Operations are not always aware of their options and responsibilities when they suspect that contamination or commingling may have occurred at their operation. Prompt and thorough reporting can help your operation maintain compliance and ensure appropriate measures are taken.
On September 11, 2015 the USDA National Organic Program released a Policy Memo updating the status of electrolyzed water under the USDA NOP regulations. The memo clarifies that hypochlorous acid generated by electrolyzed water systems is a type of chlorine material, and is now allowed to directly contact organic products in wash water, when followed by a fresh water rinse.
Farmers, do you send your fruit or other products to coolers or storage where it may be treated with an allowed material such as CO2 (marketed as Tectrol®) or ethylene? If so, that facility must be certified organic. Be sure to ask for an organic certificate before sending your crop or product to these facilities.
Handlers, do you treat organic fruit with Tectrol® or ethylene, or any other gasses or substances? If so, you must be certified organic before you receive organic crops or products.
On January 22, 2014, the National Organic Program (NOP) published guidance 5031 “Certification Requirements for Handling Unpackaged Organic Products.” This guidance is intended to address the concern that certain products have been moving through unregulated segments of the organic marketing chain.
Operations are required to update their Organic System Plan (OSP) regarding changes that can affect their compliance, such as new land managed by the operation. However, many farms implement transition of conventional ground or begin managing new ground without including it in their OSP or inspections.
All transitioning parcels and new ground should be added to your certification as soon as possible to ensure appropriate inspections and verification of practices, and to alleviate the need for costly, last-minute inspections.
Effective June 1, 2015, CCOF will require that orchards and other crops no longer utilize intensive grazing within 90 days of harvest of a crop where the edible portion does not touch soil or soil particles. This interpretation of existing raw manure restrictions is being phased in during 2015—with an expectation that growers update their practices and organic system plans by June 1, 2015—to ensure compliance during the 2015 production year and beyond.