Producing certified organic products in a facility that is also running conventional products requires careful consideration of production schedules, labeling and storage of products and tools.
Food processing represents a critical link in the organic food handling chain from farm to fork. Conventional processors are now wondering if they can produce a certified organic product in a facility that is also running conventional products - and what it will take to comply with the National Organic Program regulations. While many believe that "organic certification" will require that every product produced in their facility has to comply with the organic standards, the truth is, all products do not have to be organic.
Rather, it requires careful consideration of production schedules, labeling and storage of conventional and organic products and tools with an eye towards creating a segregated environment that protects the integrity of the organic products without interfering with the production of conventional ones.
The challenge processors face is to demystify organic processing requirements.
The opportunity
Integrated inventory control
Given the recent growth and popularity of organic foods many conventional manufacturers are asking if this is an opportune time to produce organic products or add incremental capacity for organic products to supply new or existing new customers. Many companies like Wixon Foods, a flavorings ingredient manufacturer for the specialty food industry, are planning strategic capabilities long into the future.
Wixon CEO Peter Gottsacker states, "We are a strategic company. We are always looking out five to ten years and trying to determine what are fads and what are market trends. We felt that organic was a trend and that it was here to stay. So we asked ourselves - how should we position our company to play a role in this growing marketplace?"
What potential organic processors need to know is what's involved from process and certification perspective to build a long term organic manufacturing plan and respond to these new product requests from a customer. It's important to note that whatever conventional process you run: mixing, baking, pasteurizing, you can be considered a processor under organic regulations.
Getting ready
It's up to the senior management team of your company to define your market and the marketplace opportunity with their customers or market researchers. Is organics an opportunity for your company? The organic food and beverage market is now reaching approximately $17 B in sales in 2006, grew at a 22 percent rate last year, and is expected to reach $23 B by 2010 (Scarborough Research, October, 2007). However, organic foods come with their own set of risks and rewards: ingredients are highly seasonal, in smaller supply and limited variety, with longer lead-time to market, which heightens the importance of accurate forecasts and timely commitments, and management of price premiums on market based buying. If your company has the competencies to manage these risks, you are well positioned to take advantage of the marketplace rewards.
For Wixon, there were three major drivers in making the decision to go organic. Peter Gottsacker sums them up:
Operations: For Wixon, organic wasn't a stretch from the operations side of the business. The marketplace was there and, operationally, we had a very disciplined HACCP, allergen control program. We were already ISO 9001 accredited. And, we knew that we had excellent inventory control and segregation systems in place.
Supply Side: We knew there would be ingredient challenges. But, that's what we do very well. We provide solutions to our clients' flavor and packaging challenges, especially in constrained and underserved ingredient supply chains. Organic ingredients have many flavor and functional issues - this was to our advantage.
Sales Side:Our sales team was already pulling us into the organic marketplace. We knew that there was a unique opportunity to help our existing clients extend their product lines and we believed that we could lead the flavorings industry, especially for early organic adopter brands.
A company can take the time to develop the expertise in-house to understand the ingredient sourcing and processing requirements, or hire an organic expert to fast track the process with a clear understanding of the regulations and requirements.
By making the organic expert a part of your team you will be able to rapidly develop an action plan with deliverables and timelines for your specific product categories and business opportunities, as well as to deliver turnkey organic production processes to meet regulatory requirements and contact organic certifying agents who are knowledgeable about your category. It is very important to assign a principle contact from your internal team to take responsibility for your organic program. Your lead person and the organic expert can work with your Quality Assurance department to build a separate Organic Handling HAACP Plan, and also to help your Purchasing department develop a supply chain plan to source ingredients at the right quality, timeliness and cost for the operation.
Gottsacker provides further testimonial: "We recruited a seasoned organic advisor who not only had the regulatory knowledge but organic food production experience, expertise, candor and networks to help us implement our organic program immediately. He helped us quickly understand the organic regulations, identify our challenges and develop solutions, as well as source great ingredients and find the best suppliers."
Processors should not look to certifiers as problem solvers for their own particular operation. Certifiers are prohibited by the regulation from acting as a consultant or assisting the operation in overcoming current barriers to certification, so your advisor can help keep things moving on the regulatory side as well by reviewing requirements for organic certification and accompanying documents. This advisor should also be an authority on the organic regulations and willing to follow up with the certifier regarding any points that need clarification. With this information in hand, your team will be well equipped to discuss organic food processing and organic certification with the company's management team.
Segregation, sanitation & Pest management
By reviewing the proposed manufacturing process with flow charts in hand, your team can evaluate where the organic integrity of the product might be at risk. With those critical control points identified, you can create safeguards to prevent those risks by answering the following questions:
• How will receiving personnel know the difference between organic ingredients and conventional ingredients and how will they be stored?
• How will organic products and equipment be handled to ensure organic integrity in the products or customer specified formula?
• How will the identity of the organic product or customer specified formula be maintained throughout the process?
Batch processing organic products
No matter what degree of product specialization, separate storage areas or sections within existing storage units are a good first step towards keeping raw materials segregated. Using the same coolers or storage rooms for both conventional and organic ingredients is possible as long as the boxes, shelves or pallets are clearly labeled and the raw ingredients are protected from commingling. If separate rooms are not possible within the plant layout, isolating conventional or organic manufacturing lines offers a physical barrier to segregate operations. These lines can be further separated with movable plastic curtains or doors.
Having dedicated equipment for organic processing is yet another way of insuring segregation of raw materials, and dedicated equipment should be labeled as such and kept away from conventional processing areas. However, not all products justify their own equipment from a financial or investment perspective; the same equipment can be used for both organic and conventional products as long as proper cleaning processes and scheduling procedures are in place.
If you use the same equipment for both conventional and organic processing, production runs should be scheduled at separate times. Producing organic products in the first shift or on specific days will reduce the risk of commingling of ingredients and contamination of equipment. Equipment must be thoroughly cleaned before it can be used to make organic products. Sanitizers are an important tool in organic processing but the processors must ensure that sanitized food contact surfaces have no residues and do not come in contact with organic products. Sanitation residue testing documentation is excellent tool for assuring the organic product and process integrity.
Your Organic Handling Supply Plan (OHSP) must contain a list of the methods and substances used to prevent or control facility pests. Your current pest management company may or may not be familiar with organic regulations but some pest management companies do have experience working with organic food processing operations. If you are in a segregated facility, your plan must also include the measures that you have taken to prevent pest management substances from coming into contact with organic ingredients or organically produced products. Finally and most importantly, employees should be trained by a quality assurance leader to implement these new organic procedures and to create an organic culture on the production floor.
Preparing for organic certification
Organic processors should maintain a parallel handbook or manual for the added processing portion of their operation. For National Organic Program (NOP) Certification, proof of how you are going to maintain the organic integrity of your organic processing operation from receiving through packaging, labeling and shipping should be the goal of your policies and procedures. An Organic Handling and Supply Plan (OHSP) must also include a description of monitoring practices and procedures to verify that the plan is effectively implemented. Logs should be kept to document that specified tasks have been completed. The plan must also contain a list of substances used in the processing operation.
Inspection & certification
Beginning the day with organic production
Organic inspections are much like other food and quality audits, only they focus compliance to the NOP regulations. The length of time required varies by the complexity of the facility and processes, as well as on the number of products. Most inspections take at least four hours and could last as long as a couple of days. As with all audits, you should be prepared to demonstrate your understanding of organic processing requirements and that you are operating in accordance with your Organic Handling Plan. Inspectors will tour your working facility, preferably while the facility is producing an organic product; as well as perform a thorough review of production records, policies, procedures, manuals, data logs, as well as current organic certificates for all ingredients.
Ultimately, the inspector will test the accuracy of your traceability and segregation and inventory control by following the manufacture of a product from start to finish. The Certifier will require that you show all organic labels for approval and file all labels with them prior to the production of organic products.
As with any HAACP or audit process, the inspector will write an inspection report that will be included in the processor's application file for final review by the decision-making body of the certification organization. The certifier will make a determination to approve or deny organic certification. If organic certification is approved the certifier will issue a Certificate of Organic Operation to the applicant. A cover letter will note areas of operation that need improvement by the next annual inspection or by a specified date. It may take anywhere from one month to six months to complete the application/certification process.
The key to expediting the process is to thoroughly complete the application packet and quickly responding to the certifier's request for additional information. The fewer the incomplete items that the certifier needs to follow-up on, the shorter the review process. Because your facility will be audited annually, it is important to proactively discuss potential changes in formulations, processes or procedures with your certifier to assure that they will not impact your certification.
With good planning and execution, you should be well on your way to developing a successful organic business.