Sanitation in Organic Handling Facilities

Comprehensive cleaning and sanitation programs are necessary at food handling facilities to ensure product quality and food safety. Facilities are required to protect food products from contamination by food and mineral residues and microorganisms that can lead to spoilage of food and food poisoning of consumers. When a facility is organically certified, it has the additional responsibility of protecting organic food products from commingling with non-organic ingredients and contamination by even trace amounts of, detergents, sanitizers, and pest control products used in the facility.

Certified facilities, such as grain cleaning plants and flour mills, generally do not use sanitizers and detergents. Cleaning programs in these facilities usually consist of vacuums, brooms, air compressors and self-cleaning equipment. Purges of organic product are often used in such facilities to flush non-organic products from equipment that is difficult to clean.  When using purges as the measure to protect against commingling with non-organic product or contamination with prohibited materials, it is important to look for areas in the processing line where product may lodge and to be sure that your protocols include a thorough cleaning of these areas.

Food handling facilities employing “wet cleaning” procedures do use detergents and sanitizers for equipment cleaning, including Cleaning in Place (CIP) and Cleaning Out of Place (COP) systems. In these systems, conventional facilities often use sanitizers that do not require a rinse prior to the processing of food. Under organic certification however, any material that is not included on the National List of Allowed and Prohibited Materials, section 205.605 NOP Rule, may not contact organic ingredients and products. There are only a few materials on the National Lists that are used as sanitizers, including chlorine and hydrogen peroxide. Sanitizers such as quaternary ammonia, peroxyacetic acid¹, iodine and alcohol are not included on the National List, and while they may be used in organic facilities, they must not come into contact with the organic ingredients or products.

NOTE: Peroxyacetic Acid has been recommended by the National Organic Standards Board (NOSB) for inclusion on the National List, but on the date of writing has not been listed and therefore may not contact the organic product.

Organic Sanitation Protocols to Prevent Contamination

In order to protect organic products from contamination by cleaning and sanitation materials, certified facilities usually implement special organic cleaning protocols that are communicated to employees and are thoroughly documented. Such protocols, which take the form of Organic Sanitation Standard Operating Procedures (SSOPs) and/or Pre-Organic checklists, describe how equipment and food contact surfaces are to be cleaned and sanitized and how the organic products are to be protected from sanitizer residues. Verification that these procedures have been carried out prior to each organic run is critical and may take the form of a completed checklist or employee initials/signature on posted SSOP’s.

Protecting the organic products from contamination with cleaning agents may involve the following protocols:

1. Using cleaning and sanitizing agents that are permitted for organic food contact and appear on the National List of Allowed and Prohibited Substances, section 205.605.
2. A verified adequate rinse following sanitizer use and prior to an organic run
3. Purge of organic products through the system prior to the organic run. Purged product is either diverted to a non-organic run or discarded. Records of the purge must be maintained as verification of how much organic product was purged through the system and how it was disposed of or diverted.
4. Organic run as the first product run of the day following a comprehensive clean and rinse the night before.
5. Certified facilities are also required to confirm that their special organic cleaning protocols are effective to remove sanitizer/detergent residues prior to processing organic goods. How one justifies the efficacy of these organic protocols is up to the certified facility, however QAI must approve of the method. The most common way to confirm the absence of sanitizer residues is performing residue tests. Depending on the type of sanitizers used, an appropriate residue analysis (e.g., pH, low level chlorine analysis, ammonia test, etc.) may be conducted. If using a purge of organic product, the certified facility will need to justify to QAI that the size of the purge is sufficient to remove all sanitizers or non-organic product.

To illustrate, a facility using Quaternary Ammonia as a sanitizer needs to demonstrate to QAI that Quaternary Ammonia residues do not contact the organic ingredients or products. As Quaternary Ammonia has significant residual activity, the equipment is thoroughly rinsed several times, and/or purged with an adequate quantity of organic product. To confirm the efficacy of the rinse or purge, an ammonium test strip is used with a detection level down to 0 ppm to ensure that no residues are lingering prior to organic production. This procedure is documented in an Organic SSOP or Pre-Organic Checklist. For each organic run, the rinse and/or purge is documented, the results of the residue analysis are recorded, and this is verified by the signature of the responsible person.

Special Circumstances

There may be special circumstances where a rinse and/or purge of certain equipment cannot be performed. QAI understands that every situation is different and encourages you to obtain approval on your proposed sanitation protocols from your Account Coordinator.

Opening up to the EU Marketplace - Frequently Asked Questions:

Many QAI clients have successfully navigated exporting organic products into the European Union. In this issue of QAI's eNewsletter, we give you the basics on the EU regulation and certification considerations. Take a look at the information and remember to feel free to contact Ann Hourigan, QAI EU Coordinator, should you have any questions about how to access this booming organic market!

What is the difference between EU Organic and NOP Organic?  Isn’t it all just Organic?

The term “Organic” is regulated.  Different regions have different regulations.  In the United States, the USDA regulates the requirements for products, which make an Organic claim.  The NOP (National Organic Program) has been developed within the USDA to address and execute the regulations pertaining to Organics.  The USDA accredits third-party certifiers, such as QAI, to certify operations that have demonstrated their compliance with the NOP standards.

Just like Organic commodities sold in the U.S. have to meet the requirements of the NOP, Organic commodities sold within EU member states must meet the requirements of Council Regulation (EEC 2092/91).  Although there are many similarities between these two standards, they are nonetheless different standards and require different certifications.  EU certification can be offered by an ISO 65 accredited certifier, which includes QAI.

Why should I become EU certified?

As the euro becomes stronger, the EU is becoming an increasingly desirable region to export and market products.  Sales of organic commodities tend to do especially well throughout the European Union due to consumer awareness and the integrity that is guaranteed with organic products.  For products to be sold within the EU as organic, it must first be certified to the European standard (EEC 2092/91).

 . . . but I don’t intend on exporting to Europe.  Why would I need EU certification?

For products to be certified as EU Organic, every step in the supply chain must be certified to the European standard (EEC 2092/91).  Your business may not plan on marketing to Europe, but you may have a customer that would like to export organic products.  Before your customer can be certified as EU organic, you as their supplier must first attain EU certification. 

Why should I seek certification through QAI?

QAI is accredited to certify to the NOP and EU as well as IFOAM, JAS, and the CAAQ.  As the world market place has grown and continues to grow, new organic standards and regulations are continuing to develop in various markets.  QAI has consistently sought out the necessary accreditations to be able to certify to the various standards across the globe. 

Sources:

http://ec.europa.eu/comm/agriculture/qual/organic/index_en.htm

Council Regulation (EEC 2092/91)

http://www.ams.usda.gov/nop/FactSheets/Backgrounder.html

QAI is proud to publish the following "official announcement" from the Conseil des appellations agroalimentaires du Québec (CAAQ).

Elections to the CAAQ Board

During the annual general meeting two positions were filled on the Accreditation Board in charge of organic designation. André Blanchette was re-elected by acclamation as the Processors' representative and Kasey Moctezuma, the Account Representative at Quality Assurance International (QAI) was elected as the Certifying Bodies representative to replace France Gravel from Ecocert-Canada who had not requested a renewal of her mandate.

The election of these new board members took place during the Executive Committee's reorganization.

Sweet success: A visit with Azucarera Paraguaya

Last April, QAI employee Jake van den Akker spent a couple of days with longtime QAI client Azucarera Paraguaya.  Much of his time was spent touring the cane-covered hills of Paraguay and learning about the important role of the cooperative in this small South American country.

Nearly 100 years ago, Azucarera Paraguaya (AZPA), Paraguay’s largest certified organic sugar cooperative, was formed.  Today, the sweet granules of AZPA’s organic sugar are consumed in many countries throughout the world, including the US, Germany, Israel, Italy and Japan.  Despite having a reputation for producing some of the sweetest and highest quality organic sugar on the market, AZPA looks past just producing high quality organic sugar and also focuses on two other significant aspects of sugar production: the land and the people who farm that land.

Approximately 5,000 Paraguayans work for AZPA.  The majority of them are small producers that have joined the cooperative in order to gain access to foreign markets and receive a higher price for their product.  The cooperative works hard to ensure that its farmers have the means to not only sustain their product from year to year, but also improve their livelihoods.  As part of the process to integrate farmers into the cooperative, AZPA offers frequent educational seminars that range from the production of organic sugarcane to the rules and regulations associated with organic sugarcane processing.  Since many of the farmers live in remote rural areas of Paraguay, illiteracy among AZPA’s farmers has been a major problem for the cooperative and its organic program.  Andres Vargas, Commercial Coordinator for AZPA stated, “We realized that illiteracy was a big problem in the rural areas, therefore we decided to provide the farmers with people who could help fill out the forms that are associated with organic production.” 

Along with educating the cooperative’s farmers, AZPA has taken on the challenge of educating the next generation of farmers.  Adjacent to their milling facility, lays a small community of farmers and mill workers.  Recently, with funds from the cooperative, AZPA erected a schoolhouse for the children of the community.  Soon after, they decided to fund the community’s first hospital and ambulance. 

While maintaining nearly 400 kilometers of rural roads for the farmers of the cooperative, AZPA has also begun a land ownership program for the farmers and mill workers it employs.  After working for the cooperative for five years, workers are given a small plot of land and the option of taking an interest free loan that can go to the construction of a house.  Since the program’s commencement, hundreds of AZPA employees have taken advantage of the land ownership program.

In addition to its commitment to producing high-quality sugar and striving to improve the livelihoods of its employees, AZPA has also dedicated many resources to the preservation of the environment, including an extensive reforestation project.  The main focus of the project is to reintroduce native species that have been on the decline since the inception of the sugar industry in South America.  Mario Mendez, Manager of Quality and Technology for AZPA, proudly stated that over the past two decades, AZPA has reintroduced nearly 800 hectares of native trees to the Paraguayan countryside. 

Reducing the waste from the production of sugarcane has also been a main focus of the cooperative.  As a result, many of the cooperative’s agronomists, in conjunction with the farmers, have developed ways to reduce the byproduct from sugarcane processing.  One such development has been to use the torta de filtro or leftover cane pulp as an organic fertilizer on many of their organic farms.  Furthermore, they use that same pulp to fuel the ovens in their processing mill and to generate electricity in their offices.

By limiting their ecological footprint and confronting the social issues of their employees, the cooperative has continued to add farmers year after year.  Top that off with a high quality product and AZPA’s success has been incredibly sweet.

July 9-11 NASFT Fancy Foods New York

July 18-20 Associated Grocers Inc, Tradeshow - QAI Presents/Exhibits

September 6-9 SANA International, Bologna

September 25-29 USDA Food Safety Inspection Service and NSF International to Host Food Safety Education Conference

In this issue, we turn the spotlight on QAI Reviewer/Inspector Stephen Grealy who's In The Q--so pull up a vegemite sandwich and enjoy.

Backstory: I was born number four of 11 siblings, growing up in a small country town in Australia, where milking cows, feeding the chickens and harvesting organic vegetables were part of the daily routine.  After studying to be a science teacher at university, I turned my focus of study to getting to know all the by-ways, backwoods, and backroads of Australia, surviving in this extended adventure by working in a variety of jobs throughout Australia, from chief cook and bottle washer in an iron ore mine, “deckie” on a prawning trawler, throwing hay and picking fruit, to working as a builder's laborer and pulling pints in a pub.  One of the more unusual jobs I had involved a 20 mile commute each way on a bicycle to be the driver and assistant to a legally blind government staffer whose job was to revitalize the small country towns in Tasmania with tourism projects.  I met many colorful personalities in these small towns. 

Much of my travel was by bicycle and on foot backpacking in the Aussie bush.  It was in these adventures that my passion for the environment was born – especially after seeing the devastation wrought by clear cutting in Tasmanian forests by the Japanese wood chip industry.  I then went on to travel through Asia, stopping in India for a few years.

In the 1980’s I went on to manage an organic farm and composting operation in Oregon for five years, then tried my hand at helping to run a start-up clothing import company based in Santa Barbara for two years, before settling into my present career(s) in the municipal recycling and organic industries in the late 1980’s.  I started organic inspecting and working on certifier quality review committees in the early 1990’s because, while I didn’t miss everything about operating a farm seven days a week, I did miss that contact with the earth and the farmers who care for it.  I went back to school and graduated with a Masters degree in Environmental Science and Agriculture from the University of London in 1995.

Realtime:  I came to QAI in 1996, first working as a contract reviewer and inspector and then becoming a part-time employee in 2004.  My primary role at QAI is that of a technical reviewer, however I still perform inspections as needed. I also participate in the lively policy team discussions at QAI.  I derive most of my satisfaction in these policy discussions from coming up with solutions for the clients that are good for them while being consistent with the applicable organic regulations.

My favorite poet :TS Elliot

Favorite place: the southwest of Tasmania

Favorite food: fish and chips

Favorite bands:Yes, Midnight Oil, and the Bushwackers

Hobbies: photography and gardening,

Favorite weekend activity: camping out with my 9 year old daughter, Gemma.

To contact QAI:

If you have questions, concerns, or need general information, go to the QAI web site to learn how to contact us or to send us an email. For questions pertaining to QAI’s Quality News contact Ellen P. Holton, NSF National Corporate Accounts Manager, Supply Chain at 858.792.3531 ext 115.

QAI, Inc. is an NSF International Company. Visit the NSF web site to learn more about NSF International, The Public Health and Safety Company™.