Contamination and commingling

#Preventing contamination

The USDA National Organic Program (NOP) requires that you must develop practices and systems to prevent organic products from contacting non-organic products and coming into contact with prohibited substances (e.g., sanitizers, pesticides, etc.).

Note

Contamination is when organic products come in contact with prohibited substances.

In support of your commingling and contamination prevention practices, you’ll need to maintain detailed records that verify your process (pest management, cleaning, shipping logs etc.) and ensure the integrity of your organic products and practices.

Identifying potential areas of concern
There are several scenarios that you might flag as a risk area for commingling or contamination of your organic operation’s practices. In particular, split operations are generally at much higher risk. A few sample processes that would be a red flag for an inspector and certifier can include, but are not limited to:

  • Co-storing organic and conventional ingredients in the same facility
  • Reuse of containers that store both organic and non-organic crops
  • Sanitization of equipment and surface areas
  • Store or apply prohibited materials on or near your operation
  • Use equipment on both organic and non-organic products

It’s critical to examine your operation’s practices to identify needs for practices and procedures to prevent contamination and commingling issues. Some good strategies for prevention include:

Resource

Learn tips and tricks for contamination prevention from an Oregon Tilth webinar and a short video by the Washington State Department of Agriculture.

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=TEdqeU59bmZCHg5qYy1TNz5uRFp0_19>.

#Commingling of ingredients

The USDA National Organic Program (NOP) requires that you must develop practices and systems to prevent organic products from contacting non-organic products and coming into contact with prohibited substances (e.g., sanitizers, pesticides, etc.).

Identifying potential areas of concern
You may have organic and non-organic ingredients in the same facility, you will need a clear, well-documented plan for prevention of commingling.

There are several scenarios that you might flag as a risk area for commingling or contamination of your organic operation’s practices. In particular, split operations are generally at much higher risk. A few sample processes that would be a red flag for an inspector and certifier can include, but are not limited to:

  • Co-storing organic and conventional ingredients in the same facility
  • Reuse of containers that store both organic and non-organic crops
  • Use equipment on both organic and non-organic products

It’s critical to examine your operation’s practices to identify needs for practices and procedures to prevent contamination and commingling issues. Some good strategies for prevention include:

  • Clear designation of storage areas for organic products
  • Clear and consistent labeling
  • Staff education and awareness
  • Plans for elimination and removal of cleaning and sanitizing residue
  • Dedicated equipment for organic products

Resource

See examples of commingling and contamination prevention in WSDA’s Preventative Practices for Organic Handlers video.

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=TEdqeU59bmZCHg5qYy1TNz5uRFp0_19>.

#Equipment

Equipment sanitation practices will depend on the type of processing or handling you perform.

Using equipment in a mixed operation (e.g., handling organic and non-organic products on the same equipment) elevates the risk for contamination. You’ll need a clear and well-documented plan for purging and sanitizing equipment to prevent commingling of organic and non-organic products.

Equipment purge

If you use your equipment for organic and non-organic products you will need to perform and equipment purge. You must run adequate batches of organic product through equipment — diverting all purged product to be discarded or for non-organic sales only — prior to processing the organic product.

Tip

Processing organic prior to non-organic products may save an extra step of cleaning equipment. However, you still should purge shared equipment — run organic batches diverted to non-organic sales — prior to full use.


Sanitation and organic-only facilities

If you can adequately clean equipment prior to an organic run, or you are an organic-only facility, you must ensure no residue is still present from your cleaning materials.

Note

It is important to keep thorough records of your equipment cleaning procedures.


Shared kitchens

If using a commercial kitchen, or shared kitchen facility, you must communicate with all of the other users to identify practices and materials (e.g., sanitizers) that might require additional attention and actions to prevent contamination. If multiple operations are producing organic products in a shared kitchen, consensus on pest control prevention methods and cleaning methods can help all producers.

#Pest management

The USDA National Organic Program requires preventative pest management practices as the first measure in all areas where organic products are handled, processed or stored.

Prevention approaches can be thought of as smart sanitation practices:

  • Remove potential habitat and food sources for pests
  • Prevent pest access to the area where you work with organic product
  • Control environmental conditions (e.g., temperature, light, etc.) to stop pest reproduction

Acceptable mechanical methods
If prevention methods are unsuccessful, certain mechanical controls (e.g., traps, light or sound) may be permitted.

Approved materials
Only after prevention and mechanical methods fail should you look to approved materials as a means for pest control. Understanding approved and prohibited materials per the National List is critical. Never use a material unless it is approved for use on the National List, or until after OTCO review and approval. Some examples of approved materials include carbon dioxide, nitrogen, Vitamin D3 bait, boric acid, diatomaceous earth, and soap products.

Synthetic pest controls
Only if none of the above work you may consider synthetic pest control methods. In all instances you must receive OTCO approval prior to use. For review, we will require:

  • Photocopies of the product label
  • Manufacturer safety information sheet
  • Detailed explanation need for use, including documentation of failed preventative, mechanical and approved material pest control methods
  • Detailed explanation for contamination prevention and plan for documentation
  • Updates to your Organic System Plan under pest management

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=TEdqeU59bmZCHg5qYy1TNz5uRFp0_19>.

Alert

All records of pest management strategies and application must be available at your inspection.

#Storage

Co-storing organic and non-organic products
Often facilities handle both organic and non-organic products in the same place — commonly known as a “split operation.” If you are storing both organic and non-organic products, you must prevent all organic product(s) from coming into contact with prohibited materials (e.g., sanitizers, pest control substance, etc.) or being mixed with non-organic products.

Note

Commingling is defined as the contact of organic products with non-organic products. Contamination is when organic products come in contact with prohibited substances.

If you receive, package, or ship organic products, you must readily demonstrate any organic product you ship out is the same product you received. Your plans for preventing contamination and commingling should be outlined in your Organic System Plan and backed up by records for inspection and review.

Alert

There are several scenarios that you might flag as a risk area for commingling or contamination of your organic operation’s practices. In particular, split operations are generally at much higher risk. Be sure to take time to learn strategies for contamination prevention.

Storing organic products in a non-certified facility
If your product is packaged or sealed in a container and clearly labeled prior to storage, you may be able to use a non-certified storage facility. Your product cannot be processed in any way while on-site at the non-certified facility, including repackaging, relabeling, or introducing atmospheric modifiers such as ethylene.

The non-certified storage facility must fill out an Independent Storage Information Sheet.

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=TEdqeU59bmZCHg5qYy1TNz5uRFp0_19>.

#Transportation

The USDA National Organic Program (NOP) requires that you develop practices and systems to prevent organic products from contacting non-organic products and coming into contact with prohibited substances (e.g., sanitizers, pesticides, etc.).

Storage
If you’re sending your product in a large container, such as a railcar, you’ll must provide verification that all cleaning methods follow organic guidelines.

If you’re sending or receiving your product in permeable containers (e.g., boxes, clamshells, etc.), you must provide verification from the shipping agent that it is protected from encountering prohibited gases, liquids, or materials.

Certification of transporters
You do not need to use a certified organic handler/transporter provided your product is sealed and clearly labeled prior to transporter receipt. It cannot be repackaged, relabeled or processed in any way — including use of restricted atmospheric controls — during the shipping period.

Alert

For transporters of organic livestock, OTCO requires different practices and certification protocols.

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