Organic Manufacturing: Know Your Supply Chain

One solution, he says, is to set up record-keeping systems that are easy to fill out and tailored to the size and scope of the operation. “Many times, operations set ambitious record-keeping goals for themselves, only to find out it’s nearly impossible to keep up with those records,” he adds. “Operations that can combine logs or records to check many control points on one record have success ensuring their employees complete those records.”

To help organic growers with FSMA compliance, CCOF offers product safety alliance training, good agricultural practices webinars, and food safety certifications for farms and packinghouses. “While third-party certification is not required by FSMA, it’s often required by buyers and wholesalers, and the process of certification helps prepare an operation for FSMA compliance,” says Guth.

Overall, he recommends that manufacturers have a robust supplier approval program to help ensure that they can verify the organic and food safety compliance of the ingredients they buy. Behar also emphasizes the need for a good tracking system. “If you have a good tracking system in place, doing organic is not going to be difficult,” she says.

Both Guth and Behar add that once operations become certified organic, they have an easier time with food and safety requirements overall because of their established documentation and recording systems.

Extra Work: Due Diligence

Despite a fairly rigorous certification process for meeting organic criteria all along the supply chain, gaps do exist.

One gap is an area of the supply chain that does not need to be certified organic. “Any operation that sells a product that remains enclosed in a container and is not otherwise processed while in the control of the operation, such as brokers and traders, is not required to be certified organic,” says Wyard. Problems of fraud that can result are illustrated in the above-mentioned Midwest organic fraud cases, in which middlemen profited by selling fake organic seed, as well as similar fraud uncovered in 2017 by the Cornucopia Institute of the largest importer of fake organic grain from the Black Sea region.

According to Behar, this loophole may soon be closed, pending approval and enactment of a piece of federal legislation by the USDA National Organic Program that would mandate certification of these types of operations. Called the “Strengthening Enforcement Rule”, the new rule is currently under review by the Office of Inspector General.

Until then, Behar says that manufacturers who work with noncertified brokers can request from them source organic certification and verify that certification by contacting the organic source. When working with certified brokers, she says that manufacturers can “source more domestic products certified under the National Organic Program, rather than working with foreign imported products that are more difficult to track.”

A further gap may be the difficulty of ensuring organic ingredients from farms that are transitioning from conventional to organic farming. Per USDA regulations, farms transitioning to organic cannot sell products certified as organic for three years. During the transition, farmers must reestablish an ecosystem for organic plants that prohibits the use of herbicides and pesticides and are in compliance of all organic methods. This is a labor intensive and costly undertaking, says Wyard.

Although products from these transitioning farms only become certified organic after the three-year transition window, manufacturers may need to perform extra due diligence when partnering with a new organic farmer to ensure all processes are in place. Behar notes that, for most of these newly certified farmers, obtaining information such as an organic certificate from a USDA-approved certifier should be enough, given that the requirements for organic certification are the same between newly certified and long-term certified farms. “If there are concerns, the certifier can be contacted to verify the information on the certificate,” she adds.