Organic Handling and Processing
Hi IFSQN team,
Just some thought that I have and I need your review and get opinion on.
We produce organic product on a designated equipment in designated room (we have different equipment in this room).
We schedule to produce organic product first.
We use organic chemical to our organic and conventional products.
We have handling raw material/formulation/working instruction in place
The question is why can't we produce organic and non-organic product
on different equipment in the same room at the same time ?
How far do I have to separate these two equipment?
Please advise.
We have how to handle raw materials/formulation procedure in place.
Which organic certification and who is your CB?
Hi Scampi,
It is Oregon Tilth.
I have not been organic certified for a few years, but was certified for many.
I do not know why you can't. I do not recall anything in the NOP that would say you can not do this. Just that you have to have practices in place to prevent comingling. Who informed you that you could not do this and did they site a reference?
I have not been organic certified for a few years, but was certified for many.
I do not know why you can't. I do not recall anything in the NOP that would say you can not do this. Just that you have to have practices in place to prevent comingling. Who informed you that you could not do this and did they site a reference?
Hello kingstudruler1,
Thank you for your feedback. I'm happy to hear you have the same thought. This procedure was written and implemented by someone who already left the company long time ago before I started working here.
It slows down our productivity because we cannot use that room to produce other product before organic product is finished. I'm trying to support and improve our operation.
I just try to think what do other things I have to be aware of if I'm going to change the procedure.
I am also certified through Oregon Tilth as an organic processor. Your method of processing is solid, especially if you're using equipment designated for organic or conventional. The only complaint I could see them having is related to running organic and conventional products in the same room at the same time...you should do a risk assessment to understand the cross-contamination potential for conventional product encountering organic. Some solid reasoning on file as to why the process is sound should satiate them.
For example, if you have an organic line and a conventional line: if batching for both lines starts in roughly the same area of the room, are there measures in place to prevent mixups or co-mingling of materials? Perhaps the room could be separated into organic and conventional "zones" using floor markings.
Finally, I've had good experience with OTCO in asking them questions directly. You should have a color-coded "team" assigned to you that can provide guidance. However, I've found it helpful to pose questions in the frame of something "you'd like to do" rather than something "you're currently doing". Just about anything related to an organic process requires their approval, so they want to be informed any time you're looking to change a process...
Hello kingstudruler1,
Thank you for your feedback. I'm happy to hear you have the same thought. This procedure was written and implemented by someone who already left the company long time ago before I started working here.
It slows down our productivity because we cannot use that room to produce other product before organic product is finished. I'm trying to support and improve our operation.
I just try to think what do other things I have to be aware of if I'm going to change the procedure.
I don't know your operation, but I'm pretty sure you are ok. Since you state that you will not run products at the same time in your organic plan, I would share your proposed changes to the certification body just to ensure we haven't missed anything.
Also, good job on looking for ways to improve your operation. The willingness and ability of QFS personnel to evaluate processes and risk and make measurable improvements is a desirable trait imo.
I am also certified through Oregon Tilth as an organic processor. Your method of processing is solid, especially if you're using equipment designated for organic or conventional. The only complaint I could see them having is related to running organic and conventional products in the same room at the same time...you should do a risk assessment to understand the cross-contamination potential for conventional product encountering organic. Some solid reasoning on file as to why the process is sound should satiate them.
For example, if you have an organic line and a conventional line: if batching for both lines starts in roughly the same area of the room, are there measures in place to prevent mixups or co-mingling of materials? Perhaps the room could be separated into organic and conventional "zones" using floor markings.
Finally, I've had good experience with OTCO in asking them questions directly. You should have a color-coded "team" assigned to you that can provide guidance. However, I've found it helpful to pose questions in the frame of something "you'd like to do" rather than something "you're currently doing". Just about anything related to an organic process requires their approval, so they want to be informed any time you're looking to change a process...
This is very good advice. Thank you very much, Brothbro! I will get right into it.
I don't know your operation, but I'm pretty sure you are ok. Since you state that you will not run products at the same time in your organic plan, I would share your proposed changes to the certification body just to ensure we haven't missed anything.
Also, good job on looking for ways to improve your operation. The willingness and ability of QFS personnel to evaluate processes and risk and make measurable improvements is a desirable trait imo.
Thank you very much! I appreciate your kind support.
I have also been organic certified, we always ran side by side with traditional production
Lots of times what happens with inherited programs is that they are over written by folks who don't fully understand the codes and requirements, so things tend to be overreaching as a way to achieve compliance.
Agreeing with everything said above.
As long as you let your CB know of the changes to your plan, it should be fine.
And ensuring that personnel, utensils and tools, ingredients, etc. (i.e., everything!!) is completely separate and that it is obviously separated. Color-coding or labeling would work. I do think that it could be risky with new employees who may not understand the requirements, so extensive training would be necessary as well.
With personnel and material labeling and handling practices to prevent comingling or cross contamination I would expect you to be able to run Organic parallel to conventional product -- that is how we have done things for years and our CB, QAI, has never raised an issue over parallel production.
For the question about a measure of distance between them, it will depend on your process. If your equipment is discharging fine particulates while it runs I could see that being a challenge, but if you're able to run two conventional products next to each other without cross contamination problems I wouldn't expect having one of them being organic instead making that any greater a risk. Do your current programs allow you to, for example, run a product with an allergen parallel to a product with no allergens?
Agreeing with everything said above.
As long as you let your CB know of the changes to your plan, it should be fine.
And ensuring that personnel, utensils and tools, ingredients, etc. (i.e., everything!!) is completely separate and that it is obviously separated. Color-coding or labeling would work. I do think that it could be risky with new employees who may not understand the requirements, so extensive training would be necessary as well.
Sorry for the delay. Thank you very much! I will ensure to take note on this.
With personnel and material labeling and handling practices to prevent comingling or cross contamination I would expect you to be able to run Organic parallel to conventional product -- that is how we have done things for years and our CB, QAI, has never raised an issue over parallel production.
For the question about a measure of distance between them, it will depend on your process. If your equipment is discharging fine particulates while it runs I could see that being a challenge, but if you're able to run two conventional products next to each other without cross contamination problems I wouldn't expect having one of them being organic instead making that any greater a risk. Do your current programs allow you to, for example, run a product with an allergen parallel to a product with no allergens?
Thank you so much! I appreciate your advice.
Equipment used for both organic and non-organic products are completely separated and there is no risk of cross contamination.
We have designated room for allergen product currently.