Contamination prevention

#Storage

If you store your crop(s) on-site, you’ll need to implement practices to prevent your crop(s) from commingling or contamination with non-organic products or prohibited materials.

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.

Off-farm crop storage
You must use a certified organic facility for your crop(s) storage. An uncertified storage facility may be eligible to be used, provided all of the following criteria are met:

  • Products are packaged or enclosed in a container prior to the facility’s receipt of delivery
  • Products remain in the same package or container at the facility
  • Products are not repacked or re-labeled while under control of the facility
  • Storage facility successfully completes an Independent Storage Information Sheet

On-site crop storage in a treated wood building
Crops may be stored in a treated wood facility (e.g., barn) only if not coming into contact with the treated wood. You must provide and document an appropriate barrier (e.g., distance, storage bins, etc.). Please observe additional requirements for treated wood as needed.

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=dHZZfHZMXWN6Lz1vWxxgMgZWdWlx_19>.

#Commingling and contamination on farms

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.

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.

In support of your commingling and contamination prevention practices, you’ll need to maintain detailed records that verify your process and ensure the integrity of your crops.

Identifying potential areas of concern
There are several scenarios that you might flag as a risk area for commingling or contamination of your crops. 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 crops in the same space
  • Reuse of containers that store both organic and non-organic crops
  • Custom hire or contract harvesting, seeding, input application, etc.
  • Store or apply prohibited materials on or near your operation
  • Use equipment on both organic and non-organic land or crops

It’s critical to examine your operation’s practices to identify needs for practices and procedures to prevent contamination and commingling issues.

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=dHZZfHZMXWN6Lz1vWxxgMgZWdWlx_19>.

#Farm equipment

Using farm equipment in organic production (e.g., harvesting, handling, storage, etc.) for both conventional and organic crops elevates the risk for contamination.

Alert

Your Organic System Plan (OSP) must detail management practices, physical barriers, and all other measures used on your farm to prevent commingling of organic and non-organic products and contamination from prohibited substances. If you use any custom hires or borrow someone else’s equipment for use on your organic land, you must ensure all equipment has been sufficiently cleaned and documented prior to use in your organic production.

We’ll review your post-harvest handling procedures, equipment used, and clean out protocols. It is important that your operation maintains adequate records to demonstrate compliance with commingling and contamination prevention requirements.

Note

Be sure to document the cleaning of equipment for annual inspection and verification. Write down the date, cleaning methods, and even take pictures for further verification that proper cleaning was done.

A few things to consider when developing your prevention plans:

  • Identify all areas of potential contamination or commingling
  • List all pieces of equipment used for both organic and non-organic crops
  • Document preventative equipment cleaning processes (e.g., pressure washing, etc.)
  • Purge equipment — run organic batches diverted to non-organic sales — prior to use
  • Apply practices on leased/borrowed equipment, even if they are used only for organic crops

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=dHZZfHZMXWN6Lz1vWxxgMgZWdWlx_19>.

#Buffer zones

For organic farms, a buffer zone is an area between certified organic production and non-organic land. Buffer zones provide a dedicated area to prevent contamination. You’ll monitor firsthand how to gauge the effectiveness of your prevention practices.

Note

Buffer zones should be clearly indicated on the required Farm Map.

Assessing need for buffer zones
If there is any risk of contamination from adjacent properties or activities (e.g., pesticide sprays, roadway drainage, etc.) that pose a threat to crops you intend to be “sold, labeled or represented” as organic, you need a buffer sufficient to prevent contamination.

Prohibited materials and methods
Buffer zones protect your certified organic crops and land from prohibited substances (e.g., unapproved synthetic pesticides) and excluded methods (e.g., GMO cross-pollination).

Characteristics of an effective buffer zone
There is no standard size for buffer zones. The only requirement is that a buffer zone does its job. Size matters, but so does your planting and management plan (e.g., plant type, the height of a hedgerow, plant density and bioswales). Factors such as common wind patterns, land slope, chemical application activity and stormwater drainage patterns all will inform how you set up your buffer. Simply put, it must be adequate to prevent contamination from the unintended application of a prohibited substance.

Harvesting from buffer zones
Crops can be grown in a buffer zone but they may not be sold or represented as organic. We may perform pesticide or GMO residue testing of organic crops to verify that buffer zones are adequate. You’ll need to provide clear documentation for clean out of equipment used in buffer zones and any crops harvested and stored.

Resource

Buffer zones can be used to help conserve natural resources and promote biodiversity on your farm. Learn more with our Lessons Learned series on Birds and Biodiversity.

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