Consolidation in Organic Agriculture - CCOF

commingling with non-organic foods, contactwith prohibited substances (those noton the National List of Allowed Substances),and mislabeling. Each organicintegrity hazard is assessed to determinewhether it is reasonably likely to occur. Ifit is, it must be addressed in the OCP plan.For each organic integrity hazard identified,organic control points are determined.Organic control points are where controlcan be applied to prevent the loss of organicintegrity. For example, if a companyreceives both organic and non-organicproducts, an organic control point wouldbe at receiving, where proper control canprevent or reduce the possibility of receivingnon-organic products as “organic.”HACCP programs include the conceptof “critical limits.” In some cases, the criticallimit is zero. For example where metalfragments are identified as a hazard there iszero tolerance for metal fragments. For anorganic system, the critical limit is zero forall three organic integrity hazards. There isno tolerance for commingling, contact withprohibited substances, or mislabeling underorganic standards. Thus, in our example,the critical limit for receiving non-organicproduct as “organic” is zero.The next task is to establish proceduresto monitor the critical control points. Inour example, this may be a requirementthat delivery tags for organic products aremarked “organic” by the supplier, andinclude field identification. It may includetraining receiving personnel to check preparedlists of organic suppliers and fieldidentifications.When monitoring activities show thatthe critical limit is breached, there must becorrective action. This involves having aplan or procedure to follow if the systemfails. For example, for product believed tobe “organic” but not correctly identified onthe delivery paperwork, there may be a procedureto isolate the product until its identitycan be confirmed. There should also bea review to find ways to prevent the problemfrom occurring again.Procedures to verify the OCP system isworking are necessary. This might includereviews of total product received againstestimates, or periodic oversight by supervisors.As for HACCP systems, maintainingan effective OCP system depends on regularlyscheduled verification activities.Organic operations are required to keeprecords that verify compliance with organicregulations. The records developed throughestablishment of an OCP would likely bethe same as those required under theNational Organic Program. The OrganicSystem Plan would document the developmentof the OCP. The OCP plan should beupdated and revised as necessary. Records ofmonitoring the organic control points, verification,and corrective actions would bepart of the required records maintained bya compliant organic operation.The organic food industry can increaseconsumer and regulator confidence in theorganic integrity of their products by usingOCP principles. OCP principles parallelHACCP, an internationally accepted andrational approach to food safety. By applyingthe seven principles of HACCP analysisto organic integrity issues, organic businessowners can understand how to improvetheir unique processing or handling systemsto maximize adherence to organic principlesand regulations.