Recordkeeping for Processors and Handlers

What Are The Organic Record Keeping Requirements for Processors and Handlers

Summary: If you process or handle organic products, you must keep detailed and traceable records.

These records must demonstrate compliance with USDA organic standards. Certified operations are required to make their records available to representatives of their certifier, including inspectors, during normal business hours. If you are unable to provide an inspector with the records they request, you may be issued a noncompliance notice. If you refuse to provide access to records applicable to your organic operation, Oregon Tilth may propose revocation of your certification

Why Recordkeeping Matters for Organic Processors

Strong recordkeeping is essential to maintaining your organic certification. Your records must demonstrate the organic status and traceability of products and from sourcing/procurement through receiving, storage, production, packaging, and shipping, and must verify that organic integrity was maintained throughout.

Core Organic Recordkeeping Requirements

What records must processors and handlers keep?

You must maintain documentation that covers all major activities in your facility, including:

• Ingredient sourcing and receiving
• Importing (if applicable)
• Storage and Inventory management
• Batch production and processing
• Sanitation and pest control
• Shipping, and sales

Your Organic System Plan (OSP) outlines what records you maintain and how those records capture your operation’s compliance with organic regulations. These records make up your operation’s “audit trail.”

All records must be:

• Available for inspection and copying during normal business hours
• Adapted to fit your specific operation
• Clear, organized, and auditable

How long do I need to keep records?

You must keep all records related to the production, handling, sale, and labeling of organic products for at least five years.

Audit Trail Exercises for Processors

At each annual inspection, your inspector will test your recordkeeping system by conducting at least two Audit Trail Exercises. There are two kinds of Audit Trail Exercise:

• Traceback exercise: The inspector traces a finished product from sale/shipment back to the purchase/receipt of each ingredient using unique identifiers like lot numbers.
• Mass balance exercise: The inspector verifies that your operation produced enough organic product or received enough organic ingredients to account for the amount of organic product that was produced, shipped, and/or sold as organic within a certain period of time; in other words, that your “ins” and “outs” balance.

How do I prepare for the Audit Trail Exercises?

Review your OSP H8 for the records your inspector will expect to be provided, and be ready to produce any record listed in your OSP as part of your “audit trail.” Be prepared to demonstrate traceability using your records. This may include use of lot numbers or other unique identifiers. During the audit trail exercise, inspectors will review documentation that tracks organic products from receiving through production and shipping. Records should clearly identify the product and link each step in the process.

During the audit exercises, inspectors will check that:

• The quantity of ingredients used is consistent with the quantity of product produced.
• Only certified organic ingredients and other approved inputs were used.
• Products, ingredients, and materials can be traced through receiving, production, inventory, and shipping records.
• Records identify products with the correct organic designation (such as 100% organic, organic, or made with organic (specified ingredients or food group(s)), as applicable).
• Records are complete, accurate, and consistent with your actual practices.
• The practices described in your OSP, including sanitation, pest management, and commingling prevention, are reflected in the records you keep.

Sanitation & Pest Control Records

Keep records that demonstrate equipment, containers, storage areas, and transportation vehicles are cleaned as needed to protect organic products from contamination and commingling.

What sanitation records must I keep?

Depending on your operation, records may include:

• Cleaning records for equipment, processing lines, and food contact surfaces.
• Cleaning records for reusable containers, bulk bins, or storage areas.
• Cleaning records or clean truck affidavits for vehicles transporting bulk or unpackaged organic products to verify they were cleaned before loading.
• If “purging” or “flushing” is used to remove residual non-organic material from processing lines, the operation must maintain records documenting the purge or /flush, including the quantity of material used or disposed of.

What pest control records must keep.

Depending on your operation, records may include:

• Pest monitoring or activity logs
• Records of preventive and control measures used
• Documentation for any pest control materials used

Receiving Records

Keep records that verify the organic status of ingredients and materials received. Depending on your operation, these records may include:

• Purchase orders, receiving records, and invoices that identify ingredients as organic.
• Receiving records that document lot numbers, quantities, and storage locations.
• Current organic certificates for certified organic ingredients and suppliers.
• Import documentation such as NOP Import Certificates, when applicable. 
• Product specifications or specification sheets for multi-ingredient products.
• Documentation showing non-organic ingredients comply with USDA organic requirements.

Batch Production Records

Batch production records document the ingredients used to produce each batch of product.

Batch production records should include:

• Batch or lot number.
• Ingredient lot numbers.
• Quantities of each ingredient used.
• The product produced and the quantity manufactured.

These records should correspond with your approved product formulations, Master Ingredient List (MIL), and Master Product List (MPL).

Inventory Management Records

Keep records that accurately track the receipt, storage, use, and inventory of organic products and ingredients. Depending on your operation, these records may include:

• Inventory records showing ingredient and product quantities.
• Lot numbers or other traceability information.
• Inventory counts, cycle counts, or physical inventory records.

Inventory reconciliation records that compare quantities received, used, produced, and shipped.

Shipping & Sales Records

Keep records that document the movement and sale of certified organic products and maintain traceability from production to your customer.

Depending on your operation, these records may include:

• Sales invoices that identify the organic product and, when applicable, the lot or batch number.
• Bills of lading or shipping documents.
• Packing lists.
• Shipping logs or dispatch records.
• Export documentation, such as transaction certificates or certificates of inspection, when applicable.
• Records identifying the customer, shipment date, quantity shipped, and destination.

These records should support traceability and correspond with your production, inventory, and receiving records.