These are the steps to take for a company that wants to be certified as a handler of organic products which is defined as “any operation or portion of an operation that receives or otherwise acquires agricultural products and processes, packages, or stores such products.” (7 CFR 205.270). "Organic Handler" includes any operations that handles open products – whether full processing or just repacking – once the incoming organic materials are opened they are no longer covered by the supplier’s certificate and need a new certification in the new facility. It does not include farmers/growers that have a different set of requirements.
1. Implement Organic practices
Source ingredients from organic certified suppliers
Developing a process for changeover between non-organic to organic products
Purchase color-coded equipment for organic (if dedicated equipment is needed)
Set up a separate area in the warehouse for storage of organic materials
Implement a traceability/lot tracking system
Purchase organic-approved sanitizers
Inform the pest control company and ensure their practices are are compliant
Check the operation for any potential non-organic contaminants – boiler additives, sludge, fumigants, etc. – and find alternative means
Train and communicate organic requirements to relevant staff
2. Prepare the required documentation
Application/Questionnaire from the certifying agency which details all relevant details about the company, operations, and organic products
Lists of suppliers, ingredients, and products
Organic Product Profiles (OPP’s) for each organic product listed in the product formulation and listing the supplier and organic certification for each component
Organic Certifications and Product Specifications from all ingredient suppliers
Cleaning: cleaning instructions, and SDS and labels on file for each chemical
Pest Control Program: organic practices statement, site map, SDS, and service reports
Boiler/Steam Material Labels/SDS Forms
Facility Floor Plan showing the organic processing area and a flow diagrams showing the production process
Water testing report
Traceability Records and Audit Trail (mock trace exercise)
Cleaning Records: general cleaning + organic product changeover cleaning
Shipping/Receiving Inspection Records
3. Decide to which category of organic you want to be certified:
“Organic”
“100% Organic” or
“Made with organic _____” (ingredient).
Plain “Organic” actually requires that the product are 95% Organic (not including water and salt) but that doesn’t mean that companies can choose to add 5% of non-organic ingredients because they feel like it or to save money, rather it means that specific items that are not available in non-organic form and are on the USDA National List of Allowed and Prohibited Substances can be added up to 5%. So in most cases plain “Organic” actually does mean 100% and companies can choose to use that or go all the way and claim “100% Organic” if they choose to. For companies that want to claim the use of organic ingredients without being fully organic they can use the “Made With” claim for an organic ingredients that more than 70% of the product. This is per product by the way not per company – you can choose to have different products at different levels of organic. See https://www.ams.usda.gov/grades-standards/organic-labeling-standardsfor more information.
4. Design your labels with the Organic seal on them.
While a company cannot legally sell products with an organic label until after you're certified, the labels (or packaging, if the labeling information is printed directly on the packaging) for each organic product need to be designed the labels beforehand since they need to be reviewed as part of the inspection process – art proofs or mock ups are acceptable if the final version is not ready yet. Here are some requirements for the Front Label (USDA Seal) and Back Label ("certified by...)
5. Finally go through the actual certification process which involves:
Choosing a Organic Certifier and signing and agreement with them
Fill out the certifier’s Application/Questionnaire and send it in along all supporting documentation (and payment!)
After the certifiers reviews the documents, make changes or submit additional documents based on what they request
Have the onsite Organic Inspection
Submit responses to any findings
Receive the Organic Certificate and start producing organic-labeled products
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