Transitional Program Guidelines

A. Become a Transitional Program Partner

Daily Harvest’s Transitional Program aims to scale organic agriculture by supporting growers through their organic transition period. Participants in this Program (referred to below as a “Transitional Program Partner” or “Partner”) are farmers who share the desire to increase organic production, grow nourishing, diverse fresh fruits & vegetables, and have become a contracted Daily Harvest supplier. These requirements are in addition to the other requirements, terms and conditions in the Supplier Agreement.

Program Highlights:

Daily Harvest role:

Offer a targeted premium over conventional market price for contracted transitional crop (at the time the pricing is established)
Offer a multi-year term purchase contract for transitional crop
Discuss long term options for continued transitional crop, organic sourcing, or regenerative organic transition

Supplier role:

Comply with verification and/or certification requirements of land in transition
As requested by Daily Harvest, submit samples of ingredients
Participate in annual surveying and KPI tracking around challenges and status of transition
Participate, as requested by Daily Harvest, in marketing campaigns to share stories about farm operations and the organic transition process

Partnership steps:

Daily Harvest and Partner will collaborate on and agree to crop details, ingredient specification(s), and prices, all as specified in a Supplier Agreement
Partner will submit the required documentation and allow an onsite visit
Partner will take all required steps related to onboarding as set forth in its Supplier Agreement, and will comply with the requirements of the Transitional Program at all times
Daily Harvest and Partner will align on harvest and transport logistics
Partner will participate in annual data gathering survey

Daily Harvest’s Transitional Program documentation requirements are currently:

Grower Questionnaire
GMP or GAP audit report
Annual Multiresidue Annual Testing COA (completed by accredited laboratory)
Label Sample
Lot Code example and explanation
Packaging Specifications
Pesticide Monitoring Program
Product Specification Sheet
CA Transparency Act Statement
Certificate of Insurance
Letter of Guarantee
Recall/Emergency/Contact List

AND EITHER

Transitional Organic Certificate

Transitional parcel maps and identification information
Field History and activity logs, including chemical usage information
Seed information and records
Harvest and Holding Details

B. Oversight and Core Criteria

A Transitional Program Partner must maintain continuous oversight of all farms and processing locations within its program to ensure the core criteria and standards within these requirements are met.

Onsite Visits and Evaluations

Daily Harvest will provide notice in advance of all evaluations and visits. Daily Harvest or a third party representative plans to perform an evaluation at least bi-annually.
Onsite visits may include:

Relationship building and long term strategic planning
Evaluations of the farm and transitional cropland itself, any handling or processing areas, and holding facilities for ingredients sourced by Daily Harvest
A Review of FSQA policies and practices

An evaluation may be required prior to becoming a Transitional Program Partner; Daily Harvest will notify a Supplier if this will be the case.

Deviation Requests

If a Transitional Program Partner believes that its program will not meet specific requirements set forth herein, or Ingredients will not fall within an agreed-upon Specification, Daily Harvest, may, but shall not be required to, and upon prior written consent, allow a deviation based upon the following conditions and processes:

A written request is made by the Partner detailing the reason(s) for the deviation.
The Partner presents a plan or addendum addressing a plausible alternative to the requirement in question.
Daily Harvest will review the deviation and, while not required to, may grant approval only if the plan or addendum does not jeopardize the integrity of the Transitional Program, violate any provision of the USDA organic regulations, or result in a failure to comply in a material manner with the Specifications. Any approval of a deviation request by Daily Harvest must be in writing by an authorized representative of Daily Harvest.

Crop Failure

If a Partner suspects a crop failure that will impact delivery of contracted volumes may occur or is imminent, the Partner must immediately notify Daily Harvest in writing.

Where applicable, notification should include:

Failure type;
Root cause of the failure;
Photos; and
Proposed next steps.

Supplier Suspension

The following acts will result in the suspension of a Partner from Daily Harvest’s Transitional Program (constituting a breach of the Supplier Agreement):

Failing to submit the required documentation as outlined above within reasonable timeframes and without communication
Presenting falsified documentation, including but not limited to, COAs, audit reports, and certificates
Utilizing land, facilities, equipment and/or techniques not disclosed in documentation or discussions
Knowingly violating USDA organic regulations
Knowingly misrepresenting the ingredient as natural or organically grown
Failing to communicate known specification deviation(s) that may result in a food safety hazard or major quality violation

C. Transitional Program Requirements

In order to be considered and approved for Daily Harvest’s use during the transitional period, ingredients must be farmed according to USDA organic standards. The following summary guidelines are intended to help you understand the organic requirements and standards. They are a summary only. The complete and latest requirements for the National Organic Program, which must be met at all times, can be found on the USDA website (link included at the end of this document.)

Parcels:

Land History

For your land to become certified organic, it must have been free of all prohibited materials– materials including fertilizers, pesticides, and herbicides that are not specifically approved for organic production– for at least three years. Those three years are your transition period and you will need to provide information on how the land was managed during those years.

In addition to the three-year land history, you will also provide information about your farm, including:

A map showing the features and physical characteristics of the farm and the surrounding area,
Information on how the land next to your growing areas is being used,
The acreage of each crop you grow, and
Whether you are growing only organic crops, or both organic and non-organic.

Boundaries

To the best of your ability, you must protect your organic land and crops from the unintended “drift” (water- or airborne movement of pesticides) of prohibited substances from adjacent land. If there is a high risk for these materials to flow or drift onto your land, a buffer may be required. A buffer might consist of a ditch that prevents water from flowing onto your land, a windbreak or hedgerow that protects your crop from chemicals drift, or enough space to ensure that the crop doesn’t unintentionally come into contact with prohibited substances. Understanding the activities from neighboring land is the first step to determining what will be required (if anything) to protect your crops.

Recordkeeping:

Required Records

You’ll need to record various aspects of your farming process—from seed purchases through production practices and sales. Your records will be reviewed by your organic inspector when visiting and must be kept for five years. Records should be tailored to your farm and can come in just about any form as long as they clearly track your production. Keep it as simple as possible so that you can implement consistent habits.

Soil and Water Management:

Soil Management

Organic certification requires you to manage soil in a way that maintains or improves physical, chemical, and biological conditions and minimizes soil erosion. While you don’t need to use every available fertility strategy, you must use practices that maintain or improve your soil. The following are examples of practices that help manage the fertility of your soil (among other benefits):

Crop rotation
Cover cropping
Incorporating crop residue
Using compost and/or manure
Applying mined minerals and amendments

Monitoring your soil is essential for assessing the effectiveness of your soil management program. How often you monitor your soil depends on need and circumstances. The following are examples of monitoring practices you can use:

Observing the soil condition
Observing crop performance
Comparing crop yields
Soil analysis

Preventing erosion is important for both soil health and maintaining the natural resources on your farm. These practices can be used in areas where there might be erosion problems:

Planting cover crops on empty or fallow land
Planting permanent cover crops on roadways/pathways
Using conservation (minimum) tillage practices
Strip cropping by alternating different crops in rows to minimize erosion
Contour farming or terracing by tilling the land along lines of consistent elevation to reduce soil loss

Water Management

If you use shared irrigation sources or equipment, you will need ways to prevent prohibited materials from entering your cropland. If you use an on-site well you may want to test the water to find out if there are any sources of contamination. If you use municipal water there are typically no additional steps needed to ensure the compliance of your water sources.

Seeds and Planting Stock

Seed must be certified organic, however, in certain instances, non-certified seed may be used if equivalent organic varieties are not available in a quantity that meets the production need. In this case, the conventionally-grown seed used cannot be genetically modified or treated with prohibited materials. You will be required to show that you actively search for suitable organic seed and keep records of that search.

Annual seedlings and transplants that you buy must be certified organic. You can grow your own seedlings as long as they are grown according to organic requirements and are included as one of your crops in your certification.

You can use non-certified perennial planting stock to produce organic crops if an equivalent organic variety is not available in a quantity that meets the production need. If you are growing trees or other perennials plants to sell (such as in a plant nursery) you must manage the non-organic planting stock organically for a year before it can be labeled or sold as certified organic.

The conditions for using other types of planting stock (such as rhizomes, shoots, tubers, cuttings or roots including strawberry crowns, raspberry canes, potato eyes) are the same as those for perennial planting stock.

Pest Management

Organic farmers must control pests such as insects, diseases, and weeds using preventative practices like crop rotation, nutrient management and other cultural methods, as well as, cultural and mechanical/physical controls (see bulleted list below).

On the occasions when preventative cultural, mechanical/physical methods fail to control pests, you may use one of the natural, non-synthetic materials which are allowed in cases where preventative measures have failed. If the natural, non-synthetic materials also fail there are synthetic materials that are specifically allowed and are included on the National List of Allowed and Prohibited Materials of the USDA organic regulations. Be prepared to demonstrate to your inspector that you have used preventative cultural and mechanical/physical practices before resorting to any chemical methods.

Inputs, Materials, and Production Equipment

Inputs and Materials

Organic farmers can only use fertilizers, pesticides, and herbicides that are specifically allowed for organic crop production. All products and materials—including compost and mined minerals—must be approved for your use by your certifier. Treated wood that contacts soil or crops is prohibited for use (fence posts outside of the production area are likely fine).

Two organizations, the Organic Materials Review Institute (OMRI) and the Washington State Department of Agriculture (WSDA) publish brand name lists of materials compliant to the USDA organic regulations and allowed for use by organic farmers. Most certifiers accept products that are OMRI and WSDA listed for use by the farmers they certify. These are two of the best resources to use while transitioning your farm.

There are acceptable products and materials that do not have OMRI and WSDA reviews. For example, if you make your own compost tea or buy from a local manufacturer, your certifier can review the product and determine if it is allowed. Once you find a product by one of these methods, add it to your organic System Plan (OSP) and have it officially approved for your use.

It is crucial during your transition and throughout your certification, to research materials and make sure they are allowed before you use them. If you use a prohibited substance you will have to wait three years from that date before you can certify your land.

Treated Wood

You cannot use lumber treated with arsenate or other prohibited materials for new installations or replacement purposes when it will come in contact with soil, plants, or livestock. You may use treated lumber on parts of your property that are not included in your certification or in areas where the lumber will not contact soil, plants, or livestock. If you have treated lumber on your land when you apply for organic certification you will include that information in your organic System Plan (OSP).

Production Equipment

If you use production equipment (sprayers, tractors, combines, etc.) that is also used on non-organic land or crops (or hire custom equipment), the equipment must be maintained to prevent organic products from coming in contact with materials or residue from the non-organic production. Your organic System Plan (OSP) will include information on cleaning procedures (such as triple rinsing, using compressed air, etc.) and your recordkeeping should track the actual day-to-day activities when these procedures are used.

Harvest and Transport

The way you harvest your crop depends on the types of crops you grow and where you sell them. You may harvest yourself, sell the crop in the field, or contract with someone to harvest it for you. In your Organic System Plan (OSP) you will describe the harvest process and explain how the crops are moved from the field to the next step in the process. The "next step" might be field packing, sending the product to a packing facility, moving it to the on-farm washing/packing area to prepare it for market, or transporting it on a truck belonging to the buyer.

Once a crop is harvested, it will need to be transported in a way that ensures there is no mixing with non-organic crops or residue, which could occur in containers or bulk trucks. It is your responsibility to ensure organic integrity until the point that you lose ownership of your crop or it is delivered to the final destination. If your customer is responsible for transport then it is their job to protect the organic integrity of the crop from pick-up at your location.

Post-Harvest

Unless you pack your crop in the field or sell it before harvest, you likely do some kind of handling activities before it’s sold. If you are only working with the organic crops that you grow and performing simple activities like washing, drying, dehydrating, hulling, shelling, pressing, or hand sorting you may not be required to have separate certification as a Handler (see common terms for types of certification). If you perform handling activities more complicated than these, handle both organic and non-organic produce, or handle products you didn't grow yourself, you will need to be certified as both a Grower and a Handler.

Packaging materials must be new, or used in a way that does not contaminate organic crops.

D. Appendix

1. Common Terms

The following terms are commonly used in organic farming systems and referenced throughout the guidelines. Daily Harvest has set out below the commonly understood meaning as of the date of this document solely for convenience and makes no representation as to the legal meaning or meaning in any other context.

buffer: a physical barrier that helps prevent non-organic products or residue from entering your organic land. A buffer might consist of a ditch that prevents water from flowing onto your land, a windbreak or hedgerow that protects your crop from airborne chemicals, or enough space to ensure that the crop doesn’t unintentionally come into contact with prohibited substances.

commercially available: availability of organic supplies in a quantity that is sustainable for production. Organic regulations require the use of certified organic seeds and planting stock, including annual starts. In some cases, non-certified seed may be used if equivalent organic varieties are not commercially available as long as the conventionally-grown seed is not genetically modified or treated with prohibited materials.

contamination/commingling: when non-organic products or residue from those products comes into contact with organic products and affect the organic integrity.

drift: water- or airborne movement of pesticides from non-organic land onto organic land. Contributes to contamination of final organic products.

grower certification: to be certified, organic land must be free of prohibited fertilizers, pesticides, and herbicides for at least three years. Production practices on organic farms must maintain or improve the natural resources of the operation, including soil and water quality. The source of seeds and starts and planting, harvest, and sales activities must meet organic regulations.

handler certification: handler certification is for products and operations that produce or handle organic products. Certification for processed or packaged products requires that both the ingredients in the products and the facility within which they are processed, packaged, and/or labeled be certified. Facilities must ensure that their practices include no commingling or cross-contamination with any conventional products or prohibited materials.

inputs/materials: fertilizers, pesticides, and herbicides.

livestock certification: certification for livestock includes the land which animals have access to or graze on, the management practices for the animals, and the animals themselves. All grazing land and other accessible land where animals will be located must be free of prohibited fertilizers, pesticides, or herbicides for at least three years. Cows, sheep, pigs, and other mammals must have been managed organically from the last third of gestation. Poultry must be managed organically from the second day of life. Animals can only be fed certified organic feed- this includes certified pasture too. Antibiotics are prohibited and only approved medicines can be used.

natural/non-synthetic material: certain substances such as mined minerals, non-synthetic vinegar, and hydrogen peroxide which may be approved by your certifier for use when preventative measures fail.

Organic System Plan (OSP): a plan specific to your operation that describes your farming practices, tools, and inputs (fertilizers, pesticides, herbicides, etc.) You prepare your OSP when you complete the certifier’s application for certification.

pest management: organic farmers must control pests such as insects, diseases, and weeds using preventative practices like crop rotation, nutrient management, and other cultural methods, as well as, cultural and mechanical/physical controls.

prohibited substances or materials: materials including fertilizers, pesticides, and herbicides that are not specifically approved for organic production.

three-year transition or transition: for land to be certified organic, it must be free of any prohibited materials for at least three years prior to applying for certification.