Becoming a Certified Retail Store (Part 2) Meeting the National Organic Program Regulations Topics Cleaning and Sanitation Pest Control Documenting what you do Audit Trails What to Expect at your Inspection CCOF‟s Retail Certification Program How to maintain organic integrity? 2 concepts, 7 words… Avoid commingling (even touching) between organic & nonorganic. Avoid contact with prohibited substances, (those not on the National List). And if you are certified, you need to document that you did. Cleaning & Sanitation Overview Clean facilities help maintain organic integrity. Prevent commingling – by removing nonorganic products before introducing organic. Prevent contact with prohibited substances – by washing & rinsing utensils, containers, and work surfaces. Rinsing is critical for most cleaning or sanitizing products Be very wary of leave-on sanitizers, use those on the National List. Cleaning & Sanitizing (continued) Preparation Areas: Wash & rinse counters, sinks, and containers Wash & rinse cutting boards, knives, scoops Wash hands after handling nonorganic products. Always wash organic produce in fresh water. Display: Wash & rinse bins, trays, bowls, shelf liners, and display containers before use for organic. Pest Control For certified or noncertified retail facilities. Noncertified retail stores There are no specific requirements under the National Organic Program… Are responsible for maintaining organic integrity of the products you sell. Should use good sense in controlling pests to prevent pesticides from contacting ANY foods! However, may we recommend the strategies for certified facilities… Four „Levels‟ of Pest Control for Certified Organic Facilities: 1. Prevention 2. Mechanical and physical controls 3. Materials on the National List 4. Synthetic materials not on the National List, with approval from your certifier. To be used in that order! Primary Strategy For Pest Management: Prevention Sanitation Using monitoring devices Store design Remember … an ounce of prevention is worth a pound of poison But when Prevention alone doesn‟t work... MECHANICAL & PHYSICAL CONTROLS Mechanical and/or Sticky Traps Electrocuters, Zappers Pheromone Traps or Lures Repellents Repellent: Cayenne pepper to discourage ants around the honey. Light attractant for flying insects And if mechanical and physical controls don’t work The 3rd level Using pest control materials included on the National List Boric acid (crawlies), vitamin D3 (rodents), natural citrus products, botanical pesticides. May NOT contact organic (or nonorganic) food! Boric Acid Citric Products Examples of products on retail shelves that can be used. 4th level of pest management Using Pest Control Materials Not on the National List: Synthetic Pesticides May be used by certified organic facilities - BUT Must be disclosed to & approved by your certifier. You will probably be asked to justify their use. Must not contact organic products. If you hire or contract a pest control company to do your pest management You should document that you have informed them of the requirements for pest control in organic facilities. Send a letter or memo, and keep a copy of it with the on-site inspection log. It is ultimately YOUR responsibility to comply with organic regulations. Documenting What You Do a.k.a. Keeping Records Why do you have to keep records? „Exempt‟ & excluded, noncertified retail stores not required to follow record keeping regulations… However, they must be able to verify that the products they label and sell as „organic‟ are indeed organic. Date of purchase, source, quantity, certification status. ‘Exempt’ means Maintain records 3 years the store does not process Certified retail stores, including those that process & move organic products off-site… Need to be able to document you have complied with the regulations that apply: Date of purchase, source, quantities, and certification agent of organic products. No commingling. No contact with prohibited substances. Any processed products were properly labeled. Ingredients were as stated on the label. Maintain records 5 years. Two Kinds of Records 1. Documentation of how you maintained organic integrity Cleaning and pest control records Written procedures, logs, forms Employee training 2. Audit Trail Sufficient to determine the source, transfer of ownership, and transport. 1. Documenting what you do to maintain organic integrity If you prep nonorganic & organic, records should show you cleaned between them. If you use cleaners or sanitizers that are not on the National List records should demonstrate that any residues are removed. You may develop your own forms, or purchase the GORP Manual, or use other source. Documenting what you do to maintain organic integrity (cont.) If you use any pesticides, whether or not they are on the National List, records should show what was used, how much, when, and where. Records should demonstrate what you did to prevent the pesticides from contacting organic products. If you‟re certified, you may need to document mechanical & physical controls were not effective. 2. Documenting the audit trail: Certification Status: If you purchase products from „exempt‟ operations, you may want to have a record from them verifying they qualify as „exempt‟. If you purchase direct from certified growers or processors, you need their certificates. Documenting the certification status (cont.) If you purchase from noncertified distributors, you must have a copy of the grower‟s or processor‟s certificate. If you purchase from certified distributors you only need the distributors‟ certificates. Hint Distributors who repack or relabel must be certified, at least for that portion of their handling operation. Additional audit trail documentation Orders Bills of Lading Delivery receipts Receiving documents What to Expect at Your Inspection Or how to stop worrying and love your inspector. Certification is “Plan” based You must submit an organic handling plan with your application. Practices & procedures to prevent commingling & contact with prohibited substances, substances used, monitoring practices, record keeping, procedures. Before assigning an inspector, we review your plan. We‟ll notify you if there are areas that are incomplete, unclear, or don‟t meet regulation. Inspector‟s job? Toverify you operate according to your plan! Inspectors must physically inspect each department requesting certification. Receiving areas, storage, prep areas and display. Review records and logs. Verify you are operating according to the organic handling plan you submitted. During an inspection the inspector will look at Receiving areas for cleanliness, evidence of pest control. Storage areas for potential sources of contamination, clear identification, & evidence of pest control. Prep areas for ways that organic product could contact prohibited substances or become commingled Your displays for labeling, separation. During the inspection your inspector is likely to Start with an interview with management. May interview employees. Examine files, cleaning logs, pest control logs, employee training logs. Ask for an „audit trail‟ to track products to certification verification. the inspection (cont.) Ends with an interview to identify potential areas of non-compliance, areas of concern, or request further information. Inspectors may only explain regulations, not advise. Hints: 1. Avoid interruptions having 2. Stay on topic. And then… Your inspector submits written report to certification agent. We review the report and notify you of decision. You will renew your certification annually. CCOF‟s Retail Store Certification Program California Certified Organic Farmers Non profit Since 1973 Certify over 1000 operations California & beyond Farms, processing facilities, retail stores First certified retail store: 2000 CCOF‟s Retail Store Program Applicable National Organic Program standards. Short application form. Organic Handling System Plan Questionnaire from the GORP Manual. Other pages from our processing Organic System Plan forms if you are processing. Hint: Attach your forms & other information as requested. May select which departments Timeframe: Allow for at least 8-12 weeks from when we receive a complete application. Hints: •Submit complete application. •Respond quickly if more information is required. •Be accessible for your inspector. Retail Programs CCOF certifies 1. „Exempt‟ retail store activities. 2. Repacked products labeled “organic” per NOP. 3. Retail activities plus repacking and/or relabeling. “Certified Organic by CCOF”. 4. Delis and restaurants for food handling. 5. Private labels, with or without retail certification. Costs Application packet & fee. Based on square footage of store, same price for any or all departments. Annual inspections billed according to actual inspector‟s time Private labels are separate. Happy to give an estimate by phone. Challenges We‟re still modifying our retail program to be useful, satisfying, and meaningful to our clients. Some questions Should all departments be required to participate? Should we offer a „package‟ private labels with store certification? How to encourage more deli‟s to become certified? Thank you for supporting organic farmers and processors!
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