For processors and handlers

#Requirements

Your recordkeeping system demonstrates where promise and practice meet for compliance. The annual inspection reviews every aspect — from ingredient sourcing to equipment clean out — of organic processing production. Our ability to easily audit and trace all certified organic products maintains integrity and enables quick action if issues occur.

You need to maintain documentation — your Organic System Plan outlines recordkeeping strategies, management and storage — that demonstrates all requirements are being met. Each operation’s recordkeeping systems will be different. However, a few core requirements must be minded:

Recordkeeping basic requirements:

  • Records are easily accessible on-site for inspection
  • Documentation must be adapted to reflect your operation
  • All records must be clear and auditable

Alert

All records related to your organic product need to be stored for at least five years.

What records do I need to keep?
The records listed below are examples of records that can be used to demonstrate compliance with the recordkeeping requirements in the USDA National Organic Program regulations.

  • Receiving records
    Records of authentication — typically, organic certificates — that ingredients and materials received are organic, and amounts received (e.g., BOLs, weight tickets, clean truck affidavit, etc.).
  • Production records
    Documentation of all activities and materials used to process the product (e.g., checklists, logs, batch records, etc.).
  • Organic integrity
    Records for prevention of contamination (e.g., purge records, pest control, sanitation logs, etc.).
  • Storage records
  • Inventory records and product movement records
  • Sales
    All sales records such as PO’s, transaction certificates, invoices and sales summary sheets must be maintained to verify what and how much product sold.

#Audit trail

Organic inspectors are required to conduct at least one complete audit trail exercise at each inspection. The audit trail evaluates your recordkeeping system as well as activities for traceability and compliance.

For processors, a complete and thorough audit trail enables a product — e.g., packaged soup for retail sale — to be traced to the origins of on-farm ingredients used, similar to documentation for purpose of a food safety recall.

Alert

All records related to your organic product need to be stored for at least five years.

Identify and use a strong connecting link for all of your documentation practices
It’s critical to establish a common link between all activities, materials and documents in your control system. For instance, using lot code numbers enables a reviewer to work through each phase of your operation —- e.g., ordering, receiving, processing, distribution, etc. —- to make records traceable, timely and transparent.

Resource

OTCO’s Audit Trail: Sample Documentation Process showcases a few of the most common types records you’ll need for your audit trail exercises.

Lot code numbers allow for traceability of all ingredients received and stored, amounts used for processing the product, and the amount of product shipped. In all cases, verification that the amount of incoming materials matches the amount of outgoing product is necessary. Additionally, confirmation that all materials are compliant with organic standards is required.

#Sanitation

Your Organic System Plan (OSP) outlines sanitation and water practices that must be supported by your operation’s recordkeeping system.

Ultimately, we’re looking at how your sanitation practices prevent contamination or commingling. You’ll need to keep records of your cleaning and sanitation procedures and activities. Some sample records to keep include:

  • Equipment and container cleaning logs
    For split operations that produce or handle both organic and non-organic products, you’ll need to keep a log — for all equipment used — of each time you clean out equipment to prevent commingling between organic and non-organic products. You’ll also need cleaning logs for any reused containers for unpackaged products.
  • Materials
    Per your OSP, you must maintain up-to-date lists of all boiler chemicals, sanitizing, cleaning and pest control materials used. Additionally, you’ll need safety data sheets and purchase records for all of your cleaning and pest control materials.
  • Clean truck affidavit
    For bulk products, a clean truck affidavit verifies that the transportation vehicle was properly cleaned to prevent contamination from sanitizer residues or commingling with previously held non-organic products. You must keep affidavits for all bulk and/or unpackaged produce.
  • Water analysis
    Maintain up-to-date water analysis results for any water used in processing your product(s).
  • Pest control reports
    Documentation of all pest control prevention and extermination practices, activity logs, and records of requests for non-National List pest control materials.

#Purchasing

Purchase records — for all ingredients and materials — combined with inventory and batch records, verify that the amounts of your organic ingredients match up with your product sales. Importantly, they also confirm that the ingredients used were certified organic (or an allowable non-organic ingredient).

The main purchase records needed are the invoices for all of your ingredients and materials. For all certified organic purchases, you’ll want to make sure the word “organic” appears on the invoice.

In addition, you’ll want to document spec sheets for each multi-ingredient product and forms for:

  • Organic ingredients
    Maintain current, valid organic certificates for all organic ingredients. You must also document your suppliers information and certificates. Per your Organic System Plan, you will need to keep all organic certificates stored and organized in one, easily searchable location.
  • Non-organic ingredients
    For any approved non-organic ingredients, you will need detailed information to verify compliance for approved use per the organic standards. The main requirements are that an ingredient was produced without genetic engineering, irradiation, and/or sewage sludge. You’ll also need to maintain non-organic ingredient supplier information. A commercial availability form is required for each non-organic ingredient to demonstrate that no organic version of the ingredient was available when applicable.

#Batch production

Batch records — depending on the scope of your processing operation — are important verification documents for an inspector and certifier to match that amounts of organic ingredients are sufficient to produce amounts of organic product sold. We recommend taking the time to develop a clear strategy for how you trace and record which ingredients were used in designated batches of product. The approach is similar to documentation required for the purpose of a food safety recall.

Batch records should include batch numbers of your products, lot code numbers of each ingredient, and the amount used in the designated batch. The ingredients must match those listed on your product formulation sheet, master ingredient list and master product list.

One batch record strategy is creating a production check-off list.

#Shipping and receiving

Shipping and receiving records provide a common link between the ingredients coming in to your facility and the products leaving it.

Depending on the scope of your operation, you may need:

  • Bill of lading
    An incoming bill of lading will show ingredients received as well as lot code numbers
  • Receiving log
    Records lot code numbers and storage locations of all ingredients received in your warehouse
  • Outgoing invoice
    Records the product leaving your warehouse and includes product lot code number(s)

Your shipping and receiving logs work in hand-in-hand with purchasing and batch records to create a clear picture of each ingredient from entry to exit of your facility.

#Inventory

Inventory recordkeeping management is a critical part for verification that the ingredients coming in match up with the products going out. An inspector will review your inventory records along with your product formulation sheet and batch records, working to verify that the amount of ingredients used for product creation lines up with the amount of product you sell.

Forms & Documents

Download the above and submit it to your client service team. 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.

Managing an up-to-date inventory log
The quality of an inventory log is determined by regular updates and verification “spot checks.” The log should include ingredient amounts as well as lot code numbers for traceability. Additionally, your inventory list should document the products on hand, prior to sale or transportation.

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