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2002

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The Green Café

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The Green Café
by Mark Inman

I have received a lot of calls and e-mails lately about the upcoming USDA National Organic Program (NOP) due to take effect on October 21, 2002. To many operators, this program's new certification process seems overwhelming and frustrating. Like many of you, I am in the middle of the process, and even with my small business, I am into page 93 of the 140 pages required to renew my certification. I often wonder if it's going to be worth the hassle. Do you have the desire to participate in what might be the most important food program our country has ever seen? If so, how can you wade through the process quickly and correctly?

   Come October 21, all businesses (with the exception of some retailers) planning to offer organic products will need to be certified or face fines of up to $10,000 per infraction. This may seem intimidating, but the benefits of certification can be worth it. The organic industry is expected to skyrocket over the next few years, with organic coffee projected to jump from current annual sales of 25 million dollars to a staggering 120 million dollars. Pass on certification now and you may be sorry.

   The certification process does not have to be too difficult. The trouble begins when you need assistance, because certification agencies offer little to no help. It's not that the agencies don't want you to apply. It's just that an inclusion in the new organic law makes it illegal for certifiers to offer consultation of any sort. This inclusion actually troubles some certification agencies more than you might imagine. For instance, the strength of smaller certifiers (CCOF, Oregon Tilth, etc.) was in the fact that they were run by organic farmers for organic farmers. One of the benefits of being certified by these agencies versus larger, for-profit certifiers was the level and depth of assistance, hands-on instruction and cross-promotional possibilities. These types of perks are no longer available under the new law, making the future of smaller certifiers uncertain.

   I'm not an organic certifier, but I can certainly help walk you through this overwhelming process. Applying for certification begins with deciding that you do indeed want to commit to the USDA's organic program and all that goes with it. Keep in mind that the concept of organic certification is a work in progress, and it will constantly change. So be prepared to exercise plenty of patience and tolerance. It is also important to remember that the National Organic Standards are written for all types of organic products and cannot possibly include specific standards and procedures for your particular product. In other words, what works for peach growers will not work for coffee roasters.

   Once you make the decision to apply for certification, you must choose an agency to work with. As of this writing, there are 41 private and 15 state USDA-accredited certifiers. Each offers different fee structures and services, so shop wisely. The average cost of certification for a coffee roaster or wholesale tea establishment should be around $1500 annually. If you are currently paying more, start shopping around.

   Once you choose an agency, you need to complete and return an application. The application seems basic enough. It includes five lettered sections with what appears to be a series of simple questions and tasks. From completing the application to acquiring final certification, the process takes between eight and 16 weeks. Here's a breakdown of the application.

PROCESSOR ORGANIC COMPLIANCE PLAN

Section A-Facility Map
A "facility map" is a scale drawing showing the layout of your plant, including all buildings, rooms, major equipment, and pest management devices in your business. This part took me about three hours with a tape measure, some graph paper and some colored pens. If you have up-to-date blueprints of your building, you just saved yourself some time.

Section B-Flow Chart
Create a simple drawing to illustrate all of the steps in your organic production, including names of major processing equipment (roasters, grinders, vacuum packaging, etc.). This can be hand-drawn on simple paper. Once an inspector enters your building, he or she will attempt to follow your "flow chart" as you take your product from raw material to finished goods. The easier your flow chart is to follow, the faster this part of your inspection will be.

Section C-Organic Compliance Plan Overview
This is the real snapshot of your organic practice. Part 1 simply asks for a brief overview of the activities and processes your operation conducts. This can be answered as easily as, "Roasting, grinding and packaging of organic coffee. Five hundred pounds roasted per day, five days a week."

   Part 2 asks for IPPs-or Individual Product Profiles-on each organic product you produce. The IPP is a two-page document that asks detailed questions about each organic blend, origin coffee or tea (including recipe information). It asks where each ingredient is purchased and who certifies each ingredient. It also verifies that each product is labeled properly to clearly show your company name as well as the name of your certifying agency and a USDA seal. The amount of organic products you offer will determine how long this section will take. Taylor Maid Farms offers 22 organic coffees and 28 organic teas, making this part a 100-page odyssey.

   Part 3 asks for a brief description of your "quality monitoring practices." This is simply a description of how, and how often, you review your own handling and processing system to ensure that your organic plan is being implemented correctly.

   Part 4 asks for an audit trail of documents that tracks your product from receiving through distribution. This is probably the most important part of the application process, and it will be verified by your inspector annually. Essentially, the inspector will take one of your finished products and ask you to show him or her the exact lot numbers of the ingredients of a package. I have found the easiest way to accomplish this task is to stamp my finished product with a "roasted on" date. When the inspector pulls one of my finished packages, I can trace that date to my roaster log, which contains my recipes with lot numbers. If my French Roast is pulled from January 5th, I simply go to my January 5th page, find the lot numbers for that blend, go to my green purchase file, and pull the receipts and certificates for the lot numbers of that blend. Audit accomplished!

   Part 5 asks for a brief description of your management practices used to protect the organic product from commingling with non-organic product and contamination. This is similar to the question in part 3. You must simply show that your organic product is clearly stored separately from non-organic products-use signs! Furthermore, be prepared to demonstrate that your organic product is processed in a clean manner.

Section D-Product Protection
The point of this section is to verify that the ingredients you use are not included in both organic and conventional form in the same product. If you offer 100 percent organic Colombian coffee, the package must contain 100 percent certified-organic coffee from Colombia. If you are selling 100 percent organic Colombian coffee in ground form, you need to either use a grinder for organic coffee only or show that you purge your grinder of any non-organic product before grinding any organic coffee.

Section E-Facility Pest Management
You will need to show that a pest management program is in place that emphasizes sanitation to lessen the chances for pest and rodent problems. If you place spring-loaded traps throughout your building, you will need to note the placement on your "facility map." If you use any sprays, fogs or fumigants, you will need to first verify that the materials used are approved by the National List (check with your certifier for this). Secondly, you will need to keep an incident log with reference to the date, material and specific location where the products were used.

Section F-Sanitation Procedures
You will need to show that a sanitation program is in place that protects organic ingredients (raw material, works in progress or finished goods) from coming into contact with sanitizers and cleaners. This includes residues in storage containers and processing equipment.

Section G-Quality Assurance
Like other sections, Section G ensures that your production system can maintain the integrity of your organic products. It asks for you to create a policy for documenting and addressing complaints relating to your compliance (actually, lack thereof) with organic standards. This is merely a series of yes/no questions asking if you are taking these concepts into account when producing your product.

Section H-Record Keeping
If you contract with a warehouse to store unfinished goods or to pack or process your organic products, it also must be third-party-certified and you must maintain current records of this certification. Finished, packaged goods are exempt from this section.

Section I-Explanations Section
This section simply provides a space for you to go into further detail if you cannot respond to the previous sections with a simple "yes," "no" or "none used."

   Once you have completed the application, your certifier will schedule an inspection to physically review each section of the form. Depending on the clarity of your application, your inspection will take anywhere from a couple of hours to a couple of days. Remember, your inspector charges you hourly or daily, so the easier your application is to follow and the easier your records are to access, the quicker this process will be. Plan ahead and make sure your records are neat and organized. I have learned that I cannot scramble and assemble my documents at the last minute and expect to get the physical inspection over quickly. If this is your first time applying, expect to be given a one- to two-page list stating that "your approved certification is contingent upon receipt of the following information" to send in after the inspection. Don't worry, very few people pass certification without contingencies.

   I hope this information helps you in your quest to become certified-organic. Organic certification is monumentally important to the overall food movement. It is the result of years of deliberation by committed members of the organic community educating and working with government representatives. Participate in this program and you become part of history.

Mark Inman is co-founder of and roastmaster for Taylor Maid Farms, a certified-organic herb farm and coffee roastery in Occidental, California. He is also founder of the Organic Coffee Association of America. Contact him with questions or comments via e-mail at mark@talormaidfarms.com.

For more information on the new organic standards and how to apply for certification, visit the USDA Website at www.usda.gov.

This Issue: $5 U.S.

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