IOIA/OMRI/BCS
Advanced Organic Inspector Training
Submitted by Bob Howe, Trainer
This training was held November 18th and 19th. The site for the training was a Spa Resort named “St. Joseph’s Institute”, in the northern Appalachian Mountains, in Central Pennsylvania, a few miles from PennStateUniversity. The site provided ultimately comfortable accommodations for the attendees who stayed on site and meeting rooms that were very adequate and free from distraction. Food was very good, nearly all organic, and much of it donated.
The training focused on three areas of auditing and inspection; Materials (in general for all types of organic entities), Livestock (emphasis on dairy animals) and topics pertinent to organic handling.
Materials
The Materials presentations included a half day titled “Inspecting Inputs for Organic Operations”; presented by Dr. Brian Baker (founder and current Research Director of OMRI) and Renee Mann (Quality Systems Manager at OMRI). The presentation covered the process by which brand materials are evaluated and added (or not) to the “OMRI Products List”, including the parallel comparison to the work that organic certifiers and inspectors do to verify a client for organic certification, proving to be very similar. There are opportunities for organic inspectors to become involved with OMRI through performing inspections for them.
This OMRI presentation also covered the technique of obtaining various types of materials samples and the procedures and documentation needed to maintain the appropriate chain of command.
An adjunct to the presentation was the field trip to the PennState composing operation. This is a rather large operation that takes the food wastes from the campus and the leaves and clippings from the landscaping as well as the packed manure from the farm. The process is windrow with adherence to the turning and temperature requirements for the elimination of any pathogens and completing the breakdown of the materials. Samples are analyzed for C:N ratio in the rows and for pathogens in the final product, which is stored under a large, fabric covered Quonset after being screened to remove plastic and other undesirable materials. Samples were taken by some class members to complete the training.
Emily Brown Rosen presented the subject of “Organic Integrity and Secondary Materials Issues”, alluding to the grey area “additives” with reference to FDA definitions and regulations. Central to the presentation was the conflict of the FDA regulations (under 21 CFR) and the NOP regarding ingredients, processing aids and sanitizers, in terms of allowing the use and what has to be on the label. This is a technical subject with many unclear imperatives, where the OFPA and NOP leave a final authority to the FDA and where certifiers normally apply their own interpretations. Her presentation explained how the scope of National List is limited by 21 CFR for Direct and Secondary Direct Additives and GRAS, and further confused by the exemptions for Food Contact Substances and Indirect Additives “as classified by FDA”. Those in attendance came away with a much better understanding of the subject and the problems that inspectors and certifiers are faced with.
Emily provided examples in order to demonstrate. She also explained just how an applicant for an additive and the FDA go about having the additive listed as a Food Contact Substance (FCS) through the Food Contact Notification process (FCN) and how this compares with the apparently stricter NOP policy.
Through her presentation, she was clear that:
•Materials in direct contact with organic food should be on the National list for handling.
•NOP policy still stands but may be subject to further legal action
•Certifiers may have different policies.
The subjects relative to Livestock, of an advanced inspection nature, discussed animal health and nutrition and Body Condition Scoring.
Livestock
Dr. Hubert Karreman, VMD talked about his experiences with the 80 herds of dairy cattle under his care and his observations of other cattle during his travel through the rural Lancaster countryside. Dr. Karreman is the Chair of the NOSB Livestock Committee. Dr. Karreman was a herdsman at what was and is a recognized, humane farm. Particular emphasis in his presentation was placed upon the organic dairy farm. He always avoids the use of methods and medications that would take an animal out of the certification, but would not hesitate to medicate if the situation was serious and the animal’s life and welfare would be at risk.
He explained that the organic farmer, in some cases, was more interested in maintaining the organic status of the herd. The economic effect of removing an animal to non-organic status, particularly in the smaller herds, could be significant. The case is sometimes that the farmer will delay treatment and/or use unproven remedies to cure a sick animal rather than call in the Vet earlier. With non-organic herds, more often than not, the farmer will act more quickly to treat an illness. Another concern was that many farmers do not quarantine a sick animal and the sickness can spread through the herd. He urged organic inspectors to look for these incidences and tell the farmer and, at a minimum, make an appropriate comment in the report.
Dr. Karreman talked about the livestock living conditions and cited NOP references. He emphasized this topic with pictures from organic farms that he had been on. Some pictures showed dirty drinking troughs and animals standing in and drinking from standing water that was contaminated. Others showed animals in the barns with dirty bedding or no bedding, paddocks that were nothing but mud or had poor quality forage plants and various other unsanitary and bordering on inhumane conditions. He emphasized that organic inspectors need to do more than just look at the animals and the medical records. Inspectors must persist with questions about the treatment and feeding of the animals, particularly if/when the inspector is concerned in any way about the conditions.
Dr. Karreman sees little change in a farmer’s methods and the way the farmer manages the herd over time. This being the case, an organic inspector will probably experience the same. He recommended that the farmer needed to keep records of calls made to Veterinarians and the treatment they did on the farm. The best way, he said, was to for the farmer to provide a journal that a Veterinarian would complete upon a visit, including treatments made and treatments recommended, even if the farmer refused the treatment. He also talked about animal identification. In his opinion, the tag on a neck chain was not acceptable because it can be lost or, an unscrupulous farmer could switch the tag to another animal if it would benefit him or her.
It was clear that Dr. Karreman believed in organic certification for dairy herds. It was also clear that there were problems for the animals as a result of organic certification and that inspectors needed to be more vigilant during their inspections. He also favors an increase in unannounced inspections.
Amber Lemin, PSU Extension Dairy Herd Health Educator, explained how Body Condition Scoring (BCS) is done for dairy animals. She provided a series of pictures to demonstrate how one can look at a dairy animal and come fairly close to the body condition. She explained how the BCS will vary throughout the period of lactation and over a dry period. The ideal BCS for the health of the animal, the success of pregnancy and the milk production is 3.25 in a scale of 1 to 5. This was demonstrated with graphs of results from studies, where milk production starts low at the beginning of lactation and increases to a peak, tapering off at the end of the period. The graphs showed the change in the BCS where the BCS will drop normally about 1 full point during this time and that the healthy animal with appropriate feed will eat more during peak production of milk and less at other times.
Her presentation showed that there is very little difference between an animal with a BCS of 2 and a BCS of 1; in either case being a thin animal and more subject to illness. Also, there is little difference in the scoring of an animal that has a BCS of 3.75 and greater, that they are heavy and will not produce as well and will not calve as reliably. BCS can be applied to any breed. Methods for BCS for other livestock were not discussed.
Sarah Flack, of NOFA-VT Organic Dairy and Livestock Technical Assistance and inspector, provided information and resources that an inspector can use to determine the nutritional value of the dairy rations being provided. She emphasized that rations needed to be varied according to the stage of the animal’s lactation and the availability of pasture. She showed how grass fed animals can be undernourished and how grain and other feed supplements are used to round the nutritional value of the rations. The charts she provided explained how the combination of the various components of the rations are calculated for the total dry matter and the effect the total dry matter had on milk production and on the health of the animal.
Maintaining feed records are essential for the dairy farmer. The records need to be thorough and specific to the animal when possible. Further, based on the records, when available, or at least on what the farmer explains he provides, the inspector needs to verify that the supply of organic components was sufficient to provide the rations for the herd. This will often entail looking through harvest records and purchase records and performing a mass balance audit to confirm the numbers.
Sarah’s presentation included a listing of several websites where data on harvest volumes for various feed crops can be obtained, specific to regions, and websites where conversions for dry matter and nutritional value of feed can be obtained. She tied her presentation to the earlier presentations on livestock health and BCS and implied that those could be used to help improve an inspector’s judgment about the herd being inspected and the validity of the rations data provided by the farmer.
Dr. Gregg Martin talked about Poultry Health. Dr. Martin explained how an audit of poultry health was conducted with regard to living conditions of space provided, bedding, food, water, and light and outside access. He compared types of confinement and moveable pasture, explaining the potential for parasites and transfer of disease from passing bird populations.
Dr. Martin explained that a mortality rate for the duration of the flock should be 95% or better. Less than that can indicate a problem or poor management. He has found some flocks to exceed 98% mortality. He talked about morbidity and emphasized that the inspectors need to observe for obviously unhealthy birds and birds that have been cannibalized. He explained that it was essential to cull these birds or quarantine them. Also, it is important to have the cause of death investigated if and when it appears to be unusual.
Good records at the farm were again deemed essential. The records pertaining to feed (quantities and types), medications and mortality are minimum information. He explained that well managed flocks were far more productive than those not as well managed. Egg production and size are factors in layers and size and quality in slaughter flocks. Stress will significantly reduce the productivity of layer flocks and significantly reduce the quality of the meat from slaughter flocks.
Dr. Martin does audits for a number of humane societies and is very sensitive to humane treatment of flocks, citing several factors that have an effect. Obviously well managed flocks are much less stressed than others. However; for slaughter flocks, all can be for naught if the animals are stressed prior to slaughter with rough handling or cramped confinement.
Handling
Sam Welsch, Founder and Director of One Cert, presented the One Cert Product Profile format. Sam showed examples of several product profiles to demonstrate how the Excel form is used to generate the true percentage of organic ingredients in a recipe. He began with a simple, two ingredient recipe and proceeded with subsequently more complex items containing salt and water and some with made with ingredients. The calculations take into account that only 100% organic ingredients can be included at their full weight (excluding water and salt) and ingredients that are organic must be factored at 95% of the weight if the actual % organic is not known. Made with ingredients are factored at 70% unless the actual % organic is known. This method of calculation is particularly important when products are at or slightly above the 95% range when calculated without the factoring for the % of the individual ingredients.
The format is available on the One Cert website, as are the instructions for using it: . Sam explained that the format is included when you request the certification packet for Processors/Handlers. The format has been revised since it was first made available and there are further revisions possible, making the format more useful as a tool for the processors and the CB’s to assist in maintaining the suppliers’ documentation and keeping the product profiles up to date.
Maarten Samsom discussed how 205.201(a)(3) is not always adhered to by the certified entities and how adherence can and does enhance and facilitate inspections. He also demonstrated how the level of compliance to the NOP is improved when entities apply it. The text of the section is “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.”
Maarten explained that he begins an inspection by asking the client when they last monitored (performed an “internal audit”) the effectiveness of their OHP. He explained further that the clients seem to welcome the opportunity as it is an empowering activity, particularly for the QA person or other individual who has little authority to enforce the OHP otherwise. Further, when he has returned for the annual audits he finds that the compliance has improved in almost all cases, and the time required to complete the inspection is significantly reduced, often to less than half of the time taken prior to the implementation of the internal audits.
Additionally, Maarten queried the group to ascertain the reasons why people were attending the training and why they were involved in the organic movement. The greatest number stated that they were trying to have a positive impact on the environment, second was the belief that organic food is better in terms of nutrition and food safety. With that information, Maarten briefly expressed his concerns about the use of materials that are harmful to the environment; such as the sanitizers (quats in particular) and pest control chemicals that are contaminating the ground and water in great quantities. He expressed that his belief is that organic is more than just compliance to the obvious and pointed out references within the regulation that imply a holistic standard, and inspectors and CB’s need to include the effect on the environment when auditing and reviewing the clients for certification. The concern about the use of “secondary materials” was also mentioned by Emily Brown Rosen during her presentation.
Sam Welsch talked about labeling issues pertinent to the identification of the “handler” and the “certifier”. He explained that the “handler of the final product”, who is required to be identified, is most often the labeler and not the packer. The identification of the labeler, as the handler of the final product, does not provide the information about the actual processor. The picture becomes even more unclear when the label identifies only the certifier of the labeler, particularly when the processing of the product can be certified by another certifier and the logo of that certifier is not printed on the label. The consumer can be mislead by the label and the verification of the audit trail can become cloudy, if not questionable.
(The definition of “handler”, from the NOP: Handler: Any person engaged in the business of handling agricultural products, including producers who handle crops or livestock of their own production, except such term shall not include final retailers of agricultural products that do not process agricultural products.)
Sam also talked about the 100% organic and not 100% organic and some of the factors that are used to determine the level of certification.
Bob Howe presented an overview of inspecting restaurants for organic certification. The overview included the main areas of concern and what must be considered when performing a restaurant inspection. The presentation covered the subjects of “certification Status”, “type of menu”, “sources of supply”, “facility” and “audit trail”. The presentation, overall, emphasized the need to be well prepared before initiating the inspection and to expect to spend whatever time necessary to do a comprehensive evaluation and verify compliance.