Different Labels, Same Risks

It’s probably safe to say that if you ask the general public how organic foods differ from conventionally produced foods, many people would say that organic foods are healthier and safer to eat, but cost a lot more. If you ask environmental enthusiasts the same question, they may tell you that organic foods are better for you and for the environment. On the same note, organic producers would probably tell you that their foods are different than conventional products because they follow specific guidelines that influence how they are grown, harvested and process, including the USDA Agricultural Marketing Service Standards.

But, do organic foods really have an advantage over conventional foods? Are organic foods healthier, more nutritious and safer than foods grown and produced by conventional methods?

The bottom line is that organic and conventional foods both come with the same concerns when it comes to risk and risk avoidance. They also share the same approach to organizing programs and procedures that help prevent contamination and provide safe and healthy foods. Manufacturers of organic and conventional foods share the same legal and ethical responsibilities to provide safe and wholesome foods. They prevent product contamination by implementing good manufacturing practices (GMPs) and prerequisite programs that build the foundation for HACCP and food safety.

GMPs fit very well together with organic standards. There are a variety of conventional manufacturing programs that organic manufacturers can adopt and include in their organic handling plaNS and GMP compliance manuals.

ORGANIC HANDLING PLANS. Organic manufacturers are required by their USDA accredited certifying agent to develop organic handling plans that comply with the National Organic Program. These plans offer a comprehensive explanation of how the facility intends to comply with the standards and become certified. The plan outlines the facility’s strategy to maintain the integrity of organic products.

In addition to the organic handling plan, organic manufacturers also must implement GMP or prerequisite manuals. These comprehensive plans are used by conventional manufacturers to outline their strategies for producing, packaging and shipping foods in compliance with FDA regulations.

EDUCATION AND TRAINING. Education is essential to maintain the integrity of organic products and to stay in line with the organic handling plan. Managers, supervisors and employees must understand the purpose and objective of the facilities programs. Every employee must understand why it is important to keep organic products and packaging separate from conventional products and why co-mingling organic and conventional materials is considered contamination.

RECEIVING AND STORAGE. Raw materials used to process organic foods must be certified as organic. Manufacturers can verify this by obtaining documentation from their suppliers. Once received, organic raw materials are stored in a warehouse designated for organic materials or segregated appropriately in the main warehouse. Segregation is necessary to separate organic and conventional raw materials and prevent co-mingling or cross contamination. Packaging materials for organic products must also be stored separated from conventional food products. There are two prerequisite programs that manufacturers can implement to maintain organic integrity during receiving and storage.

Transportation and Storage Program: Upon receipt, an employee completes an incoming materials inspection for all raw materials and packaging for signs of damage or contamination as they come off the trailer or railcar. The trailer or railcar also should be inspected for damage or signs of contamination. The receiving employee typically is responsible for making sure that delivered items match the bill of lading. During this inspection, she would make sure that the organic certification documents are included with shipments of organic raw materials.

Allergen Control Program: Policies for receiving, identifying and segregating organic materials in storage are the same as those used to control allergenic raw materials. In fact, the organic handling plan is similar to allergen management. Segregation does get more complicated when organic products must be segregated from conventional products, and when allergenic materials must be segregated from non-allergenic materials.

PRODUCT FORMULATION. As with any quality system, the formulas used by production employees specifically identify the raw materials used to make products. These formulas are the basis for the information required on the organic production formulation sheet (which may be titled differently by your certifying agent). This information determines by percentage the amount of organic and non-organic ingredients included in the product. The percentage of organic raw materials is what stipulates the type of organic label that can be applied to product packaging.

The formula also indicates which raw materials must be included on the ingredient statement. If the product contains or may contain any food allergens, the ingredient statement is the only source of information consumers have when deciding what foods are safe for them or their family members who have food allergies.

Strictly followed accurate formulas are critical tools to maintain organic integrity and consumer safety.

PROCESSING AND CLEANING PRODUCTION EQUIPMENT. When possible, organic products should be run first or after a deep cleaning to ensure that all conventional products and residue are removed. When organic products are run after conventional products, the changeover process must include thorough cleaning to remove conventional product residue. Another option is to purge with organic products, which means that the organic product is run after processing a conventional product long enough to remove any conventional material left behind. However, with this option, the organic raw material used for purging must be sold as a conventional product.

In any case, cleaning is an essential part of the organic handling plan and the GMPs. A variety of cleaning options are available for organic and conventional manufacturers. Sanitizers that will come in contact with organic products must be included on the National Organic Program’s (NOP) National List of Allowed and Prohibited Substances and approved for use in organic processing. If the cleaners and sanitizers used are not on the list, you can follow the cleaning with a rinse or intervention step to adequately remove them from the food contact surface. The rinse procedure will depend on the residual activity of the last sanitizer used prior to organic production. Cleaning dry processing equipment that is not dedicated to organic production is a little different and uses mechanical cleaning and purging with organic raw material.

PACKAGING. Packaging materials used for organic foods must be kept in an area where they can be protected from co-mingling with conventional foods or food residue, such as dust from raw materials. They also must be managed in a way that prevents accidental use when producing conventional products. Mislabeling conventional products as organic can show a lack of control and a failure to follow the organic handling plan.

Stored packaging materials should be protected from various sources of contamination. A clean and well-maintained warehouse helps to prevent pest contamination and cross contamination from allergens or foreign materials. It is a common practice to keep packaging materials covered until used and to cover partial pallets between production runs to avoid contamination.

PEST MANAGEMENT. The NOP has specific requirements for pest control that are in step with the current Integrated Pest Management approach. The NOP expects organic handlers to remove or exclude pests by removing habitats, food sources and breeding areas. Pest activity is greatly reduced when you prevent facility access and manage the environment. Other acceptable methods of control for organic producers include mechanical traps, light or sound deterrents, and repellents.

Organic producers do have options if these techniques do not work. Non-synthetic or synthetic substances that are consistent with the national list may be applied. If this approach does not work, synthetic substances that are not on the national list may be applied if the organic handler and certifying agent agrees on the substance and method of application. In addition, the handler must take steps to prevent contact between the organic products and the substance used. As a last result, organic producers may use substances approved by federal, state or local regulations as long as steps are taken to prevent contact with the organic products and raw materials.

Any steps taken to manage pest activity must be clearly explained in the organic handling plan and also in the GMP compliance manual.

SUMMARY. Organic producers that implement organic handling plans and prerequisite programs will enhance their operations and produce products with food safety in mind. As with conventional foods, GMPs and food safety work together to ensure the integrity of organic foods and comply with federal regulations. These programs allow consumers to select organic or conventional foods with confidence and know they are providing safe and wholesome foods for their families.