Processing
Ensuring Product Integrity Through
Organic Critical Control Points
By Bill Wolf
and Sandy Mays
The USDA certified organic seal celebrated its fifth birthday this past October and
more and more processors are obtaining
organic certification to meet the surging
demand. With this growth comes the need
for better strategies to assure the integrity of
products bearing the organic brand. The use
of Organic Critical Control Points (OCCPs)
is emerging as a useful tool for every type of
producer and handler to make their
Organic System Plan (OSP) more secure and
effective.
Under the USDA National Organic
Program (NOP) every producer and handler
must have an OSP in place that documents
how compliance with the regulations is
accomplished. This is required in order to
obtain and maintain organic certification.
(See “National Organic Program
Regulations” on page 28.) Many certified producers and processors legally meet this by
completing the certification application of
their Accredited Certification Agency (ACA),
however, this is not a substitute for a separate
written, detailed OSP.
The OSP is to organic certification what
the Hazard Analysis and Critical Control
Point (HACCP) program is to food safety and
the concept behind OCCPs is similar to that
of the critical control points within a HACCP
plan. With HACCP, these control points are
essential components of food safety and quality management plans that identify the places
where contamination can occur and define
the requirements to protect against these
risks. These points provide the detailed
roadmap for training personnel and continuously monitoring product integrity.
Like CCPs in a HACCP plan, OCCPs take
OSPs to the next level of organic security by
creating specific approval steps or gateway
protocols that must be completed at each
level—ensuring that your products meet
organic standards and are properly labeled,
certified and handled.
Each type of organic operator along the
supply chain has very different issues that
must be identified and addressed in order to
install OCCPs at these potentially vulnerable
weak points, but there are some requirements common to every organic processor.
For instance, every handler’s product flow
begins with the receiving of certified organic
ingredients into the facility.
OCCPs in Handling
An example of one of the first OCCPs that
should be in place when goods are being
received is the confirmation of the organic
status of each ingredient. Requirements of
this OCCP might look like:
OCCP 1: Confirm Organic Status. Facility
must have on file a current organic certificate
and certified product list from each ingredient supplier for every organic ingredient
being received. The certificate must confirm
certification to the USDA NOP. Incoming raw
ingredients are quarantined and not accepted into live inventory until this condition is
met. (See “Organic Handler Flow Chart” on
page 30 for an example of how this control
point is incorporated.)
OCCP 3: “No co-mingling of non-organic
ingredients” is another critical control point
commonly identified in the initial handling
and storage of raw ingredients. When there
are not adequate control points or training in
place regarding this essential step it can
