Organic Integrity: Upholding organic standards every day
by Lori Wyman, Independent organic processing inspector and education and information services administrator for Organic Trade Association

Reprinted with permission of Taste for Life, the leading publisher of in–store consumer magazines on nutrition and natural health.

When you choose organic products at your favorite natural, organic products store, you have the assurance that the food in the palm of your hand was grown and processed in accordance with the USDA's National Organic Program (NOP) regulations. The NOP's role is to accredit organic certification agencies that certify organic producers and handlers, and to propose and implement standards.

From before organic seeds are planted in the ground to the moment you hold a finished organic product in your hand, national guidelines assure that organic food is produced without the use of genetic engineering, sewage sludge, ionizing radiation, toxic and persistent pesticides, and synthetic fertilizers. These national organic standards address the methods, practices, and substances used in producing and handling crops, livestock, and processed agricultural products. Processing Requirements as well as farming and production standards apply to the way the product is created, rather than its measurable properties.

In the Real World
To show how these processes work, we visited New England Natural Bakers (NENB) in Greenfield, Massachusetts, makers of snack, cereal, and trail mix bars, granola, muesli, trail mixes and roasted nuts. Since 1977, NENB has produced natural snacks and cereals, and in the mid '80s as organic ingredients became more available, the company added organic varieties. In 2002 NENB made the decision to eliminate the use of any ingredient with genetically modified organisms (GMOs).

"Our organic lines have dramatically increased, especially over the last four years as consumer awareness has heightened," says Pam Clark, sales and marketing manager for New England Natural Bakers. "Everything new we add now is organic." In addition to the challenges of creating a competitively priced cereal with high standards and the desire to use as many organic ingredients as possible, NENB and other organic companies face a number of hurdles conventional food processing doesn't.

Avoiding "Commingling"
Commingling 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. Manufacturers producing both organic and non-organic items in the same facility are required to take steps to prevent commingling. Most food processing facilities conduct an extensive end-of-the-day cleaning and sanitizing. Cleaning and sanitizing are two different things; in a home kitchen, washing the dishes is "cleaning" while bleaching the cutting board is "sanitizing." In a commercial processing facility, both cleaning and sanitizing take place on a grand scale. An easy way to prevent commingling is for the first batch in the morning to be an organic batch. 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. At NEBN "we sanitize all of the equipment at some point, usually the weekend, prior to running on a Monday. We start the week with organic product only and run only organic on the cleaned equipment until the organic orders are complete," Clark explains.

Organic companies often need to adapt their equipment to meet the certification standards for organic processing. They must 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.

NENB has designated areas for storage of organic items and dedicated sections in the cooler and warehouse. "The organic certification for every ingredient arrives before the specific shipment itself," says materials manager Michael Baines. "The organic certification for every ingredient arrives before the product itself. We also have a system for checking every lot number at the end of each production run to double check that only the correct, organic ingredients were used."

Every company approved by an organic certification agency to process organic products has developed an organic systems plan. This plan contains a product flow chart and a system for tracking batches. The organic inspector precisely follows the route mapped out in this chart to ensure that all of the equipment down the line prevents commingling. In addition to the annual organic inspection by a certifying agent (like Quality Assurance International for NENB), other officials including the local Board of Health, Fire Department, and Occupational Safety and Health Agency (OSHA) and the Food and Drug Administration (FDA) regulate each facility.

The Paper Trail means the organic inspector also 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 for accurately following 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. In this way, s/he can see the certificate from the distributor verifying the authenticity of the organic ingredients, like organic peanuts and organic oats, for every batch of granola bars!

If the finished product will be labeled with any of the label options other than 100 percent organic, then all of the non-organic ingredients must have documentation stating that those ingredients were non-GMO, not irradiated, and never grown with sewage sludge. For any processed product labeled organic, all agricultural ingredients must be organically produced, unless the ingredient is not commercially available in organic form. Furthermore, these non-organic ingredients must have been approved by NOP for use in organic production.

Traceability
The intensive food traceability and tracking systems model used by the NOP serve as a model for other sectors of the food industry, especially in light of increasing concerns about food safety and the world political situation. This is the ability to track a finished product back to the farm. Traceability also details packaging and shipping rules under NOP procedures. At NENB, packaging must be coded with a number that corresponds with a particular batch of organic granola bars. This not only enables each batch to be tracked in case of a recall, as in conventional foods, but it is also traceable back to each organic ingredient.

For your Assurance
Organic food processing involves much of what you do every day in your own home, washing, baking, steaming-but on a larger scale. Just as you take food safety precautions to protect your family, manufacturers must follow not just standard food safety regulations-but also carefully regulated procedures to guarantee the integrity of the organic label.

Synthetic in Organic?
In the organic regulations, the term synthetic applies to any food ingredient manufactured by a process that chemically changes a substance extracted from a naturally occurring plant, animal, or mineral sources. One example is baking powder, which is made from naturally occurring minerals that are mined from the earth.

Organic handling standards require that all nonagricultural ingredients are included on the National List of Allowed Synthetic and Prohibited Non-Synthetic Substances. Common synthetics used as ingredients include calcium and vitamin C for nutritional enhancement or vitamin E as a preservative. Certain gasses such as carbon dioxide for carbonation of beverages and ethylene for ripening bananas and other fruits is allowed in the processing of organic foods. In total, 38 synthetics are allowed in organic foods. By contrast there are over 10,000 synthetics allowed in conventional foods! For more information on "synthetics" visit: http://www.ota.com/standards/nosb/otacomments/Syn/20060418.html  also http://www.tigersandstrawberries.com/2005/10/13/those-darned-chemicals-v-the-final-confrontation/

What's in a Label?
All food products labeled as organic in the United States are governed by consistent standards. Implemented in 2002, U.S. organic standards allow four different labeling options based on the percentage of organic ingredients in a product. These include three distinct categories (all of which prohibit the use of any ingredients from genetic engineered seeds, irradiation, or sewage sludge) and a fourth option for products that contain organic ingredients but not at a high enough level to meet one of the three labeling categories. To assist consumers, USDA has designed a seal that may be used only on products labeled as "100 percent organic" or "organic." Use of the seal is voluntary, but is seen as a useful tool. Grocery stores are increasingly using the "USDA Organic" seal on shelf talkers and other point of purchase materials to help identify organic sections in the store. Non-food products that meet the requirements for using the "USDA Organic" seal can also use the seal.

Categories:

•  100 percent organic: Only products that have been exclusively produced using organic methods and that contain only organic ingredients (excluding water and salt) are allowed to carry a "100 percent organic" label.
• Organic: This signifies that at least 95 percent of the ingredients (by weight, excluding water and salt) in a processed product have been organically produced. The remaining contents must be natural or synthetic ingredients not available in an organic form that are recommended by the National Organic Standards Board and allowed on the National List (for specific information on the National List, see www.ota.com/listbackground05.html).
• Made with organic: Products with at least 70 percent organic ingredients may display "Made with organic [with up to three specific organic ingredients or food groups listed]" on the front panel.
• Products with less than 70 percent organic ingredients can list the organic items only in the ingredient panel. There can be no mention of organic on the main panel.
   
  Consumers choosing organic products have the assurance that by doing so they are supporting farmers committed to maintaining the long-term health of our environment.