Beyond the Checkbox: Controlling Your Organic System Plan

By Will Daniels


“Your organic certification is in jeopardy of being revoked if you do not correct the observations made during our last inspection.” No one wants to read these words after an inspection from a certification agent, but fear of just this happening is what keeps many of us up at night wondering whether we are really in control of our organic process. You can temper your fear of this dreaded phrase by having a solid plan for maintaining your certification that covers the important elements that enable you to develop and maintain a top-notch program.

With the implementation of the National Organic Program (NOP), organic processors are required to maintain a clearly documented and closely followed Organic System Plan (OSP) as a prerequisite for certification. An OSP is a detailed description of how your operation will achieve, document and sustain compliance with all applicable provisions of the NOP regulations.

Before granting certification to your operation, your certifying agent must concur that your OSP fulfills the requirements of NOP regulations. Your OSP must be updated annually and approved by your certifying agent (NOP 205.406). If you deviate from your previously approved OSP without written approval from your certifying agent, you are no longer in compliance with NOP regulations and could be subject to suspension or revocation of your certification.

While the OSP templates help structure the process, they are simply a series of check boxes and/or fill-in-the-blanks, which do nothing to help the processor tie the pieces together into a comprehensive control plan that ensures organic integrity and ultimately, certification. To achieve that, the processor must take planning a step further and develop an OSP that is as rock-solid as the company’s food safety plan—that means focus, dedication, commitment and most importantly, a process.

As they say in the audit/inspection world, if it isn’t written down, it isn’t happening. In other words, document everything. But to what extent? Plans can be as simple as a conversation between peers, a diagram on the back of an envelope, or an all-encompassing documentation of the process, the hazards (or problems that can occur), and the corrective actions that must happen should the process deviate from the intended path.

Many Hands Make Light the Work
The Hazard Analysis and Critical Control Points (HACCP) food safety model has quickly become the norm in food processing as a “plan” to control a process to reduce or eliminate hazards. Because it has proven to be highly successful in controlling hazards in the food manufacturing environment, there have been many attempts to implement HACCP in other aspects of control in processing operations. Although a HACCP-type plan isn’t quite right for ensuring organic integrity, the process you go through in developing a HACCP plan can be successfully applied to establishing a control plan for organic integrity. This can give you the reassurance you need about your organic processes to get a good night’s sleep.

Prior to developing a HACCP program, it is imperative to establish prerequisite programs. Prerequisite programs support the HACCP plan by creating an environment that facilitates your process. For example, prerequisite programs would include an Approved Supplier Program (ASP), which verifies that your raw materials, ingredients and processing aids are coming from a reputable source; a Sanitation Program documenting that you have a verifiably clean facility; and a Traceback/Recall Program, which enables you to trace your products forward and backward to ensure quality and identify where problems originate when they are detected in order to take corrective action. By establishing such prerequisite programs for HACCP, you position yourself for a successful food safety program because controls are in place for the peripheral areas of the process and plant environment. The same applies to the development of your OSP. Each one of these prerequisite plans is as important to organic integrity as they are to food safety.

I am sure you have heard the phrase “many heads are better than one.” Well, take it to heart when you are implementing any control plan. To ensure success, be careful to address the interests of everyone involved as you develop your plan. That way, no department or group feels alienated and everyone is more likely to have an ownership stake in the plan. As with food safety, a cross-functional, cross-departmental team of key personnel will facilitate successful development of the OSP and ensure that you are not overlooking anyone or anything. If anyone in the group is not well-versed in the organic standards, your first meeting should focus on educating them on the NOP regulation and organic standards requirements.

Ignorance is Not an Excuse
Once you have the OSP team in place, it’s time to start planning. Any successful plan starts with a map or flow chart that outlines your process, step-by-step (Figure 1). Be meticulous in the development of this document and don’t leave any step or process out. This is a useful tool to reference during any evaluation to ensure that you do not forget a step. It is also a great tool to outline the controls through the process and summarize your programs on one page (prerequisite, control points, food safety, OSP, and so on). Once you have a draft on paper, go out and follow product through your process with the draft flow chart in hand. Make sure your have documented all steps, processes and ingredients on your chart.

Defining your products is another important step to have in place prior to developing your control plan. Product specifications will provide an excellent reference when identifying ingredients or materials during your hazard evaluation. They provide your suppliers with clear guidelines for what you expect from their product when it is delivered. In addition, they provide an excellent reference during inbound inspection, process inspection, or in any training setting.

Knowing that your raw materials are coming from a reputable source is extremely important. Ensure that your suppliers are exercising due diligence to the process by establishing an Approved Supplier Program. An ASP can be extremely detailed and take a large amount of time to manage, or it can be as simple as ensuring that you have a current organic certification on hand from each of your suppliers. You decide what criteria are important for you and your processes. A good rule of thumb is whatever is being asked of you, you should be asking of your supplier. In other words, get documentation of your suppliers’ controls and processes, such as organic certification, annual inspections, food safety audits, water results, and letters of guarantee, just as your customers require from your operation in order to do business.

Remember that if your suppliers are from a different segment of the industry, their standards might be different from yours, so be sure to understand their world before imposing unrealistic standards upon them. Once the criteria have been established, communicate those to your suppliers. As they meet those requirements, develop an approved supplier list to reference upon delivery of materials. Having this program in place is an easy way to ensure you have a valid organic certificate on site for all products in house.

Haste Makes Waste
Your sanitation program is another key prerequisite to your OSP. Without building organically sound cleaning processes into your operation, certification will elude you. Your sanitation program should include the Sanitation Standard Operating Procedures (SSOPs), which detail the cleaning process for each piece of equipment in the plant. In that detailed cleaning description, you should document a method that eliminates the risk of contamination from your sanitizing agents. Your sanitation program should also document your control of chemicals on site, including up-to-date Material Safety Data Sheets (MSDS) and a procedure for reviewing chemicals for organic compliance prior to use.

A recall plan is one of the most important documents that you can have in your prerequisite programs. It is a requirement for any food safety program, as well as your OSP, and every credible organic inspection agency will audit for it during an inspection. You must be able to trace raw materials through your process to the customer, as well as from the customer back to the source of your materials, which in many cases, means all the way back to the field or farm. And you must be able to complete a forward or backward trace within two hours. Your recall plan should also include annual mock recalls. Although you will encounter resistance to testing your system, it is the only way to reliably uncover areas that need improvement—you’d much rather find these shortcomings during a mock recall than during the real deal.

By now you may be thinking, “My goodness! Does this guy think I am made of time?” While it’s true that this is a time-intensive process, taking these steps now, before a major problem occurs, is a great investment if it prevents a major catastrophe—such as the closure of your company because your plan did not protect the integrity of the products you manufacture and the company’s name has been raked through the mud in the media due to contaminated product.

There is No “I” in Team
Once you have established sound prerequisite programs, you are ready to develop reliable internal controls. It is time again to convene your OSP committee to help in the development of these internal controls. As in HACCP, the first step is identification of any hazards that threaten the integrity of your products throughout the process. Create a worksheet that identifies each step in your process, as well as the hazards associated with each step. This chart will help you work through the process methodically.

Refer to your flow chart frequently to ensure you are not missing any steps or ingredients. You may also reference product specifications to make sure that you’re not missing anything. Your worksheet should include:
• The process step or ingredient
• The hazard that exists in that particular area
• The control step established to eliminate the hazard
• The person who will be responsible for the control
• How it will be documented (if necessary)
• What corrective action you will take if the control is out of your specified range

Follow this procedure for the entire process, making sure you include each step and/or ingredient in that area.

It is important to note that any process can look good on paper. The only way that your team and your company will respect the importance of the plan is when you follow the procedures you’ve set on a regular basis. If your plan calls for your team to document a control step, be sure that the frequency of your check is reasonable to control the step, but not too frequent so that the employee is not able to keep up with it, which would cause a violation of the plan. This can be considered a violation during an inspection or audit.

Be sure to make your procedures and control points reasonable or they will not be followed, and then verify that they are being followed. A good way to do this is by requiring that a supervisor sign off on each control document that you produce daily, ensuring that the document is filled out correctly and accurately and that the control points were within specifications and tolerance ranges.

Finally, the OSP should be a living document and everyone should know that. What this means is that edits or amendments should be readily made if they make sense. If you are not keeping up with the changes on the floor, then your plan does not reflect what is actually happening. You cannot make the plan a success all by yourself, so encouraging everyone to make suggestions or comments. That builds ownership of the process, and ultimately, success!

Will Daniels is the Director of Quality Assurance, for Earthbound Farm the nation’s largest grower, packer and shipper of organic produce. He is responsible for the company’s food safety, food quality and organic integrity programs. An active leader in the organic industry, he serves on the board of directors of California Certified Organic Farmers as Vice Chair, as well as being president of the Processor/Handler Chapter. Daniels can be reached at will@ebfarm.com.