AND MARKETING NEWSLETTER
Editor: J. J. Ferguson
Horticultural Sciences Department
University of Florida
PO Box 110690
Gainesville, FL 32611-0690
GOOD ORGANIC RETAIL PRACTICES
USDA National Organic Standards became effective Feb. 20, 2001. However, an 18-month implementation period
gives growers, processors, retailers, and others until Oct. 21, 2002 to comply with the Final Organic rule.
Using the USDA National Organic Program Final Rule and Regulations and American Organic Standards as a
basis, the Organic Trade Association (OTA), the primary business group representing the organic industry in the
US, has developed a 291-page copyrighted manual, CD-Rom disk and training workshops specifically designed to
"aid store managers ...in understanding and implementing practices that comply with the USDA Final Organic Rule
To give you an idea of the quality and detail covered, I have attached, with the permission of OTA, a copy of the
Table of Contents and a brief description of each section. The OTA invested considerable resources in developing
this manual which is available for $149.00 or OTA members and $295.00 for non members.
Rather than plow through the Final Organic Rule itself, IFAS (Institute of Food and Agricultural Sciences, University
of Florida) faculty who interact with retailers of organic products may want to contact the Organic Trade Association
about participating in workshops and obtaining copies of this material. (email: \\\\\ oi; com; web page: www.ota.
com; (phone: 413-774-7511).
Table of Contents
Are You Ready?
How to Use this Manual
SECTION 1. UNDERSTANDING ORGANIC!
1.1 What Are Organic Products?
1.2 Growth of the Organic Industry
1.3 Frequently Asked Questions Consumers Have about Organic Food
1.4 Short History of Organic Certification
SECTION 2. LAWS REGULATING ORGANIC PRODUCTS
2.1 The Organic Foods Production Act of 1990 (OFPA)
2.2 USDA National Organic Program Final Rule and Regulations
2.2.1 General Production, Handling and Labeling Requirements
2.2.2 General Requirements for Retail Operations
2.3 Definition of Selected Terms
2.4 Rule and Federal Regulations for Non-certified Retail Stores
2.4.1 Requirement for All Retail Stores
2.4.2 Retail Store Exemption
2.4.3 Retail Store Exclusion
2.4.4 Labeling Requirements
2.4.5 Record Keeping Requirements
2.4.6 Civil Penalties
2.4.7 Complaint Process
2.5 State Laws
SECTION. ORGANIC CERTIFICATION OF RETAIL STORES
3.1 Rule and Federal Regulations for Organic Certification of Retail Stores
3.3.1 Labeling Requirements
3.2 Steps to Organic Certification
3.3 Organic Handling System Plan
SECTION 4. GOOD ORGANIC RETAILING PRACTICES
4.1 Commingling and Contamination Issues
4.1.1 Hazard Analysis Critical Control Points
4.1.2 HACCP Definitions for the Organic Industry
4.2 Procedures for Assuring Organic Integrity
4.2.1 Identifying Organic Control Points (OCPs)
4.2.2 How to Correct Organic Control Points
4.3 Processing and Co-packing
4.4 Handling and Storage
4.5 Pest Management and Sanitation Program
4.6 Record Keeping
4.6.1 Recommended Records for Non-certified Retail Stores
4.6.2 Records Required for Certified Organic Retail Stores
4.6.3 Organic Product Verification
4.7 Labeling and Consumer Information
4.7.2 Consumer Information
4.8 Good Organic Retailing Practices Employee Training Program
4.8.1 Types of Employee Training
4.8.2 Checklists. Quizzes and Affidavits
SECTION 5: FRESH PRODUCE DEPARTMENT GOOD ORGANIC RETAILING PRACTICES
5.4 Produce Preparation
5.5 Packaging, Labeling and Display
5.6 Employee Training
5.7 Documentation Recommended for Fresh Produce
SECTION 6: BULK FOODS DEPARTMENT GOOD ORGANIC RETAILING PRACTICES
6.4 Bulk Foods Preparation
6.5 Packaging, Labeling and Display
6.6 Employee Training
6.6 Documentation Recommended for Bulk Foods Department
SECTION 7: MEAT DEPARTMENT GOOD ORGANIC RETAILING PRACTICES
7.4 Meat Processing
7.5 Packaging, Labeling and Display
7.6 Employee Training
7.7 Documentation Recommended for Meat Departments
SECTION 8: PREPARED FOODS DEPARTMENT GOOD ORGANIC RETAILING PRACTICES
8.4 Prepared Food Processing
8.4.1 Cleaning Equipment and Areas
8.6 Labeling and Display
8.7 Employee Training
8.8 Documentation Recommended for Prepared Food
SECTION 9: PRE-PACKAGED GROCERY DEPARTMENT GOOD ORGANIC RETAILING PRACTICES
9.4 Labeling and Display
9.5 Employee Training
9.6 Documentation and Pre-packaged Grocery Departments
SECTION 10: APPENDIX
10.1 Organic Foods Production Act of 1990 (OFPA)
10.2 USDA Final Organic Rule (Selected Sections)
10.3 OTAS American Organic Standards (AOS)
10.4 Good Organic Retailing Practices (GORP)
10.5 Organic Trade Association (OTA)
10.6 Independent Organic Inspectors Association (IOIA)
10.5 Organic Materials Review Institute (OMRI)
10.6 Project Participants
ARE YOU READY?
The USDA Final Organic Rule is effective February 20, 2001. There is an 18 month implementation period. All retail
stores handling organic food need to be in compliance with the Rule by October 21, 2002. Are you ready?
How does this Rule affect your retail store? What are the requirements for
retail stores? What changes are needed? What do employees need to know? What are the specific records to be
kept? What are the penalties for non-compliance? These and other questions are answered in this Manual.
RETAIL STORES ARE NOT REQUIRED BY THE USDA TO BE CERTIFIED WHEN HANDLING OR SELLING
Under the USDA Final Organic Rule, all retail stores need to meet certain requirements to protect the integrity of
Prevent commingling of organic and non-organic products. Prevent contact of organic products with
prohibited substances. No contact of organic products' packaging or storage containers with synthetic
fungicides, preservatives or fumigants.
Use bags and containers that will not compromise organic product integrity.
Label organic products properly. Keep proper records.
Use only certain types of ingredients and processing aids for organic
Label private labeled products appropriately.
Insure that all contract processors that produce private label organic products for your store are certified
Retail stores that have organic processing done off-site, such as operating a bakery which sells organic products,
are required to obtain organic certification of that processing facility.
This manual will aid store managers and department managers in understanding and implementing practices that
comply with the USDA Final Organic Rule and Regulations. It will also help train department employees and
maintenance staff to methods that prevent commingling and contact with prohibited products. The manual prepares
you for voluntary organic certification. Finally, the manual gives you the tools to insure that your store is in
compliance with the USDA Final Organic Rule and Regulations.
HOW TO USE THIS MANUAL
This manual serves as the basic curriculum material for a 3.5 hour training for retail store managers and employees.
It can also be used for self study. Using IOIA organic inspection techniques, it is designed to help employees
develop critical thinking skills to identify all areas in the store that are potential sources of contamination and to
implement good organic retailing practices.
The manual follows the format provided in the OTA's Good Organic Retail Practices (GORP). Developed by retailers
prior to the USDA Final Organic Rule, GORP is an excellent reference to implement the USDA Rule and
Regulations. It outlines practices to prevent commingling and contact with prohibited substances, employee training,
and record keeping. Because GORP contains more detailed requirements than the USDA Organic Rule, it is a
useful tool for retail stores.
The manual contains examples of consumer information signs. Oiganic Control Point checklists, cleaning/pest
control protocols, and employee training aids that you can modify to reflect the specific practices in your store. A CD
Ror accompanies the manual that contains all of the forms, lists and aids. The documents are in .pdf format for
easy translation to your computer system.
For stores that request voluntary organic certification, this manual is a valuable tool to understand the organic
certification process and develop organic handling system plans.
Since all retail stores are not alike, the manual is divided into sections. Sections 1-4 have general information.
Sections 5-9 are geared towards specific departments and can stand-alone for use as a specific department' s
Section I. Understanding Organic
Section 1 aids all personnel in understanding organic farming and livestock operations, and what makes them
different from other farming systems. It explains how organic products are processed, handled and packaged to
protect their organic integrity. Store signage examples have been designed to help retailers educate their
consumers. This section can be used as a reference to help workers answer customer questions and concerns.
Section 1 should be read by all employees who handle organic products.
Section 2. Laws Regulating Organic Products
Section 2 reviews the Organic Foods Production Act of 1990 (OFPA) and details relevant portions of the USDA
Final Organic Rule relevant to retail stores. Each retail store that handles organic products must comply with OFPA
and the USDA Final Organic Rule and subsequent Regulations. This section should be read by store and
department managers to be sure they understand compliance to these Rules and Regulations.
Section 3: Organic Certification of Retail Stores
Section 3 reviews USDA Organic Final Rule requirements for the voluntary organic certification of retail stores. It
also answers your questions on the organic certification process and provides a framework for your Organic
Handling System Plan. Use this section in conjunction with other sections to prepare your store for organic
certification. This section should be read by people in charge of preparing the store for organic certification.
Section 4: Good Organic Retailing Practices
This section is meant to help store managers, department managers, pest control and maintenance staff develop
critical thinking skills to identify and address all areas in the store where the integrity of organic products may be
compromised. USDA Rules and Regulations on organic handling, as well as the OTA's American Organic
Standards and Good Organic Retailing Practices emphasize the basics of good organic retailing practices. For
stores seeking organic certification, this section offers practical direction on how to implement an Organic Handling
System Handling Plan. Section 2 should be read by all managers and those employees in charge of compliance
with the USDA Organic Rule and Regulations.
Sections 5, 6, 7, 8, and 9: Produce, Bulk Foods, Meats, Prepared Foods and Prepackaged Grocery
Department Good Organic Retailing Practices
These easy to read sections are to be used as an employee training guide for each of these departments. Many of
the points addressed are the same for each department. However, these sections are meant to stand alone as the
specific handling plan for each department. Included in this section are the particulars of each department's handling
plan, including real life scenarios and practical solutions.
Checklists, forms and signage examples that can be modified, photocopied and laminated are offered as tools to
help each department implement an organic handling system plan. Each section has a quiz to be used for employee
training after they have read through both Sections 1 and their department section. The quiz can be given as either
an open book test, with the reference materials available, or without the manual. The questions are meant to be
educational. Managers can use this quiz to judge their employees' understanding of organic handling requirements.
Managers and employees should read the pertinent sections for their department.
Section 10: Resources
A complete version of the Oiganic Food Production Act of 1990 and pertinent sections of the USDA Organic Rule
are reprinted in the Resource section for those interested in reviewing the original documents. OTA's American
Organic Standards (AOS) provides a framework to understand organic handling requirements for stores seeking
organic certification. Only the relevant Sections 7: Handling and Labeling Standards and portions of Section 9:
Certification and Organic Plan Requirements are reprinted in this manual. The entire document is available at the
OTA website: www.ota.com
OTA's Good Organic Retailing Practices (GORP) is boxed for easy reference throughout the Manual. It is presented
in its entirety in the Resource section. Final portions of the Appendix provide information about the Organic Trade
Association, the Independent Organic Inspectors Association, and the Organic Materials Review Institute. The
section concludes with a list of retail stores that participated in the development of this manual.
Organic Assessments in Farm Bill
Should organic farmers have to pay mandatory commodity promotion assessments for commodities like peaches,
apples, etc. that are assessed on all growers, conventional or organic? The 2002 Farm Bill contains a section,
effective this October, exempting producers of certified organic products from paying mandatory commodity
promotion assessments but may apply only on federal marketing orders and only to growers that produce only
Some Washington state apple growers have been paying $.25/box of organic apples to the Washington state Apple
Commission but critics say such commissions have done little to promote organic products. On the other hand,
commodity marketing boards probably generally benefit sales of specific commodities like apples and peaches,
conventional or organic. It has also been suggested that commodity boards promote organic crops in proportion to
the percent assessment contributed by organic farmers. A related issue is whether the Feds have the power to
enjoin or direct state taxes. The Secretary of Agriculture is required to develop exemption and compliance
requirements have to be defined within one year. The Packer
Federal Marketing Order No. 905 for Oranges, Grapefruit, Tangerines, and Tangelos Grown in Florida, "except for
the area west of the Suwannee River" was first promulgated in 1939 and was last amended under formal
ruleraking on September 8, 1989. The 1996-97 budget of $230,000 is based on an assessment rate of $0.0035 per
4/5 bushel carton of citrus.
However, according to the Citrus Administrative Committee, organic growers do not currently contribute to this
marketing order and it will not apparently have any effect on them. The following marketing orders are also in effect:
Marketing Order No. 966: Florida Tomatoes
Marketing Order No. 967: Florida Celery
Marketing Order No. 967: Florida Celery
This is the text of the exemption in the 2002 Farm Bill which has become law.
SEC. 10607. EXEMPTION OF CERTIFIED ORGANIC PRODUCTS FROM ASSESSMENTS.
(a) IN GENERAL- Section 501 of the Federal Agriculture Improvement and Reform Act of 1996 (7 U.S.C. 7401) is
amended by adding at the end the following:
(e) EXEMPTION OF CERTIFIED ORGANIC PRODUCTS FROM ASSESSMENTS
(1) IN GENERAL- Notwithstanding any provision of a commodity promotion law, a person that produces and
markets solely 100 percent organic products, and that does not produce any conventional or nonorganic products,
shall be exempt from the payment of an assessment under a commodity promotion law with respect to any
agricultural commodity that is produced on a certified organic farm (as defined in section 2103 of the Organic Foods
Production Act of 1990 (7 U.S.C. 6502).
(2) REGULATIONS- Not later than 1 year after the date of enactment of this subsection, the Secretary shall
promulgate regulations concerning eligibility and compliance for an exemption under paragraph (1).
and was last updated on July 19, 2002.
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