Determining amount of product flush for organic changeover?

Greetings,

We are exploring the option of organic processing, in addition to conventional processing, here at our oat facility.

After talking with the organic certification company, we realize that we need to have a system flush between conventional and organic production (of course).

The problem is, no one can tell us now much (quantity) flush is required...and not even a range of amounts they have observed.  They just keep saying "sufficient".

So, what is "sufficient"?  What have you all observed?  I'm not asking for an exact amount, but how about a range?

I have experience with system product flushes from previous jobs, but we were flushing a medicated feed, and could use residue testing results to validate our flush amounts.  I can't think of what I could do to validate this flush, though...any ideas?

Thanks,

Brian

Who does the auditing for your organic certification?

I'd be going to the Auditing division or contracted auditing company to inquire as the what they consider "sufficient."

I've gotten four different "opinons" on this from organic certifiers - that doesn't help anything and now like you in process of going to the source - the one that would say we meet the standard or fall short, hate those grey areas!

SQF Consultant, that's who I asked - they just tell me "sufficient".  I pressed them for how they would determine that - they couldn't give me an answer.

Well, if they can't gauge it, then create your own criteria and keep the emails for validation. I would say that you would flush until you were reasonably certain that <.1% of the material remaining would be non-organic.

You mentioned the medicated feed testing, could you use the quantities needed for those old runs as a baseline? Seems like it would be a good (though probably more strict than you want) surrogate.

Thanks, FurFarmandFork,

That's probably what we'll have to do - just set our own criteria and hope it flies.

I don't even want to get close to what we used to have to do for medicated feed...that was for ionophores (medications that are lethal to horses), and we used to have to do a 12 ton flush after ionophores before we could run a horse feed or all stock feed of any kind.  To say that would be overkill would be quite the understatement...LOL

We are organic certified.......you will have to prove that whatever you've determined to be "sufficient". This should include running analysis to determine that there are zero pesticide residual in the organic product post flush

You will risk losing the organic designation/certification is residue is found. It will be very similar to the flush used for medications in feed. 

Which CB are you going to use? 

Hello Scampi,

Thanks for your response - that's the first I had ever heard anyone say anything about having to do any residue testing, so that's very interesting.  Why would it only be for pesticides?  What about herbicides or fungicides?  What type of testing do you have your lab do to verify sufficiency?  Would the CB actually test if they thought there might be an issue?

My boss wants us to use ICS (International Certification Services, Inc.).

I will give you my slant on organic production (given the changes occurring between our 2 nations) and bear in mind this is just MY interpretation of events 

1--the bag daddy crop company (wont name them because they have a reputation for going after individuals) do not like organic agriculture (cuts into their bottom line) so they are currently lobbying hard in both countries for organic production to be more heavily regulated 

2--CFIA will now be in charge of oversight for ORGANIC certification in Canada---the organic production of goods is completely separate from the food safety portion (and should be organic does not equate safe) including making transportation companies be licensed to haul organic food stuffs and what happens on my side of the border happens to on yours and vice versa. 

3--CFIA takes samples of our product for residue testing now---if an organic product is found to have residue they will revoke certification

https://www.ams.usda...1PilotStudy.pdf may be worth reading

I would ask that your supplier provide the initial residue testing to ensure that the fields they are using are actually below the MRL as set by USDA/FDA and that they are certified organic

We no longer test as the fields have been organic for 10 years, but I would research the MRLs that may be present in oats and/or the water used to irrigate (if they do) and work backwards from there

https://www.ams.usda...rganic/labeling

Uggghhh...makes me not want to even get into this whole organic thing...

Thanks for the information, Scampi...much appreciated.