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Audit Trail Requirements

The  record keeping/audit trail components of an organic farm are often the most difficult requirements for a certified organic farmer to maintain.  Get your audit trail in place and save yourself time, money and later frustrations
Why do I need to develop an audit trail?
Your audit trail permits you or anyone else to trace a certified product from the planted seed to the market shelf.  It is a cornerstone of our guarantee to the consumer, and it protects you from liability for someone else's errors.  Developing these records and maintaining them over the years is required for certification and is an integral part of organic management.  These records can help you understand your operation, from markets, to the varying microclimates, and to soil conditions on your farm.  Having these records in place will also reduce the length and cost of your annual inspection, as well as reduce the time the office and the Certification Review Committee spend on your file, thus keeping costs down for all members.   Please read through the following information, create all records that apply to your operation and call the office with any questions you may have.
Making your audit trail simple
We recommend that you locate a three-ring binder in which to organize all records, documents and office correspondences.  Three holes punched in your documents will allow you to keep them in your binder or a pocket in your binder.  Purchase three-ring binder pockets to hold loose documents such as receipts, labels, TC's, certificates, etc.  Be sure to include in your audit trail the following records and supporting documents (the first 10 items are generated by you):
  1. Farm Plan/Livestock Questionnaire(s), and any supplemental questionnaires for specialty crops
  2. Field Histories (3-year)
  3. Field maps
  4. Input records-Receipts, labels, ingredient lists for (seeds, fertilizers, insecticides, herbicides, soil builders, soil mixes, feed supplements, livestock medications/treatments, etc.)
  5. Purchased feed: TC's, invoices, copies of sellers current certificate, as applicable
  6. Storage records
  7. Lot number system
  8. Sales records
  9. Water test results
  10. Prior Land Use Declaration (PLUD) for land that has been managed by you for less than 3 years
  11. Inspection Reports
  12. Certification Determination Letters
  13. Certificates
  14. Communication with the MOSA office concerning certification
Where do I start?
Before filling out your application be sure to have the following audit Trail details in place.  It is much easier to put you audit trail in place prior to certification than going back and reconstructing records and documents afterwards.
1.  Develop a map(s) with all fields' boundaries and numbers clearly labeled.  Each distinct field or pasture should be numbered or labeled.  These boundaries and numbers should remain consistent from year to year.  Indicate on your map all neighboring fields, physical buffers (trees, field roads, hedges, etc) and other features of importance (waterways, buildings, fence lines, etc.).  Buffers/boundaries must be maintained between organic crops and adjoining conventional fields to prevent contamination of organic crops.  Indicate all areas that will require a buffer with a colored pencil or highlighter.  Be sure to show on maps all fields under your management, including all conventional or transitional fields, leased or owned.
2.  Document three years of field histories on the Field/History Plan form with your application.  Indicate the field numbers used on the maps you have already developed.  List corresponding field acres, the crop grown and any inputs applied to the field (treatment).  Indicate at the top of the columns in the space provided the year to which the below information corresponds.  Be sure to include all fields you manage, including conventional and transitional ones.  Any land that has been under your management for less than three years will require a Prior Land Use Declaration (PLUD).  Please call the office if you need a PLUD to fill out.
3.  Develop a field activity log.  Field activity logs will vary greatly depending on the type of operation you are managing.  Logs should include all field and farm activities with dates and descriptions of plowings, soil preparation, plantings, cultivations, applications of fertilizers, folia feedings, pesticide applications, harvests and amounts harvested, general observations on crops, etc.  Spacious calendars or daily planners work for some producers, while others may find notebooks placed at key locations such as in each tractor or at the dinner table more accessible.  Whatever is used and wherever it is placed, the crux of this record keeping tool is that it gets used!  There's no way around it, you will need to make the effort to record the pertinent information.
Purchased Inputs
Document all products purchased for your farm operation.  Locate some type of folder or envelope in which to place all labels, receipts, Transaction Certificates, etc. for products used.  This folder should include receipts/labels for seeds, feed, fertilizers, beneficial insects, pest control products, soil mix ingredients, inoculants, supplements, livestock medications, etc.  Information on where the product is used can be written directly on the label or receipt and/or be recorded in the field activity log.  The labels or receipts should provide the supplier's name and address or a phone number.
Storage Documentation
A system must be used to document the area in which crops are stored on the farm.  All storage bins, cribs, etc. should have an identification (ID) number, letter or name.  If many different crops are being stored in bins/storage areas during the course of a season, a storage register should be used.  The storage register would list the storage ID at the top as well as your name and the area/bin's capacity.  This register would be left at the area/bin on a clipboard so that information could be added as product enters or exits the bin.  The columns on the Register would be labeled with the following headers:  Date, Product, Field Number, Product IN, Product OUT, Balance.
 Lot Number System
Develop a lot number system to use on your first year's crops and into the future.  Lot numbers assigned by you are used on your field or storage records, sales records and outgoing documents to maintain the tracking of your crop after sale.  Processors and handlers are required to maintain an audit trail of each individual farmer's incoming loads and need these farmer-assigned lot numbers to identify each delivery.  Having your delivery identified in a clear manner protects your load from being confused with another of lesser quality.
A lot number of only one number can be very confusing down the line and should be avoided.  Instead, the lot number should clearly identify the year of production, your initials, the last location of the crop (sold directly from a field or sold from a storage bin), the commodity and the date it was shipped.  If more than one load is shipped in a day, this should be indicated.  The storage and field records should identify the field or fields the crops originated from, and the shipment's lot number should be included when noting an outgoing load on the storage or field records.  The lot number should be used on all weigh tickets, bills of lading, invoices and Transaction Certificates.  An example of a lot number could be 99-JD-5-C-1114-2 or a simpler lot number may be 99-JD-C-5.  A lot number system would be a piece of paper in your records which would act as a key or explanation to your lot number.  Here is an example of a lot number system:
99 JD 5 C 1114 2
Year of Production Your Initials          Storage #5     or Field #5 Corn Shipped on Nov. 14 Load 2
Whatever lot number system you decide on must be referenced in your records and remain consistent for each sale.
Sales Records
Sales records should include receipts, bills of lading (BOL) and Transaction Certificates.  Receipts and BOL should include the date of transaction, your name or farm name and the type of crops sold.  Be sure to distinguish between organic oats and conventional oats on the receipt, (do not omit "organic" on the receipt of an organic product).  The receipt should also include the amount for which the crop sold.  You are responsible for keeping sales records on all crops grown in parallel production-the same crop grown both organically and conventionally or transitionally.  This means you must keep sales records on conventional and transitional crops as well as the organic crop.  Some producers use an Audit Control Summary Sheet with the column headers labeled:  Date, Product, O-C-T Status (Organic-Conventional-Transitional), Amount, $ Amount, Field #, Bin #, Lot #, Invoice#, BOL #, TC #, Buyer, User Fee Due and User Fee Paid.
Records for Livestock
Individual herd health records must be established for dairy cows.  An index card or page in a notebook with corresponding cow ID label is a sufficient place to record all treatments for cows including aspirin, homeopathics with dates and doses, all reproductive information and general cow comments.  These records must be in use, however small or large the herd.
Slaughter stock must have general herd health records with reproductive information and specific treatments written down when observed/administered.  Poultry operations should maintain batch records with corresponding batch number, batch information, comments, treatments, etc.
All records must be available for verification at the time of your inspection.  Failure to have these records on hand can result in non-certification or will prolong the certification process.
Below are blank audit trail forms to help you get started and information on the Transaction Certificate (TC) System:
 

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2008 Word Documents (for electronic completion)

2008 pdf Documents (for printing)

Organic Seed Search Organic Seed Search
Crop Input Inventory Crop Input Inventory
Livestock Input Inventory Livestock Input Inventory
The Transaction Certificate (TC) System The Transaction Certificate (TC) System
Transaction Certificate Authorization Transaction Certificate Authorization
MOSA Audit Control Register MOSA Audit Control Register
Prior Land Use Declaration Prior Land Use Declaration
3-Year Field History Form 3-Year Field History Form
Current Year Field Plan Current Year Field Plan
Bin Inventory Form Bin Inventory Form
Non-Organic Crop Usage Form Non-Organic Crop Usage Form
Equipment Cleaning Log Equipment Cleaning Log
Audit Control Summary Sheet Audit Control Summary Sheet
Off-Site Transportation Cleaning Affidavit Off-Site Transportation Cleaning Affidavit
Organic Land Notification Organic Land Notification
Export Arrangement Information for Japan Export Arrangement Information for Japan
Export Arrangement Request Instructions Export Arrangement Request Instructions
Off Farm Manure/Bedding Verification Letter Off Farm Manure/Bedding Verification Letter
Organic Product Profile Sheet Organic Product Profile Sheet
Producer Additional Product/Service Affidavit Producer Additional Product or Service Request
Handler Additional Product/Service Affidavit Handler Additional Product/Service Affidavit

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