tain antimicrobials used in or on food
contact articles and gave authority for
pesticide chemicals used on most raw
agricultural commodities to EPA and
primary responsibility for pesticide
chemicals on food-contact surfaces
and in processed food (“fruits and
vegetables that are not raw agricultural commodities”) to FDA.
The National List at Sections
205.601, 205.602, 205.603 and
205.604 applies to nonsynthetic substances prohibited and synthetic substances allowed in crop and livestock
production. Some of the substances allowed in crop production are known
to be useful in post-harvest handling
of raw agricultural commodities.
Interpreting the regulation is not
easy, and certifiers do not want to put
their accreditation or the certified entity’s certification at risk by permitting
a practice that may turn out to be inappropriate. When a prospective
client asks me about a specific post-harvest handling practice, I read the
law, the regulation, the original substance petition and the TAP Reports,
and the specific practice may seem
clearly allowable. But then I learn the
reality that the certifier may not allow
it because they interpret the regulation differently than I do. There’s a
need for authoritative guidance here!
a pest under circumstances that make it deleterious to man or the environment, if it is: (a) any vertebrate animal other than man; (b) any
invertebrate animal, including but not limited to, any insect, other
arthropod, nematode, or mollusk such as a slug and snail, but excluding any internal parasite of living man or other living animals; (c) any
plant growing where not wanted, including any moss, alga, liverwort,
or other plant of any higher order, and any plant part such as a root;
or (d) any fungus, bacterium, virus, or other microorganisms, except
“P“Plant waxes on fruit are ingested by the consumer, so they are ingredients,
for those on or in living man or other living animals and those on or
in processed food or processed animal feed, beverages, drugs and
Handling practices that control pests include post-harvest washing
of fruits with water containing peracetic acid to reduce bacterial and
mold counts and adding diatomaceous earth to grain silos to control
grain beetle infestations. Examples of proper handling that can delay
senescence of raw agricultural commodities are controlled atmos-
phere storage of apples and other fruits, refrigeration of perishables
such as animal carcasses, coating fruits with wax to reduce moisture
loss and using a nonsynthetic sprout suppressor during potato storage.
Let’s look at these and other common handling practices to see
how they are permitted by the regulatory agencies—NOP, EPA, FDA
and USDA Food Safety and Inspection Service (FSIS)—with jurisdiction over their use.
according to FDA.”
Why Post-Harvest Handling Activ-
ities Are Important
Freshly harvested agricultural commodities are a lot like us human beings. The biggest threats to our
longevity are infections and the infir-mities of old age. The biggest threats
to the wholesomeness of our food are
pest infestation and the ripening
process (senescence) and rotting.
Proper handling immediately after
harvest and during storage helps
maintain the wholesomeness of raw
Proper handling can reduce or
eliminate pest infestation. According
to EPA, “an organism is declared to be
Having fresh apples available at retail virtually 12 months a year requires controlled-atmosphere (CA) storage. By displacing air with nitrogen gas and other methods, CA reduces the oxygen level in a
sealed apple storage room from approximately 21 percent to 1– 2 percent. Storage temperature is kept at a constant 32º to 36º Fahrenheit
(0° to 3°C) and the humidity is kept at 95 percent. Apples take up oxygen and emit carbon dioxide as apple starches change to sugar and
the apples metabolize the sugar. The level of carbon dioxide in the
storage room must be controlled to between 1.5 and 4. 5 percent.
Nitrogen is a nonsynthetic substance allowed for processing at Section 205.605(a) and is not listed as a prohibited nonsynthetic for crop
production at Section 205.602, so this practice is universally accepted.
The NOSB approved nitrogen in 1995 for use in storage, processing
and packaging of organic agricultural products, and for flash freezing,
uses cited in the TAP Report.