Segreagating An Organic Facility:
It’s Not as Hard as You Think

By Maury Wills


Organic food processors represent a critical link in the organic food handling chain from farm field to plate. Not only are producers who make an organic claim required to be certified under federal organic regulations but so too are organic food processors who make an organic claim. If you cook, bake, cure, heat, dry, mix, grind, churn, separate, extract, slaughter, cut, distill, eviscerate, preserve, dehydrate, freeze, chill, package, can, jar or otherwise enclose food in a container, you are considered a processor under organic regulations.

Food processors are often solicited by branding companies to process or package and label a particular organic food product for their company. The first time that a food processor receives this type of call may be a bit unsettling and the response may be, “What do you mean by organic?” Thus begins the processor’s journey into the world of organic food processing.

What conventional processors may not realize is that they can produce a certified organic product in a facility that is also running conventional products—if they adhere to organic certification standards. This does not mean that every product produced in that environment falls under organic regulation standards. Instead, it requires careful consideration of production schedules, labeling and storage of conventional and organic products and tools with an eye towards creating a segregated environment that protects the integrity of the organic products without interfering with the production of conventional ones.

You Are Already Halfway There
It is not as difficult for an organic processor to transition to organic as some may think. Processors are already familiar with many of the same kinds of auditing programs, such as Hazard Analysis and Critical Control Points (HACCP) programs for food safety, that organic certifiers perform. It is merely a process of researching expectations for organic production and changing processes and behaviors to meet those expectations.

A good first step on this journey is to visit the National Organic Program (NOP) website at www.ams.usda.gov/nop. This website will allow you to gain some familiarity with the word “organic” as a regulated term and the particular rules governing the production, processing and labeling of organic food. Here, you can delve as much into the world of organic as you wish, especially if you follow other links.

Next, contact one or more organic certifying agents to request their application packet or any pertinent materials that they offer. You’re not necessarily ready to apply for organic certification at this point, but simply exploring and gaining more knowledge regarding the potential for adding an organic component to your processing business. Certifiers can provide a wealth of information to you regarding organic food processing regulations and organic certification of your operation.

A list of organic certifying agents can be found at the same website mentioned above. These certifiers are accredited by the U.S. Department of Agriculture (USDA) and are authorized to conduct organic certification services. Some are private certifying agents and some are government agencies, such as state departments of agriculture. Many certifiers do not limit their certification activities to the state in which they are headquartered.

The processor should identify one individual in the company who will plunge into the organic learning curve and take the lead to transition the processing facility to organic certification status. This will ensure direct communication between processor and certifier. Usually, processors contact certifiers after a potential client has already knocked on their door -- suddenly the processor is trying to learn a new process under the pressure of time constraints. Many questions will arise during this period and the transition leader will facilitate a swift and accurate exchange of information.

Processors should not look to certifiers as problem solvers for their own particular operation. Certifiers are prevented by the regulation from acting as a consultant or assisting the operation in overcoming current barriers to certification.

The organic transition leader should carefully review the application for organic certification and accompanying documents, including the organic regulations, then follow up with the certifier regarding any points that need clarification. The transition leader will now be equipped to discuss organic food processing and organic certification with the company’s decision-making team. If the decision is to move forward and segregate the facility for organic use, the real work begins.

Ensuring Integrity Through Segregation
In order to transition to a segregated organic facility, processors should first review the entire proposed organic process with flow charts in hand to evaluate where organic integrity of the product might be at risk. With those critical points identified, you can create safeguards to prevent those risks.

As you peruse the flow charts, consider how you will distinguish between organic ingredients and non-organic ingredients; where and how will they be stored; and how you will guarantee segregation throughout processing and packaging.

As you begin to identify risk areas in your process, ask yourself these critical questions:
• How will receiving personnel know the difference between organic ingredients and conventional ingredients?
• How will organic products and equipment be handled to ensure organic integrity of the product?
• How will the identity of the organic product be maintained throughout the process?

How you answer these questions establishes policy and procedure. For instance, a useful policy for a segregated facility requires that all incoming organic ingredients are received only from sources that are certified organic; that documents be presented to verify the authenticity of the ingredients organic status; and that their respective organic certificates be kept on file and updated on an annual basis. A simple checklist of approved suppliers and ingredients may be made available to the receiving area to ensure that only such products are accepted into the plant.

It can also be helpful to place reminder signs and/or data logs at other critical points in the process, both to remind workers of how to work with organic ingredients and to capture relevant information pertaining to the handling and processing of the organic products. For example, a sign in log can verify how and when equipment was sanitized and with which specific chemicals; another might document that only organic ingredients were used in a product batch; and again during packaging to verify that only products from the organic line were packaged and shipped.

None of these sign-in tools are required by certifiers but they can help you track and control your processes, and offer proof to auditors or certifiers that your organic standards are being adhered to.

Simple Steps to Protect Your Product
Segregating raw material from conventional ingredients is key to the success of the segregated facility. This can mean building a separate isolated storage area dedicated solely to organic materials, or it can be as simple as placing organic products in a section within existing storage units. You can use the same cooler or the same storage rooms for both conventional and organic ingredients as long as the boxes and/or pallets are clearly labeled and the raw ingredients are protected from commingling with other ingredients via packaging.

You must also decide whether you will have dedicated equipment for organic processing or whether the same equipment will be used to batch both organic and conventional product, or a combination of the two. If equipment is dedicated it should be labeled as such and kept away from conventional processing areas. You may decide to isolate the organic line at the far end of the facility, or put it in a separate room, which offers a physical barrier to prevent accidental commingling.

If you are going to use the same equipment for both conventional and organic it is easier to manage your process if you schedule production times separately. For example, you might produce organic products in the first shift or only on Mondays. This reduces the risk of accidental commingling of ingredients and tools such as paddles, bowls, and buckets. It also eliminates the need for staff to be committed to working on only certain product lines, and it gives you the opportunity to have a flexible sanitation program.

Obviously, the equipment must be thoroughly cleaned before it can be used to make organic products. The appropriate use of sanitizers is not prohibited, however, the processor must ensure that sanitized food contact surfaces do not impart prohibited substances to the organic food product.

Most organic processors use chlorine-based sanitizers because they don’t leave a residue. This is an easy solution to meet the sanitation needs of the facility. While the NOP doesn’t require residue testing for sanitizers, it can be an easy way for you to ensure and verify the integrity of your organic process.

Finally, it is essential that company employees be trained to implement these new organic procedures. It is not necessary that employees understand all of the technical aspects of the organic rule and its processes but it is important that they understand what behavior is expected and required to maintain organic standards, and what the consequences of not following those rules will be. This training is best conducted by the quality assurance leader.

Regular reminders to staff through meetings, signage, newsletters and informal interactions offer follow up opportunities to enforce a continuing commitment to organic procedures. Using your checklists and sign-in logs will verify that the change in behavior has become embedded in the process.

You Did It, but Can You Prove It?
Once you are ready to be certified, be sure you have the documentation in place to verify your efforts. As with any certification program, proof is everything and if you can not produce the data to support your efforts you may as well not have bothered doing them.

Your documented descriptions of how you are going to maintain the organic integrity of your organic processing operation according to the NOP requirements from receiving through packaging, labeling and shipping become your policies and procedures. These policies and procedures represent the main substance of your organic handling system plan which you are required to submit to the certifier. The plan must also include a description of monitoring practices and procedures to verify that the plan is effectively implemented.

Many processors maintain a policies and procedures handbook or quality manual for the conventional portion of their operation and a parallel handbook or manual for the organic processing portion of their operation. Logs are often used to document that specified tasks have been completed.

The organic handling system plan (OHSP) must include a list of substances used in the processing operation. This list will include ingredients used in or on organic products, the source of these ingredients, and the manner in which these ingredients will be used. The regulation includes a list of nonagricultural (non-organic) substances and a list of non-organically produced agricultural products that are allowed as ingredients in products under specific organic labeling categories. It is important to become familiar with this range of ingredients to understand potential challenges that might exist in formulating and developing your organic products.

Proposed product labels must be submitted to the certifier along with product formulations consistent with the three allowed labeling categories: 100% Organic, Organic, or Made With Organic [ingredients]. The first claim, “100% Organic,” must contain 100 percent organically produced ingredients, while products labeled as “Organic” must contain not less than 95 percent organically produced raw or processed agricultural products with the additional five percent or less being made up of NOP approved substances that are not reasonably available in organic forms. Products formulated and labeled as “Made With Organic,” such as “Made with Organic Apples” must contain 70 percent organically produced ingredients. Percentages are calculated by weight or fluid volume, excluding water and salt. Labels making any of the three above claims must identify the name of the certifier. Only 100% Organic and Organic products can bear the USDA Organic seal.

Lot numbers of product ingredients used to make the organic product must be maintained in inventory storage records and documented on product batch logs. The processed product must be assigned a lot number for traceability and this should be included on the product itself and under the finished product column on the batch log. A written explanation of all product lot numbers and a description of the recordkeeping system must be provided to the certifier. Finally, a description of how commingling of organic and non-organic products will be prevented must be included in the plan.

The organic regulation contains a provision for facility pest management. Your current pest management company may or may not be familiar with organic regulations but some pest management companies do have experience working with organic food processing operations. Your OHSP must contain a list of the methods and substances used to prevent or control facility pests. If you are in a segregated facility, your plan must also include the measures that you have taken to prevent pest management substances from coming into contact with organic ingredients or organically produced products.

The Inspection Process
Some certifiers employ their own organic inspectors while other certifiers contract with independent inspectors. In either instance, the inspector records observations and reports these observations in writing to the certification decision team. If the processing facility is sufficiently large and the process is very complex, more than one inspector may be involved in the inspection process.

Inspections may take two hours to more than one day to complete, again depending upon the complexity of the operation. The inspector will meet with designated staff at the beginning and throughout much of the inspection.

The inspector will ask questions and view documents, such as the policies and procedures manuals, data logs, and certificates, as well as viewing the facility. He or she will verify whether or not the organic system handling plan is being implemented as it was written. The inspector will also conduct a product audit, often tracing the composition of the end product using lot numbers, batch logs, sales and purchase invoices, and so on, to verify that this particular product is comprised of organic ingredients.

The inspector will write an inspection report that will be included in the processor’s application file for final review by the decision-making body of the certification organization.

The Big Finish
The certifier will make a determination to approve or deny organic certification of the operation. If organic certification is approved the certifier will issue a Certificate of Organic Operation to you, the applicant. A cover letter will note any areas of operation that need improvement by the next annual inspection or by a specified date.

It may take anywhere from one month to six months to complete the application/certification process. You can expedite the process by thoroughly completing the application packet and by quickly responding to the certifier’s request for additional information. The more incomplete items that the certifier needs to follow-up on, the longer the process will take. A more complex processing operation will also take more time to review and evaluate.

Segregation in Action: An Example
It may sound complicated, but by following these basic guidelines and using common sense, creating a segregated facility is not difficult. Here is brief look at how this process would work:

Imagine, that you are the organic transition leader for a jelly and jam company and that your company has decided to add organic strawberry jelly to the product line of 10 non-organic varieties of jam and jelly products that you already produce.

To accomplish this, you will have first read and understood the regulations. Then your team develops organic policies, procedures, product formulations and labels, and staff is trained for the new operation. Suppliers of organic strawberries and organic sugar are contacted and organic certificates verifying that these products are organic are requested, attained and filed in your dedicated organic certification file drawer.

You apply for and receive your organic certification status and are ready to produce product. Containers of organic strawberries begin arriving at the dock, where the receiving clerk verifies their organic identity and applies a bright yellow sticker bearing the word “organic” on each container. The same is true for organic sugar and any other organic ingredients received at the door. The organic product is then taken to dedicated areas in the cooler and dry goods shelves that have been clearly marked with the words “organic storage.”

Your organic policy manual states that organic strawberry jelly is made on Wednesday mornings before other non-organic product is processed. Wednesday morning arrives, the organic ingredients are retrieved from storage, and ingredient lot numbers and quantity of ingredients used are documented on the “organic strawberry jelly batch log.”

Processing equipment and utensils that were cleaned the night before are used in the processing of the organic jelly. Jars are filled with organic strawberry jelly and labels already approved by the certifier are applied.

Each jar receives the lot number used for the entire batch. The lot number is documented on the batch log. The finished product is placed in boxes that are labeled to clearly indicate the organic product inside. Clearly marked pallets of organic strawberry jelly now await shipping in a space dedicated to finished organic product inventory.

It does take some time and effort, but it can be accomplished. Whether your company makes jelly, bread, ice cream, chips or salsa, you will find that including an organic product in your conventional operation is not as difficult as you might have imagined.

Maury Wills is the Bureau Chief of the Agricultural Diversification and Market Development Bureau and Administrator of the Organic Certification Program at the Iowa Department of Agriculture and Land Stewardship. Maury and his family own and operate a small certified organic apple orchard, and process organic apple products in their state-licensed certified organic kitchen.
Wills can be reached at Maury.Wills@idals.state.ia.us.