Record keeping and Audit trail. Record keeping and Audit trail

Transcription

1 IOIA Manual 4.2, pages NOP Objectives: 1. Describe inspector requirements for reviewing and auditing farm record keeping systems. 2. List the elements possible in an audit trail 3. Review samples of record keeping. 4. Practice tracking and in-out balancing. IOIA 1 IOIA 2 The NOP rules do not specify any list of required documents or format for records. Refer to the Standard for requirements NOP Organic production and handling system plan requirements Certifiers generally do not specify any certain format for most audit trail records IOIA 3 Review: What is required? (a) Must maintain records concerning production, harvesting and handling (b)(1) Be adapted to operation (b)(2) Afford full disclosure, be understandable, and be auditable (b)(3) Be kept for 5 years (b)(4) Demonstrate compliance. (c) Be available. IOIA 4 What does this mean? The record keeping system needs to achieve the following results: enable effective input tracking enable accurate output tracking document handling practices that meet the descriptions in the farm s OSP ( ) especially those pertaining to organic control points IOIA 5 Elements of the Crop Audit Trail 1. Farm and Field Maps 2. Field History Sheets 8. Labeling 9. Additional Records 10. Lot number system IOIA 6 IOIA 1

2 and (often the same document) What the Activity Log Shows: A detailed account of actual production practices: (who, what, when, where) crops and/or varieties planted and dates dates and types of tillage, cultivations inputs used, dates and rates of application harvest dates/yields storage locations compost and manure management IOIA 7 Might also show: equipment cleaning weather conditions problems and/or successes noted custom services Types of Records Vary Widely In Format and Complexity Directly on Field history sheets, field/pocket notebooks, journals, calendars, maps, or computer spreadsheets, greenhouse clipboards, etc. IOIA 8 How the Inspector Uses Activity Logs The inspector reviews the activity log to verify planned field history sheets and inputs used. An activity log often shows compliance with monitoring activities. (weed and disease observations, etc) IOIA 9 Detail of purchases and uses of off-farm and farm-generated inputs. Information includes: Application Records: inputs used field # application rate and date may also show source, name of applicator Purchase Records Receipts and Labels should match the OSP and Field History Information may be recorded on an activity log or field history sheet described above, or on a specific input record sheet IOIA 10 How the Inspector Uses Input Records: Verify inputs and production practices. Look for receipts, analysis statements. Report any use of prohibited, restricted, and/or questionable products. Obtain copies of input labels or take notes on the inputs used to submit to the certifier. Assess if the input records and other audit trail documents are well organized and INPUT RECORD This type of record is of ten used by producers who use a lot of inputs (i.e., vegetable producers) or who don't record inputs on a field history record. It may also be used for greenhouse production. To save time, assign a code to multi -ingredient inputs (soil mix recipes, spray recipes). Information on recipes and sources of inputs can be kept on the back side. Date Inputs Field # or Location Rate of Application 4/19/00 Compost ingredients garden waste, own #7: Block #1, #2 and #3 1 T/acre. horse manure, old hay and straw 5/2500 Fish emulsion starter fertilizer on tomato #7: Block #2 1 tbs/gal. transplants 7/4/00 Buckwheat planted as cover crop where peas removed #7: Block #4B 7/5/00 Bt (non-gmo) for cabbage worms on #7: Block #4A 1 tbs/gal cabbages and broccoli 7/21/00 Bt (non-gmo) for cabbage worms on #7: Block #4A 1 tbs/gal cabbages and broccoli 10/22/00 Rye planted as cover crop All accessible. IOIA 11 IOIA 12 IOIA 2

3 Must show: type of crop/product field # date harvested yield amounts. Optional: equipment clean-out methods and documentation. Harvest Records are often combined with Storage Records Harvest records may be maintained on the field history sheet, activity log, or in separate records, such as pocket notebooks, computer files, pick sheets, weight tickets, or storage/bin registers. IOIA 13 How the Inspector Uses Harvest Records: Determine if the organic products can be tracked back to Determine if yields are realistic for the operation. Verify that crops harvested are consistent with crop plans. Verify that no commingling occurs during harvesting by comparing dates of harvest on split operation. Verify that crops grown in buffer zones are harvested separately by comparing dates of buffer crop harvest with organic crop harvest. Harvest records often show equipment cleaning procedures and dates cleaned or the use of custom equipment or services. IOIA 14 a. What the Storage Record Should Show : storage unit # capacity of storage unit type of crop or product stored date of crop stored field # where harvested date and quantity in (often an estimate) date and quantity out STORAGE RECORD The storage record keeps track of crops harvested, buyer, and assigned lot number, as well as any tests done on crop sample. A simple storage record would show date crop was stored, type of crop, and field # where crop was harvested. In the example below, Jim Smith harvested 1550 bu. of organic soybeans. 800 bushels were stored in bin # bu. were stored in bin #2 with lot #JS2S00 (not shown). This record also shows the quantity out, buyer, and the date the bin was cleaned. Producer Name Jim Smith Bin # 1 Storage/Bin Capacity 1000 bu. Harvest Crop or Field # Quantity Quantity Lot # Buyer/ Bin Date Product In Out BOL # Cleaning 10/28/98 Organic #6 Grain 9/30/98 sweep 900 bu. 900 bu. JS1S98 Comm. Inc and vacuum 10/18/99 Organic #3 and #4 Grain 10/16/ bu. 850 bu. JS1S99 Comm. Inc sweep and vacuum 10/25/00 Organic #1 Grain 10/18/ bu. 800 bu. JS1S00 Comm. Inc sweep and vacuum IOIA 15 IOIA 16 b. Storage records might also J bu indicate cleaning, use of materials for pest management be accompanied by a site map showing: location of storage units; storage unit # s; capacity; and/or type. Johnson Site 1 Home Site bu. Seed Bin IOIA 17 How the Inspector Uses Storage Records: Determine if the products can be tracked back to Verify Pest Management. Verify that storage units are physically numbered and that the numbers correspond to the storage records. Verify proper clean out and that no commingling occurs for split operations. IOIA 18 IOIA 3

4 BIN NUMBERS BIN INVENTORY RECORDS IOIA 19 a. Includes: b. What they Show: invoices or receipts date of sale sales logs or summaries product sold purchase orders quantity sold Transaction Certificates name of buyer Bills of Lading lot # Farmer s Market Worksheets Weigh/scale tickets Sales will often be organized into a chronological sales summary. IOIA 20 AUDIT CONTROL SUMMARY The audit control summary is a spreadsheet of all organic production and sales activities, including the lot # assigned. For farms, it should also show how buffer crops were used or sold. It can serve as a harvest record and/or sto rage/bin record. Name Smith Organic Farm - Jim Smith Organic Certification body: # 4023G045-5 How the Inspector uses Sales Records: Date Crop/ Sold Product 11/28/98 Org. Vint 2/13/00 Org. Vint. 1/6/01 Org. Vint. Lot # Harvest $ Total Field # Bin # PO # Organic Amoun BOL # Cert. # t JS1S98 1, 2 Self bu 31, JS2S98 delivered JS1S99 1, Same JS2S bu 30, and 4 JS1S00 1, Same JS2S bu. 27, Buyer Grain Comm. Grain Comm. Grain Comm. Determine if the products can be tracked back to Determine that quantities sold as organic are consistent with the previous year s organic crop yields. Verify that lot numbers are used appropriately. Verify that products are properly designated as organic or "certified organic". IOIA 21 IOIA Product Labeling Information on label must include: type and quantity of product name and address of producer or handler Certified organic by name of ACA. Optional: Certifier s seal USDA seal 8. Labeling How the Inspector Uses Labeling Verify the OSP The inspector should obtain copies of finished product labels and/or proposed labels to submit with the inspection report, if they have not already been reviewed as part of the OSP. IOIA 23 IOIA 24 IOIA 4

5 9. Other Records: Some examples Prior Land Use Affidavits for new land Adjoining land use agreements Non-GMO verification for seed or inputs Organic Seed Non-availability documentation - pre-exemption for seed Buffer use/buffer crop sale reports Equipment cleaning logs Clean transport affidavits Additional records for split operations with nonorganic production Complaint log 10. Lot Numbers NOP Subpart A Lot: Any number of containers which contain an agricultural product of the same kind located in the same conveyance, warehouse, or packing house and which are available for inspection at the same time. Lot number (not defined in the NOP rule): A code assigned by the farmer to link products to fields of production. NOP (b) Non retail containers used to ship or store raw or processed agricultural product labeled as containing organic ingredients must display the production lot number of the product if applicable. IOIA 25 IOIA 26 Elements of a Lot Number Type of crop Field number or storage unit Year of production The lot number system must allow for tracking. Can include farmer initials for easy identification. Often use O to designate organic crops in split operations KISS: Keep it simple short as possible. IOIA 27 Examples Some sample lot numbers: B20105: B=broccoli, 201=Julian date of harvest, 05=2005 OR105-A: OR=organic rice, 10=Storage bin #10, 5=2005, A = 1 st shipment from bin JGT65: JG=Jane Goodearth, T=organic tomatoes, 6=field #, 5=2005 Is the system in use actually the one described in the plan? Is it used consistently? The inspector must understand the lot number system to track audit trails. IOIA 28 Field # or Storage Unit ID Rule of Thumb: Field numbers are used in the lot number only when crops are not stored. Storage unit numbers are used in lot numbers for crops that are stored. The storage record connects the crops sold to the field of production. IOIA 29 Exercises In groups (or individual) Use the sample OSP materials for Traceability EXAMPLES Balance or IN-OUT Worksheets IOIA 30 IOIA 5