Each operator who starts organic production activity undertakes to provide the control body with all information and documents related to the organic production activity in detail and to notify any changes.

The common name of the document in which operators can present all information and documents related to their organic production activities and provide the necessary undertakings to the control body is ‘organic system plan’, shortly OSP.

Organic System Plan – OSP;

• Forms the basis for inspection and certification
• Is a living document that must be continuously updated to reflect all changes in an operation
• Must be updated and submitted to the control body before each growing season and when there are changes in the units and activities owned by the operator
• Is a forward-looking management tool that helps the operator anticipate challenges and make informed decisions
• Helps the operator better develop potential and use existing resources more efficiently
• Contributes to the operator’s budget for the next year’s expenses and income and fulfills the potential of being feasible both economically and sustainably

It is not the responsibility of the control body to train the operator on how to fill it out. To facilitate communication and prevent delays in obtaining the required information, the control body may provide operators with simple instructions on how to fill out the forms.

During completion, it is very important that the operator answers the questions of Who, When, How, and Where, and pays attention to these in the information to be provided.

The Turkish Regulation on the Principles and Implementation of Organic Agriculture, published in the Official Gazette No. 27676, does not use the definition of OSP; however, in the relevant parts of the Regulation, it clearly explains the responsibilities of operators to provide the necessary information and documents to the control body.

According to Article 42 – Responsibilities of the operator and applicable sanctions;

The operator fully defines the field of activity and informs the control body of the measures taken. The operator submits to the control body a declaration of commitment to comply with the provisions of this Regulation and the issues contained in the quality manual of the control body and to allow any kind of control. Each year in January, the operator notifies the control body of the plant production plan for that year on a parcel basis.

If the operator has part of his/her activities carried out by a third party, he/she ensures that such activities are included in the control system by providing the control body with the necessary information and documents.

According to Article 35 – Information and documents required for the inspection of the enterprise and the operator;

Operators are obliged to provide the contracted control body with all kinds of information and documents related to their organic activities and to keep them in their enterprises. These are:

1. The name, address, capacity information of the enterprise, information and documents regarding its legal status, contract date, signed contract text, the date when the transition to organic agriculture started, information on the land history up to the contract date,
2. Conversion to organic farming and production plans covering the field of activity (such as plant production, livestock) and related information,
3. The production method previously applied in the enterprise,
4. Plans of the enterprise and its buildings,
5. All plans and sketches of land parcels or areas,
6. Existing machinery and equipment inventory of the enterprise,
7. Location of the enterprise, description of the warehouses used and their suitability for the purpose,
8. Crop rotation plan,
9. Record books for all inputs to be used,
10. Procurement and sales ledgers of the enterprise’s goods, including goods purchased from outside,
11. Product output plan, product quality, stock status, quantity, packaging method and material,
12. In the case of collection of products from forest areas and nature, all definitions of the area, official permits, and all technical interventions, disasters, quarantine measures, etc. carried out in the area.

According to Article 36 – Inspection process;
The control body conducts a risk analysis of the operator’s organic farming activities based on the information and documents obtained and determines the intensity of annual announced or unannounced controls and visits by identifying critical control points. The inspection process includes the verification of the written documents, plans, ledgers, reports, records, land, enterprise, and warehouses provided by the operator in the OSP according to the Regulations. If several units are operated in the same area by the operator, the units and warehouses where non-organic products are produced are also subject to the inspection process. Therefore, the inclusion of non-organic activities in the OSP is of critical importance.

The control body may request additional information from the operator to prove compliance with the Regulations and standards.

According to European Union Organic Farming Regulation (EU) 2018/848;
The meaning and requirements of the OSP are not explicitly stated; however, the supplementing Regulation (EU) 2021/1698, which lays down the procedural requirements for the recognition of control authorities and control bodies that are competent to carry out controls on operators and groups of operators certified organic and on organic products in third countries and with rules on their supervision and the controls and other actions to be performed by those control authorities and control bodies, contains articles guiding the information, documents, and undertakings that operators and group operators are required to provide with the OSP. The OSP should be completed taking these articles into consideration.

According to Article 10-1(a) of (EU) 2021/1698, the operator and group operator must provide a document in the form of a signed declaration, setting out:

1. a description of the organic and/or in-conversion production unit and, where relevant, of the non-organic production units and of the activities to be performed in accordance with Regulation (EU) 2018/848;
2. the relevant measures to be taken at the level of the organic and/or in-conversion unit and/or premises and/or activities to ensure compliance with Regulation (EU) 2018/848;
3. the precautionary measures to be taken in order to reduce the risk of contamination by non-authorised products or substances and the cleaning measures to be taken throughout the stages of production, preparation and distribution.

According to Article 10-1(d) of (EU) 2021/1698, the operator and group operator must submit a signed undertaking by which the operators or groups of operators commit themselves:

1. to give the control authority or control body access to all parts of all production units and all premises for control purposes, as well as to the accounts and relevant supporting documents;
2. to provide the control authority or control body with any information necessary for the purposes of the controls;
3. to submit, when requested by the control authority or control body, the results of its own quality assurance programmes;
4. to inform buyers of the products in writing and without undue delay, and to exchange relevant information with the control authority or control body, in the event that a suspicion of non-compliance has been substantiated, that a suspicion of non-compliance cannot be eliminated, or that non-compliance that affects the integrity of the products in question has been established,
5. to accept the transfer of the control file in case of a change of control authority or control body or, in the case of withdrawal from organic production, the keeping of the control file for 5 years by the last control authority or control body;
6. to inform immediately the control authority or control body in the event of withdrawal from organic production;
7. in the event that the subcontractors of the operators or of groups of operators are subject to controls by different control authorities or control bodies, to accept the exchange of information among those control authorities or control bodies;
8. to perform the activities in accordance with the organic production rules;
9. to accept the enforcement of the corrective measures established by the control authority or control body in the event of non-compliances.

In the United States Department of Agriculture (USDA) National Organic Program – NOP, the meaning and requirements of the Organic System Plan are clearly explained in the relevant articles. The information provided on the OSP within the NOP Regulation is very valuable in terms of general organic production rules and compliance and is also a guide for OSPs to be prepared according to other Regulations and Standards; therefore, we believe that the information provided on the OSP under USDA-NOP should be taken into account.

NOP has also prepared a guidance document coded NOP-2615 titled Organic System Plans, Organic System Plan Updates, and Notification of Changes, in which the OSP is explained in all details.

In addition, NOP has very instructive training files on OSP supported with videos in its own training platform ‘Organic Integrity Learning Center’, and we recommend that you take these open-access trainings.

Finally, on the USDA NOP website, there are sample OSP templates, which are good guides for the information and documents that must be provided when answering the questions included in the OSP.

• 205.201 (a): The producer or handler of a production or handling operation, except as exempt under § 205.101, intending to sell, label, or represent agricultural products as “100 percent organic,” “organic,” or “made with organic” must develop an organic production or handling system plan that is agreed to by the producer or handler and an accredited certifying agent. An organic production or handling system plan must include:

1. A description of practices and procedures to be performed and maintained, including the frequency with which they will be performed;
2. A list of each substance to be used as a production or handling input, indicating its composition, source, location(s) where it will be used, and documentation of commercial availability, as applicable;
3. A description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed, to verify that the plan is effectively implemented. This must include a description of the monitoring practices and procedures to verify suppliers in the supply chain and organic status of agricultural products received, and to prevent organic fraud, as appropriate to the certified operation’s activities, scope, and complexity;
4. A description of the recordkeeping system implemented to comply with the requirements established in § 205.103;
5. A description of the management practices and physical barriers established to prevent commingling of organic and nonorganic products on a split operation and to prevent contact of organic production and handling operations and products with prohibited substances; and
6. Additional information deemed necessary by the certifying agent to evaluate compliance with the regulations.

Important note: The certifying agent assesses the risk of exempt operations in the supply chain. Generally, exemption from certification may be possible for operators under the supervision of the main company and where it is ensured that the organic integrity of the products is not affected; if necessary, the certifying agent will also inspect these activities according to the risk assessment.

Exempted activities are not entirely risk-free. To address this risk, organic system plans must also include the monitoring of exempt activities.

If activities such as dividing, combining, clustering are carried out in a way that enters into processing activity, inspection and certification will be required and the information must be presented in the OSP.

• 205.201 (c): An organic system plan for a producer group operation must describe the internal control system. The internal control system:

1. Identifies the organizational structure, roles, qualifications, and responsibilities of all personnel;
2. Identifies the producer group production units and sites;
3. Describes safeguards against potential conflicts of interest and measures to protect internal control system personnel against them;
4. Identifies geographic proximity criteria for producer group members and producer group production units;
5. Describes procedures for the admission of new members to the producer group operator, including initial inspection and determination of compliance;
6. Identifies the characteristics of high-risk producer group members and producer group production units;
7. Describes how shared common resources, including production practices and inputs, are procured and provided to all producer group members and personnel;
8. Describes how training, education, and technical assistance are provided to producer group members and internal control system personnel;
9. Identifies the record system used to demonstrate compliance with this part, including traceability and mass-balance audits; and
10. Describes how internal monitoring, oversight, control, sanctions, and inspection are used to evaluate the compliance of all producer group members.

The following other articles of the NOP Regulation refer to the requirement of the OSP:

• 205.400 General requirements for certification;
  (b) A person seeking to receive or maintain organic certification under the regulations must Establish, implement, and update annually an organic production or handling system plan that is submitted to an accredited certifying agent as provided for in § 205.201.
• 205.401 Application for certification;
  (a) A person seeking certification of a production or handling operation must apply to a certifying agent for certification, and the application must include an organic production or handling system plan, as required in § 205.201.
• 205.403 On-site inspection;
  d-(2) The practices provided by the operator, including those presented in the organic production or handling system plan, are verified during the on-site inspection to determine whether they are accurately implemented.
• 205.404 Granting certification;
  The certifying agent will grant certification if it determines that the operator is able to conduct operations in accordance with the organic system plan.
• 205.406 Continuation of certification;
  (a) To continue certification, the operator must annually pay certification fees and submit the following information to the certifying agent:

• A summary statement, supported by documentation, detailing any deviations from, changes to, modifications to, or other amendments made to the organic system plan submitted during the previous year, and
• Any additions or deletions to the previous year’s organic system plan, intended to be undertaken in the coming year, detailed pursuant to § 205.201.

The above-mentioned NOP OSP rules are further explained below, summarized article by article, from the NOP:

• 205.201 (a)/1 – Examples of descriptions of practices and procedures to be performed and maintained:

• Practices for the protection or improvement of natural resources, including biodiversity;
• Notification procedures to neighbors to prevent contamination of organic products with prohibited substances;
• Soil tillage practices;
• Cultivation practices;
• Crop rotation practices;
• Pest management practices;
• Organic seed acquisition procedures;
• Practices for the management of products collected from nature;
• Animal husbandry practices;
• Harvest and transport practices, including cleaning of equipment to prevent contamination;
• Storage practices;
• Processing methods, including cleaning of equipment to prevent contamination;
• Labeling procedures and/or
• Procedures for the procurement of organic ingredients.

• 205.201 (a)/2 – Examples of documentation of each substance to be used as a production or handling input:

• The composition and source of the input, as well as the location(s) and frequency of its use;
• In the case of non-organic inputs, documentation that organic products are not commercially available, e.g. for non-organic seed, evidence from the producer that an equivalent organic seed variety is not available;
• Indicators that inputs are used in compliance with the restrictions set out in §§ 205.601 – 205.606;
• Evidence that the operator has first attempted to use sufficient preventive practices before using disease and pest inputs, even if approved;

• Lists of soil improvers, including compost and manure, inputs for pest and disease control, seeds and other plant production materials, processing aids, etc.

• 205.201 (a)/3 – Descriptions of monitoring practices and procedures to be performed and maintained must include monitoring practices and procedures to verify the organic status of suppliers in the supply chain and agricultural products received, and to prevent organic fraud, appropriate to the operator’s activities, scope, and complexity.

An operator must monitor activities to ensure that organic practices are effective;
The results of monitoring will help identify areas that need improvement; Monitoring will help protect organic integrity and conserve natural resources; Monitoring methods may include: soil testing (e.g. soil organic matter content test), monitoring soil moisture or water quality, product quality testing, residue testing, monitoring of diseases and pests, etc.The OSP must include a ‘fraud prevention plan’. The fraud prevention plan must verify the organic status of suppliers and organic products. Therefore, the fraud prevention plan must include description of how an operator verifies the organic status of suppliers up to the last certified operator in the supply chain.

• 205.201 (a)/4 – Recordkeeping system;

• Must be sufficient to detail the operator’s activities and transactions in an understandable and auditable manner;
• Must include purchase or acquisition, production, sales or transport times and must be traceable to the last certified operator;
• Must be retained for not less than 5 years and must be sufficient to demonstrate compliance with laws and regulations;
• Must be available for inspection and copying during normal working hours by the control body, State official or USDA official.

• 205.201 (a)/5 – Examples of management practices and physical barriers established to prevent contact of organic areas and products with prohibited substances:

• Buffer zones to prevent contamination;
• Establishment of a physical barrier (e.g. a row of tall trees) to prevent drift of unauthorised substances;
• Notification of neighbors and/or;
• Procedures for the identification of organic products during harvesting and post-harvest handling, transport, processing and distribution.