The introduction of a Common Organic System Plan, or Common OSP, is an important step toward greater consistency within the National Organic Program. Certified organic operations are all working under the same federal organic regulations, but they have often been required to describe their farms, handling systems, materials, and recordkeeping practices on forms that differ substantially from one certifier to another.
Right now, a person new to organic has to pick a certifier first and get their version of an OSP before I or other educators can even talk about how to use an OSP. A common format can reduce that unnecessary variation by creating a standard way to organize the information every certifier needs. It may also improve portability by allowing an operation to maintain one working OSP that can be updated over time and, when necessary, more easily submitted to another certifier without rebuilding the entire plan in a different format. A common complaint I hear is, “I would change certifiers but relearning and reworking all the forms is a mountain I don’t want to climb!”
A Common OSP can also make education and technical assistance much more effective. Extension educators, mentors, consultants, and farmer organizations can teach producers how an OSP works using one nationally recognized structure rather than trying to explain several certifier-specific systems. Certified operations interested in using the Common OSP should begin by asking their certifier whether it is accepted for new applications, annual updates, or transfers, and whether any supplemental forms are required. Producers should also ask whether the certifier will accept the Common OSP as the primary plan or require the same information to be entered again into a separate portal. I know that CCOF is not planning to use the new forms or recognize them for their clients since they say their forms save time. Many other certifiers will provide an option to their clients.
This new OSP is simply labeled as Version No. 1 and being the first it will probably be changed or updated over time.
Fortunately, No. 1 has started a conversation that will help determine whether a Common OSP truly reduces paperwork and gives the producer greater ownership of the document that describes how the organic operation maintains compliance.
I encourage you to take a look at the new No. 1 Common OSP. Below is the link to the USDA Website where you can download everything you need.
Currently the Texas organic program has several producers farming in Far West Texas working with soils that have a high pH and some salt and sodium concerns. Their irrigation water also carries moderate levels of salts and sodium. These are not unusual conditions in Far West Texas, but they complicate crop selection. Over time, sodium can weaken soil aggregation, reduce water infiltration, and make it more difficult for roots to explore the soil. Salinity adds another stress because plants must use more energy to extract water from the soil. The goal is to continue to find and grow crops that can not only help the bottom line but add to soil fertility and overall soil health. That is a lot to ask of any crop but especially a sweetclover crop!
Hubam Sweetclover is a Surprise Crop
Hubam is an annual white sweetclover. It is a legume, which means it can form a relationship with nitrogen-fixing bacteria and obtain much of its nitrogen from the atmosphere rather than from purchased fertilizer. That is valuable in an organic farming system, but nitrogen fixation is only part of the story.
Sweetclover develops a strong taproot that can explore deeper portions of the soil profile. Those roots create channels, add organic matter below the soil surface, and help move carbon deeper into the soil. When the roots eventually die, the channels remain available for water movement, air exchange, soil organisms, and the roots of future crops. This “biological tillage” provides a living root that opens the soil while also feeding microbes, adding carbon, and protecting the surface. Also, Hubam has a history of performing on alkaline soils and even doing so with some salt and sodium problems.
Recently, I was out in Far West Texas and got a chance to see my first field of Hubam Sweetclover and was surprised by the 5 to even 6 feet tall plants, heavily branched, and still productive even though it was the end of July and the crop was seeded out and going down. This is normal for a cool season clover, still the crop was demonstrating that an annual white sweetclover could survive and produce substantial forage and root mass even under some tough soil and water conditions. It is known to be about the most heat tolerant of all the clovers and as you can see will be growing and blooming late into summer. One source said it can get 10′ tall!
Can all that Hubam Sweetclover seed be harvested??
You can easily see from the picture that Hubam Sweetclover produces a lot of seed and is known for reseeding itself because of its good viable seed production. Unfortunately harvesting that seed for future use in other fields may be a real challenge. First, all sweetclover plants are indeterminate. That means the plant does not flower, mature, and dry down all at once. On the same plant you can see white flowers, green pods, mature brown pods, green stems, and drying stems which creates a harvest problem, when do you start? When the oldest seed is mature enough to harvest, the newest seed may still be immature. Waiting for the entire plant to mature increases the risk that the earliest, most mature seed will shatter and fall to the ground. Cutting earlier protects some of the mature seed but potentially leaves more immature seed in the windrow.
The crop is also tall and tangled. The large stems can remain green longer than the fine branches and seed pods. A combine may thresh dry seed but stall out processing heavy, moist stems. Swathing was recommended by most of the seedsmen I contacted. Darcy Turner at Turner Seed has decades of experience and he recommended swathing at about 50% dark brown to black seed. You can run a conventional swather, but the crimpers need to be open as wide as possible to minimize crushing and pod disturbance. We sure don’t want to strip off the seed with a crimper. Your combine needs a pickup attachment, but they are not too hard to find especially around any silage crop growers.
Lastly, you may be wondering if there is any problem with harvesting the seed to use either on your own farm or to sell to your neighbor – don’t worry it is not a protected variety and has been around for decades.
If You’re not into Seed Harvest, then What?
Talking with the Far West Texas farmers they like the Hubam Sweetclover but the seed is very hard to find – probably because it is so hard to harvest! That said we did discuss another variety developed because it was similar to Hubam but had some different or even better plant characteristics.
Silver River1 was developed and released through Texas A&M AgriLife Research. and is described in the Journal of Plant Registrations, Volume 11, Issue 2, pages 112–115.2 It is closely related in function and growth habit to Hubam and was selected primarily for resistance to sweetclover rust, a disease that can severely damage susceptible sweetclover plants. Published evaluations found Silver River to be similar to Hubam in maturity and forage production while having much greater rust resistance.
Rust may not be the first concern that comes to mind in the dry environment around Pecos. However, irrigation and a dense crop canopy can create humid conditions within the stand. Disease resistance is rarely a disadvantage, even when disease pressure is inconsistent. More importantly, Silver River may provide many of the same soil-building and forage functions as Hubam while being more available through several commercial seed sources. We haven’t tried it in Far West Texas yet but overall it has the potential and genetics to do really well – try a test plot and see.
Sweetclover as Hay
Both Hubam and Silver River can produce substantial forage, but sweetclover should not be managed exactly like alfalfa. As sweetclover matures, the main stems become large and woody. For hay, cutting time is critical and like other legumes earlier cutting generally provides better forage quality and finer stems, but it sacrifices some total tonnage and even root development. Later cutting produces more biomass but also increases stem size, slows drying, and reduces forage quality.
Sweetclover also requires special attention during curing since moldy sweetclover hay can develop dicoumarol, an anticoagulant associated with sweetclover bleeding disease in livestock. This risk comes from improperly cured or mold-damaged hay rather than from healthy plants standing in the field. Grazing is their strong suit, but they can be cut for hay and cattle love it!
We are right in the middle of the growing season, which also means that many certified organic farmers are receiving their annual organic inspection. During some inspections, the inspector may collect plant tissue, harvested grain, fruit, vegetables, soil, water or another sample and send it to a laboratory for pesticide residue testing.
Then the farmer receives a message saying, “A pesticide residue was detected.”
Those words can create some immediate panic! However, a pesticide detection does not automatically mean that your farm has lost organic certification or that you intentionally applied a prohibited pesticide. There is a process that the organic certifier must follow to determine what was detected, how much was found and where it may have come from.
Use Only Products Approved by Your Certifier
Let me start with the most important reminder: every material used on a certified organic farm should be approved by your certifier before it is applied. This includes pesticides, fertilizers, seed treatments, biological products, soil amendments, adjuvants, surfactants and even products used to clean equipment that may contact an organic crop. An OMRI listing is very helpful, but an OMRI-listed product should still be submitted to your certifier and included in your Organic System Plan before use. USDA states that all substances used on an organic operation must be approved by the operation’s certifying agent before use.
There are several reasons for this:
The product may only be allowed for certain uses.
The label formulation may have changed.
A product with a similar name may not be the same formulation.
The certifier may need to verify active and inactive ingredients.
Some allowed pesticides can only be used after preventive, cultural and biological controls have been documented.
My advice is simple: do not depend only on the OMRI logo on the container. Send the complete product label to your certifier and get written approval before application.
Why Are Organic Farms Tested?
USDA requires organic certifiers to sample and test products from at least 5 percent of the operations they certify each year. A certifier with fewer than 30 certified operations must test at least one operation annually.
The certifier may select farms:
randomly;
because they produce a large volume of organic products;
because the crop or location presents a higher contamination risk;
because of a complaint or suspected problem; or
as part of an investigation.
Being selected for testing does not mean that the farmer is accused of wrongdoing. Testing is a normal part of protecting the integrity of the organic label. The certifier pays for this required periodic testing, and the sample must be collected by an authorized inspector, maintained under a proper chain of custody and analyzed by an accredited laboratory.
What Happens When Nothing Is Detected?
The easiest result is “not detected.” This means that the laboratory did not find any of the pesticides included in the laboratory screen above the method’s reporting limit. Remember that “not detected” does not necessarily mean that absolutely zero molecules were present. It means that the laboratory did not detect the pesticide at or above the level the test could reliably identify and report. A report may show glyphosate at >0.01 ppm which means it is there and detectable but at very low levels.
What Happens When a Pesticide Is Detected?
Remember you are in a farming area and pesticide residues can sometimes come from:
spray drift from a neighboring field;
contaminated irrigation water (especially in rice country);
contaminated harvest or transportation equipment;
inadequate cleanout of storage bins;
commingling during handling;
residues remaining from earlier land use; or
an input that contained an ingredient not disclosed on the label.
The certifier must consider the pesticide, the amount detected, the crop tested and the available production records.
The 0.01 ppm—or 10 Parts per Billion—Decision Point
NOP guidance identifies 0.01 parts per million, or 10 parts per billion, as an important decision point. A concentration of 0.01 ppm is extremely small. It is roughly comparable to one second in a little more than three years. Modern laboratories can detect some pesticides at very low concentrations, which is why a laboratory may find a residue even when the farmer did not intentionally apply that pesticide.
When a prohibited pesticide is detected at or above 0.01 ppm, the certifier first determines whether EPA has established a legal tolerance for that pesticide on the particular crop or commodity tested.
That crop-specific detail is important. A pesticide may have:
one tolerance on cottonseed;
a different tolerance on corn;
another tolerance on vegetables; or
no legal tolerance at all on a particular crop (a pesticide is detected but one that is not for the crop being tested. I had an organic hay producer with a detected potato fungicide on the crop. Where did that come from?).
What Is an EPA Pesticide Tolerance?
An EPA tolerance is the maximum amount of a pesticide residue that may legally remain in or on a food or agricultural commodity. This is primarily a conventional pesticide and food-safety standard. It is not an organic pesticide allowance. The organic regulations use 5 percent of the EPA tolerance as the level at which an affected product must be excluded from organic sale.
For example, suppose EPA has established a tolerance of 1.0 ppm for a particular pesticide on a particular crop.
Five percent of that tolerance would be: 1.0 ppm times 0.05 = 0.05 ppm
The organic exclusion threshold would therefore be 0.05 ppm, or 50 parts per billion. This example means that if a residue is found in testing your crop that is greater than 0.05 ppm your crop cannot be sold as organic and you will get a notice of noncompliance.
Below 5 Percent of the EPA Tolerance
When the residue is at or below 5 percent of the EPA tolerance, the crop is not automatically excluded from organic sale solely because of the residue level.
However, the certifier may still investigate:
whether the farmer applied the pesticide;
whether spray drift occurred;
whether buffers were adequate;
whether shared equipment was properly cleaned;
whether storage and transportation protected the organic crop; and
whether the farmer followed the approved Organic System Plan.
If the farmer did not apply the pesticide and had reasonable preventive practices in place, the result may represent unavoidable contamination rather than a violation by the farmer. The certifier may still require corrective action. For example, the farmer may need to increase a buffer, improve equipment-cleaning records, communicate with a neighboring applicator or change how the harvested crop is stored.
Above 5 Percent of the EPA Tolerance
When testing detects a prohibited pesticide at a level greater than 5 percent of EPA’s tolerance for that pesticide on that commodity, the affected agricultural product cannot be sold, labeled or represented as organic. This does not necessarily mean that the entire farm immediately loses certification.
The certifier must determine what product the sample represents. Depending on the circumstances, the affected product could be:
one field;
one harvest lot;
one bin;
one truckload;
one storage unit; or
a larger quantity that was commingled.
Good field, harvest and storage records become extremely important. If a farmer can clearly show which field supplied each lot or bin, the certifier may be able to limit the problem to the affected product. When records are incomplete and several fields or loads have been mixed together, it may be difficult to separate the contaminated product from the rest of the crop.
What if There Is No EPA Tolerance?
Sometimes a laboratory detects a pesticide for which EPA has not established a tolerance on the tested crop. If there is no EPA tolerance and no applicable FDA action level, NOP guidance says that a prohibited pesticide residue above 0.01 ppm generally results in the affected product being excluded from organic sale. The certifier must also determine whether the result should be reported to EPA, FDA or the appropriate state agency. This is one reason that the name of the pesticide and the crop tested are just as important as the amount detected.
What if the Farmer Applied the Pesticide?
The 5-percent threshold does not create permission to use a prohibited pesticide. If an investigation shows that a prohibited pesticide was intentionally applied, the farmer may be out of compliance even when the residue detected is very low.
The certifier may consider:
exclusion of the affected crop from organic sale;
a notice of noncompliance;
suspension or revocation of certification; and
whether the field must complete a new 36-month transition period.
The basic organic requirement remains that prohibited substances cannot be applied to land during the 36 months before harvesting an organic crop. The residue level helps determine what happens to the product, but the investigation determines whether prohibited use occurred.
What Should a Farmer Do After Receiving a Positive Result?
First, do not panic—but do respond promptly.
I would recommend that the farmer:
Ask for the complete laboratory report.
Confirm the pesticide that was detected.
Confirm the concentration in ppm or ppb.
Ask whether EPA has a tolerance for that pesticide on the tested crop.
Review all input and application records.
Review neighboring pesticide applications and any drift concerns.
Review equipment cleanout, harvest, storage and transportation records.
Identify exactly which field, lot, bin or load the sample represents.
Provide the certifier with any information that could help identify the source.
Document corrective actions that may prevent another occurrence.
Do not immediately assume that a neighboring farmer caused the detection. The location of the sample, pesticide chemistry, timing of nearby applications, weather, field pattern and other evidence should be considered before reaching that conclusion.
Finally, a positive test may begin an investigation, but good practices and good records help tell the complete story.
More Resources
USDA Memo to Certifiers: Periodic Residue Testing of Organic Products. (AMS)
USDA NOP 2613: Responding to Results from Pesticide Residue Testing. (AMS)
I got emails from several of the national organic groups telling me that the Cost Share program for organic certification was finally open. On one of the emails, they had a link to the website so I could actually see how the program was going to work. USDA Farm Service Agency (FSA) is still the place to go to sign up for most organic producers since you are probably there doing other business anyway.
Eligible OCCSP applicants include any certified organic producers or handlers who have paid organic certification fees to a USDA-accredited certifying agent. OCCSP pays a maximum of $750 per certification category for crops, wild crops, livestock, processing/handling, and state organic program fees. The scopes must be listed on the producer or handler’s organic certificate to be eligible for OCCSP.
Eligible costs include:
Application fees and administrative fees for USDA organic certification
Inspection fees for USDA organic certification, including travel costs and per diem for organic inspectors
USDA organic certification costs, including fees necessary to access international markets with which AMS has equivalency agreements or arrangements
State organic program fees
User fees and sale assessments for USDA organic certification
Postage for materials related to obtaining or renewing USDA organic certification
Opportunity for State Agency Participation
FSA will soon announce a 30-day application period for state agencies to apply through grants.gov to administer OCCSP.
The state agency for Texas that does also handle the Cost Share program is the Texas Department of Agriculture or at least it has been! Typically, TDA has done it as an online application, and it has not mattered who your certifier is but simply that you follow the application process. This is what the current TDA website is showing but I am assuming it will be updated soon!
Sometimes two ears of corn can tell an important plant-breeding story.
Ears from the 2026 Taylor, Texas, corn hybrid trial. TAMZ107 (top) remained free of visible ear-rot symptoms, while an unnamed commercial hybrid (bottom) showed severe ear-rot damage.
Both ears pictured came from a 2026 corn hybrid trial near Taylor, Texas—one location in our multilocation testing program. The ear on top is TAMZ107, developed by Dr. Wenwei Xu, Texas A&M AgriLife Research corn breeder at Lubbock. The ear on bottom is an unnamed commercial hybrid.
Frequent rainfall and humid conditions during the 2026 growing season have favored corn ear rots across parts of Texas. The commercial ear shows severe ear-rot symptoms, with Fusarium among the predominant ear-rot pathogens observed this season. All commercial hybrids in this trial showed some ear-rot damage, while the TAMZ hybrids remained free of visible symptoms.
The importance of this comparison is not the identity of the commercial company. It is the value of years of public plant breeding. Dr. Xu selected resistant inbred parents and combined them to produce TAMZ hybrids adapted to Texas conditions. TAMZ107 has been tested for several years and is now ready for release and fits an organic program because it is GMO free and adapted to organic conditions.
Genetic resistance is especially valuable for organic farmers because it arrives in the seed. The plant begins the season with its own protection rather than depending on a treatment after disease develops. Resistant hybrids can also benefit any farmer facing difficult weather and disease pressure.
See the TAMZ Hybrids in the Field
The TAMZ hybrids will be featured during the Field to Fiesta Corn Tour on Wednesday, August 12, beginning at 9 a.m. at the Halfway Research Center in Halfway, Texas. The tour will include the research center and nearby farm fields, followed by a sponsored lunch.
Topics will include heat during pollination, corn borers and earworms, drought tolerance, ear rots and herbicide drift. For attendance information, contact Extension Agronomist Kristie Keys at kristie.keys@ag.tamu.edu. View the program announcement.
Sunn hemp has fast become one of my favorite summer cover crops. This organic plot at the Texas A&M AgriLife Stephenville Research Center is already up to my elbow and still growing.
The value is easy to see in the picture below. A seed tube in the drill stopped up, leaving a space where the sun could get to the soil, so we now have a thick strip of weedy grasses. Also, the Sunn Hemp plant itself is known to suppress weeds – if it gets planted!!
In the picture below you can see that the Sunn Hemp made a good stand so that the canopy is already shading the soil and suppressing weeds before they can get established. As an aside, this field has a lot of yellow nutsedge, but the Sunn Hemp is keeping it shaded and suppressed too. It won’t take it out, but it will help!
I could pretty much step into any part of the Sunn Hemp planted area and find bare soil with just a few minor purslane weeds under the canopy.
This is just a demonstration for why cover crop establishment matters. A cover crop only works where it gets planted and this field had been a weedy mess for a couple of years. Because this is now part of an organic system, we needed a strong stand of sunn hemp can act like a living weed barrier while also producing biomass and adding nitrogen back to the system. Research and Extension publications commonly report rapid sunn hemp growth, strong biomass production, nitrogen contribution, and weed suppression benefits.1
One more benefit for Texas organic farmers: sunn hemp is a tropical legume and is not normally a reseeding weed problem in our systems. It can get stemmy so you may want to cut it occasionally and have it regrow, which it does quite readily. Also, I have planted it several times with a sudangrass and the two grow together well and can be harvested as hay.
Texas A&M AgriLife Organic 