
- A description of the management practices and physical barriers
established to prevent commingling (physical contact or mixing) of organic
and non-organic products on a “split” operation (those that produce both
organic and conventional products) and to prevent contact of organic production
and handling operations and products with prohibited substances; and
- Additional information deemed necessary by the certifying agent
to evaluate compliance with the regulations.
As everyone knows, things don’t always go according to plan.
So the organic plan is just that - a plan, not necessarily a promise.
Circumstances may call for changes in the plan. If that happens, it’s critical
that a farmer check with their certifier - before, not after, implementing
a change - to be sure that the operation will still be in compliance. Organic
farm plans are required to be updated every year anyway, to reflect any
changes in management.
Some growers have good record keeping systems, and are comfortable
putting together written plans from year to year as means of organizing
their resources and managing production, markets, and money. For others,
farm planning is done in a little black notebook, on the back of an envelope,
or entirely in their heads. Most growers are already using past seed and
fertilizer orders, pest control records, sales receipts, and payroll records,
etc. to decide what to do in the coming year. If planning has been mostly
a ‘seat of the pants’ affair for you, then putting your records and recollections
together into a comprehensive farm plan may seem pretty daunting. It’s
a good thing there are some easy-to-use tools to help with the process.
In some cases, the application documents and questionnaires provided
by certifying agencies capture most of the information that’s required,
so these forms, along with the farm’s regular records, become the organic
There are also some generic forms that can help you put together
an well-organized organic plan. An excellent example is available
on the Appropriate Technology Transfer for Rural Areas (ATTRA) web site: https://attra.ncat.org/attra-pub/summaries/summary.php?pub=359.
This is a very useful document for producers who are developing an
organic plan for the first time. It can help you compile the required information
about production methods and inputs used on your farm. At the end is a
field history sheet that can be completed for as many fields as you are
certifying. The information about past management practice in various fields
is an essential part of the organic plan.
The forms on the ATTRA web site are in the public domain and may
be printed and copied as needed. Downloading them and filling them out
on your computer has the advantage of letting you modify the form and add
or remove sections to fit your farm.
If you are considering organic certification – or even if you aren’t
– developing a comprehensive farm management plan may help you find ways
to improve your production efficiency and stewardship of natural resources.
Such a plan may also help with other applications such as the Natural Resource
Conservation Service’s cost share programs.
To read the entire organic rule or to get explanations of what it
means and how to implement it, visit the NOP website at: http://www.ams.usda.gov/nop/.