Sanitation and Preventing Contamination
What To Know About Sanitation and Preventing Contamination in Organic Operations
Summary: To maintain organic integrity, you must prevent contamination from prohibited substances and commingling with non-organic products. Key areas of risk include shared equipment, storage, transportation, and pest control. Certified organic operations must follow strict sanitation and documentation protocols, especially in split or shared-use environments.
Contamination Prevention in Organic Handling
How do I identify risk areas for contamination?
Contamination occurs when organic products come into contact with prohibited substances. Common contamination risk areas include:
- Co-storage of organic and non-organic products
- Reuse of containers between organic and non-organic use
- Use of equipment without proper sanitation
- Storage or use of prohibited substances near organic ingredients
- Inadequate cleaning procedures on shared surfaces or tools
Shared Kitchens
If you use a commercial or shared-use kitchen, coordinate with other users to understand their materials and sanitation practices. Document preventive actions, such as:
- Cleaning protocols
- Labeling of ingredients
- Storage plans
- Pest control agreements
Strategies to Prevent Contamination
Develop a clear, site-specific plan based on your operation’s layout and activities. Key strategies include:
- Clearly labeled and segregated storage areas
- Sealed, tamper-evident packaging
- Cleaning records for shared transport or storage
- Use of dedicated or properly purged equipment
- Staff training on organic protocols
Preventing Commingling of Organic and Non-Organic Products
What is commingling?
Commingling refers to the contact between organic and non-organic ingredients or products, compromising organic status.
Where does commingling happen?
High-risk areas include:
- Split operations (handling both organic and non-organic)
- Shared equipment or storage
- Bulk handling and repackaging
- Inadequate labeling or signage
How to Prevent Commingling
- Use clearly marked containers and storage zones
- Maintain accurate, visible labeling at all stages
- Train employees on separation procedures
- Use dedicated or thoroughly cleaned equipment
- Log cleaning or purge events for shared equipment
For practical examples, review: WSDA’s Preventative Practices for Organic Handlers.
Equipment Use and Cleaning
Can I use equipment for both organic and non-organic products?
Yes, but you must document a cleaning or purge process before organic production begins.
When is purging required?
Use a purge when cleaning alone cannot remove residues. This involves running a batch of organic product to flush out any non-organic material.
Note: For safety, always purge shared equipment prior to running a full organic batch. Purged product cannot be sold as organic.
When is purging not required?
If the equipment can be cleaned effectively to remove all residues and is verified through testing or visual inspection, purging may not be necessary.
Pest Management Requirements
What’s allowed in organic pest control?
The USDA requires a tiered approach:
- Prevention – Exclude pests by:
- Removing food and habitat sources
- Sealing buildings
- Managing temperature and moisture
- Mechanical Controls – If prevention fails, use traps or barriers.
- Approved Materials – If needed, use only approved substances such as:
- Carbon dioxide
- Boric acid
- Diatomaceous earth
- Vitamin D3 bait
- Soap-based products
Synthetic Pest Controls
Only allowed as a last resort, with OTCO pre-approval and documentation of failure of all other measures.
To request approval, submit:
- Product label
- Safety data sheet (SDS)
- Documentation of failed prevention and mechanical controls
- Updated Organic System Plan (OSP)
Storage and Organic Integrity
Can I store organic and non-organic products in the same facility?
Yes, if you prevent contact and commingling. Use barriers, signage, and separate areas.
Using an uncertified storage facility?
Allowed if:
- Products are sealed and labeled
- No repackaging, relabeling, or processing occurs
- Facility completes an Independent & Off-Site Storage (IS) form
- Disclosed in your OSP
Download the IS Form and submit it to your OTCO client service team.
Organic Transport Requirements
Storage during Transport
For bulk shipments, cleaning logs for containers are required. For permeable containers, ensure protection from prohibited materials during transit.
Certified transporters?
Not required. You may use non-certified transporters if your product is:
- Sealed
- Clearly labeled
- Not altered during transport (no relabeling, repackaging, or atmospheric treatment)
Note: Organic livestock transport requires different certification rules.
Approved Sanitizers and Materials
Can I use non-organic sanitizers if they don’t touch the product?
Yes, but you must:
- Ensure no residue is left behind
- Rinse or air-dry equipment as needed
- Document procedures in your OSP
Sanitizers that touch organic products must be approved
Examples of approved COVID-19-era sanitizers:
- Hydrogen peroxide
- Peracetic acid
- Sodium hypochlorite
- Hypochlorous acid
- Isopropanol and ethanol (post-harvest only)
Search for compliant products via OMRI’s database.
Quaternary Ammonium Compounds (Quats)
Usage rules:
Quats are prohibited from contacting organic products. If used:
- Rinse thoroughly with clean water
- Use low-ion test strips to verify 0 ppm residue
- Document pressure, water volume, temperature, and timing
- Retest periodically to confirm process efficacy
Acceptable test kits:
- LaMotte 2934 Insta-TEST Dual Range
- Hydrion Lo Ion QAC Test Kits (QL-110)
All sanitizers and cleaning materials must be listed in your OSP. Notify OTCO before making any changes.