Guide for Organic 

Crop Producers

By Pamela Coleman

National Center for Appropriate 

Technology (NCAT)

Agriculture Specialist

November 2012

Contents

CHAPTER 1 

INTRODUCTION

New farmers, and farmers experienced in conventional agriculture, often find that 

obtaining organic certification for their crops is quite challenging. This guide is 

intended to help lead farmers through the organic certification process. Chapters 

1 through 4 explain the National Organic Program (NOP) and describe the process of 

organic certification. Later chapters explain specific USDA organic regulations that apply 

to planting, soil fertility, pest management, and other farm practices. In addition to interpreting the regulations, this guide explains the practices and materials that are allowed for 

organic production.

Who should read this guide? •	 Conventional farmers who are considering organic certification for their crops. 

•	 Farmers in the process of converting to organic practices.

•	 Farmers who are new to organic certification.

•	 Farmers who are exempt from certification because they sell less than $5,000 

of organic produce per year.

•	 Extension personnel and other information providers.

This guide was designed to be read before completing an application for organic certification. This is not a required document; it is a helpful guide that you may use as you wish. 

How to use this guide

To be certified organic by the U.S. Department of Agriculture (USDA), 

farms must be managed in accordance with the regulations in Title 7, Part 

205 of the Code of Federal Regulations. Where the USDA organic seal 

appears, the text quotes from these Federal regulations. The verbatim text 

of the regulation language follows the section and paragraph (for example, 

§ 205.203). The verbatim text is followed by an explanation of the regulation.

Chapter 1

Introduction...........................................1

Chapter 2

Organic Agriculture –

Description and History .................3

Chapter 3

The Certification Process...............7

Chapter 4

Writing the Organic 

System Plan (OSP).............................13

Chapter 5

Soil Fertility...........................................18

Chapter 6

Seeds and Planting Stock........... 25

Chapter 7 

Crop Rotation..................................... 29

Chapter 8

Managing Pests, Weeds, 

and Diseases........................................32

Chapter 9

The National List of 

Allowed and Prohibited 

Substances............................................37

Chapter 10

Greenhouse Production ............. 43

Chapter 11

Preventing Contamination 

of Organic Crops..............................46

Chapter 12

Post-Harvest and Labeling........ 50

Chapter 13 

Recordkeeping.................................. 54

Chapter 14 

Structural Pest 

Management...................................... 57

Chapter 15

Resources..............................................61

This guide uses the term “USDA organic regulations” to refer to the United States’ Federal 

regulations that govern organic crop production, livestock production, handling, processing, 

and labeling. Different terminology is often used in other publications to refer to the same 

regulations: “National Organic Standards,” “NOP Final Rule,” or simply “standards,” “Rules,” 

or “requirements” are common examples. In this guide, some of the section titles in the 

regulations are referred to as “standards” to correspond with the actual text—for example, 

“§ 205.204 Seeds and planting stock practice standard.”

The term “standard” is also commonly used in relationship to the National Organic Standards Board (NOSB). The NOSB is a citizen advisory board that helps the U.S. Department 

of Agriculture (USDA) determine which substances and practices may be used in certified 

organic production and handling. However, these recommendations are not part of the 

USDA organic regulations until the USDA decides the appropriate regulatory direction after 

completing a formal review and receiving public comments.
Page 2 www.ams.usda.gov/nop Guide for Organic Crop Producers

The book icon indicates publications available from ATTRA-National Sustainable Agriculture Information Service. ATTRA provides farmers and educators with information 

about sustainable agriculture via toll-free helplines, an extensive Web site, and hundreds 

of publications. These publications can be downloaded from the ATTRA Web site, or you 

can call the ATTRA helpline to request a print copy. ATTRA’s Web site is www.attra.ncat.org.

Its English-language helpline number is 800-346-9140; the Spanish-language helpline 

number is 800-411-3222.

Additional useful resources can be found at the end of this guide.

This icon indicates resources that are available on the Internet. 

This icon precedes the questions at the end of each chapter. The questions serve as a 

checklist to help you evaluate your farm’s eligibility for organic certification and identify 

areas where your practices may need to be changed.

Consider each of the questions carefully and place a check in the appropriate Yes, No, or 

Not Applicable box. Answers that accurately reflect your current circumstances will be the 

most helpful to you. Ideally, most of your checks will be in the Yes boxes. Negative answers 

may indicate a need to modify your farm practices to comply with the regulations.

When you have questions about whether a particular practice or product is allowed in 

organic production, consult a certifying agent. 

This icon at the end of a chapter indicates a place where you can add your own notes. 

Notes 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 3

CHAPTER 2

ORGANIC AGRICULTURE – 

DESCRIPTION AND HISTORY

The origins of organic farming

Contemporary American organic farming has its roots in the humus farming movements that spread across Great Britain and continental Europe from the 1920s through the 1950s. These movements evolved largely in response to the increasing 

use of synthetic fertilizers and pesticides. The proponents of humus farming believed that 

the highest quality food and the sustainability of agriculture were achieved by “feeding the 

soil,” thereby building soil fertility. Their goal was to increase the humus—the fully decomposed organic matter that has reached a stable state in the soil. Humus farming was typified 

by mixed farms that included livestock, food crops, feed crops, and green manures. Humus 

farming made little or no use of soluble commercial fertilizers or pesticides, in part because 

the health of the soil rendered them unnecessary. 

The 1960s and 1970s brought more visibility to organic farming in the United States, 

as public concern over pesticide use increased. In the minds of consumers, the non-use 

of pesticides was an important part of organic agriculture. The growth of the organic 

industry during this era led to the establishment of standards and third-party certification. Third-party certification is an assessment process carried out to verify compliance 

with standards. It involves the producer (farmer), the consumer (buyer), and a third 

party—the certifying agent who affirms that the product is produced in accordance with 

the organic regulations. 

As the organic industry expanded during the 1980s, different certifiers developed their own 

standards and certification processes. As a result, some certifiers did not accept the validity of organic certification by other certifiers. These disparities among certifier standards 

resulted in barriers to trade, which led many to believe that a consistent set of standards 

was needed: a single set of U.S. standards for organic production, labeling, and marketing. Eventually, Congress passed the Organic Foods Production Act (OFPA) of 1990. This 

act mandated creation of the National Organic Program (NOP), which is part of the U.S. 

Department of Agriculture (USDA) and the National Organic Standards Board (NOSB). 

The NOSB is an advisory board of 15 volunteers: 

•	 Organic producers (farmers)

•	 Organic handlers (processors)

•	 Retailers

•	 Environmentalists

•	 Scientists

•	 Consumer advocates

After the NOSB makes a recommendation on a new regulation or standard, there is a 

review and comment period. The NOP then determines the appropriate regulatory action 

to carry forward. In addition to the setting of standards (rulemaking), the accreditation of 

organic certifiers and the enforcement of the regulations are important tasks of the NOP. 

The definition of organic

With regulation came the need for more formal definitions of the term “organic.” In 1995, 

the NOSB defined organic agriculture as “an ecological production management system 

that promotes and enhances biodiversity, biological cycles, and soil biological activity.” 

Related ATTRA 

publications

www.attra.ncat.org

National Organic Program 

Compliance Checklist 

for Producers

Organic Standards for 

Crop Production: 

Highlights of the USDA’s 

National Organic Program 

Regulations
Page 4 www.ams.usda.gov/nop Guide for Organic Crop Producers

In 2002, the NOP defined organic agriculture: “Organic production [is] a production 

system that...respond[s] to site-specific conditions by integrating cultural, biological, and 

mechanical practices that foster cycling of resources, promote ecological balance, and 

conserve biological diversity” [§ 205.2].

This definition conveys both what makes each organic farm unique and all organic farms 

alike. Each farm is unique because farmers must make management decisions based on 

the singular conditions found in their own operations. Soil types, crop varieties, fertility 

requirements, pest pressures—no two organic farmers will manage all the variables that 

impact their farms the same way. Nor will changes in annual conditions such as rainfall 

and frost date allow an organic farmer to operate the same way year in and year out. Each 

season, organic farmers encounter a one-of-a-kind set of natural resource and environmental conditions to which they must adapt and respond. 

Organic agriculture as a production system 

Both definitions of organic agriculture above describe organic agriculture as a production system. This systems approach strives to understand how all parts of the system work 

together. In a systems approach, the farmer will consider how soil, water, plants, animals, 

insects, bacteria, fungi, and all other parts of the system can interact to cause problems or 

prevent them. 

The farmer’s management toolkit combines three types of techniques: cultural (e.g., planting 

disease-resistant varieties); biological (e.g., pheromone traps); and mechanical (e.g., appropriate tillage). Organic farmers combine these practices into a productive management 

system that minimizes the impact to the off-farm environment. All organic farmers share 

this approach, though their specific objectives determine how they implement it.

Since its beginning, organic agriculture has also been based on the principle of sustainability. Sustainability can be defined as meeting the needs of the present without compromising the ability of future generations to meet their own needs. In practice, this means 

that sustainable farming includes a focus on building the soil with farm-generated fertility, 

which will be covered in more detail in Chapter 5. Many farmers who convert from conventional to organic systems find that over time, as they add organic matter, populations of 

soil microbes and soil invertebrates will naturally increase, resulting in a rich, productive 

soil. This process can take several years. In time, the healthy, biologically active soil will 

produce healthy plants. The farmers then need fewer off-farm inputs because their crops 

are better able to resist drought, diseases, and insects. 

In addition to building healthy soil, successful organic farmers focus on preventing problems, rather than reacting to them. For example, organic farmers prevent insect problems 

by providing habitat for beneficial insects that keep populations of harmful insects in 

check. This guide provides many more examples in later chapters.

The importance of soil building and the need for a systems approach to organic production are sometimes overlooked or underestimated. For example, a standard practice in conventional agriculture is to plant large acreages in a single crop, which is very attractive to 

insect pests. The farmer monitors insect populations, and when the populations get so high 

that they might damage the plants, the farmer sprays insecticides. When farmers approach 

organic agriculture with an “input substitution” mentality, they react to high insect populations in the same way— search the list of allowed insecticides and choose which one to 

spray. This approach can be frustrating to the farmer. When it comes to broad-spectrum 

insecticides, there are fewer tools in the organic toolbox than in the conventional toolbox, 

Organic 

production [is] 

a production 

system that...respond[s] 

to site-specific conditions 

by integrating cultural, 

biological, and 

mechanical practices 

that foster cycling of 

resources, promote 

ecological balance, and 

conserve biological 

diversity” [§ 205.2].

“
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 5

and the tools approved for organic use can be more expensive. From this perspective, farmers might view organic production as a very limiting approach to farming. 

“Input substitution,” however, is not the approach encouraged by the organic regulations. 

This guide explains many techniques available to build soil, grow healthy crops, and prevent pest outbreaks. Many farmers who converted from conventional to organic practices 

found that this approach contributed to their success. 

Another approach to organic farming is sometimes referred to as “organic by neglect.” 

In this approach, essentially no inputs are used. The farmer avoids the use of prohibited 

chemicals but also neglects the farm-management practices needed to build soil fertility 

and prevent pest and disease outbreaks. This often results in poor crop quality and productivity and is in contrast to the organic philosophy of active management to build soil 

organic matter and enhance biodiversity.

The National Organic Program

The NOP began in 1990 to develop regulations applicable to organic certification. These 

regulations—known as the NOP Final Rule at the time—went into effect in October 

2002 and govern organic crop production, livestock production, handling, processing, 

and labeling. The regulations can be found under Title 7, Part 205, of the Code of Federal 

Regulations. Title 7 deals with agriculture, one of 50 broad topic areas that are subject 

to Federal regulation. 

The regulations include certification requirements, which producers must meet to sell 

their products as organic. Organic certification is the process of verifying compliance with 

organic regulations. The assessment process is carried out by a third-party certifier—an 

independent body that is not linked to either the seller (the farmer) or the buyer. Products 

to be sold as organic in the United States must be certified organic to the regulations and 

must be certified by a USDA-accredited certifying agent (ACA). There are about 100 such 

ACAs currently operating worldwide. Some certified organic products may be labeled with 

the USDA organic seal.

Many other countries, including Japan and members of the European Union (EU), have 

their own standards for organic products. Organic producers planning to export their

products (or sell them to distributors who may export them) should ask their buyers

whether they need to be certified to additional standards as well as USDA organic regulations. The United States has equivalence arrangements with Canada and, beginning June 

1, 2012, with the EU. Organic products certified to the USDA organic regulations may 

be sold, labeled, and represented as organic in Canada and EU member countries. This 

arrangement eliminates the need for U.S. organic operations to have a separate certification 

to the Canadian or EU standards and vice versa. There are a few exceptions to this equivalence, called “critical variances.” For example, a critical variance for EU-bound food is that 

crops produced using antibiotics (streptomycin for fire blight control in apples and pears) 

may not be sold as organic in the EU under the arrangement. Check the NOP Web site for

current information regarding critical variances.

The USDA organic regulations also include general requirements for accreditation, which 

establish the requirements that certifiers must meet in order to issue organic certificates. 

The processes for farm certification and certifier accreditation are similar: an application 

that describes the operation’s procedures, an onsite inspection, and a report that indicates 

any changes that must be made to comply with the regulations. This accreditation process 

ensures that all certifiers apply the regulations in the same way. The NOP maintains a list 

of ACAs on its Web site. 

S

ustainability can 

be defined as 

meeting the needs 

of the present without 

compromising the ability 

of future generations to 

meet their own needs.
Page 6 www.ams.usda.gov/nop Guide for Organic Crop Producers

Organic certification

§ 205.100 What has to be certified

Under the regulations, most operations or portions of operations that produce 

or handle agricultural products that are intended to be sold, labeled, or represented 

as organic must be certified. Producers who illegally represent their products as organic 

may be subject to prosecution and fines of up to $11,000 for each violation. 

During the application process, many certifiers will require farmers to sign an agreement that they 

will comply with the organic production and handling regulations in accordance with Title 7 CFR Part 

205 National Organic Program Rule.

§ 205.101 Exemptions and exclusions from certification

Producers who market less than $5,000 of organic products annually are not required to apply 

for organic certification. They must, however, comply with the organic production and handling 

requirements of the regulations, including recordkeeping. The products from non-certified 

operations cannot be used as organic ingredients in processed products produced by another 

operation, cannot be used as feed for organic animals, and may not display the USDA organic seal.

Online Resources

USDA National Organic Program, www.ams.usda.gov/nop

U.S.–European Union Organic Equivalence Arrangement Questions and 

Answers, www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5097061

Notes 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 7

CHAPTER 3

THE CERTIFICATION PROCESS

Certification under the National Organic Program (NOP) is required to label, 

represent, and market qualifying products as organic. Organic regulations are covered in Title 7, Part 205 of the Code of Federal Regulations. Subpart C is entitled 

“Organic Production and Handling Requirements.” The full text of the organic regulations is 

available on the NOP Web site and key portions of the text are excerpted in ATTRA’s “Organic 

Standards for Crop Production.” The regulations are arranged in outline format, using letters, 

numbers, and Roman numerals to indicate the levels, as follows— § 205.203 (a)(1)(i).

This guide does not include the full text of the regulations; rather, it provides excerpts from 

the text and an interpretation of the regulations that apply to fruits, vegetables, field crops, 

herbs, and greenhouse operations. If you raise mushrooms, sprouts, or livestock, you’ll 

need to consult additional references. 

There are two categories of organic operations: producers and handlers. Organic producers 

may grow crops, collect plants from the wild, or raise livestock. These farming operations 

receive an organic producer certificate. Organic handlers may buy food for resale or may 

process foods (slicing, freezing, drying, mixing, blending, etc.). These operations receive 

an organic handler certificate. The organic certificate verifies that the producer or handler 

has complied with organic regulations and allows her or him to sell or represent the product as organic. Producer certificates include the type of crop (e.g., carrots, apples) and may 

include other information as well. Sometimes crop varieties are listed (Fuji apples), as well 

as farm acreage and the name of the field from which the crop has been harvested.

This guide covers only the regulations for crop producers. Producers who are processing their products—into jams, bread, or juice, for example—need to ask their certifier 

if a handler certificate is required for those products. In some cases, certifiers will allow 

farmers to do some minor processing, such as freezing or drying, without applying for 

a separate certification. 

The process of getting certified has several steps and often requires 3 to 6 months 

to complete. In applying for certification, the farmer agrees to understand the regulations, 

be available for inspection, allow the certifier access to the farm, and answer all of the 

certifier’s questions. The certifier reads the application, assigns an inspector, reviews the 

inspection report, and makes the certification decision. 

Before beginning the certification process, it is important to consider whether your land is 

eligible for organic status, as explained below. 

Transitioning to organic production

A field is eligible for organic status if no prohibited materials have been applied for a period 

of 36 months. For example, if an apple orchard was last sprayed with a synthetic fungicide on August 1, 2010, then a crop harvested September 1, 2013, may be sold as organic, 

but only if you have a certificate verifying the organic status. You will need to be able to 

document all land use and material applications during the transitional time period. See 

Chapter 4 “Writing the Organic System Plan” for more information about documentation 

needed for new sites. 

Many of the fertilizers, insecticides, herbicides, and fungicides used by conventional farmers are prohibited in organic production. This includes the fungicides present on treated 

seeds. Chapter 9 “The National List of Allowed and Prohibited Substances” explains how 

to determine if a product is allowed or prohibited. Certain practices, while not allowed 

in organic production, would not constitute application of a prohibited material, and so 

Related ATTRA 

publications

www.attra.ncat.org

Organic Certification 

Process

Organic Field Crops 

Documentation Forms

Organic Market Farm 

Documentation Forms

Organic Standards for 

Crop Production
Page 8 www.ams.usda.gov/nop Guide for Organic Crop Producers

would not render land ineligible for certification during the transition period. Examples 

include the use of nonorganic seed or planting stock, application of manure to a food crop 

within 90 days of harvest, and cultivation of genetically modified crops.

The certification process

If you understand the regulations and your land is eligible for transitional or organic 

status, you’re ready to begin the certification process. The steps are as follows:

1. The farmer submits an application to a certifier

Producers obtain certification from state or private certifiers who are accredited by the 

NOP. Farmers may apply to any accredited certification agent (ACA). A list of all ACAs can 

be found on the NOP Web site listed at the end of this chapter. 

The cost of organic certification is borne by the certified operations and is paid directly to 

the certifying agent. Certification fees may vary significantly among certifiers. Most certifiers charge a one-time fee to new applicants to cover the administrative and review costs. 

Annual renewal fees, usually based on the sales of organic products, are assessed each year. 

The NOP currently operates a cost-share program to help defray the cost of certification for 

organic farmers. The program is explained below under Funding Opportunities. 

To allow time for the entire certification process, submit your application at least 3 to 4 

months before the harvest of your first organic crop. If you need a certificate more quickly, 

some certifiers will expedite your application for an additional fee.

The documents sent to a certifier are often collectively called the “application,” but in 

reality there are several separate documents required:

•	 Application 

•	 Organic System Plan 

•	 Farm map 

•	 Field histories for new fields

•	 Operator agreement or affirmation

•	 Report of organic yields and sales

The Organic System Plan (OSP) is your opportunity to describe your farm and farming 

operation to a person who has never seen it. Understanding what is needed and why it is 

needed makes the process easier. The next chapter will provide more detail about how to 

develop the OSP.

The person who signs the operator agreement agrees to adhere to the regulations and 

affirms that the information supplied to the certifier is correct. This agreement must be 

signed by the person who has responsibility for making decisions about the operation—

typically the farm owner.

New applicants will be asked to estimate their projected organic sales. Upon renewal of 

certification, farmers are required to report the yield and sales of organic products. Ordinarily, the sales are reported in the calendar year during which the money is collected. 

For example, the income from apples harvested in September, stored, and sold the following January will be reported as income in January. There are several reasons for collecting information on yield and sales. This information can serve as a basis for conducting 

an audit, which can then be used to discover fraud—for example, conventional produce 

sold as organic. Sales also are used to determine annual certification fees; typically, larger 

operations pay higher fees.
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 9

2. The certifier reviews the application

The certifier will read the farm plan and determine whether the practices are described in 

sufficient detail and whether the farm appears to meet organic regulations. There are cases 

where an application is denied or delayed. For example, if a farmer sprayed herbicides in 

March 2010 and applied for certification in April 2010, the application would be denied for 

2010. In this case, the land may be eligible for transitional status after March 2011 (if the 

certifier offers transitional certification) but would not be eligible for organic certification 

until April 2013.

To achieve organic status, a 3-year transition period is required. In other words, no prohibited substances may be applied to the land for 36 months prior to the harvest of any crop 

that will be represented as organic. The first organic crop may be planted at any time prior 

to or during the conversion period. One purpose for this transition period is to allow the 

farmer to build healthy soil by adding natural soil amendments, rather than fertilizers, and 

restore biodiversity by avoiding pesticides. 

If you are purchasing or renting land that is not currently certified and you wish to 

document that it has not had prohibited substances applied, you must obtain verification 

from the previous landowner or manager. Some certifiers require documentation by the 

local county Agricultural Commissioner, who keeps pesticide-use records in States that 

require 100 percent reporting of materials registered by the U.S. Environmental Protection Agency (EPA). 

3. The inspector visits the farm 

Every organic farm must be inspected each year. The individual who conducts the inspection—the organic inspector—represents the certifying agent. It is the inspector’s responsibility to verify that the system plan accurately reflects the operation and that the farmer is 

following the plan, as well as to look for any violations. Organic inspectors are trained to 

look critically at all aspects of an organic operation and to maintain strict confidentiality. 

Information you provide about yield, sales, or farm practices will not be shared with anyone except the certifier. 

During the inspection, you must allow the inspector complete access to your operation, 

including all production facilities and offices. Additional inspections may be announced or 

unannounced at the discretion of the certifier or the State organic program.

One of the most important responsibilities of the inspector is to examine records that document your farming practices. Specifically, the inspector will look at invoices, records of 

material applications, organic sales, harvest, and yield. Chapter 13 “Recordkeeping” provides examples of the type of documentation forms that inspectors may wish to examine. 

The inspector can explain the organic regulations but is not allowed to provide advice 

on how to farm or how to overcome identified barriers to certification. This separation 

between the farmer and the certifier maintains the “independent third party” nature of the 

transaction. Similarly, inspectors are not allowed to accept gifts because it may appear to 

compromise their independent status.

As a representative of the certifier, the inspector may request samples for residue testing. 

Results of the test will be provided to you. If the levels of pesticide residue exceed 5 percent 

of EPA tolerance levels, the product may not be sold, labeled, or represented as organic [§ 

205.671]. Residue testing is not an acceptable substitute for strategies to prevent contamination. It can, however, serve as an indicator that selected strategies are effective. 

During the inspection, the inspector will ask questions about your operation, visit each 

field, look at paperwork, and point out any areas where the farm may not comply with regulations. At the conclusion of the inspection, there will be an exit interview during which 
Page 10 www.ams.usda.gov/nop Guide for Organic Crop Producers

the inspector will review any areas of concern. After the inspection, the inspector will 

write a report and send it to the certification agency, typically within 2 weeks.

4. The certifier reviews the inspection report

The certifier reviews the inspection report and decides whether the farm meets the requirements of the organic regulations. The reviewer will pay particular attention to any issues 

mentioned in the exit interview and will decide the seriousness of those issues. If your 

farm is in compliance, you will receive a letter along with an organic certificate. More commonly, especially for a first inspection, there will be some issues that need to be addressed. 

In this case, certification would be delayed until these problems are corrected. The specific 

areas of concern should not be a surprise to the farmer because the inspector should have 

discussed them in the exit interview. One thing that is often a surprise is the formal language of the letter, which can be written as a Notice of Noncompliance. Often the specific 

issues are easily corrected, and you can receive organic certification once you resolve them. 

There are several types of letters that new applicants may receive from their certifiers:

•	 If the operation is in compliance with the regulations, the certifier issues an 

organic certificate. 

•	 If the operation needs to provide additional information or correct minor practices, the certifier issues a certificate with conditions.

•	 If there is something that threatens the organic integrity of the product, but it can 

be corrected, the certifier issues a Notice of Noncompliance. 

•	 If there are major noncompliance issues that cannot be corrected, the certifier 

issues a Notice of Denial of Certification to new applicants. For example, if a crop 

duster accidentally applies a synthetic fungicide to your organic field, that would 

be considered an application of a prohibited material, and the application for 

organic certification would be denied. 

•	 If there are major noncompliance issues during renewal of certification, the 

certifier issues a Notice of Noncompliance, which may be followed by or sent at the 

same time as a Notice of Proposed Suspension or Notice of Proposed Revocation. 

The producer is provided an opportunity to appeal; otherwise, the organic certification will be suspended or revoked. This happens only rarely.

If you receive a letter and do not understand the technical language, call your certifier for 

clarification. You can also call ATTRA for advice on how to resolve an issue and bring your 

operation into compliance. 

5. The certifier issues the organic certificate

Once certification is granted, it remains in effect until surrendered, suspended, or revoked. 

Any action to suspend or revoke certification must be handled in the manner prescribed 

in regulations § 205.660 through § 205.664. If the status of your certification is threatened 

and you wish to dispute the charge, a formal grievance process exists.

Every organic operation is required to renew its certification each year or surrender it. 

Certification may be suspended if it is not renewed. 

The renewal process is comprised of the following steps: 

•	 Update the Organic System Plan

•	 Sign an operator agreement

•	 Address all noncompliance issues that have not been resolved 

•	 Pay the annual certification fees 

•	 Undergo an annual inspection

I

f you receive a 

letter (from your 

certifier) and do not 

understand the technical 

language, call your 

certifier for clarification. 

You can also call ATTRA 

for advice on how to 

resolve an issue and 

bring your operation 

into compliance.
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 11

Funding opportunities

As of this writing, there are two Federal programs that reimburse farmers for some of the 

costs of organic production. The NOP administers a certification assistance cost-share program available to certified organic operators. The program reimburses farmers and handlers for a percentage of their certification fees. More information is available at the NOP 

Web site listed below. The application process is simple. More information can be obtained 

from your certifier, your State department of agriculture, the NOP, or ATTRA. 

In addition to the NOP, the USDA Natural Resources Conservation Service (NRCS) provides funding to farmers as they implement practices that conserve natural resources. This 

program, the Environmental Quality Incentives Program (EQIP), has a special section for 

organic farmers because many organic practices focus on soil conservation. This program 

offers an opportunity for organic producers to receive substantial grant funding, but the 

application process can be lengthy. More information is available at your local NRCS office. 

The meaning of organic certification

It is important to recognize that organic certification addresses the process involved 

in producing and handling a product. Organic certification is a process claim, not a 

product claim, and the OSP is the principal document that describes the production 

process on a specific farm. Organic certification assures the consumer that the organic 

farmer followed the requirements and restrictions spelled out in the regulations. Organic 

certification does not guarantee that the product is completely free of all pesticide 

residues or genetically modified organism (GMO) contamination. 

Questions

•	 Do you have easy access to the USDA organic regulations?

•	 If you are now selling crops as organic, do they all come from land that has been free of 

prohibited substances for a minimum of 36 months prior to harvest?

•	 Did you advise your certifier of any previous applications for certification?

•	 If you are renewing your certification, have you addressed all noncompliance issues and 

conditions previously noted by the certifier?

•	 Are you documenting the harvest, yield, and sale of all organic crops?

•	 Are you saving purchase receipts for all inputs?

•	 Are you documenting the applications of fertilizers and pest-control materials?

Online Resources

National Organic Program, www.ams.usda.gov/nop

New Farm Guide to U.S. Organic Certifiers, www.rodaleinstitute.org/

certifier_directory
Page 12 www.ams.usda.gov/nop Guide for Organic Crop Producers

Notes
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 13

CHAPTER 4

WRITING THE ORGANIC SYSTEM PLAN (OSP)

Developing and then maintaining the OSP is an essential part of the initial and ongoing certification process. The OSP must be written by the producer and approved by the certifier. Taking care to write clearly and thoroughly can save time later. The 

OSP provides a description of your farm to a person who has never seen it. It must be sufficiently detailed so that the certifier can get a clear picture of your farm’s crops, harvest, 

sales, recordkeeping, soil-building practices, pest management, and any other practices 

related to organic production. The plan must allow the certifier to assess whether you can 

meet the requirements for organic certification. 

The OSP covers many aspects of your organic farm:

•	 Crops to be grown

•	 Farm acreage — organic

•	 Source of seeds or plants

•	 Maintaining soil fertility

•	 Preventing pest outbreaks

•	 Controlling weeds

•	 Managing diseases

•	 Sales and marketing 

Producers should use the OSP to explain the practices they use to manage their farms. It 

is particularly important to describe all management practices used to prevent problems 

rather than merely reacting to them. For example, apple growers should have plans to monitor codling moth, and asparagus growers should have plans to manage asparagus aphids. 

Having these monitoring and management practices in place will enable an organic farmer 

to address pest pressure before an infestation becomes severe. The time spent to ensure 

accuracy and completeness on your OSP is worthwhile because the OSP is vital for managing your farm and assuring compliance with the regulations.

§ 205.201 Organic production and handling system plan 

Under the USDA organic regulations, each certified organic farm must have an 

Organic System Plan (OSP). The OSP is a detailed outline that explains how you 

intend to operate your farm or ranch to satisfy the requirements of the regulations. 

 According to § 205.201(a), the OSP must contain the following:

•	 A description of farm practices, including the frequency with which they will be 

performed

•	 A list of each substance to be used as a production input

•	 A description of monitoring practices, including the frequency with which they will 

be performed, to verify that the plan is effectively implemented

•	 A description of the recordkeeping system implemented to comply with the 

requirements established in § 205.103 (see Chapter 13)

•	 A description of the management practices and physical barriers established to 

prevent commingling of organic and conventional products and to prevent 

contamination of organic products with prohibited substances

•	 Any additional information deemed necessary by the certifying agent to evaluate 

compliance with the regulations

Related ATTRA 

publications

www.attra.ncat.org

Organic System Plan 

Templates for Certifiers 

Organic System Plans: 

Market Farms and 

Greenhouses

Organic System Plans: 

Field and Row Crops and 

Pasture and Range Systems
Page 14 www.ams.usda.gov/nop Guide for Organic Crop Producers

It is standard practice for the OSP to be incorporated in the application materials that are 

required by certifiers. In other words, you are completing your OSP at the same time that 

you are filling out your application for certification. There may be some instances in which 

plans submitted to qualify for Federal aid or assistance programs may satisfy the requirement for an OSP.

The materials list 

The OSP includes a list of each substance to be used as a production input, sometimes 

called a Materials List. This is simply a list of composts, fertilizers, insecticides, fungicides, 

or other materials that might be used. Certifiers realize that farmers are not able to predict 

every eventuality and that unforeseen problems will occur. If there is a need to apply a pest 

control or other material that was not originally listed in the system plan, contact your certifier to add it to your OSP. Many certifiers will accept notifications by telephone, fax, or 

email. Do not wait until inspection to update your OSP.

There have been unfortunate instances of farmers who applied a material without receiving approval from their certifier, only to discover later that the material was prohibited. If 

this happens, the certifier must revoke certification from the fields to which the prohibited 

material was applied. The land is not eligible for organic status again for 36 months from 

the last application of the prohibited material.

Split operations

Many conventional farmers choose to explore organic production by converting only a 

small portion of their land to organic practices, while continuing to farm the rest of land 

in a conventional manner. Production of both organic and nonorganic products is called 

split production. Crops grown during the 36-month transition period are considered conventional. Parallel production, a subset of split production, refers to a situation where the 

same crop is produced both organically and conventionally on the same farm operation. 

In parallel operations, it is particularly important that the OSP address all hazards 

of contamination and commingling that may arise. Contamination can be defined as 

contact with a prohibited substance (for example, conventional pesticides). This includes 

physical contact with conventionally grown products. Commingling is the mixing 

of an organic product with a similar conventional product (for example, mixing organic and conventional grain in the same grain bin). For split operations, many 

certifiers request information on both conventional and organic crops. The certifier and 

the inspector will want to ensure that procedures are well documented to ensure the 

integrity of organic products. Chapter 11 “Preventing Contamination of Organic Crops” 

provides additional information.

§ 205.202 Land requirements 

Fields from which organic crops are harvested must have distinct, defined 

boundaries and buffer zones. No prohibited materials can be applied to the land 

for a period of 36 months prior to harvest of the organic crop. Prohibited materials 

include synthetic fertilizers and seeds treated with fungicides, as well as most synthetic 

(chemical) herbicides, pesticides, and fungicides.

Some useful 

definitions

•	 Buffer zones—the 

boundary between 

conventional crops 

and organic crops. 

Buffer zones are 

established to prevent 

organic crops from 

being contaminated 

by spray drift. 

•	 Commingling—the 

mixing of an organic 

product with a similar 

conventional product.

•	 Contamination—

contact with a prohibited substance (conventional pesticides, 

for example). This 

includes physical contact with conventionally grown products.

•	 Parallel production—

a subset of split 

production. The term 

is used to describe 

a situation in which 

the same crop (and 

often the same crop 

variety) is produced 

both organically and 

conventionally on the 

same farm operation.

•	 Split production or 

mixed operations—

those operations that 

produce both organic 

and nonorganic products. (The nonorganic 

category includes 

transitional products.)
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 15

The farm map

An accurate map of all farm acreage and production units is typically required as part of 

the OSP. Important map features include the following:

•	 Consistent scale

•	 Permanent field numbers or names

•	 Buildings, roads, and permanent features

•	 Streams, ponds, irrigation ditches

•	 Field boundaries

•	 Adjoining land use: conventional, organic, or fallow

•	 Buffer zones

Organic crops must be protected from contamination by prohibited substances, such 

as pesticides and fertilizers, used on adjoining lands. Preventing contamination usually 

requires a multi-pronged approach for organic systems. 

Strategies may include one or more of the following:

•	 Isolation. Fields located at substantial distances from conventional production or 

roadside spraying are considered to be adequately protected.

•	 Barriers. Tall plants and trees serve as barriers to airborne contaminants.

•	 Buffer zones. Buffers are used to separate adjoining crops that are conventionally 

managed. Crops harvested from buffer zones must be sold as conventional. 
Page 16 www.ams.usda.gov/nop Guide for Organic Crop Producers

•	 Drainage diversion. Water runoff from conventional fields is diverted.

•	 Posting of property. Signage reading “Organic Farm: Do Not Spray” is placed at 

field boundaries. You may need to assume responsibility for weed control on roadsides and post signs reading “Owner Will Maintain.” 

•	 Formal notification. Written notification of your organic status is provided to 

neighbors who manage adjoining lands. Copies of formal notification letters must 

be kept on file.

Regulations do not specify the required width for a buffer zone, but they state that buffers 

must be “sufficient to prevent contamination.” It is the farmer’s responsibility to assess the 

risks and take appropriate measures to minimize contamination. Therefore, the width of 

buffers must be adjusted for individual circumstances. For example, a more significant buffer is needed where adjacent land is sprayed by plane or airblast sprayer or where there are 

prevailing winds that blow across nonorganic fields onto the organic farm. A smaller buffer may be needed if a row of tall trees provides a barrier to drift. Regardless of the size of 

the buffer, any crops harvested from buffer zones must be sold as conventional. Sale must 

be documented and available for review at inspection.

Water runoff from conventional fields can contaminate organic crops. If the possibility of 

contamination exists, a drainage ditch will be needed. 

Field histories for new fields and new farms

Field histories will be required the first time you request to have a field certified organic. To 

obtain organic certification for a field, you must be able to document all materials applied 

to that field for 36 months prior to the harvest of a first organic crop. 

Field histories for new fields should document the following:

•	 Field size (You may use square footage for greenhouse/production beds.)

•	 Crops, including cover crops, for the past 36 months

•	 All inputs used for the past 36 months 

Online Resources

Rodale Institute’s Organic System Plan Tool, www.tritrainingcenter.org/

code/osp_index.php
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 17

Questions

•	 Have you completed your Organic System Plan (OSP)?

•	 Is your farm map complete and accurate?

•	 Have you completed a field history for each new field?

•	 Are the numbers/names used on your map consistent with those used on field 

histories, audit documents, and other records?

•	 Do all fields have buffers that are adequate to prevent contamination?

•	 If there is danger of contamination from adjoining land or conventional crops, 

are you taking steps to minimize the risk?

Notes 
Page 18 www.ams.usda.gov/nop Guide for Organic Crop Producers

CHAPTER 5

SOIL FERTILITY

Healthy soil is the basis for organic agriculture. Healthy soil can provide an abundant crop of healthy plants, which in turn provide healthy food and feed. When grown in good soils, crops are better able to resist disease, survive drought, and 

tolerate insects. 

This chapter provides a brief overview of building and conserving the soil. For more 

detailed information, consult additional references tailored to your climatic region and 

soil type. The materials listed in the Further Resources section are a good place to start. 

Soil building 

Adding organic matter is a fundamental way to build soils. Organic matter provides food 

for microorganisms such as fungi and bacteria and macroorganisms such as earthworms. 

As these diverse soil organisms decompose organic matter, they convert nutrients into 

forms that are available to plants. Soils high in organic matter also have improved waterholding capacity, helping plants resist drought. 

For centuries before the advent of chemical fertilizers, farmers supplied all the nutrients 

for their crops solely by adding organic matter to the soil. As fresh organic matter, such as 

crop residues, decomposes, it forms a stable substance called humus. Organic matter can 

be added to soils with compost, animal manures, or green manures. 

Green manures

Green manures are crops grown specifically for soil improvement. They are typically incorporated into the soil after they have produced a large amount of biomass, or fixed a significant amount of nitrogen in the case of legumes. Managing green manure crops to increase 

organic matter and provide the maximum amount of nitrogen to the following crop is both 

an art and a science.

Annual grasses, small grains, legumes, and other useful plants like buckwheat can be 

inserted into the cropping sequence to serve as green manures. Their roots pull nutrients 

from deeper soil layers, and the tops are plowed into the soil to add organic matter and a 

stable source of nutrients. In particular, deep tap-rooted crops such as alfalfa, sweet clover, 

rape, and mustard are known to extract and use minerals from the deeper layers of soil. 

Legumes add nitrogen to the soil. Nitrogen accumulations by leguminous cover crops can 

range from 40 to 200 pounds of nitrogen per acre. The amount of nitrogen captured by 

legumes depends on the species of legume grown, the total biomass produced, and the percentage of nitrogen in the plant tissue. Cultural and environmental conditions that limit 

legume growth—such as a delayed planting date, poor stand establishment, and drought—

will reduce the amount of nitrogen produced. Conditions that favor high nitrogen 

Related ATTRA 

publications

www.attra.ncat.org

Federal Conservation 

Resources for Sustainable 

Farming and Ranching

Sustainable Soil 

Management

§ 205.203 Soil fertility and crop nutrient management 

practice standard 

Section (a) of this regulation states that the producer must “maintain or improve 

the physical, chemical, and biological condition of the soil and minimize erosion.” 

Section (c)(1) regulates the application of raw manure to organic crops, and Section (c)

(2) regulates the process of making of composts from animal manures.
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 19

production include a good stand, optimum soil nutrient levels and soil pH, good nodulation, and 

adequate soil moisture. 

Animal manures

Conservation of manure and its proper application are key means of recycling nutrients 

and building soil. Farms without livestock often buy manure or compost because they are 

considered to be among the best fertilizers available, though sole reliance on fertilizers 

from other farms can have its drawbacks.

Manures from conventional systems are allowed in organic production, including manure 

from livestock grown in confinement and from those that have been fed genetically engineered feeds. Manure sources containing excessive levels of pesticides, heavy metals, or 

other contaminants may be prohibited from use. Such contamination is likely present in 

manure obtained from industrial-scale feedlots and other confinement facilities. Certifiers 

may require testing for these contaminants if there is reason to suspect a problem.

Herbicide residues have been found in manures and manure-based composts. One type—

aminopyralid—is used in pastures for control of broadleaf weeds. Grass and corn are not 

affected by the herbicide, and cows are not affected when they eat the grass or silage. However, the herbicide can be present in their manure in concentrations high enough to stunt 

the growth of tomatoes, peppers, and other susceptible broadleaf crops. 

If a manure source is suspected of being contaminated with excessive amounts of prohibited substances, appropriate testing should be conducted. If test results indicate that the 

manure is free of excessive contamination, and it is subsequently used in production, the 

test results should be kept on file.

Used properly, manures can replace all or most needs for purchased fertilizer, especially 

when combined with a whole-system fertility plan that includes crop rotation and cover 

cropping with nitrogen-fixing legumes. Manure is typically applied just ahead of a crop 

requiring high fertility, such as corn or squash. Manures also can be applied just prior to a 

cover crop planting. Incorporating the manure as soon as possible after application, rather 

than allowing it to remain on the soil surface, will conserve the maximum amount of the 

nitrogen. Although manure is an excellent fertilizer for crops, and it has been used that 

way for centuries, manure may harbor microorganisms that are pathogenic to humans. To 

minimize the possibility of illness due to organic foods, there are strict regulations on the 

use of manure in organic crops.

The 90–120-day rule

Application of manure to organic crops is restricted by what is known as the 90–120-day 

rule, as described in § 205.203(c)(1). You may not apply raw, uncomposted livestock manure 

to food crops unless it is:

1. Incorporated into the soil a minimum of 120 days prior to harvest when the edible 

portion of the crop has soil contact; OR

2. Incorporated into the soil a minimum of 90 days prior to harvest of all other food crops.

Incorporation is generally assumed to mean mechanical tillage to mix the manure into 

the soil. Crops that have soil contact include leafy greens, melons, squash, peas, and many 

other vegetables. Any harvestable portion of a crop that can be splashed with soil during 

precipitation or irrigation might be considered to have soil contact. Crops that do not have 

soil contact include tree fruits and sweet corn. 

Take note that the 90- and 120-day restrictions apply only to food crops; they do not apply 

to fiber crops, cover crops, or to crops used as livestock feed.

When grown 

in good soils, 

crops are 

better able to resist 

disease, survive drought, 

and tolerate insects.
Page 20 www.ams.usda.gov/nop Guide for Organic Crop Producers

Compost

Perhaps no other process is more closely associated with organic agriculture than composting. Composting is one of the most reliable and time-honored means of conserving 

nutrients to build soil fertility. Because matured, well-made compost is a stable fertilizer 

that will not burn plants and because composting kills most human and plant pathogens, 

compost can safely be used as a side-dress fertilizer on food crops. 

Animal manures used in organic crop production often are composted before use, in part 

because some types of raw manure will burn plants if applied directly to crops. Composting reduces the number of viable weed seeds, creates a uniform product with predictable 

nutrient levels, and eliminates worries about human pathogens. If manures are composted 

according to USDA organic regulations, then they are considered compost, not manure, 

and may be applied without restrictions. If manure is aged but not composted according to 

the regulations, then the material is still considered manure and must be applied in accordance with the 90–120-day rule explained above.

The regulations define compost as “the product of a managed process through which 

microorganisms break down plant and animal materials into more available forms suitable 

for application to the soil...” Compost used in organic production must be made according to the criteria set out in § 205.203(c)(2). This section of the regulations specifies that:

1. The initial carbon:nitrogen ratio of the blended feedstocks must be between 25:1 

and 40:1.

2. The temperature must remain between 131 °F and 170 °F for 3 days when an 

in-vessel or a static-aerated-pile system is used.

3. The temperature must remain between 131 and 170°F for 15 days when a windrow 

composting system is used, during which period the windrow must be turned at least 

five times.

The composting procedures above are adapted from U.S. Environmental Protection 

Agency (EPA) and USDA’s Natural Resources Conservation Service (NRCS) guidelines for 

composting biosolids. This policy was established to ensure the elimination of pathogens 

that cause illness in humans. 

Organic farmers often maintain a compost pile on the farm as an efficient and cost-effective 

way to retain nutrients on the farm and build soil. If compost feedstocks include raw manure, 

they must be composted in the method detailed above. This composting process must be 

explained in your system plan and documented with temperature records. If those requirements are not met, then the resulting compost must be applied according to the 90-120-day 

raw manure rule. If compost feedstocks do not include raw animal manures, then the resulting compost is considered plant material and there are no restrictions on its use.

Compost tea

Some organic farmers apply compost teas to crops or soil to increase the populations 

of beneficial microbes. If compost tea will be applied to organic crops, it is critical that 

the compost used to produce the extract has been made according to USDA organic regulations. The procedures for making both the compost and the compost tea must be explained 

in your OSP. Applications of teas made from uncomposted manure must follow the 90-120-

day rule. The tea extract may need to be tested to ensure that it is free of dangerous pathogens, particularly if the tea has been made with compost tea additives. The additives, such 

as molasses, provide nutrients for microbes and thereby increase their rate of growth. There 

is some concern that any human pathogens present will grow more abundantly in a tea 

made with these additives. Further details on the recommendations for the use of compost 

tea are available in the NOP publications listed at the end of this chapter. 

Composting is one 

of the most 

reliable and 

time-honored means of 

conserving nutrients to 

build soil fertility.
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 21

Vermicompost

Vermicompost is compost that uses worms to digest the feedstocks. Since feedstocks may 

include animal manures, there has been debate as to whether the 90-120-day rule should 

apply to vermicompost. The NOP has issued the following guidance: feedstocks for vermicompost materials may include organic matter of plant or animal origin. Feedstocks should 

be thoroughly macerated and mixed before processing. 

Vermicomposting systems depend upon regular additions of thin layers of organic 

matter at 1- to 3-day intervals. Doing so will maintain an aerobic environment and avoid 

temperature increases above 35 °C (95 °F), which will kill the earthworms. The composting process must be described in the OSP, reviewed by the certifier, and well documented 

on the farm. Further details are available in the NOP publications listed at the end of 

this chapter. 

Processed animal manures

Heat-treated, processed manure products may be used in organic production. There is no 

required interval between application of processed manure and crop harvest. From the 

standpoint of the farmer, of course, these inputs would be applied well before harvest, so 

that the nutrients would be available to the crop. To be considered processed, the manure 

must be heated to 150 °F for 1 hour and dried to 12 percent moisture or less. 

Soil conservation

Organic farmers have long recognized the value of basic soil conservation. There are many 

practices that help conserve soil, including cover crops, mulches, conservation tillage, 

contour plowing, and strip cropping.

Careful conservation and management of crop residues is part of organic soil management, since this residue plays a valuable role in improving and protecting the soil. The 

key to soil conservation is to keep the ground covered for as much of the year as possible. 

Since water erosion is initiated by raindrop impact on bare soil, any management practice that protects the soil from raindrop impact will decrease erosion and increase water 

entry into the soil. Mulches, cover crops, and crop residues all serve this purpose well. A 

major limitation of organic row-crop farming is that cultivation is used for weed control, 

since herbicides are not allowed. This cultivation creates and maintains bare ground, 

which increases the likelihood of soil erosion. By contrast, soil that is covered with an 

organic mulch of crop residue, such as that typically found in no-till fields, is less likely 

to erode. Organic no-till systems have yet to be perfected for annual row crops, but they 

work well for perennial fruit crops and pasture, allowing for year-round ground cover 

and virtually no soil erosion. 

Cover crops

Cover crops are single species or mixtures of plants grown to provide a vegetative cover 

between perennial trees, vines, or bushes; between annual crop rows; or on fields between 

cropping seasons. The vegetative cover on the land prevents soil erosion by wind and water, 

builds soil fertility, suppresses weeds, and provides habitat for beneficial organisms. Cover 

crops also can help reduce insect pests and diseases, and legume cover crops fix nitrogen. 

Any crop grown to provide soil cover is considered a cover crop, regardless of whether that 

crop is later incorporated into the soil as a green manure. Both green manures and other 

types of cover crops can consist of annual, biennial, or perennial herbaceous plants grown in 

a pure or mixed stand during all or part of the year. When cover crops are planted to reduce 

nutrient leaching following a cash crop, they are termed “catch crops.” This type of cover crop 

is typically grown over the winter when the field would otherwise be unoccupied. 

The key to soil 

conservation is to 

keep the ground 

covered for as much of the 

year as possible.
Page 22 www.ams.usda.gov/nop Guide for Organic Crop Producers

Organic mulches

Organic mulches cover the soil and provide many of the same benefits as cover crops, 

especially the prevention of soil erosion. Many organic materials, such as straw, leaves, 

pine needles, and wood chips, can be effective mulches. Straw and other materials that are 

easily decomposed are applied to strawberries and vegetables during the growing season. 

The mulch can be tilled in at the end of the season, where it will quickly decompose. Wood 

chips, because they decompose very slowly, are more commonly applied to perennial crops 

such as blueberries, where they will not be tilled in. Applying organic mulch can be laborintensive. Tree fruit growers sometimes mow the drive rows and blow the green clippings 

into the tree rows, which automates the mulching process.

Heavy mulches can be a benefit by suppressing weed growth, or a nuisance by providing 

a haven for slugs. Organic mulches keep the soil cool, which may be a boon for blueberries in hot climates and a drawback for tomatoes in cool spring weather. Organic mulches 

have a beneficial long-term effect because they add nutrients to the soil as they decompose. 

Mulches of high-carbon material may have the opposite effect because they tie up nitrogen 

during the decomposition process. However, this should not be a problem if mulches are 

used properly—that is, placed on top of the soil, and not incorporated. 

Conservation tillage

In conservation tillage, crops are grown with minimal soil cultivation. This is also known 

as no-till, minimum till, incomplete tillage, or reduced tillage. When the amount of tillage 

is reduced, the residues from the plant canopy are not completely incorporated into the soil 

after harvest. Crop residues remain on top of the soil and prevent soil erosion, a practice 

known as crop residue cover. The new crop is planted into this stubble or small strips of 

tilled soil within the stubble.

Contour cultivation and strip cropping

Slope plays a role in soil conservation, in that flat ground erodes less than sloping ground 

with equal amounts of ground cover. Contour plowing is the practice of plowing across 

a slope following its elevation contour lines, rather than straight up and down the slope. 

The cross-slope rows formed by contour plowing slow water runoff during rainstorms to 

prevent soil erosion. 

Strip farming, also known as strip cropping, alternates strips of closely sown crops, such 

as hay or small grains, with strips of row crops, such as corn, soybeans, or cotton. Strip 

farming helps prevent soil erosion by creating natural dams for water, helping to preserve 

the soil. 

Federal programs for sustainable agriculture

Sustainable and organic agricultural systems produce some of the best conservation results 

in the Nation, as they enhance the natural resource base and provide multiple environmental services. These systems can conserve biodiversity and improve soil quality, water quality, air quality, carbon sequestration, energy efficiency, and wildlife habitat. The adoption 

of sustainable and organic systems of production is directly in line with NRCS’s mission of 

“helping people help the land.” 

In recognition of the benefits of sustainable farming systems, the 2008 Farm Bill 

authorized funding to encourage implementation of conservation practices. The bill led 

to implementation of specific provisions for organic and sustainable farmers: 

•	 The Environmental Quality Incentive Program (EQIP) Organic Initiative
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 23

•	 The Conservation Stewardship Program (CSP) 

•	 The Conservation Reserve Program Transition Option

To apply for these programs, contact your local NRCS office or visit its Web site.

Applications for these programs can be challenging, as these are competitive programs. 

Several organizations are working to help farmers, especially small and mixed-crop 

farmers, successfully compete for funds. Helpful publications are available from ATTRA 

or the National Sustainable Agriculture Coalition (NSAC). Web sites are listed at the end 

of this chapter.

Nutrient management: nitrogen and trace minerals

Although organic matter plays an important role in building productive soils, there 

are specific crops and soil types that will benefit from additional applications of 

specific nutrients. Organic farmers are allowed to use a variety of fertilizers to provide 

micronutrients to their crops. Before applying micronutrients, soil deficiencies must be 

documented through soil tests, plant tissue tests, observing the condition of plants, or 

evaluating crop quality at harvest. 

Nitrogen is often a limiting nutrient, especially for vegetables and other row crops. Including legumes in the rotation can help to ensure sufficient nitrogen for the following crop. Biological nitrogen fixation in legumes results from a symbiotic relationship between the plant 

and Rhizobium bacteria. These bacteria “infect” the roots of legumes, forming nodules. The 

bacteria then fix nitrogen from the air, which results in sufficient nitrogen both for their own 

needs and for subsequent crops.

The inoculation of legume seed may be necessary to optimize nitrogen fixation. Be certain 

that you are purchasing an inoculant appropriate to the kind of legume you are planting 

and verify that it is not genetically modified. Genetically modified inoculants are prohibited in organic production. 

Online Resources

Alternative Farming Systems Information Center, http://afsic.nal.usda.gov

Building Soils for Better Crops, www.sare.org/publications/soils.htm

Compost and Vermicompost in Organic Crop Production, NOP Program 

Handbook, www.ams.usda.gov/nopprogramhandbook

Farmers’ Guide to the Conservation Stewardship Program, 

www.sustainableagriculture.net/wp-content/uploads/2011/09/

NSAC-Farmers-Guide-to-CSP-2011.pdf

National Sustainable Agriculture Coalition publications list, 

www.sustainableagriculture.net/publications

Natural Resources Conservation Service, www.nrcs.usda.gov

NOP Program Handbook, www.ams.usda.gov/nopprogramhandbook

Processed Animal Manures in Organic Crop Production, NOP Program Handbook, 

www.ams.usda.gov/nopprogramhandbook

Sustainable Agriculture Research and Education, www.sare.org

The Rodale Institute, www.rodaleinstitute.org
Page 24 www.ams.usda.gov/nop Guide for Organic Crop Producers

Questions 

•	 Do you keep your current and past soil test results on file as a means of monitoring 

the effects of your farming practices?

•	 Do you make fertility management decisions based on soil tests, tissue tests, 

or observed nutrient deficiencies? 

•	 Are you using cultural practices to maintain or improve soil organic matter? 

 a) Green manures 

 b) Animal manures 

 c) Composts 

•	 Are you using cultural practices to conserve soil? 

 a) Cover crops

 b) Organic mulches

 c) Conservation tillage

 d) Contour cultivation

 e) Strip cropping

•	 Are all the fertilizers and soil amendments you use allowed in organic production? See Chapter 9 “The National List of Allowed and Prohibited Substances” for 

assistance with choosing materials.

•	 Do you keep records of all fertilizer and amendment purchases and applications, 

along with product labels?

•	 If your compost contains animal manure, has it been prepared according to the 

requirements of § 205.203(c)(2)? 

•	 Are soil amendments, including compost and manure, applied according to soil 

and crop needs? 

•	 Are all your manure applications to food crops in compliance with the 90- and 

120-day rules?

•	 Are your sources of manure and compost free of contamination from excessive 

amounts of prohibited substances? 

•	 Are records kept of manure applications that include date, tonnage, and fields 

receiving application?

Notes 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 25

CHAPTER 6

SEEDS AND PLANTING STOCK

The USDA organic regulations address three basic categories of propagation materials: seeds, annual seedlings, and planting stock. The term “seeds” is self-explanatory. “Annual seedlings” are transplants of annual crops that have been removed from 

their original place of production and replanted elsewhere [§ 205.2]. “Planting stock” is 

defined as “[a]ny plant or plant tissue other than annual seedlings but including rhizomes, 

shoots, leaf or stem cuttings, roots, or tubers, used in plant production or propagation” [§ 

205.2]. Ideally, only organic seed and planting stock would be used in organic production. 

When you purchase organic seeds, transplants, and planting stock, you are assured that 

the variety is not genetically engineered and that any seed treatments that may have been 

used are allowed for organic production. However, because the organic industry represents 

only a fraction of the total agriculture industry, organic seeds and planting stock may not 

be available. The applicable regulations are discussed below. 

Seeds

Organic seeds must be used unless they are not commercially available. When an equivalent organic variety is not commercially available, conventionally grown seed may be used. 

The determination of “equivalent” is made by the farmer, who takes into account the plant 

variety, maturity dates, disease resistance, and other desired characteristics. In order to use 

conventional seed, the farmer must provide documentation to verify that: (1) the organic 

seed was not available; (2) the variety is not genetically engineered; and (3) the seed was not 

treated with prohibited materials. Each of these is discussed in more detail below.

Commercial availability

First, in order to document that organic seed was not commercially available, certifiers want clear indication that several (at least three) suppliers have been contacted in an 

attempt to locate organic seed sources. This usually entails records of phone calls, letters, or 

emails to and from seed suppliers documenting your attempts to find an organic source. If 

you are required to use a specific variety by the buyer of the crop, then the buyer must supply documentation to verify that the variety was not available in organic form. 

A variety of seed is considered commercially unavailable if the farmer could not locate an 

organic supplier, if the organic supplier could not provide seed in the quantities needed, or 

if the seed quality was substandard. Seed quality may be substandard due to the presence of 

seed-borne disease, very low germination percentages, or high weed-seed content. The higher 

cost of organic seed is not considered an acceptable reason for using nonorganic seed.

§ 205.204 Seeds and planting stock practice standard 

 1. Organic seeds must be used unless they are not commercially available.

 2. Seeds may not be treated with prohibited substances.

 3. Genetically engineered varieties are prohibited.

§ 205.204(a)(4) states: “[N]onorganically produced planting stock to be used to produce a 

perennial crop may be sold, labeled, or represented as organically produced only after the 

planting stock has been maintained under a system of organic management for a period of 

no less than one year...”

Related ATTRA 

publications

www.attra.ncat.org

Transgenic Crops
Page 26 www.ams.usda.gov/nop Guide for Organic Crop Producers

Genetic engineering

Second, if conventional seed is planted, the certifier will request proof that it is not genetically engineered. This verification is becoming more important each year, as the number 

of genetically modified (GM) crops increases. The use of GM seeds is prohibited in organic 

agriculture, and it is the responsibility of organic growers to make certain that the crops 

they grow are not genetically engineered. GM crops that are now being planted or will soon 

be available include alfalfa, beets, corn, soybeans, papaya, plum, rapeseed, tobacco, potato, 

tomato, squash, cotton, and rice. This list is expected to change, as genetically engineered 

versions of several other crops have been developed but have not yet been released for commercial production. The most current information about GM crops is maintained by the 

USDA Animal and Plant Health Inspection Service (APHIS). The planting of GM crops is 

regulated—new varieties may not be widely planted until they’ve been approved by USDA. 

Seed companies that develop a new variety of genetically modified seeds must submit a 

petition to APHIS before that seed can be distributed to the public. These varieties are 

identified by APHIS on the list of Petitions for Nonregulated Status (see Online Resources 

at the end of this chapter).

Genetic engineering is considered an excluded method and is defined as “a variety of methods used to genetically modify organisms or influence their growth and development by 

means that are not possible under natural conditions or processes and are not considered 

compatible with organic production. Such methods include cell fusion, microencapsulation 

and macroencapsulation, and recombinant DNA technology (including gene deletion, gene 

doubling, introducing a foreign gene, and changing the positions of genes when achieved 

by recombinant DNA technology). Such methods do not include the use of traditional 

breeding, conjugation, fermentation, hybridization, in vitro fertilization, or tissue culture.”

Again, if it is necessary to use conventional seeds, it is essential to verify that the variety 

has not been genetically engineered and to keep documentation of this verification, as your 

inspector will ask to see it. Seed companies that have taken the Safe Seed Pledge may be 

convenient sources of non-GMO seeds. The Safe Seed Pledge was developed by the Council 

for Responsible Genetics and has been signed by numerous seed companies.

Treatment with prohibited materials

Third, seed must not be treated with prohibited materials, such as conventional fungicides

and inoculants made with GMO bacteria. Conventional seed treatments are usually 

fungicidal; most fungicides used for this purpose are prohibited in organic production. If 

fungicides are present on seeds it will be obvious, as the seeds must be tinted (commonly 

bright pink or green). The seed packets also will state that fungicides have been used.

Genetically 

modified crops 

that are now 

being planted or will 

soon be available include 

alfalfa, beets, corn, 

soybeans, papaya, plum, 

rapeseed, tobacco, 

potato, tomato, squash, 

cotton, and rice.

The Safe Seed Pledge

“Agriculture and seeds provide the basis upon which our lives depend. We must protect this 

foundation as a safe and genetically stable source for future generations. For the benefit of 

all farmers, gardeners and consumers who want an alternative, 

We pledge that we do not knowingly buy or sell genetically engineered seeds or plants.

The mechanical transfer of genetic material outside of natural reproductive methods and 

between genera, families, or kingdoms, poses great biological risks as well as economic, 

political, and cultural threats. We feel that genetically engineered varieties have been insufficiently tested prior to public release. More research and testing is necessary to further assess 

the potential risks of genetically engineered seeds. Further, we wish to support agricultural 

progress that leads to healthier soils, genetically diverse agricultural ecosystems and ultimately healthy people and communities.”
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 27

Some seed treatments are allowed in organic production—the inoculation of legume seeds 

with beneficial bacteria, for example. However, since some inoculants might be genetically 

engineered, it is important to ensure that the product is approved. Labels for seed inoculant 

do not typically state whether or not the product contains genetically engineered materials. If the label does not clearly state the information, you can obtain written documentation from the manufacturer. Several inoculants are listed by the Organic Materials Review 

Institute (OMRI). Visit the OMRI Web site and search for “inoculants” to obtain the names 

of allowed materials. 

Planting seeds treated with prohibited materials on land that is certified organic is considered an application of a prohibited material. The land where those seeds were planted will 

be removed from organic certification and will not be eligible for organic status again until 

36 months after the seeds were planted.

Even if the seeds are purchased for the farmer, such as crops grown under contract for processors, the farmer will need verification that the variety is not available in organic forms, 

that the variety is not genetically engineered, and that the seeds are not treated with prohibited materials. That documentation should be provided to the farmer by the processor 

who supplies the seeds, and it should be available at inspection. 

Many farmers ask whether the organic seed requirement also applies to cover crop seeds. 

Cover crop seed must be organic as well. Commonly, cover crops are chosen for being well 

adapted to the local growing area. If a nearby neighbor grows conventional cover crop 

seeds and you wish to plant them because they are locally adapted, you may claim that 

organic seeds of that variety are not commercially available. However, the cover crop seed 

must still be neither genetically engineered nor treated with a prohibited substance.

Annual seedlings

Transplants, starts, or seedlings used to produce an annual organic crop must have been 

organically grown. This section of the regulations applies to tomatoes, sweet potatoes, peppers, flowers grown from transplants (e.g., snapdragons sold as cut flowers) and similar 

crops. The farmer must have documentation that the transplants are organic. Documentation may be obtained by an organic certificate from the seller or an invoice on which the 

purchase is identified as organic. If large quantities of transplants will be needed, it will be 

necessary to order them well in advance. 

A variance to use conventional seedlings to grow an organic crop may be granted only if 

the original transplants were destroyed through “...drought, wind, flood, excessive moisture, hail, tornado, earthquake, fire or other business interruption...” Contact your certifying agent to obtain a variance.

Planting stock 

Whenever possible, organic planting stock should be used for organic production. At the 

time of this writing, many plant varieties are not commercially available in sufficient quantity, which may require the use of nonorganic planting stock. However, it is necessary to 

search for organic sources and to document that search.

Planting stock for annual crops is subject to the same requirements as seeds for annual 

crops. Note that this part of the rule applies to crops like garlic, white potatoes, and flowers 

grown from bulbs (e.g., daffodils or tulips sold as cut flowers).

Planting stock for perennial crops may be obtained from nonorganic sources but must be 

under organic management for at least 12 months before the first harvest of an organic 

crop. This rule applies to tree fruits (e.g., apples, peaches, pears), nuts (e.g., walnuts, pecans), 

berries (e.g., blueberries, caneberries, strawberries), grapes, asparagus, lavender (lavender 
Page 28 www.ams.usda.gov/nop Guide for Organic Crop Producers

flowers, lavender plants), lilies, and others. Some perennial crops are managed as annuals 

in some climate regions (e.g., strawberries, caneberries). If this is the case, then the rules 

for annual planting stock apply. 

Although the seeds, annual seedlings, and planting stock used in organic production must 

not be treated with prohibited substances, there is one exception. Treatment with prohibited substances is allowed when the application of those substances is a requirement of Federal or State phytosanitary regulations. For example, strawberry crowns may be required to 

be treated with fungicides prior to interstate shipments. 

Online Resources

ATTRA Online Directory of Organic Seed Suppliers, www.attra.ncat.org/

attra-pub/organic_seed

Organic Seed Alliance, www.seedalliance.org

 Petitions for Nonregulated Status Granted or Pending by APHIS, 

www.aphis.usda.gov/biotechnology/not_reg.html

Questions 

•	 Is all seed organically produced? 

•	 Have you retained invoices or empty seed packets to verify organic status of seeds?

•	 If conventional seeds were purchased, have you documented your attempts to 

source organic seeds?

•	 If conventional seeds were purchased, do you have verification that the varieties 

are not genetically modified?

•	 If conventional seeds were purchased, do you have verification that no prohibited 

substances were applied to the seeds?

•	 Are all annual seedlings and transplants acquired from organic sources?

•	 Have you obtained a copy of the organic certificate from the supplier of transplants?

•	 If annual seedlings and transplants are grown on-farm, are they produced using 

organic methods?

•	 If seed or plant treatments are used, have you determined that they are allowed materials? 

Notes 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 29

CHAPTER 7 

CROP ROTATION

Crop rotation refers to the sequencing of crops over time on a field or planting bed. 

It is not unique to organic systems; it is practiced by many conventional farmers 

as well. Organic systems are unique in that crop rotation is specifically required in 

the USDA organic regulations. 

Crop rotation in annual crops 

For producers of annual crops, complying with NOP crop rotation standards is straightforward and often beneficial for crop health. Crop rotation can:

•	 Interrupt insect life cycles

•	 Suppress soilborne plant diseases

•	 Prevent soil erosion

•	 Build organic matter

•	 Fix nitrogen

•	 Increase biodiversity of the farm 

Crop rotations are an important way to suppress insects and diseases. For example, farmers who raise potatoes will rotate the field out of solanaceous crops for at least 2 years 

before replanting potatoes. This helps reduce populations of insects such as the Colorado 

potato beetle and diseases such as late blight. Rotations typically mean that crops are not 

followed by a member of the same crop family. Rotations with 3 to 5 years between the 

same crop may be needed to effectively reduce insect and disease levels.

Rotations also can be designed to increase soil fertility. A crop sequence that features 

soil-improving crops can counterbalance soil-depleting crops. Soil-improving crops 

include sod crops dominated by perennial grasses and perennial legumes. Sod crops in 

rotation build soil organic matter and reverse the decline that typically occurs when cultivated annual crops are grown year after year. Legumes, such as alfalfa, clovers, beans, and 

peas, are especially beneficial because they fix nitrogen from the atmosphere and make it 

available to subsequent crops.

Even short-term, nonleguminous cover crops can provide benefits when used as part of the 

crop-rotation plan. The best cover crops are specific varieties adapted to the soil, climate, and 

season. They are sown at a fairly high rate to cover the soil quickly and prevent erosion. 

When planning crop rotations, it is important to consider that cultivated row crops such 

as vegetables tend to degrade soil. Since the soil is open and cultivated between rows, 

microbes break down organic matter at a more rapid pace. Furthermore, row crops have 

modest root systems and consequently do not contribute enough new organic matter 

to replace that lost from the open soil between rows. In most cases, above-ground crop 

residues make only minor contributions to replacing lost organic matter.

§ 205.205 Crop rotation practice standard 

Farmers are required to implement a crop rotation that maintains or builds soil 

organic matter, works to control pests, manages and conserves nutrients, and 

protects against erosion. Producers of perennial crops that aren’t rotated may 

utilize other practices, such as cover crops, to maintain soil health.

Related ATTRA 

publications

www.attra.ncat.org

Overview of Cover Crops 

and Green Manures
Page 30 www.ams.usda.gov/nop Guide for Organic Crop Producers

In contrast, cereals and cover crops are more closely spaced and have more extensive root systems than row crops, greatly reducing the amount of soil exposed to degradation. In addition, 

these crops receive little or no cultivation after planting, which reduces organic-matter loss 

even more. As a result, cereals and green manures can be considered neutral crops, replacing soil organic matter at roughly the same rate at which it breaks down. Crops that make a 

perennial sod cover, such as grasses, clovers, and alfalfa, not only keep the soil entirely covered but also have massive root systems that produce far more organic matter than is lost. 

Incorporating sod crops as a fundamental part of a crop rotation not only builds soil but 

also supports weed-control strategies. Weed control improves because the types of weeds 

encouraged by row-cropping systems are usually adapted to growing in a sod/hay crop. 

To make the most efficient use of sod crops, it will be necessary to include livestock in the 

system or to find a market for the hay. Livestock will assist in transferring (via manure) 

nutrients from one part of the farm to another. The major drawback to selling hay is that 

the nutrients it contains are shipped off the farm. 

Crop rotation in perennial crops

For producers of organic perennial crops, the requirement for crop rotation can be confusing. Section 205.205, the crop rotation practice standard, is meant to ensure that the 

farmer implements practices that will maintain soil organic matter, control pests, conserve 

nutrients, and protect the soil against erosion. For growers of annual crops, those practices typically include crop rotation, but other practices can be substituted if rotation is not 

practical. Some perennials will be part of a long-term crop rotation, which may last a few 

years or even decades. Asparagus, for example, is a perennial that can be productive for 

15 years or more. When a field is taken out of asparagus production, it is typically planted 

with another crop to reduce the incidence of soilborne disease. That practice is considered a 

long crop rotation. Several other perennials, such as strawberries, Echinacea, and lavender, 

are not required to have a cover crop because they are typically part of a long crop rotation.

Other types of perennials—those that will not be part of a crop rotation—may require 

additional practices to ensure soil conservation and biodiversity in the cropping system. 

This is important with large perennials, such as trees, that have large drive rows between 

the crop rows. For example, organic farmers must have a cover crop (often grass) between 

the rows of trees in an orchard. Crops that are required to have a cover crop between crop 

rows include caneberries, grapevines, blueberries, tree fruits, and nut trees.

Some perennial crops, such as alfalfa, develop a canopy that covers the ground and 

prevents soil erosion. Such crops are not required to be rotated to other crops.

Biodiversity

Organic production is a system that “respond[s] to site-specific conditions by integrating ... 

practices that .... conserve biodiversity.” The regulations also mention that perennial cropping systems must introduce biological diversity in lieu of crop rotation. 

Although farmers are encouraged to have diverse systems, there are no specific requirements, standards, or monitoring practices. Nonetheless, many organic farmers actively 

manage their farms to increase biodiversity, due to its many benefits.

Biodiversity plays a particularly crucial role in pest management. Diverse agricultural systems support strong populations of predators and parasites that help keep pest populations at 

manageable levels. This approach is proactive rather than reactive because a diverse system 

reaches an equilibrium that prevents pest outbreaks from becoming too severe. Birds and bats 

can keep insect populations low. Raptors can scare away fruit-eating birds. Coyotes, owls, 

and foxes can keep rodent populations under control. These animals can be encouraged by 

providing needed shelter, water, and habitat. 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 31

Organic producers increase biological diversity in the plant canopy by planting a diversity 

of crops and plant varieties in any given season. Use of cover crops and hedgerows also 

adds biodiversity. The diversity of vegetation, combined with reduced use of broad-spectrum pesticides, increases the diversity of insects and spiders in the plant canopy. Introducing beneficial insects and providing habitat for them to become established will increase 

biodiversity. To promote biodiversity in the soil, it is helpful to minimize tillage, introduce 

microorganisms in compost, and avoid broad-spectrum pesticides. These practices will 

increase the variety of bacteria, fungi, and invertebrates in the soil. 

For helpful resources that expand on the idea of biodiversity, see materials on the Wild 

Farm Alliance Web site.

Online Resources

Crop Rotation on Organic Farms: A Planning Manual, www.sare.org/

Learning-Center/Books/Crop-Rotation-on-Organic-Farms

Managing Cover Crops Profitably, www.sare.org/Learning-Center/

Books/Managing-Cover-Crops-Profitably-3rd-Edition

Western SARE Farm Internship Curriculum and Handbook, 

www.attra.ncat.org/intern_handbook/crop_rotation.html

Wild Farm Alliance, www.wildfarmalliance.org/resources/organic_BD.htm

Questions 

•	 If your crops are annuals, have you implemented a crop rotation that maintains 

soil organic matter, controls pests, minimizes diseases, and prevents erosion?

•	 If your crops are perennials, have you established cover crops between the plant 

rows to prevent soil erosion?

•	 Are you managing your cover crops to support beneficial insects and wildlife, 

as well as to preserve soil health?

•	 Are you providing additional habitat for beneficial insects and wildlife?

•	 Have you taken steps to maintain or increase biodiversity on your farm?

•	 Do you apply approved fertilizers and manures so that runoff and leaching 

are prevented?

•	 Do you manage all your fields to prevent soil erosion?

Notes 
Page 32 www.ams.usda.gov/nop Guide for Organic Crop Producers

CHAPTER 8

MANAGING PESTS, WEEDS, AND DISEASES

Farmers who transition from conventional to organic production systems often find 

that pest, disease, and weed control are their biggest challenges. For insect control, 

conventional farmers can wait until they see an outbreak of insects and then choose a 

chemical to control the insect. This approach is workable for conventional farmers because 

they have a large toolbox of chemicals available. For disease prevention, conventional farmers can fumigate the soil with broad-spectrum pesticides. Fumigation also kills beneficial 

soil organisms, which has negative long-term consequences. Organic farmers have fewer 

chemical tools available because there are far fewer insecticides, fungicides, and herbicides 

allowed for application to organic crops. In order to successfully transition to an organic 

system, farmers should be willing to approach these challenges from a different perspective. The key difference is preventing problems by designing a system that prevents most of 

the pest problems. Preventing severe pest outbreaks will allow the farmer to avoid broadspectrum pesticides that will lead to future imbalances in the ecosystem. 

Three levels of pest management

The USDA organic regulations are written to require farmers to employ tactics to minimize pest and disease problems using a three-level hierarchical approach.

Level A

The first line of defense in managing weed, insect, and disease pests is a systemsbased approach. It is based on the fact that a well-designed and healthy organic system 

will naturally have fewer pest problems. The system is designed to prevent pest and 

disease outbreaks. 

Level B

The second line of defense is utilized if the practices of level A are not sufficient to control the 

weed, insect, or disease problem. Level B generally includes mechanical and physical practices that are traditional in organics, as well as the use of nonsynthetic or natural materials.

Level C

The third line of defense is used if the level of pest control required is not achieved after A 

and B control options are applied. Level C practices include the use of inputs such as biologicals and botanicals to control pests. This level also provides the option of using those 

Related ATTRA 

publications

www.attra.ncat.org

Intercropping Principles 

and Production Practices

Farmscaping to Enhance 

Biological Control

Principles of Sustainable 

Weed Management 

for Croplands

§ 205.206 Crop pest, weed, and disease management 

practice standard

This section of the USDA organic regulations requires that producers use a threetiered approach in deciding how to deal with pest, weed, and disease problems. 

This can most easily be explained by designating these levels A, B, and C. 

 Level A, § 205.206 (a), is prevention of the problem. 

 Level B, § 205.206 (b, c, d), involves the use of mechanical or physical methods. 

 Level C, § 205.206 (e), is the application of allowed materials. 

Each level is explained in more detail later in this section. 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 33

materials included on the National List under § 205.601 Synthetic substances allowed for 

use in organic crop production.

If you anticipate the need for level C control measures, be sure that you indicate this in 

your Organic System Plan. Be specific about the control materials you might be using and 

outline the indicators or thresholds you monitor that will trigger the use of those materials. See Chapter 9 “The National List of Allowed and Prohibited Substances” for information on choosing materials, verifying that they are allowed, and informing your certifier 

regarding their use.

The organic regulations prescribe the type of practices but allow farmers to choose the 

specific practices that will work best for their systems. The remainder of this chapter will 

discuss specific level A and level B practices. Since many practices control both diseases 

and arthropod pests (insects and mites), these will be discussed together, and weed management will be discussed separately. 

Pest and disease management

Organic producers maintain that organic soil-building practices will result in crops that 

are properly nourished and thereby less susceptible to attack by pests and diseases. Natural 

biological pest control arises in a healthy organic system in the form of an active complex 

of natural predators and parasites that suppress pest populations. Incorporating habitat 

and food sources for beneficial insects into your farm, known as farmscaping, can provide 

long-term benefits. 

In many field crop and vegetable systems, maintaining a diverse, healthy ecosystem and 

using well-timed cultural practices are sufficient for pest management. Pests may not be 

eliminated, but damage levels are low enough to be tolerated. 

Examples of Level A practices to manage pests and diseases

Cover crops: Some cover crops, including sudangrass, rapeseed, and mustard, are effective 

at suppressing nematodes.

Crop rotation: Solanaceous crops, including tomatoes and potatoes, are planted in rotation 

with other crops that are not in the same family. This minimizes the risk of late blight disease and Colorado potato beetle outbreaks. Grain crops, including wheat, barley, and corn, 

are susceptible to Fusarium head blight. Moving to a legume or oilseed in the rotation can 

help break this disease cycle by allowing the grain crop residues to decompose fully.

Cultural practices: Use of disease-resistant varieties is a common cultural control. In addition, delaying spring planting until the soil is warmer minimizes fungal diseases and 

allows the crop to establish a healthy stand.

Intercropping: Two or more crops grown in close proximity is known as intercropping, 

strip cropping, or companion planting. This approach increases biodiversity and decreases 

pest outbreaks. 

Providing habitat for insect predators and parasites: In organic apple orchards, natural 

populations of predatory mites become high enough to control the plant-eating spider 

mites because the orchard provides a good habitat for the predatory mites. Conventional 

orchards, by contrast, are susceptible to outbreaks of spider mites because pesticides reduce 

the populations of beneficial predatory mites. Growing some plants that attract ladybugs or 

other beneficials will help reduce populations of plant pests. 

Resistant varieties: As one example, tomato varieties advertised as VFN are resistant to 

Verticillium, Fusarium, and nematodes. Stem rust is a common grain disease that can be 

managed by selecting resistant varieties.

Natural 

biological pest 

control arises in 

a healthy organic system 

in the form of an active 

complex of natural 

predators and parasites 

that suppress pest 

populations.
Page 34 www.ams.usda.gov/nop Guide for Organic Crop Producers

Sanitation: Sanitation entails the removal of sources of disease infection or insect pest 

infestation. For example, apple and pear growers remove branches infected with fire blight 

(strikes). The strikes are removed from the orchard and burned to kill the bacteria that 

cause fire blight. Mushroom growers pasteurize the compost to kill fungi that would 

compete with the mushroom crop.

Trap crops: These are small plantings of a crop or crop variety intended to draw a particular pest away from the main crop. For example, alfalfa planted in strips amid cotton 

attracts lygus bugs away from the cotton crop. Typically, trap crops must be destroyed to 

kill the pests that have been attracted to them. Use of trap crops requires a good understanding of the biology of the pest. 

Examples of Level B practices to manage pests and diseases

Burning crop residues: In organic production, the burning of crop residues is allowed only for 

suppression of disease. Rice straw often is burned in the field. Before using this disease-control practice, it must be clearly stated in the organic system plan and approved by the certifier.

Canopy management: By training and pruning trees, orchardists can increase airflow and 

decrease disease pressure. Viticulturists practice leaf removal to control Botrytis bunch rot 

of grapes. 

Introducing insect predators and parasites: Several types of insects can be purchased in 

large quantities and released on the farm. For example, to control aphids, release ladybugs 

and provide favorable conditions to encourage the ladybugs to stay and eat the aphids. 

Mulching: Mulching can reduce disease on tomatoes and similar crops by reducing soil 

contact and maintaining an even soil moisture. However, organic mulches also can serve 

as habitat for certain pests, such as the squash bug and slugs.

Row covers: Floating row covers, made of lightweight fabric, can keep insects out of shortseason crops. For example, they can prevent flea beetles in arugula and prevent cabbage 

root maggots in radishes. 

Solarization: Soil solarization is achieved by covering the soil with plastic during the summer. 

This allows the soil to get hot enough to kill many pathogens, yet it allows microbial spores 

to survive. Survivors can re-establish the microbial populations needed for healthy soil.

Weed management

According to the USDA’s Invasive Weed Management Unit, the most critical problem facing today’s organic grower is weeds. Weeds compete with crops for moisture, nutrients, and 

sunlight. Weeds do not always need to be eliminated—short weeds in a tall corn crop may 

be harmless—but weeds do need to be managed. Fortunately, there are many classic ways 

to reduce the number of weed seeds, and new ways are being developed to remove weeds 

that compete with crops. The appearance of many difficult-to-control weeds may be an 

indication that the soil has nutritional or physical problems and nature is trying to restore 

health and balance. 

Examples of Level A practices to manage weeds

Variety selection: Select grain varieties that emerge early and close the canopy as quickly 

as possible. This shades the soil so weeds are not as competitive.

High-crop seeding rates: Some crops can be planted at high rates to smother weeds. 

Another strategy is to increase the crop density by decreasing within-row distance or 

between-row distance. This is especially true when planting cover crops, forages, or grains. 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 35

Nurse crops: Companion crops can be sown with other crops to suppress weeds during the 

establishment year. A common example is planting oats to serve as the nurse crop for alfalfa.

Sanitation: For long-term weed control, it is important to avoid letting weeds go to seed. 

This keeps the field free of weed seeds for the next crop. Crops that go to seed also can 

become weeds the following year.

Cover crops: Rotations that include cover crops can provide some weed control, especially 

fast-growing cover crops, such as buckwheat. If cover crops are likely to self-seed, it will be 

necessary to mow them before seed sets. 

Solarization: Clear plastic traps the sun’s heat to raise the soil temperature. 

Examples of Level B practices to manage weeds

Cultivation: Mechanical cultivation is effective in killing weeds, especially if done at the 

seedling stage. Hilling potatoes controls the weeds while covering the tubers with soil.

Flaming: Flamers kill the above-ground portions of plants. They do not kill the roots, nor 

do they prevent weeds from re-sprouting. Several types of flamers are available, including 

small hand-held propane flamers and tractor-mounted flamers typically used in orchards.

Grazing: Animals such as goats or geese can control the height of cover crops sown in the 

drive rows in orchards. Animals must be removed 90 days before harvest of the crop, in 

accordance with the 90-120-day rule on manure applications. Chickens in movable pens 

can remove all weeds from small areas.

Hand weeding: Organic growers are all too familiar with the expense (if you hire someone) 

and exhaustion (if you do the work yourself) of hand weeding. However, hand weeding is 

still an effective method of weed control.

Mowing: In orchards, the cover crops in the drive rows are kept mowed. 

Mulching: A thick layer of mulch can smother weed seedlings. Mulch is less effective on 

perennial weeds because weeds that emerge from rhizomes, stolons, or tap roots may be 

able to grow through the mulch. Mulches are most commonly used when they can serve 

more than one purpose because applying mulch can be labor-intensive and therefore costly. 

For example, wood-chip mulches are commonly used in blueberry plantings to smother 

weeds, add organic matter, reduce soil pH, retain moisture near the soil surface, and keep 

the soil cool, all of which are important for shallow-rooted blueberry plants.

Transplanting: Transplanting onions rather than direct seeding gives the onions a head 

start on the weeds.

Weed cloth or black plastic: Weed cloth is often used in perennials, such as organic blueberry plantings, because the cloth controls weeds for several years. Black plastic is more 

commonly used in annual crops, such as tomatoes. Plastic mulches should not be allowed 

to photodegrade or deteriorate in the field; they may not be disced, plowed, or otherwise 

incorporated into the soil. In annual production systems, plastic mulch must be removed 

at the end of the growing season.

Online Resources

Biorationals: Ecological Pest Management Database, www.attra.ncat.

org/attra-pub/biorationals

Organic IPM Field Guide, www.attra.ncat.org/attra-pub/summaries/

summary.php?pub=148
Page 36 www.ams.usda.gov/nop Guide for Organic Crop Producers

Questions 

•	 Does your production system keep insects and diseases at manageable levels?

•	 Which of the following practices do you use?

Beneficial insects

Canopy management

Companion planting

Cover crops

Crop rotation

Cultivation

Flaming 

Grazing 

Habitat for beneficial insects

Habitat for predators 

Hand weeding or hoeing

High crop seeding rates

Intercropping

Mowing

Mulching

Resistant crop varieties

Row covers

Sanitation

Solarization

Trap crops

Weed cloth

•	 Are all of the insect, pest, weed, and disease control materials you are using allowed 

in organic production? See Chapter 9 “The National List of Allowed and Prohibited 

Substances” for more information on choosing pest-control materials. 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 37

CHAPTER 9

THE NATIONAL LIST OF ALLOWED AND PROHIBITED 

SUBSTANCES

The National List of Allowed and Prohibited Substances identifies substances that 

may or may not be used in organic crop production. In general, synthetic substances 

are prohibited unless specifically allowed and non-synthetic substances are allowed 

unless specifically prohibited.

First, it’s important to define a few terms. An “input” is any material applied to a crop, 

including compost, pheromones, and any pesticides. The term “pesticide” refers to any 

agent used to kill a pest. For example, insecticides kill insects, fungicides kill fungi, and 

herbicides kill plants. The National List uses the word “substance” to include not only 

inputs to crops but also any materials used for other purposes, such as rodent baits. All 

substances are listed by the generic terms only (e.g., sodium bicarbonate), not by the brand 

name (e.g., Arm and Hammer baking soda). This avoids suggesting that any one brand is 

better than any other. 

In this context, the term “product” will refer to the brand name of an input material. For 

example, Biomin® Calcium 2-0-0 is the name of a calcium product manufactured by JHBiotech, Inc. Pesticides contain an active ingredient, which is the material that kills the pest. 

Both pesticides and fertilizers also have inert ingredients, which make up the remainder 

of the product. Active ingredients are listed on the label, but inert ingredients typically are 

not listed. Although the inert ingredients are not listed on the product labels, they must be 

allowed for organic production, in order to use a specific product. 

Related ATTRA 

publications

www.attra.ncat.org

Sources of Organic 

Fertilizers and 

Amendments

§ 205.105 Allowed and prohibited substances, methods, 

and ingredients in organic production and handling

There are two main criteria that determine whether a given substance, such 

as a fertilizer or pesticide, is allowed in organic crop production: 

 1. Synthetic substances are prohibited unless specifically allowed on the National List.

 2. Nonsynthetic (natural) substances are allowed unless specifically prohibited on the 

National List.

In addition to these guidelines, genetically modified organisms are prohibited because 

they are produced by a prohibited method. Sewage sludge is prohibited because it usually 

contains prohibited substances.

§ 205.601 Synthetic substances allowed for use in organic crop production

The National List of synthetic substances includes materials that are specifically allowed 

in organic crop production. The list includes algaecides, disinfectants, sanitizers, irrigation 

system cleaners, herbicides, animal repellents, insecticides, miticides, pheromones, rodenticides, slug baits, plant disease controls, soil amendments, and plant growth regulators; 

in short, many of the materials needed for crop production. Any synthetic substance that 

is not on the National List is not allowed. For example, herbicides containing the synthetic 

material glyphosate are prohibited. Herbicides containing only natural substances, such as 

vinegar and clove oils, are allowed. 

§ 205.602 Non-synthetic substances prohibited for use in organic 

crop production

This is the National List of natural, or nonsynthetic, materials that are specifically prohibited in 

organic crop production. This list includes natural—but highly toxic—materials, such as arsenic.
Page 38 www.ams.usda.gov/nop Guide for Organic Crop Producers

There are two organizations that review products and publish lists of products allowed for 

organic production: the Organic Materials Review Institute (OMRI) and the Washington 

State Department of Agriculture (WSDA) Organic Food Program. These organizations 

obtain information about all the inert and active ingredients in a product formulation, 

review them, and assess whether the product is allowed.

As explained in the previous chapter, the USDA organic regulations require that farmers 

implement pest-management practices in a hierarchical fashion, beginning with a systems 

approach. If that approach is not sufficient, inputs may be needed, whether for plant nutrition, 

disease prevention, or pest management. This chapter explains broadly the types of materials allowed and specifically how to choose a product that will be approved by your certifier. 

Allowed pesticides

Generally speaking, pesticides derived from natural materials or living organisms are 

allowed in organic production as long as they do not contain synthetic additives or are not 

specifically prohibited on the National List under § 205.602. By contrast, most synthetic 

pesticides are not allowed; those few that are can be found on the National List under 

§ 205.601.

Allowed inputs typically include but are not limited to the following:

•	 Biological pesticides 

•	 Botanical pesticides

•	 Dormant and summer oils

•	 Fatty acid insecticidal soaps

•	 Minerals

•	 Pheromones

Biological pesticides

Biologicals may contain living microbes, such as the fungi Beauveria bassiana or Trichoderma harzianum. Other biologicals contain toxins derived from naturally occurring 

microbes, such as the Bt toxin, produced by the bacterium Bacillus thuringiensis. There are 

various formulations of Bt, all of which control insect larvae.

Spinosads are a relatively new class of biological insecticides derived from a rare form of 

soil-dwelling actinomycete. Spinosads control a variety of insect pests, including thrips, 

fruit flies, and caterpillars, without harming beneficial insects. 

Botanical pesticides

Botanicals are derived from plants. They include pyrethrum, rotenone, sabadilla, neem, 

ryania, and garlic. Strychnine and nicotine are also botanicals, but are expressly prohibited 

in organic production. Since botanical pesticides are relatively nonselective, they can affect 

natural predators and other nontarget organisms. Rotenone, for example, is highly toxic to 

fish. For this reason, many organic growers use botanical pesticides only as a last resort. 

Spray oils

Vegetable- or animal-derived oils are generally allowed as suffocating (stylet) oils, summer 

oils, dormant oils, and surfactants. Some petroleum-derived oils, referred to as “narrowrange oils,” are allowed for the same purposes. Spray oils are commonly used to control 

scale and mite pests. 

There are two 

organizations 

that review 

products and publish lists 

of products allowed for 

organic production: 

the Organic Materials 

Review Institute (OMRI) 

and the Washington State 

Department of 

Agriculture (WSDA) 

Organic Food Program.
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 39

Insecticidal soaps

Fatty acid insecticidal soaps are synthetic pesticides specifically allowed in organic production. Safer® Brand Insect Killing Soap Concentrate II is a product that is commonly used 

by organic farmers. Insecticidal soaps can be hard on beneficial predatory mites, so they 

should be used with caution.

Minerals

Mineral-based pesticides include sulfur, copper products, diatomaceous earth, and kaolin 

clay. These must be used with caution, even though they are allowed. Sulfur can reduce 

the populations of some beneficial insects and may burn plants if used during hot weather. 

Diatomaceous earth can cause respiratory problems and itching in the farmworkers who 

apply it. Copper can accumulate in soils, so it is allowed with restrictions. The organic 

regulations state that “copper-based materials must be used in a manner that minimizes 

accumulation in the soil...” Certifiers may require soil testing to verify that copper is not 

accumulating in the soil. Certain highly toxic minerals, including arsenic and lead, are 

specifically prohibited. 

Pheromones

Pheromones are chemicals released from insects that cause other insects of the same 

species to change their behavior. Pheromones are not considered pesticides because they 

do not kill the insects. The pheromones used for pest control are often called mating 

disrupters because they alter mating behavior. Being totally natural, the pheromones themselves are allowed in organic production. However, some of the inert ingredients in mating 

disrupter products are prohibited. 

Allowed fertilizers

Allowed fertilizers and amendments typically include, but are not limited to, the following:

•	 Plant materials such as crop residues

•	 Rock dusts such as gypsum, rock phosphates, granite dust, greensand, natural 

potassium sulfate, sulfate of potash-magnesia, and glacial gravel dust

•	 Animal byproducts

•	 Manures

•	 Composts

•	 Marine products and byproducts, such as seaweed and fish emulsion 

•	 Non-GMO microbial inoculants 

•	 Sodium nitrate (Chilean nitrate), only if its use constitutes no more than 

20 percent of the crop’s total nitrogen requirement 

How to determine if a product is allowed 

for organic agriculture

The allowed pesticides on the National List are called active ingredients when they are formulated into a commercial product. Even if the active ingredient in a pesticide is allowed, 

if an inert ingredient is not allowed, the pesticide may not be used in organic crop production. The U.S. Environmental Protection Agency provides four classifications of inert 

ingredients: List 1, List 2, List 3, and List 4. At this time, only a small fraction of the inert 

ingredients on these lists is allowed in organic production.
Page 40 www.ams.usda.gov/nop Guide for Organic Crop Producers

The active ingredient is listed on the product label, but the inert ingredients often are not 

listed, and companies may choose not to reveal that information. Determining whether 

a commercial pesticide is allowed for organic production is a daunting task.

The same situation holds true for fertilizers and soil amendments. For example, the commonly sold agricultural gypsum often is made from recycled wallboard, a construction 

material that contains synthetic chemicals. For that reason, gypsum used in organic 

production must be obtained only from a mined source. 

The safest option for organic farmers is to avoid using any product unless you’re sure that it is 

allowed. One way to verify the product’s status is to review the lists published by OMRI and 

the WSDA Organic Food Program. When companies develop a fertilizer or pesticide that 

they believe is suitable for organic production, they typically list the product with OMRI or 

WSDA, or both. The organizations review the products, including the inert ingredients, and 

determine if they meet the requirements of the USDA organic regulations. Organic farmers 

can use these listed products with confidence that their use will not jeopardize their organic 

certification. The review does not include a review of product effectiveness, and the listing is 

not an endorsement of the product. On the other hand, organic producers should be aware 

that many companies choose not to list their products with OMRI or WSDA, yet their products are allowed in organic agriculture. 

Using the OMRI list

OMRI has two lists: the OMRI Products List and the OMRI Generic Materials List. Both 

include materials for crops, livestock, and processing. To use either OMRI list, start on the 

OMRI Web site home page, and click “OMRI list” on the left side of the page. The next 

screen allows you to search the OMRI lists for your product. 

For example, if you search using the word “gypsum,” the Products List will include brand 

names of several products (e.g., Ida-Grow Pelletized Gypsum). The generic materials list 

will simply list gypsum. 

At the bottom of the page, there is a link to download the Products List as a PDF file. If you 

use the downloaded file, be sure to update it frequently, as new products are added and others are removed on an ongoing basis. The OMRI Web site also has links to the names and 

addresses of suppliers to make it easier to purchase approved materials. 

Using the WSDA Brand Name Materials List 

The Brand Name Material List (BNML) is maintained by the WSDA Organic Food Program and can be accessed on its Web site. There are three versions: Sorted by Product, 

Sorted by Company, and Sorted by Type. Each of these lists can be downloaded as a PDF 

file. The list of materials sorted by product is best used to look up a specific product, such 

as MicroPak PolyAmine, which is a fertilizer sold by Northwest Agricultural Products. The 

list of materials sorted by company is useful when searching for products from a particular company, such as Bio-Gro, NuFarm, or Northwest Agricultural Products. The list of 

materials sorted by type can be used to find an approved product. For example, searching 

under D&PC (Disease and Pest Control), there are numerous sub-types, including neem, 

pheromones, and fungicides.

Although this list was developed by one certification agency, it is accepted by most of the 

certifiers in the United States.

Caveats

Companies that sell agricultural products will often state in their catalog that a product 

is OMRI or WSDA approved. Some manufacturers will state on the package that the mateEven if the 

catalog or the 

manufacturer 

claims that a product is 

allowed, it’s a good idea 

to verify that the product 

approval is current 

before it is applied to 

organic land.
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 41

rial is listed with OMRI or WSDA. Even if the catalog or the manufacturer claims that a 

product is allowed, it’s a good idea to verify that the product approval is current before it is 

applied to organic land. 

When using either WSDA or OMRI lists to verify the product’s status, be sure to check 

the most recent version. Each list is updated several times each year, and the most current 

version is posted online. Using the complete and correct name of the product will make it 

easier to find the product if it is listed. 

Restrictions on use of approved products

Although products may be listed by OMRI or WSDA, there may be restrictions on their 

use. The WSDA indicates restrictions in the column on annotations. For example, the 

product Biomin Zinc is allowed as a fertilizer, but there is a restriction: soil deficiency must 

be documented by testing. Before applying zinc to crops, farmers are required to obtain a 

soil test to verify that the crop needed additional zinc. Some certifiers will accept fruit or 

leaf tests that indicate a deficiency in the plant, as opposed to the soil.

The Organic System Plan

Each year, when a farmer prepares the paperwork to renew organic certification, one of the 

questions will be: “Please list any materials you plan to use in this year’s growing season.” 

This list should be based on the types of inputs applied in the previous year or the past 

few years. This is a list of materials that might be applied, but they should only be applied 

if they are needed. Always, if it is necessary to use a product that is not on the Organic 

System Plan, the certifier must be notified before use.

Online Resources

OMRI Materials Lists, www.omri.org/omri-lists

WSDA Materials Lists, www.agr.wa.gov/FoodAnimal/Organic/

MaterialsLists.aspx

Biorationals Database, www.attra.ncat.org/attra-pub/biorationals

Questions 

•	 Do you have a list of all inputs used for insect control in the previous growing season?

•	 Do you have a list of all inputs used for weed control in the previous growing season?

•	 Do you have a list of all inputs for disease control in the previous season?

•	 For a product listed by OMRI or WSDA, do you have evidence that it is allowed for 

organic agriculture? This can be a label or a copy of the online listing.

•	 If you are using natural materials such as gypsum, do you have evidence that they 

are from a naturally mined source?

•	 Do you understand any restrictions on the use of the products and have you 

complied with the restrictions?

•	 Have you kept invoices of all materials purchased?
Page 42 www.ams.usda.gov/nop Guide for Organic Crop Producers

Notes 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 43

CHAPTER 10

GREENHOUSE PRODUCTION

This chapter does not reference a particular section of the USDA organic regulations 

because there is no one section addressing greenhouse production. Whether growing plants in the field or in the greenhouse, organic producers must comply with all 

practice standards related to fertility management, pest control, allowed materials, seed, 

and treated lumber. For example, treated lumber may be allowed for structural support of 

buildings, benches, or trellises, but it is not allowed for raised beds or plant supports. 

The word “greenhouse” traditionally refers to a heated, permanent structure. The discussion in this chapter refers to plants grown in any enclosed structure, whether heated or 

unheated, temporary or permanent, including cold frames and hoop houses, since many 

of the same considerations apply to all enclosed systems. 

There are several types of greenhouse growing systems. Plants can be grown in containers, in the ground, or in water. Container-grown plants may be short-term crops, such as 

annual transplants, nursery perennials, or research studies, or they may be grown for harvest. 

Peat, compost, vermiculite, perlite, and many typical ingredients in soilless potting mixes 

are allowed in organic production. Other ingredients are not allowed, such as the chemicals 

used to increase water-holding capacity of the soil and the fertilizers that are added to some 

potting mixes. Before using a potting mix, read the label carefully, list the brand name on 

your system plan, and save an empty bag to show your inspector. A greenhouse with container-grown plants will not need a 3-year transition period to become certified organic. If 

the pots are reused, they can be cleaned with soap and water or disinfected with a chlorine 

solution. The method used to sanitize containers will need to be approved by the certifier. 

Hoop houses often are used to cover plants growing directly in the ground, rather than 

in pots. If plants are grown in the ground within the greenhouse, the soil will require a 

36-month period free of prohibited materials, just like an outdoor field. Cover crops typically 

are not used in a greenhouse, but rotation may be required if crops are grown in the ground. 

When there is both organic and conventional production at the same location, either in adjacent or shared greenhouse structures, there are additional challenges related to avoiding 

contamination and commingling. For example, you must take extra care to ensure that 

pesticide drift does not reach organic crops and that shared equipment is adequately cleaned. 

Split production within a single greenhouse structure is not prohibited but is discouraged 

due to the difficulties in controlling pesticide drift and monitoring fertilizer applications. 

Handling, labeling, and segregation procedures must be well established to guarantee that 

conventional and organic products are not commingled. The inspector will observe a split 

operation closely to ensure that organic products are grown and handled properly.

Despite the emphasis that organic agriculture places on the importance of soil, crops grown 

in a hydroponic system, rather than soil, can be certified organic. Hydroponics is the production of plants in a soilless medium, whereby all of the nutrients supplied to the crop are 

dissolved in water. Aquaponics is a type of hydroponic production in which nutrient-rich 

effluent from fish tanks fertilizes the crops grown in hydroponic production beds. The waste 

products of one biological system—the fish tank—produce nutrients for a second biological 

system—the crop plants. 

Management of insects, diseases, and weeds

Regardless of the system they use, greenhouse growers will need to have a plan for insect 

and disease management. In an enclosed environment such as a greenhouse, insects and 

foliar diseases can reach damaging levels very quickly. Conventional greenhouse production 

Related ATTRA 

publications

www.attra.ncat.org

Organic Greenhouse 

Tomato Production 

Organic Greenhouse 

Vegetable Production 

Herbs: Organic 

Greenhouse Production 

Potting Mixes for Certified 

Organic Production 
Page 44 www.ams.usda.gov/nop Guide for Organic Crop Producers

can rely on pesticides for control. In contrast, many organic producers focus on a systems 

approach for insect and disease management:

•	 Choose crops adapted to greenhouse production

•	 Plant a diversity of crops

•	 Use screens to exclude insects

•	 Introduce predators such as ladybugs to reduce insect populations

•	 Break the pest cycle using heat or cold

In order to break the pest cycle, choose a time when the greenhouse is not in use for crops 

and create conditions unfavorable for insect survival. A greenhouse used in the winter can 

be closed in summer and allowed to heat to high temperatures to kill insects. Conversely, 

a greenhouse used in the summer can be opened in the winter so that insects are killed by 

cold temperatures.

Foliar diseases can become a problem in the enclosed, humid greenhouse environment, but 

there are simple techniques to minimize disease outbreaks: 

•	 Water plants early in the day

•	 Space plants far enough apart to allow air flow

•	 Use drip irrigation rather than overhead watering

•	 Open vents to encourage air movement

The goal of all these techniques is to reduce humidity and minimize periods of leaf wetness. When ventilating an organic greenhouse, be sure to avoid drift from attached conventional greenhouses or from pesticides sprayed outside the greenhouse. 

Weed control can be a challenge in a greenhouse. Only approved herbicide materials may 

be used inside the greenhouse, even if you are spraying the ground and all the plants rest 

on benches. Use of black plastic or landscape fabrics for weed control must follow the

guidelines for organic production, as explained in Chapter 8.

Questions 

•	 Are all planting media ingredients allowed in organic production?

•	 Are all fertilizers allowed in organic production?

•	 Do you actively take steps to prevent disease and pest outbreaks?

•	 If growing trays and pots are reused, are they cleaned using approved practices 

and materials?

•	 Do you manage weeds in and around the greenhouse site with allowed technologies and inputs? 

•	 Are your greenhouse structures adequately distanced or protected from sources 

of pesticide drift?

•	 Are greenhouse construction materials selected and managed to prevent contamination of producing soils and crops? Pay special attention to the use of treated lumber.

•	 If you produce conventional crops, are separate structures used to segregate 

conventional and organic production? Is air exchange prevented?

•	 Are adequate barriers present and/or procedures in place to prevent pesticideladen air movement from conventional production areas into organically 

managed sections?
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 45

Questions 

•	 Are the organic production areas situated to prevent contamination by drainage 

from conventional areas?

•	 Are sprayers and other application equipment for organic use labeled and segregated?

•	 Does shared equipment have clearly defined cleanup protocols? Are cleanup logs 

maintained?

•	 Where fertigation is used in split production, are the water systems fully segregated to prevent contamination?

Notes 
Page 46 www.ams.usda.gov/nop Guide for Organic Crop Producers

CHAPTER 11

PREVENTING CONTAMINATION OF 

ORGANIC CROPS

This chapter discusses various precautions and additional recordkeeping that are 

needed to prevent contamination of organic crops. These precautions are important for split operations (farms that raise both organic and conventional crops) and 

are essential for parallel production (farms that raise the same crop in both an organic and 

conventional manner). Managing a split operation requires extra care to ensure the organic 

integrity of the crops because of the risk of spray drift, contaminated equipment, or accidental sprays of conventional chemicals on organic crops. Preventing contamination also 

is a concern if contractors are hired for seeding, spraying, or harvesting, or if spray drift 

from neighbors is a possibility.

It is the responsibility of the organic farmer to ensure that organic crops are not contaminated with conventional materials. Contractors hired for seeding, spraying, or harvest may 

not be familiar with practices needed to prevent contamination of organic crops. If a prohibited material is applied, even if it is done by a contractor by mistake, an organic farmer 

can lose organic certification for 3 years. Certainly this would have an economic impact. 

It pays to educate employees and contractors and verify that they follow organic practices 

carefully.

Seeding

Many conventional growers use seeds treated with fungicides that are prohibited in organic 

production. These fungicide-treated seeds are required by law to be dyed, usually bright 

pink or green, so the fungicide will be obvious to the user. Before seeding equipment 

is used to plant organic crops, all fungicide-treated seeds must be completely removed 

from the planting equipment. The seed drills may need special attention, typically cleaning with compressed air, to remove fungicide deposits or seeds that may be caught. After 

cleaning the equipment, it’s a good idea to check that the fungicide-treated seeds have all 

been removed. If the seeding equipment is not cleaned and treated seeds are distributed 

throughout the field, this will be considered an application of a prohibited material and the 

field will lose organic status for 36 months.

Special considerations apply to split operations that grow genetically modified (GM) crops, 

or that have nearby neighbors that grow GM crops (also referred to as GMOs, or Genetically Modified Organisms). Pollen from GM crops has been contaminating organic crops 

with increasing frequency. There is little information on the distance that would be needed 

to prevent pollen from traveling from the GM crop to the organic crop. The distance will 

depend on the type of crop, the surrounding vegetation, and the terrain that separates 

the two crops. The isolation distances used for seed production are intended to minimize 

transfer of pollen from one crop to another. These will provide a starting place to determine the isolation distance needed to prevent organic crop contamination with GM pollen, 

but there are no guarantees. 

Spraying and maintaining buffers

As an organic farmer, you are responsible for all materials applied to your fields, even when 

you do not apply those materials yourself. Organic crops can be contaminated through 

residues in spray equipment, drift from nearby fields, accidental sprays, or mistakes made 

by employees. 

Related ATTRA 

publications

www.attra.ncat.org

Sources of Spraying 

Prohibited Signs for 

Organic Farms

Transgenic Crops
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 47

Residues from spray used for conventional crops must be thoroughly removed before 

equipment is used to spray organic crops. Although most farmers rinse equipment with 

water after spraying, some conventional pesticides, such as DDT, are hard to remove, so 

rinsing may not be adequate. Residues may be removed more effectively by using a cleaner 

such as Nutra-sol. 

Pesticide drift is a concern if there are conventional crops growing near organic crops. Even 

if a farm is entirely organic, pesticide drift may occur if the neighbors manage conventional 

fields near the organic fields. In the past, farmers maintained a 25-foot buffer between 

organic and conventional crops, but this is no longer considered a standard. Buffers may 

need to be larger than 25 feet, or they may be smaller, but they must be large enough to 

prevent measurable drift. Windbreaks, made of hedgerows or tall crops such as corn, will 

reduce the likelihood of drift. If the conventional crop is fruit trees sprayed with an airblast sprayer, a large buffer will be needed. Conversely, if the nearby conventional spray is 

for weed control, using a backpack sprayer near the ground, a smaller buffer will be sufficient. It is important to educate neighbors and employees to be careful to avoid drift onto 

organic crops.

Accidental spraying of conventional pesticides onto organic fields is something that should 

never happen, but it does. A neighbor might believe he or she is being helpful by spraying herbicides at the edges of your organic fields, or custom applicators might apply aerial 

sprays to the wrong fields. To minimize the chances of instances such as these happening, 

notify your neighbors in writing that some of your fields are organic. Supplying a map—

perhaps the map sent as part of the Organic System Plan (OSP)—can be very helpful. Additionally, if organic crops are planted near roadsides, it may be necessary to inform county 

authorities that they should not spray herbicides near your organic crops. Some counties 

provide free signs that state “Owner Will Maintain.” These are placed at the beginning 

of the organic property to indicate that the owner will control weeds along the roadside. 

Other sources of signs are provided in the ATTRA publication “Sources of Spraying Prohibited Signs for Organic Farms.” 

Mistakes by employees should never happen, but they do. During the transition period 

from conventional to organic, it’s easy to reach for familiar conventional pesticides without 

realizing that they are prohibited. If employees will be spraying pesticides, it is essential to 

educate them about the use of materials approved for organic production, the proper cleaning of sprayers, the importance of accurate spray records, and any other organic procedures 

for which they are responsible. One common mistake is to use a material that is allowed in 

organic production in the United States but is not allowed according to the organic standards in Europe. If any product will be exported, be especially vigilant to be aware of additional restrictions.

Fertilizing (custom mixing) 

Each material applied to an organic crop must be documented, reported to the certification 

agency, and allowed for use in organic production. The list of ingredients used in a custom 

mix, including the brand names and copies of invoices, must be available for review by the 

organic inspector.

Irrigation 

The USDA organic regulations have very little to say about irrigation and irrigation water 

quality. However, since it is the general intent of these regulations that crops and soils not 

be contaminated with prohibited substances, producers should take precautions to ensure 

that irrigation water is not loaded with agricultural pesticides or other polluting chemicals. 
Page 48 www.ams.usda.gov/nop Guide for Organic Crop Producers

If you have a split operation and shared irrigation equipment is used for fertigation or other 

chemical application, protocols for decontamination of the equipment and a cleanout log 

will be required. It is probably easier to use separate irrigation equipment for organic and 

conventional crops. If irrigation lines require a cleaning agent, an algaecide, or any antimicrobial chemical, consult your certifier to be certain the material you choose is allowed 

for use in organic production.

Harvest

If the same equipment is used to harvest both organic and conventional crops, there is a 

possibility of commingling, or combining, of organic products with conventional products. Several precautions are needed to prevent commingling. Cleanout procedures need 

to be established and documented to ensure that product mixing does not occur. Along 

with clearly written protocols, a log of cleanout dates also will be expected by the certifier.

Before beginning the organic harvest, organic farmers often rely on purging to scour 

combines and other harvesting equipment that is used for conventional crops. One way 

to purge equipment of conventional crops is to harvest the first organic crop row and 

sell it as conventional. This is a common technique for hay balers and combines. Purging may not be an adequate cleanout technique in circumstances where the remains of 

GM crops need to be removed. Very small quantities of GM crops can be detected with 

current testing procedures.

Transportation of organic products

Transporting organic crops from the field to the storage location might present a contamination hazard. If trucks have been used to transport conventional crops, they need to be 

thoroughly cleaned before being used to transport organic crops. Even small details can be 

very important. For example, cleanout protocols must include cleanup of the tarps used to 

cover grain trucks or hay bales. 

Cleaning procedures for harvest and transportation equipment will depend on the specific 

crop. The protocols, or step-by-step procedures, should be written down so that employees can easily follow the directions. A cleaning log should be used to document the dates 

that cleaning occurred. This is especially important if contractors are used. Farm produce 

that is transported by your own farm equipment is covered under your OSP for the farm 

certification. If other transportation is used, truck or rail, the company must be mentioned 

in your OSP. 

Storage

In a split operation, several precautions should be taken to avoid commingling of organic 

and conventional crops in storage. Organic crops must be stored separately from conventional crops. Separation can be achieved with a separate location in the storage area, identified by clearly readable signs, or an entirely separate room. Your certifier will determine 

whether the separation is adequate. All bins and storage areas should be clearly labeled. 

Inventory records, cleanout protocols, and cleanout logs must be current. The inspector 

may conduct a detailed in/out audit to compare the amount of product sold to the amount 

of product harvested. All records should be available at inspection. 

Pest-management decisions for storage areas will need to follow organic guidelines as well. 

These are explained in chapter 14 “Structural Pest Management.”
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 49

Online Resources

Isolation Distances and Pinning Maps in Organic Seed Production, www.

extension.org/pages/18435/isolation-distances-and-pinning-maps-inorganic-seed-production

NOP 5031 Draft Guidance: Handling Bulk, Unpackaged Organic Products, 

www.ams.usda.gov/nopprogramhandbook

Notes 

Questions 

•	 If planters or seeders are also used to apply prohibited materials, are cleanout 

protocols clearly established and cleanout logs maintained? 

•	 If conventional crops are grown, is separate spraying equipment available and 

clearly marked?

•	 If sprayers are also used to apply prohibited materials, are cleanout protocols 

clearly established and cleanout logs maintained? 

•	 If both organic and conventional crops are irrigated using the same equipment, are 

you taking steps to ensure that prohibited materials do not contaminate organic 

crops?

•	 Is all runoff from conventionally managed land properly diverted to prevent 

contamination of land and water resources used in organic production?

•	 If equipment is used to harvest both conventional and organic products, are 

cleanout protocols established and cleanout logs maintained?

•	 When harvesting equipment is purged, have adequate records been kept on the 

quantity of organic product used in purging and how it was subsequently used or 

disposed of?

•	 Are crops harvested from buffer zones segregated, documented, and sold as 

nonorganic product?

•	 Are cleanout protocols maintained for farm-owned trucks?

•	 Do all hired trucks have either clean truck affidavits or cleanout logs?
Page 50 www.ams.usda.gov/nop Guide for Organic Crop Producers

CHAPTER 12

POST-HARVEST AND LABELING

The importance of maintaining organic integrity not only while the crop is being 

grown but also after the crop is harvested cannot be overstated. To ensure organic 

integrity from the field to the consumer, it is important to develop standard procedures, or protocols, for harvesting, washing, storing, transporting, and labeling organic 

produce. These protocols should be written in the Organic System Plan (OSP), approved by 

the certifier, and followed by all farmworkers. 

Protocols differ from farm to farm, depending on the size of the farm and the storage facilities. 

On every farm, there are two common goals: preventing contamination of organic crops 

and preventing commingling of organic crops with conventional crops. This chapter discusses some important considerations for harvesting, washing, storing, packing, labeling, 

and transporting organic crops. Chapter 13 “Recordkeeping” will discuss the importance 

of an audit trail, which allows products to be traced from the consumer back to the farm 

and perhaps to the field where the crop was grown. 

Containers

Any container used for harvest, storage, or shipping can present a threat of contamination to organic produce. This includes bins, cardboard boxes, and trucks used to transport 

produce from the farm to a local market. 

As organic producers harvest crops into containers, they should consider the potential for 

contamination and take appropriate steps to prevent it. Harvest and storage bins should 

be clean and free of residue left from conventional produce. Almost any type of soap or 

detergent can be used to clean containers, as long as the containers are thoroughly rinsed. 

A few sanitizers, such as quaternary ammonium compounds, are prohibited because they 

leave residues that are difficult to remove. If the harvest containers must be sanitized, 

several brands of chlorine and peroxyacetic acid sanitizers are allowed for organic use. The 

chlorine residues can be easily washed off with water. Peroxyacetic acids may not even need 

rinsing because they will decompose into water and oxygen and because washing with 

water after using peroxyacetic acid risks further contamination. 

Packaging and shipping materials that are impregnated with prohibited pesticides can 

contaminate organic products. For example, reusing cardboard boxes that have been 

used for conventional produce is an excellent idea from the standpoint of sustainability. 

However, many of those boxes have been treated with fungicides, so they should not be 

used for organic produce. 

Washing produce

Microbial contamination of water used to wash fresh produce is a high-profile issue in the 

organic community. Some types of produce, such as lettuce, are simply rinsed with plain 

water to remove field heat. In those cases, the farmer needs to be aware of basic food safety 

and ensure that the water used is potable. For other types of produce, such as apples, synthetic materials are added to the wash water to reduce microbial loads. Adding hydrogen 

peroxide, ozone, or chlorine to control microbial growth is allowed in organic processing, 

but there are restrictions on the use of these chemicals.

Section 205.605 of the National List of Allowed and Prohibited Substances states that chlorine (Cl) materials are allowed for “disinfecting and sanitizing food contact surfaces” in 

organic processing. The regulation also states that “residual chlorine levels in the water 

shall not exceed the maximum residual disinfectant limit under the Safe Drinking Water 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 51

Act,” which is currently 4 parts per million chlorine. The interpretation of this regulation 

caused some confusion, leading the NOP to issue additional guidance. The guidance document can be found in the NOP Program Handbook as NOP5026, “The Use of Chlorine 

Materials in Organic Production and Handling,” and is summarized below.

When washing produce, the rinse water that makes final contact with the organic product 

must not contain more than 4 ppm chlorine. In other words, a food product, such as apples, 

may be bathed in water containing a higher concentration of chlorine, if it is permitted by 

the U.S. Food and Drug Administration (FDA), but that product must receive a final rinse 

of water containing no more than 4 ppm chlorine. The procedures used to wash produce 

and to monitor chlorine levels in the wash water must be included in the OSP. 

Some farmers may choose to use chlorine materials for irrigating crops or cleaning irrigation systems. For those purposes, the water must contain no more than 4 ppm chlorine. 

Storing produce

Storing produce appropriately is just as important as growing it. Your OSP should state 

the names of any storage facilities that you use. The farm inspector will want to visit any 

storage facilities that are used for organic crops, even if they are offsite. Storage in an open 

container, such as an apple bin, presents more possibility of contamination or commingling 

than produce stored in a closed container, such as a 40-pound cardboard box of apples. For 

bulk storage of certain crops such as apples and potatoes, it may be necessary to have a dedicated organic cooler to avoid contact with post-harvest chemicals applied to conventional 

crops. Potato storages, in particular, must be carefully cleaned after storage of conventional 

crops and before storage of organic crops. 

Labeling nonretail containers

Nonretail containers include cardboard boxes, plastic bins, totes, or other containers used 

to transport fruits and vegetables to the warehouse, farmers market, or retailer. Such containers must be labeled with information that allows the product to be traced back to the 

farm and field where it was grown. Nonretail containers on the farm include only raw agricultural products, but these rules apply as well to processed (e.g., frozen) products kept in 

bulk storage by processors. 

For many small farmers who market raw products, it will be sufficient to label the container 

with the word “organic” and the farm name. The USDA organic seal or the seal of the certification agency may be used, but they are not required. Farmers who have multiple fields 

of the same crop will need to assign lot numbers to the crops harvested from different fields 

and ensure that the lot number is attached to the container. For example, a farmer with 

three fields of sweet corn, all being sent to a processor to be frozen, may choose lot numbers 

of swc_JY30, swc_AU15, and swc_AU30. This code indicates the crop (swc), the harvest 

month (JY, AU) and the harvest day (15, 30).

Labeling retail containers

The NOP 

Program 

Handbook 

includes a guidance 

document titled 

“The Use of Chlorine 

Materials in Organic 

Production and 

Handling.”

§ 205.301 Product composition

(a) Products sold, labeled, or represented as “100 percent organic.” 

(b) Products sold, labeled, or represented as “organic.” 

(c) Products sold, labeled, or represented as “made with organic” (specified ingredients 

or food group(s)). 

(d) Products with less than 70 percent organically produced ingredients.
Page 52 www.ams.usda.gov/nop Guide for Organic Crop Producers

The rules for labeling organic retail products, both raw and processed, are addressed under 

the “Product Composition” section of the USDA organic regulations. The regulations cover 

the wording allowed on both the front panel and the information panel of a packaged product. The four categories of labeling based on product composition are summarized below:

•	 “100 percent organic” can be used to label any product that contains 100 percent 

organic ingredients (excluding salt and water, which are considered natural). Most 

raw, unprocessed farm products can be designated “100 percent organic.” Likewise, 

many value-added farm products that have no added ingredients—such as grain 

flours, rolled oats, etc.—can also be labeled “100 percent organic.”

•	 “Organic” can be used to label any product that contains a minimum of 95 percent 

organic ingredients (excluding salt and water). Up to 5 percent of the ingredients 

may be nonorganic agricultural products that are not commercially available as 

organic and/or nonagricultural products that are on the National List.1

•	 “Made with Organic ______” can be used to label a product that contains at least 

70 percent organically produced ingredients (excluding salt and water). There are 

a number of detailed constraints regarding the ingredients that comprise the nonorganic portion. 

•	 The specific organic ingredients may be listed in the ingredient statement of products containing less than 70 percent organic contents—for example, “Ingredients: 

water, barley, beans, organic tomatoes, salt.”

Many farmers make jams, teas, salsas, or other processed products from their excess 

produce. These value-added products can be an excellent source of income, but there 

are additional requirements if they are to be labeled organic. Depending on the certifier, 

simple processing—such as drying of herbs, freezing of fruits, or grinding of grains—may 

be covered under the farm’s Organic Producer certificate. If the product undergoes complex processing and is labeled organic on the front panel, an Organic Handler certificate 

will be required. If the organic ingredients are only listed in the information panel and 

those ingredients are grown on the farm, then the Organic Handler certificate is not necessary. For example, farmers can list organic strawberries as an ingredient in the jam if they 

make jam from organic strawberries that they grow. The certifier will want to review copies 

of the labels to ensure that they comply with organic regulations.

1 For an explanation of the National List, see Chapter 9 “The National List of Allowed and Prohibited Substances.”

Online Resources

NOP 5026 Guidance: The Use of Chlorine Materials in Organic Production 

and Handling, www.ams.usda.gov/nopprogramhandbook

NOP 5031 Draft Guidance: Handling Bulk, Unpackaged Organic 

Products, www.ams.usda.gov/nopprogramhandbook
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 53

Questions 

•	 If both organic and conventional crops are grown, are harvest procedures sufficient 

to ensure segregation? Do adequate labeling protocols exist to ensure segregation?

•	 Have labels been sent to the certifier for approval?

•	 If you are reusing bags or containers, are you taking measures to ensure that there 

is no risk of commingling with nonorganic products or of contamination with 

prohibited substances?

•	 Are all packaging materials free of impregnated pesticides or other prohibited 

substances?

Notes 
Page 54 www.ams.usda.gov/nop Guide for Organic Crop Producers

CHAPTER 13 

RECORDKEEPING

The previous chapter discussed the importance of implementing protocols to prevent 

contamination and commingling after harvest. In order to verify that the protocols 

are followed, they must be documented as part of the recordkeeping requirements 

for organic operations. Each organic farm receives a visit from an inspector only once a 

year. The records verify that the protocols have been followed throughout the remainder of 

the year. The inspector reviews records as evidence that the farm practices are being carried out according to the Organic System Plan. Thus, the records are essential for ensuring 

organic integrity because they demonstrate compliance with organic standards. 

The actual amount of documentation the individual producer will need in order to comply 

with organic regulations will depend on the complexity of the operation. A list of the types 

of documents kept by organic farmers is provided at the end of this chapter. Although the 

list may appear to be rather lengthy, many of these records are the same ones kept by any 

farmer, such as records of planting, fertilizing, spraying, harvest, and sales. 

The audit trail

The records of particular importance to the organic industry are the documents necessary to 

determine the source, movement, and transfer of ownership of any organic product. These 

records, also called the audit trail, provide a paper trail that can trace the product from farm 

to table. A complete audit trail allows a product—an apple in a grocery store, for example—

to be traced back to the orchard where the apple was grown. Processed products will have 

a lot code to allow each ingredient in the product to be traced back through the processor 

and to the farmer. The audit trail for fresh produce will be simpler than that for a processed 

product, but it may still involve records kept by several operations including the grower, the 

warehouse, the packer, the distributor, and the final retail store, plus all shippers. The records 

will include harvest records, purchase invoices, sales invoices, bills of lading, and others as 

needed. Sometimes the concept of audit trail is also extended to include production records 

and inputs, which also serve to demonstrate that the producer is farming organically.

Lot numbers

Lot numbers are an important aspect of a good audit trail. Lot numbers are codes assigned 

by producers to link products to the fields of origin and the year or date on which they were 

produced. Lot numbers may not be necessary for farmers who sell all produce directly to 

consumers soon after harvest, such as farmers who grow for a subscription Community Supported Agriculture (CSA) program. A lot number or other tracking system is useful for farmers who sell into wholesale markets or to processors. A good lot numbering system is logical 

and can readily be decoded. For example, Lot No. OC0603 might indicate Organic Corn, 

from bin #06, which was harvested in 2003. Lot No. B041433 might indicate Broccoli, from 

Related ATTRA 

publications

www.attra.ncat.org

Organic Market Farm 

Documentation Forms 

Organic Field Crops 

Documentation Forms 

Organic Orchard, 

Vineyard, and Berry Crop 

Documentation Forms 

Forms, Documents, 

and Sample Letters for 

Organic Producers 

§ 205.103 Recordkeeping by certified operations

Certified operators must maintain records concerning the production, 

harvesting, and handling of organic products. The records must:

•	 Be well adapted to the business being conducted

•	 Disclose all activities and transactions in adequate detail

•	 Be maintained for not less than 5 years beyond their creation

•	 Be sufficient to demonstrate compliance with Federal regulations

Records must also be available for inspection and copying during normal business hours 

by authorized representatives of the certifying agent.
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 55

field 04, harvested on the Julian day 143 (May 23), in the year 2003. In the Julian Date Calendar, each day is assigned a number in sequence from 001 through 365 (366 in leap years). The 

Julian system is commonly used for product coding. 

Types of records

Correspondence

•	 Organic System Plan sent to certifier

•	 Application materials sent to certifier (map, affidavit, record of sales, etc.)

•	 Notices to neighbors, county road maintenance authorities, utilities, and others 

that demonstrate efforts protect organic fields from spray drift

•	 Correspondence from your certifier

•	 Correspondence to your certifier, addressing corrective actions to address any 

compliance issues

•	 Complaint log

Land

•	 Maps, with field names 

•	 Field history sheets 

Seeds and Planting Stock

•	 Verification of the organic status of seeds, seedlings, transplants

•	 Invoices to verify purchase of organic seeds and stock

•	 Documentation of efforts to procure organic seeds and planting stock when 

nonorganic materials have been used

•	 Verification of non-GMO status of nonorganic inputs

Production

•	 Planting records

•	 Material application records

•	 Soil tests

•	 Activity records with dates of field operations

•	 Labels from fertilizers

•	 Labels from pest control materials

•	 Invoices for purchased materials

Harvest and Storage

•	 Harvest equipment cleanout logs 

•	 Storage unit cleanout logs

•	 Storage records

•	 Harvest and yield records

•	 Packout records

Transportation and Sale

•	 Clean truck affidavits

•	 Sales invoices

•	 Sales records

•	 Outgoing bills of lading

•	 Weigh tags
Page 56 www.ams.usda.gov/nop Guide for Organic Crop Producers

Questions 

•	 Can your records be easily understood and audited? 

•	 Are you maintaining a complete set of operation records covering the production, 

harvesting, and handling of all of your organic crops?

•	 Are sales records maintained to ensure a complete audit trail?

•	 Does your lot-numbering system permit accurate tracking of products from 

harvest through storage and marketing?

•	 Do you retain all records applicable to your operation for at least 5 years?

Notes 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 57

CHAPTER 14 

STRUCTURAL PEST MANAGEMENT

The previous chapters of this guide have focused on the contamination of organic 

crops that can occur when materials are applied to crops in the field. The possibility 

of contamination also exists if crops or soil come in contact with treated lumber used 

as part of a trellis system, a raised bed, or structural support in a greenhouse. Crops may 

also be contaminated or commingled if they are kept in storage after harvest. This chapter 

explains regulations on treated lumber, storage facilities, and pest control inside buildings. 

Lumber has many uses on a farm: trellises, fences, tomato stakes, the sides of raised beds, 

and structural support in greenhouses. The usefulness of lumber can be limited because 

pines and other common tree species will quickly decay when exposed to soil and humidity. Conventional farmers often use lumber treated with arsenate or other fungicides, which 

prevents or slows the natural decay of wood. These fungicides are highly toxic and they can 

leach into soil where they remain for a long time. For this reason, the NOP prohibits organic 

farmers from installing treated lumber in places where it can contaminate soil or contact 

livestock. The prohibition applies to new and replacement installations—treated wood on 

existing structures will not need to be replaced unless the certifier identifies a clear hazard. 

Treated lumber is also harmful to humans. It is recommended that farmers wear a dust mask 

as they cut treated lumber to avoid breathing the sawdust laden with arsenic.

Treated lumber may be used in circumstances and in ways that ensure that contamination 

cannot and will not occur. For example, trellises can be installed outside the perimeter of 

the organic site, far enough away from the organic crop to avoid contamination. The distance will need to be approved by the certifier. Treated wood can be used in the base of a 

greenhouse, where plants are grown above ground on benches. 

There are several alternatives to treated lumber. Alternative structural materials, such as 

metal posts, can be used for trellises. Tree species that resist decay, such as cedar or black 

locust, can be used for fence posts. There are also some natural treatments that can help 

prevent wood decay, although they are not as effective as arsenic treatments. 

Structural pest management

This section on pest control applies to any buildings where organic product is stored or handled, such as grain bins, cold rooms, freezers, warehouses, packing sheds, and farm stands. 

When food is stored, there is the possibility that it may become contaminated by insects, 

rodents, or other pests. As explained in Chapter 8 “Managing Pests, Weeds, and Diseases,” 

a multi-level hierarchical approach is required when dealing with pests. The first three levels, A, B, and C, are analogous to those discussed previously to manage pests on crops in 

Related ATTRA 

publications

www.attra.ncat.org

Pressure-Treated Wood: 

Organic and Natural 

Alternatives

§ 205.206 (f). The producer must not use lumber treated with arsenate or 

other prohibited materials for new installations or replacement purposes in 

contact with soil or livestock.

§ 205.271 Facility pest management practice standard

The facilities where organic products are stored must use management 

practices to prevent pests.
Page 58 www.ams.usda.gov/nop Guide for Organic Crop Producers

the field. The fourth level, D, is available for use inside and around the outside perimeter of 

buildings if the organic products can be protected from contamination. 

Level A

The first line of defense is prevention. Exclusion of pests from the facility saves time and 

money by reducing the need for further pest control. To prevent pests from entering a storage building, use screens on windows, keep doors closed, and ensure that doors are wellsealed when they are closed. If crops such as alfalfa are stored in an open barn, be sure 

they are covered to avoid contamination from bird droppings. Removing food sources will 

prevent pest populations from increasing. This may include sweeping up spilled grains and 

ensuring that food left in a lunch room is in sealed containers. Managing the environment 

so that it is unfavorable for pests will also prevent outbreaks. The area outside the facility 

should be kept clear so there are no places for rodents to hide. Inside the storage rooms, 

bins and boxes should be kept at least 12 inches from the walls. This will allow traps to be 

set for rodents, which like to run next to walls. 

Level B

The second line of defense is the use of mechanical and physical controls. Level B practices 

include insect lights that attract and kill insects and mechanical rodent traps baited with 

food, such as cheese. Baits that kill rodents or insects are Level C practices.

Level C

The third line of defense, Level C, is to be used only after A and B control options are 

applied. Level C practices include the use of materials on the National List, section § 

205.601. Examples include vitamin D3 bait to kill rodents, and diatomaceous earth placed 

in grain bins to kill insects. If any pest-control materials are used, application records must 

be maintained. 

Level D

The fourth line of defense, Level D, may only be considered if pest control actions A, B, 

and C do not adequately prevent or control facility pests. Level D practices include the use 

of synthetic insecticides or rodenticides not on the National List. These substances, which 

are prohibited for most uses in organic agriculture, may be used only as a last resort. Use 

of prohibited pest control materials must be approved by the certifier. Before approving a 

Level D application, the certifier will verify that Level A, B, and C pest control actions have 

already been employed. The certifier will review the substance to be applied, the method of 

application, and the measures to be taken to prevent contact with organic products. 

If use of a prohibited pesticide is required by Federal, State, or local laws or regulations, 

notify your certifier and agree on a plan to ensure that measures are taken to prevent contamination of organic products. If your certifier has agreed to the practice, it will not compromise your organic status. 

Storage buildings

Just as every field where organic crops are grown must be inspected annually, every building where organic crops are stored must be inspected annually. All buildings where organic 

crops are handled or stored must be listed on your organic system plan. Examples include 

seed cleaning, potato washing, or controlled-atmosphere apple warehouses. These areas 

must be under your control, or else they must have their own organic certification, if there 

is any chance that organic integrity could be compromised while the product is in the storage or handling facility. Retail stores and other operations that have products packaged in 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 59

sealed retail containers do not need to be inspected or certified because there is no danger 

of contamination, and some retail stores are exempt or excluded from the requirement of 

certification according to § 205.101.

Records of crop storage will vary depending on the type of crops and length of storage. 

Vegetables kept in a cold room for a few days typically do not require complex storage 

records. On the other hand, grain bins where a large volume of grain is stored for a long 

period of time will require more detailed records. 

Records for grain storage may include: 

•	 Bin capacity

•	 Status of crop (organic, conventional)

•	 Name of crop (wheat, corn)

•	 Date of harvest

•	 Source of crop (field identification)

•	 Amounts of grain added or removed

•	 Dates on which grain was added or removed

•	 Cleanout dates

•	 Dates when pest control treatments were applied

If storage rooms include both organic and conventional products, the organic products 

should be stored in a manner that reduces the possibility of contamination or commingling 

with conventional products. Areas where organic product is stored must be clearly labeled. 

Organic products should always be stored on the upper shelves and conventional products 

stored on the lower shelves. Storing organic products on upper shelves reduces the chances 

of commingling. For example, an organic apple falling into a conventional lot means the 

loss of organic status and price premium for a single apple. A conventional apple falling 

into an organic lot is a violation of organic integrity and results in the loss of organic status 

and premium for the entire lot. Storing organic products on higher shelves also reduces the 

chances of contamination from pesticide residues and other prohibited materials. 

Questions

•	 Are all pest-control products allowed for organic use?

•	 If you were obliged to use a synthetic pest-control material, did you obtain 

approval from your certifier? 

•	 If you have used pest-control materials in buildings, are pesticide-use records 

maintained?

•	 Are grain storage bins sealed to prevent infestation by rodents, birds, and pest animals?

•	 Is each storage container or shelf clearly labeled “organic” or “conventional”? 

•	 Are cleanout protocols established after storage of conventional crops?

•	 Where both conventional and organic produce is stored, are the storage areas 

clearly marked and segregated from each other?

•	 Are prohibited materials (for example, fuels, pesticides, etc.) stored well away from 

organic crop storage areas?

•	 If pest-control products are used, is their use recorded in a pest-control log?
Page 60 www.ams.usda.gov/nop Guide for Organic Crop Producers

Questions 

•	 If a pest-control company is contracted to manage pest control, has it been notified 

that it must comply with organic standards? 

•	 Are storage facilities large enough to segregate organic and conventional crops as 

needed?

•	 If crops are stored off-farm, are the off-farm storage units either certified organic 

or included in your farm’s inspection and certification?

•	 Are fence posts constructed of approved materials or located where they cannot 

contaminate organic crops?

•	 Are trellis posts constructed of approved materials?

Notes 
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 61

CHAPTER 15

RESOURCES

The information presented in this chapter is intended as a helpful reference. It is for 

information purposes only and inclusion in this list does not constitute endorsement 

by USDA. It is the user’s responsibility to verify the accuracy of any information. 

The following resources provide information on organic regulations, the organic products 

industry, and food-safety regulations. This list is not intended to be exhaustive. There are 

many additional resources available, notably in the areas of business management or 

government programs for small business.

Acres USA

www.acresusa.com

Acres USA publishes a national magazine that offers a comprehensive guide to sustainable 

agriculture. It also sponsors a conference and distributes books and videos on alternative 

agriculture.

Alternative Farming Systems Information Center (AFSIC) 

http://afsic.nal.usda.gov

AFSIC is part of the USDA National Agricultural Library (NAL). AFSIC focuses on topics 

related to sustainable and alternative agricultural systems, crops and livestock, and implementing the NAL mission of “advancing access to global information for agriculture.” Such systems 

include sustainable, low-input, regenerative, biodynamic, and organic farming and gardening.

ATTRA

www.attra.ncat.org

ATTRA–National Sustainable Agriculture Information Service is managed by the National 

Center for Appropriate Technology (NCAT). ATTRA has produced more than 300 publications on a variety of sustainable agriculture topics, as well as a number of webinars and 

other resources. 

eOrganic

www.eorganic.info

The goal of eOrganic is to foster a national organic research and outreach community and to disseminate information about organic farming practices and regulations. 

eOrganic provides information to the agriculture community in the form of articles, 

videos, and webinars. Its resources are part of the Cooperative Extension System, called 

eXtension (www.extension.org/organic_production). 

National Sustainable Agriculture Coalition (NSAC) 

www.sustainableagriculture.net

NSAC is an alliance of grassroots organizations that advocates for Federal policy reform to 

advance the sustainability of agriculture, food systems, and natural resources. Its Web site 

has current information about the Farm Bill and other legislation that will impact organic 

farmers. NSAC publishes several documents that explain Federal programs, food safety, and 

public policy that affects agriculture. One recent publication is the “Farmer’s Guide to the 

Conservation Stewardship Program,” which can be found at www.sustainableagriculture.net/

wp-content/uploads/2011/09/NSAC-Farmers-Guide-to-CSP-2011.pdf. The complete publications list can be found at www.sustainableagriculture.net/publications.
Page 62 www.ams.usda.gov/nop Guide for Organic Crop Producers

Natural Resource, Agriculture, and Engineering Service (NRAES)

www.nraes.org

The NRAES publishes practical books on agriculture and related subjects. One example is 

the book “Crop Rotation on Organic Farms: A Planning Manual.”

Organic Farming Research Foundation (OFRF)

www.ofrf.org

The OFRF sponsors grants for research in organic farming, offers free publications on its 

Web site, and educates the public about the importance of organic agriculture.

Organic Materials Review Institute (OMRI)

www.omri.org

OMRI provides an independent review of products intended for use in organic agriculture 

and processing. The OMRI list of allowed products can be found on its Web site. 

Organic Seed Alliance (OSA)

www.seedalliance.org

The OSA conducts research on organic seed production and hosts the Organic Seed Growers Conference each year. Its Web site includes a list of seed companies that sell organic seed.

Organic Trade Association (OTA)

www.ota.com

The OTA is a business association geared to wholesaling organic products in North America. 

OTA maintains “The Organic Pages,” a directory of suppliers of organic products, at www.

theorganicpages.com. It also maintains a Web site, www.HowToGoOrganic.com, that offers 

information on the transition from conventional to organic farming and processing. 

Rodale Institute

www.rodaleinstitute.org

Rodale Institute conducts research on its organic farm in southeast Pennsylvania. The 

institute publishes ”New Farm” magazine, offers a free online course in organic farming, 

and has an information-packed Web site. Two areas of special interest to organic farmers 

are the guide to organic certifiers at www.rodaleinstitute.org/certifier_directory and the 

organic system plan tool at www.tritrainingcenter.org/code/osp_index.php. 

Sustainable Agriculture Research and Education (SARE)

www.sare.org

SARE promotes research and education to improve profitability and sustainability of 

farms. SARE’s learning center contains books, videos, online courses, and fact sheets. The 

publications are typically national in scope and provide a thorough review of the subject. 

SARE also provides grants to farmers, researchers, and extension personnel to conduct onfarm research. 

The Soil and Health Library 

www.soilandhealth.org

This is a free, electronically accessible public library offering a collection of books on 

holistic agriculture. Many titles are out of print. It is an excellent place to find classic 

organic farming texts by pioneers from the early and mid 1900s.
Guide for Organic Crop Producers www.ams.usda.gov/nop Page 63

USDA Cooperative Extension System

www.csrees.usda.gov/Extension

The Cooperative Extension System is a nationwide, noncredit educational network. 

Each U.S. State and territory has a State office at its land-grant university and a network 

of county offices to provide information related to local issues. 

USDA National Organic Program (NOP)

www.ams.usda.gov/nop

The mission of the NOP is to ensure the integrity of USDA organic products in 

the United States and throughout the world. The NOP implements the Organic Foods 

Production Act. Its Web site has a link to the electronic Code of Federal Regulations 

applicable to organic production and handling, a list of accredited certification agencies, 

a list of all certified organic operations, and a wealth of other information. The Program 

Handbook, which can be downloaded from the Web site, provides guidance to assist in 

complying with NOP regulations.

USDA Natural Resources Conservation Service (NRCS)

www.nrcs.usda.gov

The NRCS provides technical assistance, through its employees or through Technical Service Providers (TSPs), to enhance soil- and water-conservation efforts on the farm. TSPs 

have technical expertise in conservation planning and design for a variety of conservation 

activities. TSPs are hired by farmers to provide these services on behalf of the NRCS.

Washington State Department of Agriculture (WSDA)

www.agr.wa.gov/FoodAnimal/Organic/MaterialsLists.aspx

The WSDA Organic Food Program reviews materials allowed in organic production 

and publishes the WSDA Materials List on the Web. 

Publications

Farmers’ Guide to the Conservation Stewardship Program, www.sustainableagriculture.

net/wp-content/uploads/2011/09/NSAC-Farmers-Guide-to-CSP-2011.pdf

Building Soils for Better Crops, www.sare.org/publications/soils.htm
The U.S. Department of Agriculture (USDA) prohibits discrimination against its customers. If you believe you experienced discrimination when 

obtaining services from USDA, participating in a USDA program, or participating in a program that receives financial assistance from USDA, 

you may file a complaint with USDA. Information about how to file a discrimination complaint is available from the Office of the Assistant 

Secretary for Civil Rights.

To file a complaint of discrimination, complete, sign and mail a program discrimination complaint form, available at any USDA office location 

or online at www.ascr.usda.gov, or write to: USDA, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, S.W., 

Washington, D.C. 20250-9410.

Or call toll free at (866) 632-9992 (voice) to obtain additional information, the appropriate office or to request documents. Individuals who are 

deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay service at (800) 877-8339 or (800) 845-6136 (in 

Spanish). USDA is an equal opportunity provider, employer and lender.

Persons with disabilities who require alternative means for communication of program information (e.g., Braille, large print, audiotape, etc.) 

should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). 

Page 64 www.ams.usda.gov/nop Guide for Organic Crop Producers

For more information, please contact the 

USDA National Organic Program:

 National Organic Program

Agricultural Marketing Service

U.S. Department of Agriculture

1400 Independence Avenue, SW

Stop 0268, Room 2648-S

Washington, DC 20250-0268

Tel. 202-720-3252

Fax 202-205-7808

www.ams.usda.gov/NOP

This publication is available online at:

www.attra.ncat.org

or by calling NCAT’s ATTRA project: 800-346-9140

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