Food Safety Standard

Auditing organic food processors

Many processors have recognised the massive and sustained growth in the organic food sector. In order to take advantage of this, or remain competitive, or keep major customers, they have had to give consideration to developing organic processed products. Due to market place changes in the last 2–3 years the practical and commercial viability of organic processing is now much more attractive and organic market growth is running at around 40% per annum.

Defining organic food processing:

Organically grown food is food that is grown according to a set of principles and legally defined standards. Organic food processing can be defined as taking ingredients produced to these standards and converting them into a product that is acceptable and desirable to the consumer whilst maintaining the organic ‘integrity’ of the ingredients, the product and process. The ‘integrity’ can be defined as the organic product maintaining its ‘identity’, being free of cross contamination from other foods and chemicals and not having its organic ‘vitality’ lost by over processing. Put simply, organic food processing is not just the substitution of organically grown ingredients for non-organically grown ones, but the conversion of a set of production principles into a consumer product. Organic food processing must be viewed as part of a whole food production and supply system and not just a separate function that sits between primary production and consumption.

Organic food processing has to meet many conflicting demands which nonorganic products do not have to satisfy. Examples would include:

having to meet high standards of food safety but have minimal packaging and use minimal additives
trying to adopt a local ingredient sourcing policy when there is currently a UK shortage of organically produced raw materials
having to satisfy environmental requirements such as efficient energy use but short production runs in non-dedicated factories leads to greater cleaning requirements and greater processing losses.

To give an introduction to the challenges of organic food processing and auditing within the industry some of the main issues relating to organic processing are described below.

Consumer perception and requirements:

Organic food processing must not just satisfy a set of guiding principles and standards, but must also give consideration to consumer beliefs and expectations for both the health and environmental benefits of the food and absence of agrichemicals and food additives. There is also a desire and belief that organic foods are not processed using undesirable practices and processes and that minimal processing and packaging is used. However, the consumer also requires that organic foods are equally as safe as their non-organic counterparts in microbiological terms and shelf stability. They also increasingly require them to meet similar ‘convenience’ factors to their non-organic counterparts. Additionally, most organic foods are perceived to be more expensive than their non-organic counterparts (Anon, 1999), although certain organic food products, particularly dairy products, are being priced much more closely to similar nonorganic products. There is pressure for prices to become lower to make organic foods affordable for a wider range of socio-economic consumers.

Guiding principles and ethics:

The International Federation of Organic Agricultural Movements (IFOAM) has produced a set of principle aims of organic production and processing. The aims related to processing are listed below:

To produce food of high nutritional quality in sufficient quantity.
To consider the wider social and ecological impact of the organic production and processing system.
To promote the healthy use and proper care of water, water resources and all life therein.
To use, as far as possible, renewable resources in locally organised agricultural systems.
To work, as far as possible, with materials and substances that can be reused or recycled, either on the farm or elsewhere.
To minimize all forms of pollution.
To process organic products using renewable resources.
To allow everyone involved in organic production and processing a quality of life which meets their basic needs and allows an adequate return and satisfaction from their work, including a safe working environment.
To consider the wider social and ecological impact of the farming system.
To produce fully biodegradable organic products.
To progress towards an entire organic production, processing and distribution chain, which is both socially just and ecologically responsible.

Regulation:

Organic food production is the only system of food production that is legally defined. Because organic food production is a specific system of production, it is necessary to ensure that there is a credible guarantee of authenticity of organic production methods from primary production to consumption. It is often not known or simply overlooked that the organic inspection is actually a legal requirement and that organic standards and certification are not just ‘another accreditation or quality assurance scheme’. Organic food processing is controlled in the EU by a regulatory structure which is applied at operator level by means of a certification system. The certification system is discussed in more detail later.

The organic standards cover the entire organic food chain from primary production to storage, distribution, importing, processing and retailing.

Product formulation:

Ingredients used in organic foods are divided into the following categories: organic agricultural, non-organic agricultural, non-agricultural and processing aids. Non-organic agricultural ingredients can only be derived from a limited list published in the standards. These include certain starches, vegetable oils (excluding sunflower and olive which must be organic) and a few other minor ingredients. Non-agricultural ingredients include salt and water and a limited range of food additives which excludes preservatives (except sodium nitrate and nitrite) and colourings. Certain processing aids are permitted but again this list is very limited. Full details can be obtained from the Soil Association Standards for Organic Food and Farming.

Process restrictions:

Although it is preferred that organic processing takes place at dedicated organic processing facilities, it is acceptable for processing to be undertaken at nondedicated facilities providing comprehensive separation and documentary procedures are applied. Bulk powder handling and continuous flow operations tend to offer the greatest challenges for integrating organic production into a non-dedicated process. Most standard food industry unit operations are permitted for organic foods but with processing becoming ever more technically diverse, there is an increasing pressure for certain processes to become restricted. Practices such as mechanical recovery of meat are prohibited but other processes are coming under increasing scrutiny such as standardisation and homogenisation of liquid milk.

Challenges for auditing:

The greatest problem facing the inspector is that organic food looks the same as non-organic. Gone are the days of irregularly shaped, pest-damaged fruit and vegetables as lessons have been learned in production techniques and grading. This makes documentation and traceability the only method of identifying a product’s organic status. Agro-chemical and veterinary residue analysis is impractical for verifying organic status due to the expense, the wide number of agro-chemicals used and the fact that produce may be subject to contamination during production, storage and distribution. Organic standards only prohibit the use of such materials but do not guarantee that the end product is free of these materials. The standards do have requirements for minimising contamination and operators are required to report any suspected contamination.

The range of processing operations is large ranging from small on-farm processing operations such as veg-box schemes to multi-national processors supplying major multiples. This equates to a wide range of operator ability as small operations tend not to have technically qualified staff. Therefore the inspection has to be ‘pitched’ at the level of operation being inspected. Other challenges for auditing include the relative lack of experience of operators in organic processing due to the rapid growth of the industry in a relatively short period.

Because demand is outstripping supply, there are elevated premiums for organic produce with commodity prices up to treble the price of non-organic produce which feeds through to retail sales. However, these premiums are also necessary for producers, as organic agricultural production is a much more expensive method of production. Due to these increased premiums and shortage of organic raw commodities and ingredients, temptation to supplement organic ingredients with non-organic ones must be increasingly attractive both to meet customer demands and take economic advantage of the current premiums making the inspectors role increasingly challenging.

Organic ingredient verification:

This is a key part of organic operation and is often overlooked by processors. Companies often pay a much higher price for organic ingredients and for this reason alone it would make sense to do some basic checks on the product to ensure it is what they have paid for when it arrives on site. The certification body checks organic certification of ingredients when a product specification is submitted for approval. The inspector will check the following at inspection:

The supplier and certification of ingredients being used are the same as those detailed on the specification sheet.
Delivery documentation/purchase invoices clearly state the product is organic.
Packaging and labelling clearly indicates the product is organic.
Imported product from outside of the EU is from a correctly licensed importer and is accompanied by EU import certificates.

Purchase documentation and stored product labelling will be checked to ensure that they clearly state raw materials are organic as this will be the only proof that organic ingredients have been used. Goods in records will also be checked to ensure that the result of organic verification check is explicitly mentioned in the goods in records or equivalent. It is considered best practice for licensees to obtain and keep on file, a copy of the up to date organic certificate for the product and supplier. Certification of products and suppliers has to be differentiated because wholesalers who do not repack product do not need to be certified, so ingredients purchased from these suppliers need to have their certification verified back to point of last operation. It must not be assumed that the intermediate wholesaler has checked the certification as they are under no obligation to do this. Companies need to be aware that the demand for organic ingredients and high dependence on imported product adds to the risk of fraud and close monitoring of the status of imported ingredients is therefore essential.

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