1.8 Recordkeeping
Section 1: Application and General Information
Notifications
NOP 205.2 ‘Audit Trail’ is defined as “Documentation that is sufficient to determine the source, transfer of ownership, and transportation of any agricultural product labeled as “100 percent organic,” the organic ingredients of any agricultural product labeled as “organic” or “made with organic (specified ingredients)” or the organic ingredients of any agricultural product containing less than 70 percent organic ingredients identified as organic in an ingredients statement."
Guidance and Additional Regulations
(a) A certified operation must maintain records concerning the production, harvesting, and handling of agricultural products that are or that are intended to be sold, labeled, or represented as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s)).” (b) Such records must: (1) Be adapted to the particular business that the certified operation is conducting; (2) Fully disclose all activities and transactions of the certified operation in sufficient detail as to be readily understood and audited; (3) Be maintained for not less than 5 years beyond their creation; and (4) Be sufficient to demonstrate compliance with the Act and the regulations in this part. (c) The certified operation must make such records available for inspection and copying during normal business hours by authorized representatives of the Secretary, the applicable State program's governing State official, and the certifying agent.
Resources and Links
Latest Updates
Added questions related to audit trail documentation - SOE requires audit trail documentation to identify product as 'organic'
Worksheet Questions
Describe your organic recordkeeping system including how your operation maintains transaction records and audit trails.
Check all records that are maintained by your operation. Then below, complete all questions that apply to your operation.
Cleaning & Sanitation Records
Pest Control Records
Sales Records
Shipping Records
Storage Records
Internal Organic Management Review Records
Transportation records
Container cleaning records
Do you grow crops or maintain, including reseed, pasture/outdoor access areas?Fungi and mushrooms, except those harvested as wild crops, are considered crops at this time.
What types of CROP PRODUCTION records do you use in your organic recordkeeping system? Check all that apply.
Field maps
Field history sheets
Field input logs
Input labels/SDS
Input purchase receipts
Organic seed search records
Seed purchase records and labels
Planting and production records
Harvest records
Crop yield records
Crop inventory and storage records
Soil test records including analysis
Water test records
Insect and crop pest monitoring records
Truck cleanout records
Product Labels and approval records
Other
Do you raise livestock, including bees or other non-plant life? Crickets and snails are "other nonplant life". Fish and other aquaticanimals cannot be certifiedorganic to the NOP standard at this time.
Do you handle ingredients and/or products?
Do you harvest wild crops?
Do you use a lot numbering system?
Product Identification
Does your operation maintain records of activities that span the time of purchase or acquisition through production to sale and transport?
Do all records trace back to the last certified operation in the supply chain?
Are all certified agricultural products identified as ‘organic’ on audit trail records produced by this operation?