Processing
Nonprocessing Handling: Navigating the Gray
Regulatory Area Between the Farm and the Factory
By Richard C.
Theuer, Ph.D.
If you ask most individuals involved in or- ganic where to find the list of the materials they can use to handle raw organic foods,
they will likely refer you to Sections 205.605
and 205.606 of the National List and think
that they have given you a complete answer.
Think again. These sections relate to materials you can use in or on processed organic
foods. But you can handle organic foods without processing them. There is “nonprocessing
handling.” This includes the post-harvest
cleaning and storage of raw (unprocessed)
agricultural commodities.
The National Organic Program (NOP)
regulation at Section 205.105 requires that a
food sold or labeled as organic must be produced and handled without the use of prohibited nonsynthetic substances and only use
those synthetic substances allowed on the National List. The use of these materials is categorized into two areas: production (farming)
and processing. But which of these two categories does an item fall into during the time
after harvest, but prior to processing? The National List does not have a specific listing of
substances that can or cannot be used on
items during nonprocessing handling. This
situation creates confusion, leading to inconsistencies in how certifiers look at certain
practices and material uses, as they try their
best to interpret the regulations.
What Led to the Confusion…
Since the National Organic Standards
Board (NOSB) began reviewing materials for
organic production and handling, it always fo-
cused on its statutory responsibility—which
materials should or should not be allowed for
which particular uses. Determining which reg-
ulatory pigeonholes the approved and disal-
lowed materials should fit into was the task of
the regulation writers at the USDA.
