Question of the Week
Answer: Thank you for contacting ATTRA for information about achieving recognition of your fertilizer products as allowed for use in organic production. I state it that way, because input materials are not actually “certified”, but rather may be recognized as being allowed for use in organic production. Often that recognition takes the form of being included on a list of allowed products that is recognized by the USDA accredited certifiers that have responsibility for verifying compliance of organic producers’ practices with National Organic Program (NOP) regulations.
Two commonly used lists are the Organic Materials Review Institute (OMRI) see http://www.omri.org/suppliers and Washington State Department of Agriculture (WSDA). http://agr.wa.gov/FoodAnimal/Organic/MaterialsLists.aspx
Application forms are available on line, and both have frequently asked questions sections.
I understand that the Environmental Protection Agency (EPA) also has a process (see http://www.epa.gov/oecaagct/torg.html#Guidance%20for%20Labeling for evaluating and labeling EPA-registered pesticides, but I believe this program applies only to pesticide materials that have an EPA registration number, and not to fertilizer materials, which do not.
It is important for you to know that a material need not be listed on either the OMRI or WSDA lists to be recognized by a certifier as allowed for use in organic production. Producers wishing to use products as inputs must list them in their Organic System Plan (OSP) that is submitted to their certifier, and the certifier must approve it for the intended use. As the manufacturer, you can offer clear information to producers who wish to use your product, and to their certifiers. If they have adequate documentation about the material, they can make a determination about whether the material is allowable.
With that said, both the OMRI and WSDA lists are widely used by producers and accepted by many USDA accredited organic certifiers. Producers often learn about products from these lists, and can have confidence in listing a product on their OSP when it appears on one of these lists. As an organic inspector, I rely on these lists every time I do an inspection, and consider them invaluable to the certification process. You may consider whether this visibility and level of confidence is worthwhile to you.
Both organizations charge for their services, and both must do a careful review of the material before they list it as allowed. As I understand it, that process involves several steps. After receiving an application, they review it for completeness and potential for eligibility with organic standards. In most if not all cases, they arrange for an on-site inspection, then review the report and any sample results from that visit. All these things require time. They have to get it right, because many organic producers and certifiers rely on the veracity of this information. If a material is not listed on one of these two lists, then a certifier must do its own due diligence to verify allowability.
What you can do to make sure that this process of evaluation proceeds as quickly and efficiently as possible is to fill out the application and accompanying documentation carefully and completely. You will want to be familiar with the National Organic Program regulations on materials. See the Electronic Code of Federal Regulations (eCFR) (Standards) to open the electronic copy of the federal code of regulations.
If the reviewer comes back to you with any requests for further information, you can respond promptly with any clarification or additional information. If timing is critical, or you wish to have your materials listed by some certain date, you will want to ask about the timing of their review process, and inquire whether either organization offers expedited processing for an additional fee.
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