Inspections…Opportunities to Learn & Make Improvements

By:  Richard & Andrea

Operating a farm is not just planting, harvesting, washing, and packing vegetables. It’s also accountability, certifications, maintaining integrity, upholding standards and a lot of record keeping!  Over the course of a calendar year, we undergo several different inspections, a part of doing business for us as well as many other companies. Some of the inspections we undergo happen annually while others may occur every few years, spontaneously, or in response to an application or the like. Welcoming an inspector onto the farm can be intimidating sometimes, but we’ve come to look at inspections as opportunities to learn, grow and improve which means we walk away better than we were before!  Over the last month, we have undergone two on-farm inspections, so this is a topic that’s pretty fresh in our minds!  We thought we’d take a little time this week to share a glimpse into the inspection side of farming.  

We ease into the new year without any inspections scheduled for the month of January, but we take advantage of this first month to get ready for our first inspection which is usually scheduled for mid-February. The inspection I am referring to is our annual housing inspection with the Wisconsin Department of Workforce Development. This is a required inspection and is a necessary part of our application process for receiving H2A work visas for our workers. Even though we’ve been doing these inspections for over 20 years now, we learn something new and make additional improvements to our housing every year!  In recent years we’ve added Emergency Exit signs near all the door and window exits…in both Spanish and English!  We also make structural improvements such as remodeling a bathroom in one of our houses to convert an old tub to a more useful shower and replacing kitchen cabinets and flooring. We also regularly replace light fixtures and ceiling fans that wear out, repair leaking faucets, replace worn out furniture, and washers and dryers as needed….which can be quite frequently given the amount of heavy duty laundry that moves through those machines each week!  Of course, we also take care of the usual things such as replacing batteries in smoke and carbon monoxide detectors, making sure the beds have mattress covers and all the required bedding components, check to make sure the water heaters are working properly along with all the plumbing, and a long list of other requirements.  We have a total of three properties where we house our H2A employees and the inspector visits each property.  It’s a long inspection process, but a necessary part of being able to move forward with our application to get our crew members here for the season!  

Fire Training and
Extinguisher Inspection!

We typically don’t have any inspections in March, but sometime in early spring we contact a local team to come out and inspect our vast collection of fire extinguishers!  We have so many that they usually camp out in front of our shop for most of the day and work out of their mobile unit. We take fire safety very seriously and want to make sure our fire extinguishers are available and functional if and when we need them! We have fire extinguishers in all of the buildings on our main farm, in all of our housing units as well as in nearly all of our sheds and outbuildings. Additionally, we have fire extinguishers in our delivery trucks and on the three pick-up trucks that have additional fuel tanks on them for refueling. That’s not all though, we also mount a fire extinguisher on our propane forklift, the flamer and the bulldozer.  We are really thankful that they can come to the farm to do these inspections as it would be quite an ordeal to have to take them all into town! While we seldom need to use them, thankfully, we do find great peace of mind in knowing they are accessible and in working order should we have an emergency and need to use them!

Color Coded Brushes to Prevent
Cross-Contamination!

Once the growing season is underway, we have to schedule our annual organic inspection with our certifier, MOSA. As a certified organic farm, this is obviously a big inspection for us and a critical one at that! The timing for our organic inspection varies from year to year as the certifier likes to see our operation in the different seasons of production. Some years we have our inspection in late April or early May so they can inspect the woods where we wild harvest ramps while we’re actively harvesting.  This year they came in late July, which gave the inspector the opportunity to see our happenings mid-season, including our peak summer grazing pastures for our animals. We have a pretty thick file and it takes one to two days of onsite inspection plus some follow up as needed to submit additional documentation as requested by our reviewer.  This is a very thorough inspection. We submit paperwork in advance of the inspection as well as having documents available at the onsite visit for review. The inspector looks at everything from water tests for the packing shed processing water to receipts for our seed purchases. Over the past two years they have focused more on the animal side of our operation and we had to provide receipts and documentation for all of our animal feed purchases as well as any additional supplements we gave them (e.g. aloe pellets and essential oils used for their face rubbers).  As part of the inspection we also undergo at least two audits.  One audit is done for our meat sales and the other for vegetable sales. We have to provide documentation that demonstrates we only sold what we produced, so the production records need to be in alignment with the sales records.  This is one way they verify our integrity and sniff out fraud in operations. Another main focus over the past two years has been verifying our integrity related to the seeds we are purchasing. As organic growers, we are required to purchase organic seed whenever it is available. If organic seed is available on the market but we do not purchase it, we have to provide documentation for why we did not use it. Sometimes the seed is in short supply, and we have to substitute untreated seed, while in other cases the quality of the seed may be compromised for some reason (e.g. low germination) and we opt to go with the untreated seed.  All of this needs to be documented! We have file folders, electronic documents, and binder after binder that we consult along the way to provide the inspector with everything they ask for. It’s intense, but manageable if we are diligent about keeping good records throughout the year.  We also care about the integrity of the organic label and wish for all organic inspections to be conducted so as to uphold the organic standards industry wide!

Irrigation Pump & Filter Trailer

Given we’re in a drought year, irrigation is a primary topic in our thoughts and conversations from day to day.  This is another area where we are held accountable with oversight to ensure we’re using irrigation water responsibly.  We can’t just go drop an irrigation pump in any waterway we want to and pump any quantity of water we want or need.  We have to obtain an irrigation permit from the Department of Natural Resources (DNR) for each of our different pumping sites. This can sometimes be a long application and review process that at times has taken up to three years to complete! They establish a benchmark, which is the level we use to determine whether or not we can pump water. If the water level falls below the benchmark, we cannot extract water from that site. They come out with their surveying equipment and measure the benchmark to a very tiny margin of error. Throughout the irrigation season we have to monitor and record the benchmark water level, along with detailed records showing how much water we’re extracting.  At any point in time the DNR or a member of the public may ask to see our records and at the end of the season, we upload all of our irrigation records, and it becomes public record.  We’ve been pumping irrigation water from the Bad Axe River and our smaller creeks for over twenty years with no negative impact to the ecosystem or the wildlife in our area that depend on this water for life, habitat, and nourishment proving that it is possible to work in harmony with nature!

A place for everything and
everything in its place!

At the beginning of August, we welcomed our longtime inspector and food safety advisor, Dr. Kolb, back to our farm for our annual food safety inspection. We’ve been working with Dr. Kolb and Ceres Certifications International for over twenty years now.  We have been voluntarily doing annual food safety inspections for many years before it ever became mandatory by law, and because of that we’ve been able to stay ahead of the curve and create a “culture of cleanliness” that we hold in high regard on our farm.  Every year he has given us new challenges, doable improvements, one step at a time. He has told us, “when I come around the last curve on the road as I approach the farm and see clean fields and perimeters, no brush piles, no junk piles, all is in order, I know it will be a good inspection.”  This year he concluded our inspection visit by telling us “you are a model farm!”  Wow, we appreciate hearing that from a man who has inspected many farms across the country! Now don’t think he let us off easy.  We have a list of improvements we need to make to our policies and practices over the next year, including implementing a new “Plasters Policy” which involves establishing a system for being accountable for every band-aid used on our farm! He also encourages continuing education, so over the next year we will be investing in additional training on HACCP analysis for agricultural operations and improving our processes and policies along the way.

In addition to the inspections I’ve already mentioned, we also expect a visit every few years from the state food safety team to complete an onsite visit related to the FDA’s enforcement of the Food Safety Modernization Act (FSMA).  Our insurance company also likes to keep us in check, so they set us up with a Safety Audit every few years. We’ve found this to be very helpful and educational.  Last year the inspector asked us to secure the propane tanks we use for our propane forklift in one of our storage facilities. Of course, she told us a story about another client that did not have their back up tanks properly secured and one tumbled over and exploded. Ok, point taken! Within a few days of her visit, we had installed a safety chain to secure the tanks! Thank you!

Inspections can be intimidating, but we have been fortunate to have inspectors who take our inspections as an opportunity to educate us and help us make positive improvements to our operation. Inspections help us see our farm from a different perspective which can help strengthen our processes and keep us on our toes.  There’s no way around inspections, so we might as well make the most of the experience and use it as a way to improve and expand.  For you, our customers, inspections, and third-party audits provide you with the reassurance that we are doing what we say we’re doing!  We value integrity and want others to be held accountable as well, so we’ll keep on showing up and doing the best we can!

As we wrap up this year and head into another calendar year and growing season, we’ll start our preparations for next year’s inspections.  Over the winter months we’ll consult our lists of notes that we’ve made over the course of the busy season for improvements we want to make to our record keeping systems, filing systems, procedures, policies, etc. to make us stronger and help us pass our inspections with flying colors!  One important thing we emphasize is that while we may prepare for inspections, we don’t do anything different while the inspector is here than we do every other day of the year.  When you operate to the standards, inspections are just a technicality. The day-to-day operations are in check, and you have nothing to fret or worry about! 

Maintaining Organic Integrity

By Farmer Richard

Last week we had our annual organic inspection.  We’ve had this annual inspection every year for over forty years and have been inspected by three different certifying agencies.  Despite our history, we go through this inspection and our practices are reviewed every year in order for us to continue to be certified organic producers.  I’ve always been an advocate for organic certification and have encouraged many farmers to do the same over the years.  In fact I was part of some of the earliest efforts to form and support organic certification and was one of the first farms to be certified in the Midwest.  In order to understand today’s organic marketplace, I think it’s important to understand a little history.

The OGBA (Organic Growers and Buyers Association) of Minnesota was one of the first independent certifiers and was the certifier I worked with to get my organic certificate and be recognized as a “Certified Organic” grower when I was farming in Eagan, Minnesota back in the 70’s and early 80’s.  After moving to our present farm in Wisconsin I helped start the OCIA Wisconsin Chapter#1 (Organic Crop Improvement Association), which is still in existence and continues to certify worldwide.  From OCIA Wisconsin Chapter #1 was born MOSA (Midwest Organic Services Association) which is headquartered out of Viroqua, Wisconsin and is our current certifying agency.  They are a good, trustworthy organization!

 

In 1990 Congress passed The Organic Foods Production Act which mandated that the USDA would develop and write regulations to establish national standards for organic producers.  The purpose of this legislation was to bring clarity to the organic market place and establish a set of national standards.  Organic inspections are done by dozens of independent inspection agencies.  The USDA audits those agencies for compliance with the NOP (National Organic Program) standards.  The NOP is guided by the NOSB (National Organic Standards Board) appointed by USDA to oversee organic standards.  The NOP is now the federal regulator of these organic standards.

Organic inspectors are part of an independent certification organization where they receive training and guidance from experienced inspectors.  They do not “work for” any one certifier, but may do inspections for more than one.  I took certifier training in 1988 when I helped found OCIA Wisconsin Chapter#1.  Not because I intended to be an inspector, but wanted to know how well inspectors were trained.  I wanted consumers to trust “certified organic” and the certification process.  We have “trained” new inspectors through our own organic inspections and have been part of USDA Audits.  I have seen numerous producers who want to sell in the organic market, but want to hang on to their favorite conventional practices.  “I’ll just use a little Round-Up to keep the weeds out of my asparagus, it is safe!”  “A little ammonium sulfate fertilizer is needed to keep my crops green.”  “I can’t do all the paperwork that is required for certification.”  I’ve heard these phrases many times over the years and I’ve learned that the people saying these things are really saying “I do not have a clue about my operation because I don’t keep records!  I have no ability to ‘trace back’ and I don’t really know what inputs are approved for organic production.”   Part of going through organic certification is also about education and awareness, which is good for any farmer!

One of the reasons I’m an advocate for organic certification is that I don’t think consumers should have to be able to ask a producer about the many details of their production.  A consumer should be able to trust the standards upon which an organic farmer is held to and know what that certification represents.  There are hundreds of suppliers trying to sell products as “natural & organic,” but are they?  There’s another organization called OMRI (Organic Materials Review Institute) that is very important for organic growers.  They precede the NOP and continue to be approved by the NOP to review all products including additives and fillers to get “OMRI approval.”  We only use OMRI approved products because we trust their scientific diligence more than any sales person or brochure and it makes certification much easier when we’re using products we know are already approved.

So what does an inspection involve?  Our inspector arrived at 9:00 am.  We started with a facilities tour, at which time he chose three crops to audit for trace back.  We continued the inspection and showed him all of our buildings, every field, all the animals, animal housing, pastures and our ducks. He was also able to view the first hatch of 21 ducklings!  We showed him our intentional habitat for pollinators and beneficial insects and creatures.  He also observed our crop production systems including the use of reflective mulch to deter pests.  We use this as a first line of defense for problem pests and consider it a “must” before we use any organic based pesticide.

Then the paperwork!  We were asked to show every input from seed to harvest, from field to end customer as part of the trace back audit.  All of our products are assigned a lot number that allows them to be traced back to the field they were grown in, the day they were harvested, who harvested the crop, etc.  Additionally, we have to provide documentation of what seed was planted, the field work associated with the crop, etc.  Compare that to the recent illness and death from contaminated romaine lettuce and pre-cut packs.  It took weeks and still no resolution for the cause of contamination.  Most conventional foods have no trace-back or lot number system and thus, no transparency.  If you want cheap food, that is what you get, no accountability.  Certified organic has always required traceability!  We passed our audits, provided all the information and supporting evidence he asked for and did our exit interview at 3:30 pm.  Our inspector submitted his report to MOSA where it will be reviewed by the MOSA review board and we expect to receive our renewal that will include our “free-range organic ducks” this year! 

Organic Integrity?  Is it a process you can trust?  If the certifier is MOSA, for sure.  In my opinion, they are the best certifying agency available.   The USDA Organic seal?  Well there are some problems!  When organic sales rose to several billion dollars, the Big Ag players wanted to get in on the market.  Of course, they didn’t like the rules so they paid politicians to represent them and get the rules changed.  They got the animal welfare and pasture rules thrown out and “no soil” hydroponic production is now in.  So if you buy the cheaper organic at the larger chains you probably are getting milk from cows that never see a blade of grass and organic eggs from chickens stacked three deep per square foot and never see the outdoors.  MOSA says they will not certify those farms, but there are several certifiers who will.  You can look at scorecard reports from Cornucopia Institute, an

excellent “organic watch dog” organization.  They have reviewed many companies who say they are organic, yet there practices are not in line with the standards.  USDA has not done

due diligence to preserve “organic integrity.”  There were significant quantities of fraudulent organic grain shipped from Turkey and Russia that should have been stopped at the port of entry.  We are now watching the development of standards that go “beyond” USDA organic that are being developed by the Organic Farmers Association  headquartered at Rodale Institute. They plan to certify farmers for all aspects of “organic integrity.”  In the meantime, buy with care and, as always, it is best to know your farmers!