Manufacturing Organic Products And SQF
Ok, "Hypothetical Situation" time here, folks.
Let's say the Chocolate Manufacturer I work for one day decides to enter the Organic business to become "100% Organic Certified" in order to produce a line of new Organic items.
Since there are Certification Bodies that are strictly dedicated to Organics, I'm assuming that any regulations and requirements would primarily flow through that particular Certification Body.
However, what is the direct impact (if any) upon our company's pursuit of and implementation of an SQF Level 2 Certification? In other words (and I'm sorry for not knowing this off the top of my head as I probably should), but is there a whole other Module that we would need to worry about if we ever decide to go down this road? Anyone out there already in the Organics business, especially those who create Organic Candy/Chocolate products let's say?
As always, thanks in advance for your time and help!
JKR
mostly during SQF an auditor might just be curious to see if your organic product is listed in the scope of the organic certification body. Normally they don't dwell much in those checks so if you have your paperwork then you don't need to worry
Hello JKR,
While I am not SQF (Im BRC) I am Organic - So I may to be able to help, at least partially.
Your Organic CB should provide the regulations and requirements needed to obtain certification for that particular body, something like an application process will be initiated. As far as GFSI impact, this is where you might find a different answer for SQF as I know very very little of the requirements ... BUT... - in BRC there is a little blurb about "Identity Preserved" products, Organic and Kosher, etc. products fall under this category.
Our BRC auditor seems to think that their regs trump any regs that the Organic CB may have (This has not been validated - maybe someone else could confirm??) (Like for instance, BRC Issue 6 stated that a mass balance activity must be conducted every 6 months, while our Organic CB stated a mass balance activity only had to be conducted annually. BRC trumps Organic so we did 2x per year) (Side Note - Thankfully Issue 7 has changed this section dramatically and now the requirement simply reads "where claims are made yada yada.. the site will maintain the necessary certification" leaving all the knitty gritty details out.
Hope you find some more helpful answers - check your message inbox, I am going to send an example of the organic application from the CB that we use.
IRI
Yes and no?
For SQF, you'll have to comply with 2.8.1 for IP foods (organic, non-GMO, Kosher, Halal, etc), for level two that's pretty easy, as the clause does not apply to level 2. So no added compliance issues there.
However, going organic can impact your FSMS system and other parameters that SQF covers -
pesticides and chemicals will have to comply to your organization's standards (there are a lot of different organic standards), so you'll have to revise your chemical control program and pesticide program, you'll need to make sure your product specifications contain organic certification,etc.
California has super special regulation regarding the use of "organic" , but that's for pre-gate / farms
That's a great point about the Chemical Control Program.
It will be interesting to see the "Organic" specific requirements from that CB and how they differ and/or are similar to SQF requirements should we go down this road.
Thanks!
JKR
when going through our sqf audits all the guy asked was "do you have organic products? Are you certified? show me your scope of certification? show me your audit report?, identification yada yada separation blah blah blah and you follow these rules? yes your auditing it right now lol " Good lets carry on
easy as that
Like what I'm hearing!
Yes, the more I dig into this, the more it definitely seems pretty "straightforward" and "easy" as you point out, especially as we pursue SQF Level 2 Certification since (as someone else previously noted) Clause "2.8.1 - Identity Preserved Foods" is NOT APPLIED at SQF Level 2 so yay for me!
JKRed