How Will Organic Rules Affect Retailers?
After years of long and frustrating delays, the USDA Organic Rule will be implemented during 2002. Although this will be a "phase-in" period for coming into compliance, it will bring with it many changes for retailers and new questions from consumers. In order to avoid surprises and to provide the best possible information, grocers and cooperatives should get ready as soon as possible to meet new demands. They are a critical component of the organic system. Retailers are most often the final handlers of our food supply before it ends up on our tables.
Under the Organic Foods Production Act, retailers who "process" organic food must be certified. "Processing" is defined in the Rule in such a manner that most retail stores would be considered processors. Processing includes: cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, extracting, slaughtering, cutting, fermenting, distilling, eviscerating, preserving, dehydrating, freezing, chilling, or otherwise manufacturing, and includes the packaging, canning, jarring, or otherwise enclosing food in a container.
Although some retailers have already taken the certification step -- whether voluntarily or required by state law -- the vast majority have little clue of what retailer certification entails. At this time USDA is not requiring retail certification. Certified or not, however, retailers have a responsibility to their loyal customers to ensure that "organic" has meaning. [See p. 8 of this edition re access to the Wedge Co-op certification plan.--ed.] While the certification process assists retailers greatly in providing assurance of organic integrity, several steps should be taken regardless of regulations:
1. All products labeled as "organic" should be verified to be certified organic by a reputable certification agency or be produced on a small farm that complies with the small farm exemption in the Rule. Certified products must carry certification information on their label, and their status can be verified by contacting the certifier. There is a small farm exemption: yes, you can buy "organic" veggies from the local farmer who is not certified, BUT that farmer is still required to follow the same production standards as the certified farmers. Make sure that anyone claiming to fit into this exemption knows the standards and can offer some assurance of compliance (usually field records and documentation of inputs being free from prohibited substances). Ask questions and, if possible, visit the farm. Some certifiers offer registration to these small farms, which provides additional documentation of use of organic methods. Some retailers have drawn up a set of their own requirements as well.
2. Prevent "contamination" by prohibited substances. Retail establishments often use chemicals -- for sanitizing, washing and pest control -- that are not allowed in organic production and which can get on food in a number of ways. Several alternatives exist and work very well. Sticky traps, vitamin D-based rodent traps and environmentally friendly cleaning supplies are readily available. Food should be protected with a barrier whenever sprays are used.
3. Prevent "commingling" with non-organic products. Store and display the products in such a manner as to protect their organic integrity. Make sure that there is clear segregation between organic and conventional items. It is very easy for customers or staff to mix products that look alike. Make sure that there are signs on or near all organic products so they can be easily identified.
4. Label products honestly and accurately. Draw attention to your organic products, and be sure you understand the Rule's labeling language (7 Part CFR 205.300). It's pretty much common sense: if it is all-organic, then you can call it "organic." If it is made with one or more organic items, you can call it "made with organic." But there are some details involved in labeling of processed products.
Think of these steps as part of an "organic system plan" for your establishment. The system plan is basically an overview of how you make sure the products you sell as organic maintain their organic quality up to final sale to a customer. Organic certification requires such a plan of all producers and processors. Following the above steps will help retailers to better serve the consumer and to begin thinking about meeting future requirements.
At this time the National Organics Standards Board and USDA are having conversations about what retailer certification will entail. The standards and process they create will eventually affect almost every retailer who sells organic products. Unfortunately the voices of the cooperative grocers and those of small, privately owned retail stores have seldom been heard at the public input sessions. However, the NOSB would welcome their input on this issue. The large, chain stores are speaking up. Cooperatives also need to be loud and clear.
Comments can be sent and information on the National Organic Program found at www.ams.usda.gov/nop.