result in costly mistakes. One company, for example, had the same
organic and non-organic ingredients stored next to each other with
no segregation or delineating signage. There were no OCCPs in
place and the company had not offered much training about the
“B“Because they didn’t have an OCCP in place that
required them to check labels prior to printing
this oversight cost the company nearly $22,000.”
organic regulations and their purpose. This led to disaster when a
few bags of the non-organic ingredient were pulled and added to a
cook tank during an organic run. The entire production batch had
to be diverted to non-organic product and sold as conventional at a
loss of over $15,000. Adding insult to injury, the processor could not
run the original order because the botched production run had
used up key organic ingredients that were in short supply. Orders
for that item could not be filled for 90 days and key customers were
nearly lost. If proper OCCPs and a staff training program had been
National Organic Program Regulations (USDA NOP 7 CFR 205)
Subpart C-Organic Production and Handling Requirements
§ 205.201: Organic production and handling system plan
(a) The producer or handler of a production or handling operation, except as exempt or excluded
under §205.101, intending to sell, label, or represent agricultural products as “100 percent
organic,” “organic,” or “made with organic (specified ingredients or food group(s))” must develop an organic production or handling system plan that is agreed to by the producer or handler
and an accredited certifying agent. An organic system plan must meet the requirements set
forth in this section for organic production or handling. An organic production or handling
system plan must include:
(1) A description of practices and procedures to be performed and maintained, including the frequency with which they will be performed;
(2) A list of each substance to be used as a production or handling input, indicating its composition, source, location(s) where it will be used, and documentation of commercial availability,
as applicable;
( 3) A description of the monitoring practices and procedures to be performed and maintained,
including the frequency with which they will be performed, to verify that the plan is effectively implemented;
( 4) A description of the recordkeeping system implemented to comply with the requirements
established in §205.103;
( 5) A description of the management practices and physical barriers established to prevent commingling of organic and nonorganic products on a split operation and to prevent contact of
organic production and handling operations and products with prohibited substances; and
( 6) Additional information deemed necessary by the certifying agent to evaluate compliance with
the regulations.
(b) A producer may substitute a plan prepared to meet the requirements of another Federal,
State, or local government regulatory program for the organic system plan: Provided, That, the
submitted plan meets all the requirements of this subpart.
in place, it is highly unlikely that this
would have happened.
OCCP 6: “No contamination with
prohibited pesticides,” which is a
requirement of both raw ingredients
and packaging materials, is another
one to include in your plan. A snack
food company introduced a line of
certified organic products and everything was going well until they had to
fumigate the storage warehouse. All
organic products were removed to
cold storage before fogging.
However, due to an oversight by
untrained personnel without an
organic roadmap, all of the corrugated packaging used for their organic
products was contaminated by the
insecticide and could no longer be
used, again costing thousands of dollars and production delays.
The potential risk of contamination or co-mingling of organic product with conventional in the supply
chain can be greatly reduced with
OCCPs, especially considering that a
vast majority of organic handlers also
process or store non-organic products. For example, a produce distributor now maintains an OCCP that
requires conventional product never
be stored above organic product.
They learned this the hard way, when
pallets of fresh organic berries were
contaminated by moisture from conventional produce that dripped down
onto the certified product.
OCCPs in Labeling
Organic labeling review and compliance is another area where OCCPs
can save money and grief. Here are
two recent cases we encountered
where investing in proper control
points would have paid dividends:
• A dry goods manufacturer printed
organic product labels prior to
our review and without approval
of their Organic Compliance
Officer. The USDA seal was the
wrong color, the certifier seal was
