An Inspector’s Perspective:
Best Practices for Organic Food Processors

By Lori Wyman


In organic certification, it’s all about the process. In other words, rather than testing the final product to measure certain properties, organic standards instead carefully verify each and every step—from production and processing to labeling—taken to create each product.

This means that organic companies often need to adapt equipment to meet the certification standards for organic processing. They must also draw from a list of approved cleaning substances that can come in contact with the food. For example, residues from quaternary ammonia sanitizer are permitted to come in contact with conventional foods—but not with organic—so organic inspectors use test strips to check for its presence. Organic companies must also utilize preventative, nontoxic pest controls such as traps and lures rather than routinely spraying pesticides or rodenticides.

Organic inspectors encounter a variety of ways in which food processors go about complying with the standards, often involving innovative and creative methods. These producers should be commended for their enthusiasm and financial investment in developing systems that do the job. These innovations may include computer systems for tracking organic lot codes, specially designed storage and handling containers to prevent commingling and NOP-approved sanitation systems for food safety. Below are some excellent examples from a variety of businesses that were willing to share their methods with Organic Processing Magazine’s readers.

Commingling and Contamination
Contamination is a term that organic inspectors use when an organic product comes in contact with a prohibited substance that may be allowed in conventional foods. By keeping the organic ingredients separated by packaging, barriers or distance, the organic ingredients are less likely become contaminated. The term “commingling” is used when these practices are not adhered to and organic products or ingredients come in contact with conventional ingredients, which could compromise their organic integrity. Manufacturers that are producing both organic and non-organic items in the same facility are required to take steps to prevent commingling and contamination.

The George Howell Coffee Company, an artisan coffee roaster based in Acton, Massachusetts that focuses single estate and micro-lot coffees, is an example of a facility that is an inspector’s delight. Most coffee roasters store raw beans in big jute bags that are often left open, exposed to air and airborne contaminants. George Howell, however, instead works directly with its small producers to ensure that organic green coffee beans are put into vacuum-sealed bags directly after harvest.

This is not only an easy way prevent contamination and commingling, it also ensures that the beans stay fresh, said Jerry O’Hare, sales and customer service manager. “Either packed at origin or repacked at the warehouse upon arrival, moving coffee out of the industry-standard jute bags not only benefits the freshness of the coffee, but helps maintain the path of organic integrity as well, making the path much more manageable,” he said.

Another good example of contamination prevention is Cedar’s Mediterranean Foods’ innovative color-coding system. Cedar’s Hommus is located in the Merrimack Valley of New Hampshire, about 35 miles north of Boston, where they produce three varieties of organic hommus. Cedar’s prides themselves on their fresh ingredients. What makes them unique compared to other hommus facilities is that they steam their own chick peas while many other companies use canned or dried chick peas. The company’s organic processing methods are no exception to these high standards. Cedar’s quality control department color codes utensils, tubs and even the coats worn by production staff. Anything used for organic production is labeled green to indicate “Organic Only.” Quality control manager Samo McGray explains, “The whole company recognizes we are processing organic products when they walk through and see all the green colors on equipment and employee coats.”

Keeping Things Clean
In a commercial processing facility, both cleaning and sanitizing take place on a grand scale. Most food processing facilities that produce organic products conduct an extensive end-of-the-day cleaning and sanitizing and then the first batch in the morning is organic. Only after that batch is finished do the non-organic batches go through the system. In this way, the raw organic ingredients are processed in cooking equipment that has been thoroughly cleaned after processing the last conventional ingredients.

Kettle Cuisine, based in Chelsea, Massachusetts, is at the forefront of a growing demand for exceptional-tasting real food that satisfies everyday wellness lifestyles. Jerry Shafir, president and CEO and executive chef Volker Frick have developed more than 50 premium soups, stews, chilies and chowders by using artisan cooking techniques and ensuring that food is handled with care from the source to the company’s kitchen and then to the consumer.

One important process that enables them to meet their high standards and organic certification is sanitation. They keep things clean at Kettle Cuisine by using a machine called a two-lane tunnel washer, which washes, dries and sanitizes. While most machines still need to be washed down with a chemical sanitizer, this machine uses intense heat to sanitize, thereby eliminating the need for chemicals. A belt transports containers, utensils and other storage and handling devices through a 160-degree F recirculating wash chamber. After leaving the wash chamber, containers are rinsed and sanitized at 180 degrees F before exiting the machine. A dwell zone is provided between the wash and rinse sections to prevent cross-contamination of fresh and detergent water and to manage the flow of the water back into the re-circulating wash tank or to a drain.

The Paper Trail
During the annual organic inspection, the organic inspector examines the books to make sure that the number of pounds of organic raw ingredients matches up with the amount of finished organic product. A tracking system is required to accurately follow the product flow of every batch. The inspector also must review organic certification documents from all ingredient suppliers for each substance used in each organic product.

Also, in light of increasing concerns about food safety, the intensive food traceability and tracking systems required by the NOP are now being used as a model for other sectors of the food industry. This is the ability to track a finished product back to the farm. Traceability also ensures that packaging and shipping rules under NOP procedures are met.

One company that illustrates best practices in tracking and traceability is Venus Wafers Inc. Based in Hingham, Massachusetts, Venus is a family-owned baking facility that has been producing crackers since 1930. In addition to organic certification, they are AIB Superior and BRC certified.

What sets Venus apart regarding tracking and traceability is the fact that they involve staff all along the production chain in the effort. Unlike most facilities that rely solely on Quality Assurance employees to handle such matters, Venus trains several of its staff at each stage on organic tracking documentation, as well as organic handling procedures.

According to Fran Haddix, quality assurance manager, “The most important part of record keeping is making sure everyone is properly trained on all the programs, from shipping and receiving to mixing and production. It is also important to check your supply chain, from ingredients to packaging materials, for NOP compliance.”

Here are a few of the tracking programs used by Venus Wafers:

Record Keeping: The distribution records should contain sufficient information to permit traceability to a particular code or lot number.

Raw Material Tracking:
• The receiving records should be accurate and maintained on a daily basis.

• Receivers must record the product received, the amount received and the product lot code.

• Receivers should monitor the raw materials such that proper stock rotation is maintained.

• If any of the raw materials are damaged and must be destroyed, the amount of product destroyed must be recorded for proper reconciliation.

• Mixers should accurately record the lot numbers used in each batch.

• Mixers who store minor ingredients in white ingredient bins must record the lot number of the replacement product.

Product Code Identification:
• Each pre-packaged food has permanent, legible code marks or lot numbers on the packages.

• The code identifies the day on which the food was produced or an expiry date which can be traced back to the manufacturing date.

• Code marks used and the exact meaning of the code should be available.

• Where used, case codes should be legible and represent the container code within.

In Closing
The companies discussed here are shining examples of enthusiasm and respect for the organic industry. Incorporating these types of best practices can make an inspector’s job much easier and help your company avoid confusion and obstacles that can draw out the inspection process—leading to fewer headaches, less wasted time and oftentimes a better product.

Lori Wyman is the certification and outreach manager for Control Union Certification, a logistics, quality, certification and risk management company. She works with many organic food processing operations as well as organic textile manufactuers—inspecting mills, spinneries, bleacheries and dye houses according to the Global Organic Textile Standard (GOTS). Lori has worked in the natural products industry for over 25 years, most recently in the role of education and outreach specialist for the Organic Trade Association. Contact Lori at lwyman@controlunion.com.