News / Events
HOFA's 18th annual membership meeting
September 26, 2010 - September 26, 2010
Contact:
808-969-7789 toll-free: 1-877-ORG-ISLE (674-4753)
hofa@hawaiiorganic.org
HOFA ceasing certification activities in 2011
July 1, 2010 - October 1, 2011
Contact:
HOFA Hilo office: 969-7789
hofa@hawaiiorganic.org
USDA NOP instructions for changing certifying agents
Handling / Processing
Frequently asked questions for processing/handling certification
What are the requirements for handlers and processors of organic food?
• Processors and handlers must complete an Organic System Plan.
• Procedures must be in place that ensure that no commingling or misidentification occurs between organic food products and non-organic food products.
• Prohibited substances used within the processing or handling facility must not come in contact or contaminate the organic food products.
• A list of all organic ingredients used in organic products must be provided. All organic ingredients must be certified by NOP accredited certification agencies, and certificates must be on file.
• Labels for all organic food products must be submitted and approved by your certifier for compliance to rule requirements prior to obtaining organic certification.
• All organic food products must be processed with only approved minor ingredients and processing aids.
• A lot identification system to allow for the tracking of organic products is required to complete an audit trail.
Are there restrictions on post-harvest materials, minor ingredients and processing aids that I can use?
Yes. Generally, only naturally derived materials can be used to extend shelf life or storage time. The rules prohibit use of irradiation, GMOs, synthetic preservatives, fumigants, and artificial flavors or colors.
Do all processors and handlers of organic food need to be certified?
Yes, except for handlers and processors exempt or excluded from certification, all processors and handlers of organic food must be certified.
Exemptions
1. Handlers that sell less than $5,000 worth of organic products.
2. Retail food stores.
3. Processors that produce products with less than 70 percent organic ingredients.
4. Processors that produce products that limit their organic claims to the ingredients list.
Exclusions
Exclusions
1. Handlers that only sell pre-packaged organic food products.
2. Retailers that have in-store bakeries, delicatessen, salad bar, or ready-to-eat food.
What records am I required to keep?
Complete and accurate records must be kept that track the organic food products from receiving through final sale or shipping. All records must be kept in sufficient detail as to be readily understood and audited, and must be sufficient to demonstrate compliance with the National Organic Program. Records must be maintained for five (5) years. An audit of your practices will take place during your organic food inspection to ensure that appropriate records are being kept.
What is a lot numbering system?
Lot numbers, which should originate at the farm level for bulk produce, are important to assist in identification and tracking of products. Lot numbers can be used for quality control purposes, product recall, and to identify a particular run, or to check production, inventory, shipping and organic sales records. Lot numbers can be coded, often referring to product type and date, or specific run or batch. The inspector will need to understand the producer’s code in order to “read” the lot number. For the audit trail to remain intact, any time more than one lot is combined, or ingredients are blended, a new lot number is assigned, and both the incoming lot numbers and the new lot number must be recorded on a document.
What permits do I need?
Health/Safety permits for food manufacturing establishments: On February 25, 2009, the USDA National Organic Program (NOP) issued a notice to all Organic Certifying Agencies concerning food safety. The notice serves to protect public health by reminding us that no certified organic operation “can demonstrate compliance with [NOP] regulations if the operation fails to comply; … that is, the operation exhibits any pest infestation that could lead to a health hazard…”
The notice also specifies that “…organic certification shall not be granted or continued when current health or safety inspections have not been granted or renewed for the facility.” This requirement pertains only to processing establishments, not to growers.
Ensure you have obtained all required Health Department Permits, Certificates and/or Inspection Reports, submit them with your Organic System Plan and make them available for review at the time of organic inspection. If your facility does not have a health/sanitation certificate, please contact your local Health Department for guidance. (Ref: NOP sections 205.501, 205.271 (a)(b)(c)(d), 205.103 (b.4) and (c) also 205.104).
While the NOP is not a health or safety program, the regulations in §205.271 clearly recognize the importance of pest prevention because of the problems that pests can cause—disease and illness. Your certifier must verify that processing facilities have obtained health/safety certificates as required by Hawai’i State law. The Hawaii Department of Health requires that food processing facilities apply for and obtain a Food Establishment Sanitation Permit. Not having an FEP is not an organic non-compliance, but is a condition that may affect organic certification.