Observations of an Inspector

Wow, I just finished my third season of organic farm inspections and am mostly impressed with the 61 farms I visited this summer.
Here are my observations and take-aways from my work, with the caveat that I am unable identify clients due to the confidentiality agreement between inspector, producer and certifier.
My inspection list included farms in Wisconsin, Iowa and Illinois. There were 27 farms with livestock (18 dairy cattle, six beef, and three goat milk), 18 strictly crop farms (including four produce and one maple syrup), and 16 poultry operations.
The story of the year of course was a blistering drought that had set in by Memorial Day and didn’t break until the Fourth of July, or even Labor Day for some.
I remember Amish farmers in the Kalona, Iowa area scrambling to find moisture to plant corn into the weekend before Memorial Day.
They say innovation is the mother of invention and that was never truer than the farmer who had set the row cleaners to the lowest setting, making a trench for the planting unit, and also placed tractor weights where the insecticide boxes were originally mounted to force seed even deeper. Sure enough with a little luck and timely rain, the field looked fabulous when I returned to the area in August.
There was still plenty of hardship to go around, however, as farms that missed those early July rains would fall into the category of crop failure. And a handful of dairies had to curtail grazing after pastures became void of vegetation.
One lesson for the future here is to be sure to notify your certifier if pasture dry matter intake drops below the 30% threshold. Certifiers will likely grant waivers in these instances, but if the inspector shows up and cows (or goats) are not on pasture, you will likely get hit with a non-compliance.
While the drought was a huge challenge for almost every farmer, it was surprising to see later in the season how good the majority of the organic crops looked once the rains came. It bolsters what I had heard and seen in the past. Organic systems seek to be more resilient than conventional ones.
Most surprising were the two farmers who grow both organic and conventional crops pretty much side-by-side who remarked that their organic soybeans would likely equal or exceed the yield of the conventional beans. This is an important observation for an inspector to document due to the risk parallel production poses to organic integrity. Next year’s inspector will need to take a deep dive into harvest records to confirm no co-mingling has occurred.
For me personally it was great to see how many organic farmers are reaching such a high level of production. Nowhere was that more apparent than in Amish communities in Iowa where soybean yields are consistently in the 60s and corn in the 180s.
Beans are a relatively new crop for the Amish with harvest methods having been the biggest hindrance. Some communities allow using custom combining (with guidance and yield monitors no less), but others cut beans with the same binder they use to harvest oats and the beans are immediately run through a thresher and loaded for market.
Corn is picked, stored in ear corn cribs, and shelled and sold in the spring. I asked one of them why he was storing the cobs in a round crib. “I use those to heat the house,” he said. Some have also found a specialty market for organic cobs and insisted I list them in their product profile.
I have been around the Amish a good deal of my life and always wondered why they seemed to be born with a green thumb. I thought more about that this summer than I ever have before and wondered out loud what we can learn from them.
There is something to be said about developing a system and sticking to it. The Amish have been using the same farming system for generations – long before organic came into existence. The crop rotation is simple, and tillage is consistent. Moldboard plowing is at the center of their tillage system and, still, I seldom see severe erosion on these farms.
Manure is the other constant on Amish farms. Almost all have a livestock enterprise. But in the one community with no tractors there were also plenty of horses. One of the farmers with about 100 tillable acres told me he had close to 20 of the big draft horses which could be expected to produce close to a ton of manure per day!
I would have to say these farms also tend to be using more and more of the biologicals such as compost tea. It appears there is a benefit in bolstering the microbial makeup of the soil – especially when manure and crop residues are plentiful.
On the larger non-Amish grain farms, it appears chicken manure pellets are becoming more available again. Shortages the past few years were driven by high demand from conventional farmers and the bird flu shrinking layer flocks. Fewer birds mean less poop.
Some, but not all, mainstream organic grain farmers also seem to be making progress in reducing weed pressure.
They have a new weapon in the war against giant ragweed. It’s the weed zapper. I’ve only seen very mixed results in the past, but this year was different. It may be improved machines or better operators, but in one case it actually looked like the field had been sprayed. Now I’m wondering if we might need to require some kind of verification that a zapper was used.
A farmer in Illinois told me he plans on building a self-propelled zapper this winter as he has had many requests for custom work next season, some even coming from conventional farmers with herbicide resistant ragweed.
In the livestock sector, a major focus is the new Origin of Livestock rule aimed at eliminating the practice of perpetual “transitioning” replacement animals. Fortunately, more times than not I was able to breathe a sigh of relief when farmers answered the OOL question with “all animals on my farm were born on the farm to organic mothers.”
Transitioning or purchasing animals as replacements will trigger a thorough review of sales records to show animal ID was maintained. Most livestock operations I inspected still struggled with ID issues –mostly animals losing tags. Add in problems sourcing replacement tags post Covid, and animal ID is a serious challenge for certifiers.
The beef herds have an added challenge in tagging their calves. I have personal knowledge of the danger in handling a new-born calf with their protective mamma watching and listening nearby. I give these operations a little leeway by listing cow/calf pairs until the offspring are weaned and have been tagged. Each calf will eventually have to have a dam listed on the animal ID list.
The animal ID issue is also central if/when an animal is sold for organic slaughter. The farm ID and whatever ID (usually a sticky back tag the buyer uses to track the animal through slaughter) has to be included in the Bill of Lading or other record of sale/transfer. This is becoming more important as the demand for organic beef – mostly in the form of cull dairy cows – appears to be on the rise.
More conventional livestock outlets are becoming certified as processor/handlers for organic animals, including a number of salebarns. The demand for organic beef is a welcome development for the smaller dairy farms I inspect. In auditing organic slaughter records, I came across a receipt for an organic cull cow that sold at a live auction for $3,050. A Holstein, she weighed in at 1,709 lbs.
The one disappointment in the livestock sector is the apparent lack of pigs being certified organic. I have not seen even one farm with pigs listed in their certification in three years of inspecting. There are a number of organic farms that have pigs, but they choose not to certify them. I suppose it could be the cost of organic feed, or maybe lack of certified processors?
While I do inspect organic beef farms, it appears there could be more potential there as well. The hot market at this time is for grass-fed beef and most buyers are not insisting on organic certification as well.
From my own personal experience as a former beef producer, the single most important obstacle to organic beef certification is the issue of buffers which require double fencing and separate management of the buffer. The issue of buffers in general is a contentious issue in organic agriculture and probably worthy of an article all to its own.
Organic poultry inspections have become my specialty. After all, I started in the business before the National Organic Program and its green seal became the standard in the industry. This would have been in the late 1990s and skeptics were quick to tell me that raising poultry without the aid of antibiotics was destined to failure. But, today millions of hens, organic and cage-free, carry the no antibiotics label.
The excitement over eggs has even spread to anyone with a backyard as cities across the country now allow residents to keep a few birds as a source of fresh eggs. Farm supply stores are a flurry of activity in early spring when chicks arrive, making steel stock tanks their homes until their loving owners scoop them up along with feed and other supplies.
A note for anybody who wants to certify the farm store chicks. Unless the store provides organic, or you pick them up before feed is offered, they will not pass the rule that chickens be under the owners’ control no later than two days of age.
When it comes to commercial organic egg production, the standard today is the 20,000-bird house (about 50 x 500). There are still a few 5,000 to 10,000 bird barns and at least one I inspected has a total of 33,000 layers in two barns. Processors are all about volume and the rule of thumb is that it takes 40,000 hens to produce a semi load of eggs in one week.
Two controversial issues – synthetic methionine and outdoor access – are the dominate issues at poultry inspections.
Methionine is an essential amino acid that is normally deficient in poultry feed ingredients. Failure to supplement rations with methionine results in slower growth rates of pullets and undersized eggs in layers. The NOP negotiated a deal with the commercial poultry industry that limits methionine to 2 lbs./ton of feed over the life of the bird.
As an inspector that means I have to review pullet feed records to calculate methionine rates for those first 16 weeks of life. Then, there needs to be a review and calculation for methionine use in the layer barn – anywhere from 56 to 70 weeks. For the standard 20,000-bird layer barn, that amounts to about 40, 24-ton deliveries. The math involved is very intimidating and time consuming.
The challenge of outdoor access is that the inspector is there just one day. And the rule is just vague enough that a lot is left up to interpretation. It actually states outdoor access is to be year-round, but lists exceptions for stage of life, climate etc. The rule applies to all poultry and livestock.
I think this rule was propagated by the bucolic image of cows grazing on green grass and chickens scratching around the barnyard. But, in reality, animals just prefer to be comfortable. I expect cows to be inside the airy free stall barn on hot summer days and graze at night.
Chickens also do not like to be in direct sunlight and are prone to laying eggs outside if not properly “nest trained.” The farmer is required to provide a log of any “temporary confinement” and certifiers require I report on the condition of the access lot. There is a fine line there, however, as some require 50% vegetation, but some chicken yards I see are freshly mowed and it’s obvious (but not provable) that chickens had spent little or no time in the access area.
The key term is access, and I am comfortable with letting the animals decide if they want to go out. The free stall gate leading to the pasture should be open. The poultry barn doors as well. Basically, I would prefer to leave animal welfare decisions up to the animals.
All in all, it was a pleasurable inspection season for me. Yes, there were a few serious non-compliances that certifiers will have to deal with and there would not be a need for inspectors if every producer followed the rules. Overall, the job of organic inspector is important and rewarding. I would recommend it to anyone with agriculture knowledge looking for seasonal work.
Dean Dickel was born and raised on an Iowa grain and livestock farm and been involved in agriculture ever since, including as an ag journalist, organic egg and crop producer, and independent inspector. Dean and his wife Mary Glindinning, also a journalist, reside in historic Mineral Point.

Issue: 32-01-01
By: Dean Dickel