Organic Manufacturing: Know Your Supply Chain

Recent cases of massive organic fraud in the Midwest highlight a central tenet of organic manufacturing: Know your supply chain. In February 2020, a man in South Dakota was indicted for selling non-organic grain and seed products marketed as organic to buyers. This comes on the heels of the August 2019 sentencing of four farmers in federal court in Cedar Rapids, Iowa for a scheme in which non-organic grain was sold to livestock producers as certified organic grain.

These types of stories must send shivers down the backs of food manufacturers who strive to build trust with consumers by ensuring that foods they process and sell as organic are truly organic.

The best way to ensure that ingredients are organic, says Gwendolyn Wyard, vice president of regulatory and technical affairs for the Organic Trade Association (OTA), is for food manufacturers to know their supply chain. “There is nothing more important than developing relationships with your suppliers and getting to know them,” she says, adding that undertaking this extra work is critical to ensure that products labeled organic are indeed organic.

Meeting Organic Certification

The basic threshold for ensuring that organic products are organic is to make sure all products are certified as organic. USDA mandates that farmers and handlers follow strict production and labeling requirements to represent their products as organic and receive the USDA Organic Seal. One way to verify the authenticity of organic ingredients is for manufacturers to check organic claims of their suppliers by using USDA’s Organic Integrity Database.

Harriet Behar, an outreach specialist in the Organic and Sustainable Cropping System Program at the University of Wisconsin-Madison, who also sits on the Governing Council and Policy Committee of the Organic Farmers Association, a policy arm of the Rodale Institute, says that the database includes all operations certified by the USDA National Organic Program and allows manufacturers to look up farms and processors that handle specific ingredients or products and where to buy them. Open to the public, the large database includes organizations certified by all of the 80 different certifiers, she adds.

Wyard also refers to the database as a place manufacturers can go to verify that an operation is operating with a valid (in good standing) certificate. She says that all products certified as organic must be accompanied by a valid organic certificate, along with additional supporting documents ensuring that the product received connects to the organic certificate. This includes ensuring that the product documentation meets the organic certification all along the supply chain, including storage and transportation of the product. “One of the beautiful things about the organic system is that, with a narrow exception that may be made for brokers and traders, everyone handling a product in the supply chain has to be certified,” she adds. “There is a chain of custody and traceability that can and should occur all the way through the supply chain, so that is very helpful.”

Ensuring organic throughout the supply chain includes not only making sure that the primary production and manufacturing of food meet organic requirements, but also that contamination prevention controls are put in place as the product moves from field to manufacturer to retailer. All of these factors need to meet the food safety regulations detailed in the Food Safety Modernization Act (FSMA). Jacob Guth, director of food safety for California Certified Organic Farmers (CCOF), emphasizes that organic farmers need to be aware of various requirements when working to meet FSMA requirements.

Major hurdles for organic farmers in meeting these requirements, he says, include the paperwork and record keeping needed. “If it’s not written down, then it didn’t happen,” he says, adding that even though many operations may have practices in line with food safety and organic requirements, it may still be difficult for them to document the many policies, procedures, and practices needed to demonstrate compliance.