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Org Devas Organic
Consulting Services |
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Consultation with Food Processor
Report to Anon. Food Processor Processed Foods
Evaluation and recommendation concerning Organic Certification
I visited the Anytown Facility of Anon. Food Processor Foods on May 1. I was met by Paul Weber: Plant Manager, Wayne Wxxxx: Ag Supervisor and Sharon Hxxxxxx: Quality Assurance Supervisor. We reviewed the methodology of organic certification inspection and went through a step by step review of the approach and response to effectively deal with the inspector. We then went through the inspection report item by item. The participants took notes in the appropriate instances.
Next we went through the plant, noting as we went specific needs for each area in product receiving, in production, in storage and in shipping. I will note problematic and challenging areas. In some areas of both operations: Anytown and the Everytown there is the possibility of "organic by neglect", a term not totally applicable, but meaningful none-the-less. By "doing nothing" many early organic farmers qualified for certification. Anon. Food Processor may qualify by merely eliminating certain elements in it's processes and protocols. The other approach is to substitute analogs for the prohibited substances and processes.
At the Anytown plant on May 2, I met with Andy Stxxxxx: Plant Superintendent, Ron Qxxxxx: Plant Manager, Gary Cxxxxx: Raw Product Manager and Wayne Wxxxx: Ag Supervisor. We went through basically the same process as at Everytown. The major difference being the review that I went through with Gary Cxxxxx. Because Anon. Food Processor actually holds the farm land they have some different considerations; for example fees: this will be less. It was noted here that the actual food handler certification and fees will be based on the corporate headquarters. So, both plants are subs of Corporate Anon. Food Processor.
From a marketing perspective, it is best to be as pure and as progressive as possible and to market this fact. Below are the specific changes that I recommend you address:
1. Defoamer.. Every instance where the synthetic defoamer is used it should be replaced with an organic oil. In meetings with a substantial (1.5 billion U$D) corporate entity I recommended that they replace their defoamer with an organic oil. They decided to risk rejection of their certification and not replace the defoamer. They are still trying to plea their position. If you accept this recommendation and advise me of your decision, I will send you a list of OGBA approved (and economical) sources. This is more of an issue in Anytown due to the nature of the products being processed.
2. Fumigation (fogging).. Fumigation is only a problem due to the synthetic nature. Simply use the natural form of Pyrethrum with an alcohol or water base. What you are using currently is a synthetic pyretheroid with a PPB inert as a base. The base would easily kill insects by itself. Again if your current pest control provider can not supply what you need contact me and I will give you the contacts.
3. Storage during fogging.. Organic materials must be removed for 72 hours after fogging and all machinery triple rinsed.
4. Audit Trail dynamics.. At every step of the process, all paperwork must contain:
a. the word "organic" preceding the name of the item (e.g. "peas", "carrots") b. a lot code that can be tracked throughout the entire process; from delivery of raw material through shipment of finished product. I spent a great deal of time elaborating on this using:
1. the process flow chart 2. the inspection report form 3. the physical plant tour
The lot code and word "organic" must appear on every document used. In the case of Anytown, the current forms may be altered. I left specific instructions on site.
Some specifics discussed: Receiving schedule, receiving report, scale ticket. Wash out the (carrot) bins in-between the non-organic and organic products. Clean trucks in between organic and non-organic hauling. A "OGBA clean Truck Document" must accompany each load inbound and should go in a file with the other truck documents. Production record must have organic and should show the change from the inbound lot number (grower's lot number) to the production lot number (case code). This must also be on pallet tag, warehouse log and shipping documents as well as all cases of finished products. Create a finished product record for organic audit purposes.
The lot code and word "organic" must appear on all QA documents.
5) A file enumerating all complaints concerning the organic nature of the products and the companies response must be kept on file with the QA department.
6) Move all unused pesticides. Flush the "flume" with fresh water and fill with fresh water for the organic production run. Clean the waste water pit completely using a vacuum or a sump pump. Clean all splash guards. (Anytown)
7) Have all MSDS records ready for a review and a copy of each and everyone ready. They must be related to the products that you are currently using. You MUST take this seriously.
8) You may need to change some of your boiler additives. I am enclosing comments separately. I am not able to determine what Phosphenic Acid is.
9) I reviewed the application step by step (basically we filled out the Ap.)
10) We discussed the basics of Transaction Certificates.
11) Label with Lot Codes and the word "organic" as well as the product name must appear on every tote bag going to be frozen (use the grower lot code here). (Everytown)
12) Consider changing your sweeping compound.
13) Use the audit trail flow chart I left. Fell free to use this in any of Anon. Food Processors plant and alter this as necessary. If you chose to use it outside of your corp. ask me honor my gift, it's copyrighted.
14) Use Organic Vegetable oil on your can seamers. Again if you decide to do so you may use the same oil as you use for defoamers. Remember to replace the defoamer everywhere. (e.g. color sorters at Everytown).
15) Do NOT use Quats anywhere. They are currently being used on the walls and ceilings in Everytown at least.
16) Consider not using the rust inhibitor during the organic production run in the coolers (Everytown, at least). I will research a substitute.
17) Consider using organic sugar. It is not necessary, but advisable; consider it wise marketing move.
Reach for the absolute best and market it. Make a high quality, good tasting product and use the right label and marketing tools to position yourself in the organic consumer's mind.
To summarize briefly: be prepared:
Make the changes that I recommended: material, recordkeeping and methodological and you should pass. Remember that the inspector will need to watch you run product.
Synthetic Chemicals:
Everytown
Mitco B-5305 Not enough information
Mitco LB-19 Not enough information
Mitco B-5305 Prohibited
Mitco R-9 Sodium Sulphate is prohibited, This is Sodium Sulphite - Not enough information
Mitco A-8 Not enough information
Mitco R10 Not enough information
Mitco AF-35 Not enough information
Hach Phosver For starters, contains Sodium Molybdate OGBA says, “use as a last resort” also contains potasium phyrophosate (I am researching this).
Allstar Liberate Not enough information
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