Storage and transport operators
Organic certification may not be required, depending on the product your operation stores or transports.
If you handle bulk, unpackaged organic products (e.g., milk, livestock, grain, etc.) or perform any other activities that may be defined as processing, you will require certification. In some instances, you may be eligible to be included under a different organic operation’s certification.
The USDA National Organic Program (NOP) defines processing as cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, extracting, slaughtering, cutting, fermenting, distilling, eviscerating, preserving, dehydrating, freezing, chilling, or otherwise manufacturing, including the packaging, canning, jarring, or otherwise enclosing food in a container.
If you transport unpackaged or bulk organic products, certification is not required provided you do not handle, process, or split lots of the product.
If you only store or handle already packaged products that remain in the same container without being processed, you do not require certification.
Even if you are not required to be certified, as a handler of organic products you will be responsible for adhering to all regulations and protecting the integrity of organic products. This includes prevention of commingling with non-organic products or contact with prohibited substances, meeting USDA NOP organic labeling requirements, and maintenance of all organic product records for at least three years.
While certification is not required, you may choose to get certified for additional flexibility in the organic products you would be eligible to transport as well as types of actions you can take, such as refrigeration. If you are included under another operation’s certification, you must provide an Independent Storage Information Sheet.
As part of the organic certification process, an annual on-site inspection is required.
At inspection, you’ll need to clearly demonstrate the organic integrity of the products you are shipping or storing throughout their lifecycle. We will observe and review each aspect of your operation (e.g., transport, storage, facilities, etc.) as well as perform a thorough audit of your documentation records. For new applicants, your initial inspection will verify that your Organic System Plan (OSP) is in alignment with your facility’s capacity and purpose. For currently certified clients, the annual inspection will verify that your operation is meeting all prescribed activities per your OSP.
You must maintain well-organized, accessible records that date back at least five years from the creation date for each organic product.
During your inspection, there will be a review to ensure your organic products were properly stored to prevent commingling and contamination, and that you have adequate records to document the organic integrity (i.e. organic certificates) of the products. In addition, the inspector will conduct audit exercises, including an “in-out balance” audit, to ensure that the number of products received match the number of products shipped for your storage or transport operation.