Critical Control Points for Organic Certification

a HACCP based approach to organic certification

Jonathan Lackie Business Development Manager Quality Assurance International

I. QAI Background II. The Organic Certification Process

A. Product Composition & Labeling B. Product Protection C. Five Steps to Organic Certification

Agenda

As a pioneer in the organic industry for over 20 years, QAI remains a leader and advocate for certified organic practices today

As a member of the NSF International family of

companies, NSF’s heritage in food safety combines with and compliments QAI’s leadership in organic certification

Quality Assurance International Certifying integrity of claims and products,

from field to retail shelf, since 1989

USDA – National Organic Program

European Recognition Programme

Canadian Organic Regime

Conseil des appellations reserves et des termes valorisants (CARTV, Quebec Canada)

Japanese Agricultural Standard

NSF/ANSI “Contains Organic Ingredients” Personal Care Certification

NaTrue Personal Care Certification

Gluten-Free Certification

QAI Certification Services

The Organic Certification Process

Key Regulations for Processors

USDA Organic Regulations

TITLE 7--Agriculture

Subtitle B- Regulations of the Department of Agriculture

Chapter I- Agricultural Marketing Service (Standards, Inspections,

Marketing Practices), Department of Agriculture

Subchapter M - Organic Foods Production Act Provisions

PART 205 -National Organic Program

205.201 (a) The producer or handler of a production or handling operation, … must develop an organic production or handling system plan that is agreed to by the producer or handler and an accredited certifying agent.

Establish an Organic Certification Plan

205.301 - 3 Recognized Levels of Organic Certification: 100 Percent Organic.

• 100% organic ingredients (excluding water and salt) • Processing aids must be certified organic

Organic • ≥ 95% organic (excluding water and salt) - 5% must be from

allowed non-organic ingredients ( 205.605 & 205.606) and free from prohibited methods - Genetic Modification, Ionizing Radiation and Sewage Sludge (as a fertility input)

Made with Organic • ≥ 70% organic (excluding water and salt) - 30% from allowed

non-organic ingredients ( 205.605) or non-organic agricultural ingredients produced without the use of prohibited methods

Product Composition

205.300 (a) The term, “organic,” may only be used on labels and in labeling of raw or processed agricultural products, including ingredients, that have been produced and handled in accordance with the regulations in this part. The term, “organic,” may not be used in a product name to modify a nonorganic ingredient in the product.

Product Labels & Marketing Regulations

205.303 Packaged products labeled “100 percent organic” or “organic.” • May display the claim “100 percent organic”

or “Organic” as applicable • May use the USDA Organic Logo or

Certification Agency Logo • Must identify each organic ingredient in the

ingredient statement as organic • Must identify the certification agency with the

phrase “Certified Organic by …” below the information identifying the handler or distributor

205.304 Packaged products labeled “made with organic” • May NOT use the USDA Organic Logo • May display the statement “Made with

Organic (Specified Ingredients or Food Groups)

• May use the Certification Agency Logo • Must identify each organic ingredient in

the ingredient statement as organic • Must identify the certification agency

with the phrase “Certified Organic by …” below the information identifying the handler or distributor

205.311 USDA Seal. • Color logo must be green with a brown outer circle and a white

background. • Black logo may have a white or a transparent background. • Certifier’s logo cannot be more prominent that the USDA Seal

205.272 (a) The handler of an organic handling operation must implement measures necessary to prevent the commingling of organic and nonorganic products and protect organic products from contact with prohibited substances.

The National List of Allowed and Prohibited Substances • 205.605 - Non-Agricultural • 205.606 - Agricultural

Product Protection

Storage & Handling

• 205.272 What management practices and/or physical measures are in place to prevent commingling of organic and non-organic ingredients or products?

Packaging Materials

• § 205.272 (b)(1) Are packaging materials or containers free of prohibited synthetic fungicides, preservatives and fumigants?

Water

• Does water come into contact with certified organic products?

– Potable as defined by the Safe Water Drinking Act • Is water chemically treated in your operation?

– i.e. – Boiler Treatment Additives

Salt

• If salt is used, is it free from prohibited “free-flow” and “anti-caking” agents?

Cleaning and Sanitation Products

• If using sanitizers not on the National List ( 205.605), how are you able to verify that sanitizer residues are removed from food contact surfaces prior to organic handling?

Facility Pest Management

• 205.271 - Facility pest management practice standard.

“Pest Control Hierarchy”

205.103 (a) A certified operation must maintain records concerning the production, harvesting, and handling of agricultural products that are or that are intended to be sold, labeled, or represented as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s)).”

Recordkeeping and Audit Trail

Records of Organic Production must: • Be designed to the operations being performed; • Fully disclose all activities and transactions in sufficient detail as to

be readily understood and audited; • Be maintained for not less than 5 years beyond their creation; • Be sufficient to demonstrate compliance with organic regulations • Be made readily available at the organic inspection

Step 1: Application for Organic Certification • Contact a certification agency accredited by the USDA’s

National Organic Program • Provide the certification agency with all of the details

and scope of your organic operations

Step 2: Review of the Organic System Plan • Certification agency will review application documents to ensure the

application is complete and that procedures are in compliance with NOP regulations.

Five Steps to Organic Certification

Step 3: On-site Inspection

• Certifier schedules an on-site inspection with a qualified inspector • During this audit, the inspector will verify the information provided

during the application process. • Inspector prepares an Inspection Report for the Certification Agency

Step 4: Review of the Inspection Report

• Certifier reviews the results of inspection report and compares it to the original application to ensure consistency and compliance with the organic regulations.

Step 5: Certification Decision

• Notice of any non-compliance issues that must be resolved with corrective actions prior to certification, or

• Organic Certification (may include minor conditions that need to be addressed to maintain certification)

Resources Guide to Organic Certification Guide for Organic Processors Program Handbook Organic Materials Review Institute Organic Industry Consultant List

Questions?

Thank you! Jonathan Lackie

Business Development Manager E-mail: jlackie@qai-inc.com

www.qai-inc.com 858-200-9708