Creating a System for Inspections

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Creating a System for Inspections

• Greenmarket, CENYC 2009
• Michael Hurwitz
• June Russell
• Bernadette Martin
• info_at_greenmarket.cc
• 212-788-7476

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Trust everyone, but verify

• Ronald Reagan

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Trust everyone, but cut the cards

• W. C. Fields

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Purpose of Inspections

• What is the Mission of your market?
• Inspections should support the mission and the
  rules of the market.
• Support your identity, and the promise of that
  identity name/logo/certification.
• Inspections verify producers claims.
• Your identity gives legitimacy to producers. They
  may receive contracts, restaurant business,
  press.
• Most importantly, the trust of the individual
  consumer.
• Inspections should also deter participants from
  breaking the rules and assist in holding those
  who are, accountable.
• Inspections are a foundation for publicity and
  advocacy.
• Inspections ultimately should build trust and
  relationships within the community.

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Part I Know Who You Are (or who you are
working for)

• What are your standards?
• Clear rules
• Establish clear rules for your market
• Models for rules.
• Farmers Market Coalition as a resource for
  developing rules.
• Other Markets from around the country post their
  rules online.
• Contact Greenmarket

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These are the strengths of Greenmarket that the
Rules must protect
Key Facet of Greenmarket Details of the Situation
Strong Consumer Brand Consumers have faith in the Greenmarket Brand and look to it for local, fresh food.
Favored Tenant of the City of NY Without the space and modest rents that the City charges, Greenmarket, would be unable to offer the attractive stands that it can offer to the Farmers/Producers.
Go-between from the City to the Farmers/Producers Organizing and overseeing the Producers so that they can sell their wares directly to the consumer, without having to go through the complexity and restrictions of the Citys street vendor program.
Vehicle for Protection of Farms and Producers Promoting and strengthening the small family farmer in the radius of the Region
Distribution Mechanism to ensure that fresh, local food reaches the City, including areas that are poorly served by other forms of food retailing.
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Long Term Purpose, Goals and Achievements of the
Rules

• Some of the things that should be considered when
  thinking about Rules
• Why are we creating rules in the first place?
• What is the impact of Rules on the long term
  achievements of Greenmarket? Can we design Rules
  that actually help us to accomplish what we want
  to as an organization?
• Can Rules, properly designed, encourage Farmers
  to take on product and capital investment?
• How do we provide Guidance for Evaluating rules
  on specific topics of Product Eligibility,
  Producer Eligibility, Compliance and Fees against
  the Mission of Greenmarket for the future
• Can we develop a research agenda that guides rule
  making. For example the Orchard Rule. Should we
  be encouraging ownership of cider presses? The
  Grain Issue should we be encouraging local grain
  production?

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Part II A System for Inspections

• Intake
• At Market
• Managers
• Inventories
• In the field
• Confidentiality
• Preparation
• Check lists
• Follow up
• Issuing violations

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Intake The Application

• Set yourself up with good information
• Establish an agreement between market management
  and producers that producers sign.
• Require that producers submit
• Crop plans Product lists, (similar to ,OSPs,
  Organic system plan)
• Farm Maps
• Production facilities being used
• Information requested reinforces the terms of the
  market place.

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At Market

• Working with management, training managers.
  Market managers are the frontline of enforcement.
• Collecting information, monitoring product at
  market. Knowing what is at your market is
  important for several reasons.
• Seasonality/ Publicity - Education
• Authenticity/Inspections

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At Market Inventories

• Inventories are key in documenting products and
  volume at market and become essential in proving
  when a producer is in violation of the rules.
• Make inventories routine. It will help lessen
  hostility and suspicion from your producers if
  this is seen as routine and not indicative of
  harassment, a witch hunt, a pending
  inspection
• Opening/closing inventories. Try to get the best
  information possible. Complete opening and
  closing numbers.
• Units of measure. Create standards i.e.. Apple
  crate, tomato box, flats.
• Inventories can be a sensitive area. Be clear
  with your producers about what the information
  will be used for.

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In the Field Inspections

• Who is doing the inspection? Dynamics will be
  different.
• In house, a staff person is a member of the
  community. Ideally, they will be removed from
  final decision making.
• Contracted inspectors from outside the community,
  can be more objective, if less familiar.
• Certifying agencies NOFA, Demeter, Certified
  Naturally Grown
• Other farm market inspectors
• Extension agents
• Experts in a particular area or aspect of
  production

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Confidentiality

• Confidentiality is critical to inspections and
  must be practiced by both management and
  inspectors.
• Develop confidentiality agreements with
  inspectors.
• Train your staff and managers to abide by
  confidentiality.
• Be aware of potential conflicts of interest.

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51 Chambers Street, Suite 1231, New York, NY
10007 ? [phone] ? fax 212 533
0242 As a Greenmarket Farm Inspector, I
agree To inform the Greenmarket Director of any
ties - past, present, or future that I have, or
plan to have with a producer, prior to conducting
an inspection of his/her establishment. To
present Inspection Reports to the Greenmarket
Director and/or the Farm Inspections Coordinator
for the purpose of enforcing Greenmarket's
grow-your-own regulations. Not to divulge to
anyone the nature and/or content of any
documentation that has been provided to
Greenmarket, or acquired as part of the
inspection process, unless I am authorized to do
so by the Greenmarket Director. Not to discuss
producer affairs with anyone except the
Greenmarket Director and/or The Farm Inspections
Coordinator without prior approval from the
Director. _________________________
___ ____________________ Greenmarket Farm
Inspector Date
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Preparing for an Inspection

• Make sure you are familiar with the
  rules/standards of the organization you are
  inspecting for.
• Review product lists, maps, previous inspection
  reports and inventories.
• Compare product lists and inventories.
• Request any information you may need ahead of
  time, i.e.. Seed receipts, processing invoices.
• Contact producer and arrange a time.
• Allow adequate time for the inspection. For
  example if a farm has an orchard, vegetable
  production and a bakery, you will need enough
  time to inspect all aspects and facilities of
  production.

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Items to Bring on an Inspection

• Maps of the area/compass
• Directions to the farm
• All relevant documentation farm maps, crop
  plans, inventories, etc.
• Copy of the rules
• Check list/templates
• Note pad/clipboard/pen(s)
• Camera
• Phone

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Attire

• Dress appropriately
• Boots, raingear, sun protection
• Be ready to get dirty
• Note Clean your boots be conscientious of
  tracking potential contaminants from/onto farms.

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Basic Check list

• Meet and greet farmer or person designated to
  give the tour
• Check fields, greenhouses, orchards, livestock
  areas, processing facilities that are used.
• Identify crops, acreage, assess yields and
  evidence of current and future yields.
• Equipment
• Labor
• Storage facilities barns, storage units, washing
  and grading areas
• Packing areas and packaging supplies
• Exit interview and sign off

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Categories of farm production

• Greenhouses plants
• Vegetable production
• Orchards small fruits
• Ocean or fresh water fish
• Processing preserves, pickles, baking, prepared
  foods, juice cider, grain milling
• Livestock pigs, poultry, beef cattle, lamb,goat
• Dairy fluid milk and cheese production
• Foraging
• Honey/Maple Syrup
• Aquaculture

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Sample Dairy Checklist

• Land (both owned and leased) while visiting each
  parcel listed on crop plan verify the lease
  agreement is on file.
• Livestock Breed and size of herd, health, care
  and breeding practices
• Housing and conditions
• Feed sources
• Milking facilities and practices quantity in
  pounds of milk produced each day.
• Pasture and grazing land management
• Manure management and composting to minimize
  environmental impact
• Number of employees
• Processing facilities on farm? If not you must
  visit site location. List all equipment used.
• Additives or flavorings used? Where are they
  from?
• Single or mixed milk products? See rules for s
• Storage facilities refrigeration, cellars and
  temperature control at market.
• Ensuring integrity of products sold at GM are
  from your own herd Indicate only if product is
  purchased from other sources.
• Labeling
• HACCP plan for dairy in place and being utilized
• Sample Audit Show the math here. Provide copies
  of feed receipts if applicable. Also audit run
  for one day and compare to days inventory at
  market.
• Vehicles
• Marketing how are they doing at Greenmarket?
• Exit Interview Additional Information Needed,
  Issues of Concern

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Sample Orchard Checklist

• Land (both owned and leased) while visiting each
  parcel listed on crop plan verify the lease
  agreement is on file.
• List each variety of fruit, of trees per acre
  or per row, of rows and spacing) age of trees
  in production. of bushels or bins harvested per
  tree.
• Number of employees, additional at harvest
  time.
• IPM, biological controls, are spray records and
  certification current? Is equipment visible?
• Problem pests
• Fertilization Spray, compost, or mulching
  practices
• Irrigation and water sources
• Thinning practices?
• Bushel baskets and bins is farm name present?
  Please list if name is different.
• Grading or labeling machines in use? Bagging
  machines? Name listed on bags?
• Ensuring integrity of products sold at GM are
  from your own trees Indicate only if product is
  purchased from other sources.
• Cider production? Are they pressing on farm? Is
  equipment clean? Can you detect that it has been
  in recent use? If pressing off farm, where. See
  invoices, agreements.
• Labeling processed by, sold by, etc. If not
  pasteurized, is consumer warning label visible?
• HACCP plan for cider in place and being utilized
• Sample Audit Show the math here. Provide copies
  of receipts if possible or applicable.
• Vehicles
• Marketing how are they doing at Greenmarket?
• Exit Interview Additional Information Needed,
  Issues of Concern

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Remember

• Ask lots of questions
• Listen
• Make notes of everything
• Take photos
• Maintain respect and confidentiality
• Do not talk about other producers
• You are there to gather information and to report
• Violations can only be issued by the Director or
  Board (Depending on your organization)

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Communicating an Area of Concern

• In the exit interview you should discuss any
  areas of concern you have with a producer, before
  you leave the farm.
• Make sure that they understand any confusion you
  may have with regard to their process.
• Give the producer every opportunity to show you
  what you need to see to clear up the confusion.
  If you are not satisfied with their explanation,
  let them know that too.
• Follow up in a timely manner, do not let a
  possible violation linger if you can help it.

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Follow Up After an Inspection

• Write reports of each inspection and include good
  documentation.
• Gather further information, research topics and
  issues where you have more questions.
• Conduct follow up inspections if necessary to
  further verify products, processes, volume.
• Report suspected violations to your supervisor.

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Build an Archive

• Develop baseline information about your
  producers.
• Establish Farmer/producer files
• Crop plans, product lists, farm maps
• Farm Inspection Reports
• Market Inventories
• Photos

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Issuing Violations or Penalties

• You must develop a system for determining
  violations. The inspector should not be the
  investigator, the judge and the jury. This will
  depend on the organizational structure of your
  market.
• Within staff Director, senior manager,
  inspector.
• By committee if this includes farmers, then
  those with a conflict of interest should recues
  themselves.

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Procedures Following a Violation

• Establish penalties for violations.
• Penalties should be reasonable and fair, but are
  also meant to deter violations of the rules.
• Notify the producer of the violation and
  subsequent penalty.
• Create a system for review that is available for
  producers to challenge your findings.

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Part III For Inspectors

• Develop your resources
• Reference materials, seed catalogs
• Trusted advisors who are removed from your
  community
• Ag. Experts at Universities or extension offices.
  
• Advocacy organizations ATTRA, Rodale
• Inspector networks and training IOIA
  (Independent Organic Inspectors Association)

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Psychology of Inspections

• Freds speed limit /cop theory. Everybody will
  speed if they do not see an enforcement presence.
  People will at least slow down if they see a cop
  on the highway.
• The human capacity to rationalize and lie
• Perfectly likeable people will lie to your face.
• To be caught is (usually), embarrassing.
• Methods of avoidance distraction, denial
• Confrontation is difficult. Sometimes simply
  asking a direct question can be confrontational,
  and will elicit an emotional response.
• Always stick to the facts. Do not make it
  personal.
• Keep in mind the impact of community and agreed
  to community norms.

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Chatter

• People like to talk about each other
• .A LOT.
• Rumor
• Do listen to rumors but take them with a grain of
  salt but know that sometimes there is a grain of
  truth as well.
• Falsehoods people will say terrible and wildly
  inaccurate things about each other. Know that
  envy, maliciousness and plain ignorance exist.
• Work to develop a filter.

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Code of Conduct for Inspectors

• Support and encourage the development,
  implementation and advancement of the markets
  mission
• Abide confidentiality agreements
• Maintain the highest possible standards of
  integrity
• Foster goodwill and cooperation
• Report suspected fraud
• Avoid situations of conflict of interest

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Conclusion The Social Contract of the Market

• Inspector Management reliability
• You will be wrong sometimes, make mistakes, make
  oversights. You will not know everything.
• Your reliability as an inspector, member of the
  community is most important. Your word is
  everything.
• Producers must ultimately trust that you are
  working on their behalf, and for the good of the
  market.
• Producer accountability
• Producers who are breaking the rules must be held
  accountable.
• Over time, the inconsistencies will be revealed
  Inspector X
• Consumer Trust
• Consumers must have trust in the identity and
  promise of your market.

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• Greenmarket is a program of the Council on the
  Environment
• New York City, N.Y.
• Prepared for the Farmers Market Federation of
  New York
• March, 2009