AMERICERT INTERNATIONAL 2603 NW 13th ST. #228, Gainesville FL Ph: ** Fax:

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1 AMERICERT INTERNATIONAL 2603 NW 13th ST. #228, Gainesville FL Ph: ** Fax: NOP Organic Grower Inspection Report Form# NOP BG4-v Page 1 of 15 Operation Name: Blueberry Hill, LLC CLIENT #: Date of Inspection: September 18, 2014 AI APPLICATION #: Inspector: Areas / Locations Inspected: Jesse Starkey 6000 Berry Groves Road Clermont, FL Operation's Primary Authorized Representatives Present: John Gray I. General Fields, Crops, and Parcel Information (Application Section II; Appendix II) Parcel Information 1. Did the operation accurately disclose in the application each parcel on which organic production will occur? 2. Did the operation accurately disclose in the application the location of each parcel on which organic production will occur? 3. Based on your observations during the inspection did the operation accurately disclose in the application the acreage, ownership status, and length of time under the operators contronl (owned, leased, or managed) for each parcel on which organic production will occur? of the previous three Field or Production Area Information 1. Did the operation accurately disclose in the application each field on which organic production will occur? 2. Did the operation accurately disclose in the application the location of each field on which organic production will occur? 3. Based on your observations during the inspection did the operation accurately disclose in the application the acreage, and date of last application of prohibited substance for each field on which organic production will occur? of the previous three

2 Page 2 of 15 Crop Information 1. Did the operation accurately disclose in the application each crop and variety for which certification is sought? 2. Did the operation accurately disclose in the application the fields where grown and the acreage planted or intended for planting for the crop? 3. Based on your observations during the inspection did the operation accurately disclose in the application whether these crops will be grown as non-organic on any parcel controlled by the operator? of the previous three **Blueberries only II. Seeds, Seedlings and Planting Stock (Application Section III; Appendix III-B) 1. Did the operation accurately disclose in the application whether or not they use non-organic seed, seedlings and planting stock? previous question is "NO" please describe fully 2. Does the operation use any non-organic seed, seedlings and planting stock? previous question is "YES" please list each non-organic seed, seedling, or planting stock used by the operator: As to question 2: Stock currently in production was planted in March, Stock/"liners" were supplied by Tavis Douglas Douglas Tree farm, Citra, FL, and have been managed organically for well over a year. Please describe the operator's attempt to source the seed, seedling, or planting stock organically and the documentation of the operator's efforts, including justification why similar organic varieties were not suitable: Please see above..

3 Page 3 of If non-organic seeds, seedlings or planting stock (annual) are used,does the operator maintain documentation that the seed, seedlings, or planting stock (annual) was produced without or is free of prohibited substances?. 4. If non-organic perennial planting stock is used, did the operator accurately describe its sourcing and use in the application?. 5. If non-organic perennial planting stock is used, did the operator accurately describe practices intended to prevent contamination or certified organic soil by prohibited substances which might be present in soil or media of containerized perennial planting stock planted on the farm?. 6. If non-organic perennial planting stock is used, does the operator have practices in place to ensure that the stock is managed organically for at least one year prior to being harvested as organic?. If the answer to any of the previous 4 7. Based on your review of the application, and your observations during the inspection, does the operator's seed, seedling, and planting stock practices appear to be sufficient to address risk of noncompliance with the NOP Seeds and planting stock practice standard in section and all other applicable sections of the NOP regulation?. previous question is "NO" please describe fully OPTIONAL COMMENTS/ NOTES ON SEEDS, SEEDLING, AND PLANTING STOCK PRACTICES USED BY THE OPERATION:

4 Page 4 of 15 III. Soil, Crop Fertility, and Nutrient Management (Application Section IV) 1. Did the operator accurately describe and disclose in its application the selected and implemented tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion? 2. Based on your observations, are the tillage and cultivation practices implemented and are they sufficient to maintain or improve the physical, chemical, and biological condition of soil and to minimize soil erosion? **Tillage between row is "as needed" (see attached Tillage Log). Tillage is between rows and includes a unique implement that "rolls" either of the previous 2 some tilled dirt next to planted rows as an additional weed control (see photographic documentation) 3. Did the operator accurately describe and disclose in its application the how the operation manages crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials? 4. Based on your observations, are the practices implemented and are they sufficient to manage crop nutrients and soil fertility? either of the previous 2 Manure Use (Application Section IV; Appendix IV-A-1) 3. Did the operator accurately describe and disclose in its application manure used in production?. 4. If the operation uses raw manure is it applied to land use for crops not intended for human consumption?. 4. If the operation uses raw manure is it Incorporated into the soil not less than 120 days prior to the harvest of a product whose edible portion has direct contact with the soil surface or soil particles?. 4. If the operation uses raw manure is it Incorporated into the soil not less than 90 days prior to the harvest of a product whose edible portion does not have direct contact with the soil surface or soil particles?. Please discuss the operation's manure use here and describe what documentation was available and reviewed which demonstrates compliance with provisions governing manure use in section (c)(1):

5 Page 5 of 15 Compost Use (Application Section IV; Appendix IV-A-2) 5. Did the operator accurately describe and disclose in its application compost in production? 6. Are adequate records of compost production maintained to demonstrate compliance with the time and temperature requirements of s (c)(2)? either of the previous 2 Please discuss the operation's compost use, the ingredients, process and documentation reviewed: Crop Rotations and Cover Crops (Application Section IV; Appendix IV-A-3) 7. Did the operator accurately describe and disclose in its application its crop rotations and cover crops used in production? Please describe and discuss the crop rotations and cover crops used in production: **Because blueberries are perennial, crop rotation (of the production crop) is not applicable in this case. As to cover crops, none are being used at this time. Areas between rows are still being actively/regularly tilled to control weeds. Additional Provisions (Application Section IV) 7. Does the operation burn crop residues or use sewage sludge or biosolids? 8.. Do any of the operator's soil, crop fertility, or nutrient management practices contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances. 8.. Do any of the operator's soil, crop fertility, or nutrient management practices fail to maintain or improve wildlife habitat and biodiversity? either of the previous 3 questions is "YES"

6 Page 6 of 15 IV. Weed, Pest, and Disease Management (Application Section V) Weed Management 1. Did the operation accurately and completely disclose its weed management practices in the application? 2. If the operation uses plastic or synthetic mulches are they removed from the field at the end of the growing season? 3. Did the operator have available records of weed management activities that record the date, locations, and description of weed management activities? 4. Was the operation free from observed indicators of prohibited weed control practices? any of the previous 4 As to question 2: This operation does uses a synthetic ground cover/landscaping cloth for weed and pest control on the planting rows. A monitoring log is kept to identify problems and replacement issues (see attached documentation). As mentioned above, this farm also uses a cultivator that "rolls" the weeds next to the planting rows into the area between, and then will be tilled into the soil. Pest Management 1. Did the operation accurately and completely disclose its pest management practices in the application? 2. Did the operator have available records of pest management activities that record the date, locations, and description of pest management activities? 3. Was the operation free from observed indicators of prohibited pest control practices? any of the previous 3 Disease Management 1. Did the operation accurately and completely disclose its disease management practices in the application? 2. Did the operator have available records of disease management activities that record the date, locations, and description of disease management activities? of the previous 2

7 Page 7 of 15 Restricted Pest, Weed, and Disease Control Practices Plan 1. Did the operation accurately and completely disclose its restricted control practices plan in the application? 2. Did the operator have available records of restricted control practices and activities that record the date, locations, and description of restricted practices? 3. Did the operator comply with the step-wise nature, preconditions for use, and all annotations and restrictions of restricted control practices? 4. Based on your inspection and observations, was the operation free from observed indicators of the use of prohibited practices for pest, weed, and disease control, and noncompliance with annotations or restrictions applicable to restricted control practices? 5. Based on your inspection and observations, was the operation free from observed indicators or evidence of the use of prohibited substances? any of the previous 5 V. Maintaining Organic Integrity (Application Section VI) Land, Field, and Crops 1. Are the borders for organic fields distinct and defined and in the manner described in the application? 2. Did the operator accurately and completely disclose the surrounding land use in the application? 3. Did the operator accurately and completely disclose and describe in the application the physical barriers, buffer zones, notifications, and other measures adopted to prevent the unintended application of prohibited substances to organic fields or contamination of organic fields from application of prohibited substances to adjoining non-organic land or fields? 4. Did the operator accurately and completely disclose and describe the use of buffer zones, the practices intended to prevent commingling of harvested buffer fruit, and the practices in place to prevent contamination of organic crops through the use of equipment in the buffer zone? 5. Did the operator accurately and completely disclose the production of non-organic crops on any parcel controlled by the operator? 6. If the operator produces non-organic crops on any parcel controlled by the operator, did the operator accurately and completely disclose and describe the practices in place to prevent contamination and commingling between organic and non-organic production? any of the previous 6 S Buffer: A 50' (East/West) buffer separates the conventional production area from the organic production area. This buffer includes a ditch that both fields drain into. Drainage water is collected in a catch pond that is in the East buffer zone. This negates the potential of conventional water runoff contaminating the organic production areas. (See photographic documentation). N Buffer: Heavily wooded area (See photographic documentation). W Buffer: 60' Grassy area, fence with pasture beyond. (See photographic documentation). East Buffer: Grass/pasture with pond and access roadway (See photographic documentation).

8 Page 8 of Based on your inspection and observations, are there any unaddressed risks to organic integrity arising from the use of buffer zones, the surrounding land use, the production of organic and non-organic crops, or practices in place to prevent contamination or commingling? previous question is "YES" please describe fully Please describe any identified risks to organic integrity related to field or land boundaries, the use of buffer zones, the surrounding land use, the production of organic and non-organic crops, or practices in place to prevent contamination or commingling: Equipment (Application Section VI; Appendix VI-B-1) 1. Did the operator accurately and completely disclose and describe the equipment use on the farm, and the practices in place to prevent contamination through equipment use? 2. Based on your inspection and observations are there any unaddressed risks of contamination that arise from equipment use on the farm? of the previous two As to question 2: The only equipment to be used for both conventional and organic use is a sprayer. Equipment cleaning SOP includes a soap & water wash and triple rinse procedure for the tank, hoses and nozzles. (See photographic documentation- SOP) All other equipment is dedicated organic. All equipment is washed after every use, and everything is washed weekly soap and water (Dawn). Equipment cleaning log to be forwarded to AI. Harvest, Transport, and Storage (Application Section VI; Appendix VI-C-1; Appendix VI-C-2; Appendix VI-C-3; Appendix VI-C-4) 1. Did the operator accurately and completely disclose and describe the harvest and transport of organic crops? 2. Did the operator accurately and completely disclose and describe the practices intended to prevent contamination and commingling in the harvest, transport, and storage of organic crops? of the previous two **Transportation was by Wish Farm (organic handler) last year. Discussions at the time of inspection indicated that plans were being considered to transport to the handler by the farm. That is, a refer trailer would be leased/rented and transported to the handler by the farm. Discussions included the need for the farm to update the OSP to reflect this new strategy.

9 Page 9 of Did the operator accurately and completely disclose and describe the harvest documentation maintained? 4. Are the harvesting, transport, and storage practices sufficient to prevent contamination and commingling? of the previous two **Harvest documentation to be forwarded to AI. 5. Are the use of packing materials, storage containers, and bins and bags compliant free of unreasonable risks of contamination of organic crops and compliant with the requirements of ? 6. Does the operator engage in any of the following (check all that apply): Repacking from harvest containers into Washing, cleaning, de-stoning, sizing of product. Transporting to buyer, processor, or market. labeled containers. Cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, extracting, slaughtering, cutting, fermenting, distilling, eviscerating, preserving, dehydrating, freezing, chilling, or otherwise manufacturing including packaging, canning, jarring, or otherwise enclosing food in a container. VI. Recordkeeping and Monitoring (Application Section VII) Records Maintained 1. Did the operator accurately and completely disclose and describe the records maintained by the operation? 2. Did the records fully disclose all activities and transactions in sufficient detail to be readily understood and audited? 3. Are the records maintained for 5 years? 4. Are the records sufficient to demonstrate compliance with the NOP regulations? 5. Did the operation make all requested records available during the inspection? 6. Were the records sufficient to trace the inputs applied back to the source of the inputs? 7. Were the records sufficient to trace products sold back to the field from which harvested? 8. Was the recordkeeping sufficient to prevent noncompliance with the NOP regulations? If the answer to any of the previous eight **All records observed/verified were accessible, clear, complete and accurate. Please list the records reviewed during the inspection: Fertility Input Tillage Weed Control Soil Test Land Management Form Harvest/Sales Equipment Cleaning Log **Farm uses the COGPRO record keeping system. More complete records were observed/verified, are are available upon request. Additionally, this farm is GAP inspected by The PrimusLabs GAP program which also requires extensive and accurate records.

10 Page 10 of 15 Monitoring 1. Did the operator accurately and completely disclose in their application the monitoring practices undertaken? 2. Are the monitoring practices sufficient to prevent unreasonable risks of noncompliance? of the previous two Planned Inputs Requested for Approval As Part of Plan 1. Did the operator accurately and completely disclose in their application the inputs to be used in the operation? 2. Did the operator comply with all restrictions or annotations for restricted products? 3. Was the operation free of evidence of the use of any input not listed in the plan? 4. Was the operation free of evidence of the use of any prohibited inputs? If the answer to any of the previous four **Labels and organic documentation attached VII. Supplemental Information from Plan Appendices Land Use Report and Affidavit: For 1st Time Certifications and New Land (Appendix II-A) 1. Is the information in the Land Use Report and Affidavit consistent with information, observations, and records reviewed during the inspection? previous question is "NO" please describe fully Greenhouse Production Plan and Report (Appendix II-G) 1. Did the operator accurately and completely disclose in their application the actual greenhouse production practices conducted? 2. Are the practices free from unreasonable risk of noncompliance? of the previous two

11 Page 11 of 15 Plan and Report for Packing and Labels (Appendix VI-C-1) 1. Did the operator accurately and completely disclose the actual postharvest packing conducted? 2. Did the operator accurately and completely disclose the final packaging of the product as it leaves the operator's possession? 3. Did you collect copies or photographs of all labels, printed packaging, and marketing materials used by the operator for forwarding to Americert? If the answer to any of the previous three As to question 3: Labeling is not a part of the post harvest procedure with this operation. Harvested product will be sent to a processor (Wish Farms) for handling. However, harvest lugs/flats will be differentiated by color and labeled "organic" (see attached photographic documentation) 4. Did you identify and potential noncompliances or unreasonable risks to compliance related to the postharvest packing or labeling? If your answer to the previous question was "YES", please describe fully Plan and Report for Light Cleaning and Processing of Crops (Appendix VI-C-2) 1. Did the operator accurately and completely disclose in their application the actual cleaning and processing of crops which are conducted? 2. Did the operator accurately and completely disclose in their application the use of sanitizers? 3. Did the operator accurately and completely disclose in their application the practices to preserve the organic integrity of crops during processing/cleaning? 4. Did the actual practices in place appear to be sufficient to prevent noncompliance? If the answer to any of the previous four **No sanitizers are used on equipment at this time; soap and water only. Plan and Report for Crop Storage (Appendix VI-C-3) 1. Did the operator accurately and completely disclose in their application the actual crop storage facilities, practices, and procedures? 2. If off-site crop storage is used, did you visit that location as part of your inspection? 3. Are the actual crop storage facilities, practices, and procedures sufficient to prevent contamination (through pest control for instance) and commingling? If the answer to any of the previous three **There is no crop storage with this operation. Harvested crop is cooled in the same trailer that it transported to the handler.

12 VIII. Recordkeeping, Traceability, and Audits A. Input Traceability Does the operation have records sufficient to allow the inputs used on specific harvest can be traced back to the source of those inputs and the date received? No If no, please explain. If yes, please test this system and describe the results NOP Organic Grower Inspection Report Form# NOP BG4-v Page 12 of 15 B. Forward Traceability Does the operation have records sufficient to allow the buyers of the product of a particular day's harvest can be identified? No If no, please explain.. If yes, please discuss the adequacy of this system: D. Mass Balance of Inputs Does the operation have records sufficient to allow a balancing of on-hand inventory of inputs, the inputs applied to fields, and the original amount of inputs purchased for a period? No If no, please explain. If yes, please describe the sufficiency of this system. E. Balance of Yield and Sales Does the operation have records sufficient to allow computation of the actual yields of crops produced and balance this against actual sales made? No If no, **A review of Yields and Sales was conducted (both conventional & organic). Organic yields wold seem low given the acreage being certified, but the please organic production planting are just three years old and have not yet reached production potential (see photographic documentation). Records explain. If appeared well within acceptable limits and expectations. (see attached documentation) yes, please describe the sufficiency of this system.

13 Page 13 of 15 F. RISK ANALYSIS AUDITS 1. Unless otherwise instructed by AI, it is within the inspector's discretion to conduct a fully audit of any of the primary record keeping systems discussed in this section ( traceability, mass balance, yield and sales ) Such an audit should be conducted when an identified deficiency in the system indicates a risk to organic integrity or the possibility of commingling, mislabeling, misrepresentation (intentional or unintentional) or the organic status of a product or ingredient. The inspector should explain their decision to audit or to not audit. Did you choose to conduct a risk analysis audit of any of the primary record keeping systems? No 2. Please explain your decision As described above, a yield/sale review was conducted, and appeared accurate and complete. Additionally, because other conventional vs. organic concerns are present with this operation, the buffer separating the two growing areas, input record, input storage and storage identification were also scrutinized. All cross contamination and commingling issues seemed well addressed. All records presented, observed and described were clear, accurate and understandable. 3. If you did conduct an audit, in the space at right, please describe the system audited, the method used, the documentat ion relied upon, and your findings. Please attach all documents in support of your findings. IX. SPECIAL INSPECTION INSTRUCTIONS FROM AMERICERT If AI issued special inspection instructions with this assignment, please use this section to address, respond, and report on how the special instructions were addressed: As to question 1: Ground Cover: Please ascertain if applicant has a policy and procedure to inspect ground cover. Policy verified and repairs noted/ observed. As to question 2:Soil Test: As to question 3: Harvest Records: Records being forwarded to AI As to question 4: Mass Balance: Records attached As to question 5: FYI-Chilean Nitrate: that being used with the understanding this prevents recognition of his product as organic under the US- Canadian Equivalency agreement. This farms product handler (Wish Farms) does not require US-Canadian Equivalency agreement. As to question 6: Labels: No labels are used. As to question 7: Non-organic Land Management Form: Updated form attached

14 Page 14 of 15 X. CONCLUSIONS AND FINDINGS 1. Did the Authorized Representatives and staff of the operation evidence an understanding of the standard? 2. Does the operation appear to be governed by a systematic plan intended to ensure compliance with the standard? 3. Does the operation appear to have effectively implemented the plan? 4. Does the operation appear to be committed to maintaining compliance with the plan and appear capable of doing so? 5. Does the operation appear to free of unreasonable risks to the integrity of the plan or compliance with the applicable standard? If you answered "No" to any of the previous 5 questions, please fully explain your answer 6. Does the operation appear to, in fact, comply with the standard? If you answered "No", please cite to specific provisions of the standard and indicate what leads you to this conclusion.. Where corrective action is possible, please describe:

15 Page 15 of 15 OPTIONAL COMMENTS OR DESCRIPTION OF SAMPLES TAKEN. XI. INSPECTOR AFFIRMATIONS Florida Law, which is the law governing this inspection and the inspector's services allows for the use of "electronic signatures." Specifically, Chapter 668 of the Florida Statutes provides that "Electronic signature" means any letters, characters, or symbols, manifested by electronic or similar means, executed or adopted by a party with an intent to authenticate a writing. A writing is electronically signed if an electronic signature is logically associated with such writing. It also provides that an "electronic signature" shall have the same force and effect as a written signature. You have the right not use "electronic signatures". Once you have used an "electronic signature" for one transaction, or one submission of your application, it does not mean that you must use "electronic signatures" in the future. You may "opt out" at any time, by submitting any document requested by AI using the "original handwritten signature" provisions included on each AI document. AI provides all official notices using "original handwritten signatures" you have the right to provide all of your official notices and submissions and communications in the same way. Submitting any document to AI using the approved AI Electronic Submissions Provisions will be deemed as consent to use and intent to be bound by such provisions for that document only. You can receive a paper copy of any documents signed by you using an "Electronic Signature" simply by asking AI in writing. AI will provide electronic copies that can be printed by you and will not charge for this. If AI prints the document and mails it to you, AI will charge 10 cents ($0.10) per page so sent. If you have any questions about this policy or the use of "Electronic Signatures" you should not use an 'Electronic Signature" but should contact AI for more information. If you agree with each of the following, please place a check mark by each provision. In order to use an "electronic signature" you must agree to each of the following provisions. If you do not want to use an "electronic signature" you may skip to the next section. I would like to sign this and future documents using an "electronic signature." I understand that I have the right to not use an "Electronic Signature" but to use an "original handwritten signature" for any document required by AI. I understand that consenting to the use of of an "Electronic Signature" in this document, does not constitute consent to use "Electronic Signatures" for any future document. I understand that I have the right to obtain a printed copy of this or any other document I have executed using an "electronic signature" from AI, using the procedure and conditions described above. I understand that an "electronic signature" is binding, valid, and has the same full legal effect of an "original handwritten signature". I agree that this document shall not be held to be unenforceable, inadmissible, or invalid on the basis that it contains an "electronic signature" rather than a "handwritten original signature". I agree that this document shall be entered into evidence in any proceeding on the basis of the stipulation that I am now giving that it is true, accurate, authentic, and was signed knowingly, voluntarily, and with full legal authority to do so on behalf of the organization or operation on whose behalf I am submitting it. I waive all evidentiary and procedural objections to its admission into evidence in any proceeding, as a condition and term of AI accepting this inspection report. Under penalties of perjury, I affirm that the observations and information in this report are accurate and truthful to the best of my knowledge, and were developed through a review of the documentation submitted and provided, and my on site observations and interviews of the operation's staff and representatives. Inspector's Name: Inspector's Signature*: Jesse Starkey Date: September 20, 2014 JStarkey912 *To use an Electronic Signature rather than an original handwritten signature, please enter the first letter of your first name, your last name and the last three digits of your social security number (e.g. JSMITH024.)