Recordkeeping for processors and handlers
#Processor recordkeeping requirements
Your recordkeeping system demonstrates where promise and practice meet for compliance with organic standards. The annual inspection reviews every aspect — from ingredient sourcing to contamination prevention — of organic processing production. Our ability to easily audit and trace all certified organic products maintains the integrity of your food business and enables quick action if issues occur.
What basic requirements are needed for recordkeeping?
Each food business’s recordkeeping system will be different. You must maintain documentation — your Organic System Plan outlines recordkeeping strategies, management, and storage — that demonstrates all requirements are being met. Additionally, a few core practices are needed:
- Records are easily accessible on-site for inspection
- Documentation must be adapted to reflect your operation
- All records must be clear and auditable
How long do I need to keep records for?
All records related to your organic product need to be stored for at least five years.
What records do I need to keep?
You will need to keep records for all of your major food processing activities and practices. Check out the other articles in this section for examples of records required by activity, as well as our collection of recordkeeping templates.
#Audit trail exercises for processors
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.
How does an audit trail exercise work?
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 the purpose of a food safety recall.
How do I build my recordkeeping system so it’s easily audited?
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. From ordering and receiving to processing and distribution, lot codes make individual records traceable, timely, and transparent.
No matter what system you use, it’s critical that recordkeeping is well understood by all employees and is clear and well-organized for inspectors and certifier review.
What are the key inspected criteria of an audit exercise?
Using lot code numbers allows an inspector to examine and trace all ingredients received and stored, amounts used for processing the product, and the amount of product shipped. Verification that the amount of incoming materials matches the amount of outgoing product is necessary. Additionally, this process confirms all materials used are compliant with organic standards.
Your Organic System Plan (OSP) outlines sanitation and water practices that must be supported by your operation’s recordkeeping system to demonstrate how you prevent contamination or commingling.
What types of records should be documented for sanitation?
You’ll need to keep records for all of your cleaning and sanitation procedures and activities. You’ll need equipment and container logs for cleanouts between organic and non-organic ingredients if you handle or produce both. This includes cleaning logs for reused containers for bulk products.
What information do I need to keep for sanitation 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.
What information do I need for transportation sanitation?
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.
Do I need water analysis records?
Yes, you should maintain up-to-date water analysis results for any water used in processing your product(s).
What about pest control records?
You are required to keep records of all pest control prevention and extermination practices, activity logs, and records of requests for pest control materials not found on the National List.
Purchase records for ingredients and materials help verify that the amounts of your organic ingredients match up with your product sales. They also confirm that the ingredients used were certified organic (or an allowable non-organic ingredient).
What documents should be saved for purchase records?
Your main purchase records are 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.
What companion records are needed for tracking purchases?
In addition to invoices, you’ll want to document spec sheets for each multi-ingredient product and forms for organic ingredients and non-organic ingredients. For organic ingredients, you’ll need to keep and organize organic certificates for each one. For approved non-organic ingredients, we’ll need detailed info verifying it was produced without genetic engineering, irradiation, and/or sewage sludge. You also will need to maintain non-organic ingredient supplier information.
#Batch production records
Depending on the scope of your business, batch records are one of the most important verification documents for an inspector and certifier. We recommend taking the time to develop a clear strategy, such as using a production check-off list, to trace and record which ingredients were used each product batch.
How are batch records used in an organic inspection?
Batch records allow us to match that amounts of organic ingredients on hand are sufficient to produce the amounts of organic product sold. The approach is similar to documentation required for the purpose of a food safety recall.
What information should be included in a batch record?
A batch record should include batch numbers of your products, lot code numbers for each ingredient, and the total amount used in the designated batch. The ingredients must match those listed on your product formulation sheet, master ingredient list and master product list.
#Shipping and receiving
Shipping and receiving records provide a traceable link between the ingredients coming into your facility and the products leaving it.
What types of shipping and receiving records do I need?
Depending on your operation, the following records will satisfy documentation for ingredients received and products leaving your warehouse: bill of lading (with lot codes), receiving log (with lot codes and storage info), and outgoing invoices (with lot codes).
#Inventory management records
Inventory management records, along with your product formulation sheet and batch records, allow an inspector to verify that the amount of ingredients used for product creation lines up with the amount of product you sell.
What information should be included in an inventory (log) record?
An inventory 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. The quality of an inventory log is determined by regular updates and dated verification “spot checks.”