Consolidation in Organic Agriculture - CCOF

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HANDLER HIGHLIGHTSFINDING YOUR ORGANIC CONTROL POINTSA DAPTING H AZARD A NALYSIS AND C RITICAL CONTROL P OINTS TO YOUR O RGANIC S YSTEM P LANBy Janning Kennedy, Director of Handler CertificationTHE CONCEPT OF “ CRITICALcontrol points,” originally developedover 40 years ago to protectastronauts from microbial food contamination,can be used by organic processors andpost-harvest handlers to optimize theirOrganic System Plan. “Hazard Analysis andCritical Control Points,” or “HACCP,” isnow applied not only to microbial hazardslike bacteria, but also to physical hazards, likemetal shards, and chemical hazards, like toxins.The concepts introduced by HACCPprotect consumers from food safety hazardsby identifying and monitoring critical controlpoints. They can be adapted by organic businessesto protect organic integrity by identifyingand monitoring organic control points(OCP). Both HACCP and OCP conceptscan be used by the entire organic food productionsystem: growing, harvesting, postharvesthandling, processing, packaging,shipping, retail stores and food servicebusinesses.ORGANIC INTEGRITY, OCPS& ORGANIC SYSTEM PLANSOrganic integrity can be defined as the qualitiesof an organic product that come fromadhering to organic standards. Organicintegrity starts in the field and must be maintainedby the food handling system to thepoint of final sale. The concept of organicintegrity is included in National Organic Programstandards and in CCOF’s InternationalStandards, which were adopted from theAmerican Organic Standards. For example,the preamble to the National Organic Programstates, “The requirements for preventionof commingling and contact withprohibited substances, and labeling requirementsprotect the integrity of organically producedproducts.” An Organic System Plandescribes how a producer or processorintends to maintain organic integrity. Similarly,the goals of an OCP program are toidentify where organic integrity could becompromised, and to establish monitoringprocedures to prevent it. A well-writtenOrganic System Plan includes identificationand monitoring of organic control points,even though those terms may not be used.OCP programs can prevent costly andembarrassing recalls and help companies producea product of the highest organic qualityand integrity. First we will explore howOrganic Critical Control Pointsin Food ProcessingPRESENTATION AT THE 24TH ANNUAL ECO-FARM CONFERENCEASILOMAR, PACIFIC GROVE, CAFRIDAY, JANUARY 23, 2003 • WORKSHOP SESSION E, 1:30–3:30PMOrganic Critical Control Points analysis is an extension of Hazard Analysis and Critical ControlPoint (HACCP) analysis that many large and small processors use to determine places or activitiesduring food processing where food-borne illnesses could be introduced, allowing the implementationof control measures. This workshop will first cover the essential concepts of HACCPanalysis, and then apply these concepts to cover Organic Critical Control Points.Presenters: JANNING KENNEDY, CCOF, Santa Cruz; MIKE WISE, Wiseguys Consulting, ClovisModerator: BRIAN LEAHY, CCOF PresidentHACCP programs are set up, and then showhow OCP programs can use some of thesame principles to protect organic integrity.BENEFITS OF HACCP PROGRAMSHACCP programs reduce outbreaks of foodborne illnesses or injury by emphasizingmonitoring procedures and preventative measuresto prevent potential food safety hazards.HACCP has been adopted throughout thefood processing industry as an exemplaryfood safety program. The USDA requiresHACCP for plants that slaughter or processmeat, poultry, or fish and for low acid canneries.Other segments of the food processingindustry have set up voluntary HACCP programsbecause of their proven value.HACCP programs can virtually eliminatethe need for snapshot, hit-or-miss food safetyinspections and end-product testing forpathogens or hazards. Instead, HACCP programssystematically identify the causes ofbiological or physical hazards, and monitorthose specific points in the manufacturingprocess where they can occur. When properlyimplemented, HACCP provides a record thatall reasonable precautions have been taken toprevent hazardous food from reaching theconsumer. HACCP encourages consumerand regulatory confidence in food safety.STARTING A HACCP PROGRAMTo work well, management must be committedto the HACCP system. Company leadersmust recognize the value of delivering safe,high quality products, understand the principlesand practices that make it successful, andimpart that commitment to employees.Employees must recognize their role in producingsafe food. Only when employees aretrained and the program is incorporated as anintegral part of the quality system will it betruly successful.The first step in setting up a HACCP programis to review the unique conditions inPage 34CCOF Magazine
the food processing or handling facility. Theproduct is defined, including who consumesit, and how (for example, will it be consumedby infants or the elderly? Will it be cooked, orfrozen, or eaten raw?). All ingredients, productionaids, and packaging are identified.A flow diagram is developed which describesthe process. The flow diagram provides a simple,complete outline of the steps involved,like receiving, storage, processing, packaging,warehousing, and shipment. A block typeflow diagram is usually used.APPLYING HACCP PRINCIPLESOnce the product is defined and the flowchart written, the HACCP principles canbe applied. There are seven principles ofHACCP:1. Analyze the hazards2.Identify the critical control points3. Establish critical limits4. Establish critical control pointmonitoring procedures5. Establish corrective actions6. Establish verification procedures7. Establish record keeping ordocumentation proceduresIn the first step, conducting a hazardanalysis, the flow diagram is used to identifypotential biological, physical, and chemicalhazards. For example, salmonella, a moderate-to-seriousfood borne infection, can becaused by ingestion of only a few cells of Salmonella.Salmonella may be identified as ahazard in a product that contains liquid eggs.Each hazard is assessed to determine itspotential severity and whether it is “reasonablylikely to occur.” Hazards that are likelyto occur are included in the HACCP plan.If the potential hazard were inconsequentialor not reasonably likely to occur, it would notbe included.For each hazard, critical control points aredetermined. Critical control points are thesteps at which control can be applied. Thecontrol that will be applied is essential to preventthe food safety hazard, or reduce it to anacceptable level. Examples might be cookingor freezing.For each critical control point, criticallimits must be defined. A critical limit is themaximum or minimum value to which ahazard must be controlled to prevent orreduce it to an acceptable level of risk. Forexample, in a cooked food, this might be theminimum cooking temperature and timerequired to eliminate Salmonella. Settingcritical limits for food safety may involveresearch into scientific literature orgovernment regulations.Once critical limits are defined, proceduresare established to monitor the critical controlpoints. This might include determining howand by whom cooking times and temperatureswill be monitored.Corrective actions are established that willbe taken when monitoring shows the criticallimit has not been met. Corrective actions arethose that would remedy the problem. Thismight include reprocessing the food or disposingof it if the minimum time and temperatureswere not met. When a breach of thecritical limit is discovered, it is important todetermine the cause of the deviation andeliminate it. Measures to prevent recurrencemust be established if the problem couldreoccur.Next, procedures are established to verifythe system is working. An example might becalibrating and testing the temperature andtime recorders to verify each cooking unit isworking properly, or observation of the monitoringactivities and corrective actions to besure they are implemented properly.Record keeping, the final principle, documentsthe HACCP system. Records includethe written HACCP plan and decision-makingdocuments used in its development,which justify critical limits. It includes actualdata collected, documenting the monitoringof critical control points and critical limits.Records of the corrective actions are necessary,such as the reason for holding a suspectedproduct, how and when it wasreprocessed or disposed of, and who wasresponsible. Records also include documentsof the verification procedures.STARTING AN OCP PROGRAMLike a HACCP program, an OCP (OrganicControl Points) program also requires commitmentfrom top managers to be effective.The company must communicate the importanceof maintaining organic integrity to allemployees who handle organic products.There must be a sense of dedication throughoutthe company to producing organic productsthat meet the highest standards ofintegrity.To start an OCP program, a flow diagramis needed. The same one may be used as for aHACCP program, but it will be analyzed differently.Instead of food safety hazards, theflow diagram will be analyzed for organicintegrity hazards. The three ways organicintegrity can be compromised are throughWinter 2003–2004 Page 35
Page 1 and 2: California Certified Organic Farmer
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Page 8 and 9: estrictions on corporate involvemen
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Page 15 and 16: PROGRAMSNRCS &ORGANIC FARMERSBy Jes
Page 17 and 18: VValley Center is the avocado capit
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Page 21 and 22: EDUCATIONPhoto courtesy of Life Lab
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Page 35: CCOF in order to verify compliance,
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Page 42 and 43: BRAND NAME OF PRODUCT SUPPLIER GENE
Page 45 and 46: CCOF CERTIFIED OPERATIONSAUGUST 16
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