WEEK #2
FSA 578 Form & Crop Management
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Auditors have started scheduling monitoring visits. To avoid being missed or extra monitoring visit fees, please regularly check your phone, texts, and email for any auditor communications and respond promptly.
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2024 FSA 578 Form
All Growers listed on the Certification application (Primary and Associate) are required to have a 2024 FSA 578 Report of Commodities at the time of the monitoring visit that lists the total tobacco acreage. If a grower's acreage has changed since the time of application they will have a chance to update that acreage at the monitoring visit. Auditors will verify that the 2024 578 lists the acreage being reported at the time of the visit.
To ensure timely reporting please remember crops must be filed with FSA by the
final acreage report date (ARD). Contact your County FSA office for the applicable
ARD for tobacco.
If a grower does not have a 2024 578 listing the total tobacco acreage being reported at the time of monitoring visit they will have a chance to go through remediation. Remediation is subject to costs with the monitoring firm and must be completed within 30 days. If a grower does not obtain and allow the auditor to verify the 2024 578 with the correct tobacco acreage
either during the monitoring visit or within 30 days of the monitoring visit they will not be eligible for GAPC Certification in 2024.
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During the monitoring visit growers will be asked questions related to the nutrient management, integrated pest management (IPM), and crop operations management.
The next three segments provide more details about the Critical Standards and what specifically will be requested during the monitoring visit. Review the Compliance Guide for details regarding Additional Standards.
1. Nutrient Management
If required in your watershed, growers must comply with mandatory nutrient management regulations by maintaining a Nutrient Management Plan (NMP) approved by the county soil and water conservation district. If you are unsure if you need a NMP, contact your county NRCS office. Your county conservation district can assist in writing a NMP or if you are not considered a Concentrated Animal Feeding Operation (CAFO) you have the option to write your own Manure Management Plan (MMP). More information on writing your own MMP can be found here.
2. Integrated Pest Management
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All CPA applications, restricted or non-restricted, should be completed or supervised by a licensed pesticide applicator. Growers must have a current pesticide license at time of audit. If grower uses a third-party to apply pesticides on the operation you must have a copy of their applicators pesticide license at time of audit. Allowing anyone who is pregnant or nursing to apply CPAs is prohibited.
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Growers are required to follow label instructions when applying CPAs and only use CPAs that have been approved by the EPA for use on tobacco. Always refer to your grower contract as some buyers may prohibit use of certain CPAs which are labeled for tobacco.
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The following documentation should be maintained for CPA application records: (a) date of application, (b) entity performing application, (c) reason for application, (d) product brand name and common name/active ingredients, (e) EPA#, (f) restricted entry interval (REI) by field/tract, (g) rate applied, (h) identification or field treated and size of treated area, and (i) method of CPA application.
All CPA Application Records can be found in Tab 2 of the 2024 GAP Records.
3. Crop Operations Management
- Growers are required to direct the day-to-day activities involved in producing the tobacco sold under your name, the name of an Associated Grower, employee, or the name of the farming operation.
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Use only Certified and/or approved seed for tobacco production.
- Air and Fire operations are required to only use Low Converting seed for tobacco production.
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Use only non-GMO seed for tobacco productions and if growing GMO tobacco keep it strictly separate from non-GMO tobacco from seed to bale.
- Whether you produce or purchase your tobacco plants, keep records of transplant/greenhouse seeding dates, varieties, and seed lot numbers by field/tract.
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If multiple tobacco types are grown of the farm, they must be kept strictly separated at all levels of production.
- If tarps are used when transporting, they must be free of contaminates and made of acceptable tarping materials (non-plastic) on the side which the tobacco is in contact.
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If an enclosed trailer/vehicle is used when transporting, all surfaces should be free of contaminants. Stock trailers should not be used for tobacco transport.
Documentation for Crop Management can be found in Tab 3 of the 2024 GAP Records.
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Purchase Your Plants?
Plant growers should provide a Transplant Purchase Record. The record should contain: (a) farm name (seller) and address, (b) greenhouse ID number, (c) variety name, (d) LC variety (burley & dark only), (e) seed lot number, (f) seedling source, (g) date of seeding, and (h) date the plants were received/picked up along with the following related to greenhouse fertilization and IPM records: (a) date of application, (b) applicator, (c) brand or product name, (e) reason for application, (f) rate per 1,000 square foot, (g) total application, and (h) start/finish time.
If you raise plants for sale, click here for the link to the Transplant Purchase Record.
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| Accurate Data Matters!
During the Monitoring Visit, growers will be asked to produce and show auditors your 2024 tobacco records. Growers may use whatever type of record keeping system that works best for you as long as all the required information is documented. See the Certification Records and Materials List when using another record keeping method. GAPC Records are available to purchase in the GAP Store or you may download the pdf or Excel versions for free on the GAPC Website.
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www.gapconnections.com | 865.622.4606 | info@gapconnections.com
2450 E.J. Chapman Drive Knoxville, TN 37996
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