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:

• Shared storage areas for organic and non-organic products
• Reuse of containers between organic and non-organic production
• Use of equipment without proper sanitation
• Storage or use of prohibited substances near organic ingredients
• Inadequate cleaning procedures on shared surfaces or tools
• Use of persistent sanitizers (such as quaternary ammonia)

What are 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 cleaned/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?

Purging is needed when cleaning alone is not enough to remove non-organic materials or residues from shared equipment. A purge involves running organic product through the equipment to flush out any remaining non-organic material before organic production. Purged product cannot be sold as organic.

When is purging not required?

Purging may not be required if cleaning equipment removes all residues and is verified through visual inspection or testing.

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

Pest Management Requirements

What’s allowed in organic pest control?

The USDA requires a tiered approach:

• Prevention – Prevent pests by:
  • Removing food and habitat sources
  • Sealing buildings and preventing access
  • Managing temperature, moisture, and air circulation
    
    
• Mechanical Controls – If prevention fails, traps, light, or sound may be used to control pests..
  
  
• Allowed Materials – If needed, approved substances consistent with the National List of Allowed Substances that have been reviewed by OTCO may be used such as:
  • Carbon dioxide
  • Boric acid
  • Diatomaceous earth
  • Vitamin D3 bait
  • Soap-based products

Synthetic Pest Controls

Only allowed as a last resort, after all other measures have failed, with OTCO approval and documentation.

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 commingling and contamination through barriers, signage, and/or separate areas.

Can I use an uncertified storage facility?

Uncertified storage facilities may be used to store organic products under certain conditions if:

• Products are enclosed in sealed, tamper-evident packages/containers and remain in those same packages/containers while in storage
• No repackaging, labeling/relabeling, or processing occurs
• The storage facility completes an Independent & Off-Site Storage (IS) form
• The storage facility is disclosed in your OSP

Download the IS Form and submit it to your OTCO client service team.

Organic Transport Requirements

Certified transporters?

Transporting organic products alone is not considered handling and does not require organic certification.

However, certified operations are responsible for protecting the organic integrity of their products during transport. This may include:

• Cleaning of transport vehicles prior to loading with organic products.
• Using dedicated organic transport when appropriate.
• Using sealed and/or clearly labeled containers to prevent commingling or product misidentification.

Some activities are not considered transport and do require organic certification. These include:

• Combining products
• Splitting lots or loads
• Repackaging
• Atmospheric treatment

Loading or unloading of unpackaged products into or from a storage facility.

Your Organic System Plan (OSP) must describe the transportation methods your operation uses and explain the measures you have in place to ensure products transported by uncertified carriers continue to comply with organic regulations.

Note: Organic livestock transport follows different certification rules.

Approved Sanitizers and Materials

Can I use sanitizers on equipment?

All sanitizers used on organic production equipment must comply with organic requirements and be included in the OSP. Procedures for cleaning and sanitizing equipment must also be included in your OSP.

Some sanitizers require:

• Rinsing or air-drying equipment
• Ensuring no residue is left behind

Examples of allowed sanitizers:

• Hydrogen peroxide
• Peracetic acid
• Chlorine materials
• Isopropyl Alcohol
• Ethanol

Refer to the NOP’s Guidance on Allowed Detergents and Sanitizers for Food Contact Surfaces and Equipment in Organic Operations.

Search for compliant products via OMRI’s database.

Can I use sanitizers on equipment?

The active ingredients in direct contact sanitizers must be listed on the National List of Allowed Substances, and must be included in your OSP. Some examples of allowed direct contact sanitizers are:

• Chlorine materials (in water at levels approved by the FDA or EPA for food sanitizing, followed by a rinse with potable water with no greater than 4ppm chlorine)
• Acidified sodium citrate (as a secondary antimicrobial treatment)
• Peracetic acid/Peroxyacetic acid (CAS # 79-21-0)—for use in wash and/or rinse water according to FDA limitations.
• Allowed nonsynthetics such as vinegar

Quaternary Ammonium Compounds (Quats)

Usage rules:

Examples of 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.