14, 2004: There has been a lot of talk lately about
the safety of organic food. It is important to note that organic
foods must meet the same state and federal food safety requirements
as non-organic foods. In addition, the National Organic Program
(NOP) Final Rule mandates certified organic producers and
handlers meet requirements that have food safety implications.
Producers and handlers of non-organic products do not have
to meet such requirements.
For example, certified organic operations must comply with
strict requirements for traceability; restrictions on the
use of animal manure and compost; no contact with prohibited
toxic substances; and significantly lower residue levels than
allowed for non-organic foods.
NOP requirements which have food safety implications can
be grouped into five categories: 1) records and traceability;
2) crop management; 3) livestock management; 4) processing
and handling; and 5) residue tolerances.
1. Records and traceability
Traceability is a fundamental requirement for organic certification.
All organic operations are required to maintain records of
their production and handling activities.
Such records must:
- Be adapted to the particular business that the operation
- Fully disclose all activities and transactions of the
operation in sufficient detail as to be readily understood
- Be maintained for not less than 5 years beyond their creation;
- Be sufficient to demonstrate compliance with OFPA and
In addition, NOP section 205.236.c requires that all organic
livestock operations maintain records “sufficient to
preserve the identity of all organically managed animals and
edible and non-edible animal products produced on the operation.”
Every certified organic operation must make its records available
for inspection and copying during normal business hours by
authorized representatives of the USDA, the applicable State
official, and the certifying agent.
This means that records kept by organic producers and handlers
must verify compliance with the organic regulation, and provide
traceability. For instance, an organic livestock producer
must track all animals, including the source(s) of the animals;
the sources and quantities of feed; all medications; and all
products produced and sold. This requirement goes well beyond
the requirements for non-organic producers, as evidenced by
last winter’s case of BSE, where 450 calves were slaughtered
because one of the calves was from a BSE-positive cow, but
there was no traceability to connect the calf to the cow.
2. Crop Management
In order to be certified organic, land must have had no prohibited
substances applied to it for a period of 3 years immediately
preceding harvest of the organic crop. Prohibited substances
include toxic fertilizers, pesticides, and genetically engineered
organisms (excluded methods). Non-use of toxic substances
avoids the presence of toxic residues in organic foods.
Certified land must have distinct boundaries and buffer zones
such as runoff diversions to prevent the unintended application
of a prohibited substance to the organic crop, or contact with
a prohibited substance applied to adjoining land that is not
under organic management. Certified farmers and handlers must
prevent prohibited substances from coming into contact with
||"The restrictions on the application
of raw animal manure for organic producers go well beyond
those imposed on non-organic producers."
Organic producers must manage plant and animal materials
to maintain or improve the soil in a manner that does not
contribute to contamination of crops, soil, or water by plant
nutrients, pathogenic organisms, heavy metals, or residues
of prohibited substances.
Raw animal manure must be composted unless it is:
(i) Applied to land used for a crop not intended for human
(ii) Incorporated into the soil not less than 120 days prior
to the harvest of a product whose edible portion has direct
contact with the soil surface or soil particles; or
(iii) Incorporated into the soil not less than 90 days prior
to the harvest of a product whose edible portion does not
have direct contact with the soil surface or soil particles.
The restrictions on the application of raw animal manure
for organic producers go well beyond those imposed on non-organic
producers. While all producers are required to follow certain
nutrient management requirements, there are no restrictions
on when or how raw manure is applied to non-organic cropland
linked to projected harvest of the crop. These restrictions
help prevent certified organic products from coming into contact
with microbial contaminants.
A recent study of microbial contamination of certified organic,
self-proclaimed “organic,” and conventional produce
by Mukherjee, Speh, Dyck, and Diez-Gonzalez of the University
of Minnesota, published in the Journal of Food Protection,
concluded that “the E.coli prevalence in certified organic
produce was not statistically different from that in conventional
Organic producers must not use sewage sludge or arsenic compounds.
Arsenic compounds, commonly used in non-organic poultry feed
as growth promoters and parasiticides, are linked to high
incidence of cancer and other illnesses in areas where poultry
litter containing arsenic is used as fertilizer.
3. Livestock Management
Organic livestock producers must not feed mammalian or poultry
slaughter by-products to mammals or poultry. The feeding of
manure is also prohibited. While the FDA banned the feeding
of cattle brain and spinal tissue to cattle in 1997, and recently
banned the feeding of blood, blood products, human food waste,
and poultry litter, it still allows the following materials
to be fed to non-organic cattle:
- Gelatin (rendered from the hooves of cattle and other
- Fats, oils, grease, and tallow (from cattle and other
- Poultry and poultry by-products;
- Rendered pork protein; and
- Rendered horse protein.
None of these may be fed to organic cattle or other organic
livestock, including organic poultry.
In order to produce organic livestock feed, feed mills must
be inspected and certified. If they produce both organic and
non-organic feed, they must implement procedures, documented
with written records, to prevent the commingling of organic
and non-organic feed.
Organic feed mills must prevent the contamination of organic
feed with antibiotics, hormones, slaughter by-products, and
insecticides, which may be added to non-organic rations. They
must also ensure that rodenticides and insecticides used in
the facility do not contaminate organic feed or packaging.
Organic livestock must be slaughtered in certified organic
slaughter facilities. As such, the facilities must slaughter
organic animals when all equipment is clean and empty. There
must be no chance of commingling organic with non-organic
meat, or contaminating organic meat with prohibited materials.
Records must be maintained of all organic slaughter activities
and steps taken to protect organic integrity.
4. Processing and Handling
There are a number of measures that must be implemented by
organic processors and handlers that exceed the requirements
imposed on handlers of non-organic products. For instance,
organic handlers must use non-toxic management practices to
prevent pests, including but not limited to removal of pest
habitat, food sources, and breeding areas; prevention of access
to processing facilities; and management of environmental
factors, such as temperature, light, humidity, atmosphere,
and air circulation, to prevent pest reproduction.
An organic handler who applies a nonsynthetic or synthetic
substance to control pests must prevent the substance from
coming into contact with organic products, ingredients, or
packaging. The operator must also update the operation’s
organic handling plan to reflect the use of such substances
and methods of application, and include a list of all measures
taken to prevent the substance from coming into contact of
organic products, ingredients, or packaging.
Organic handlers must implement measures to prevent the commingling
of organic and nonorganic products and protect organic products
and packaging materials from having contact with prohibited
The following are prohibited for use in organic handling:
packaging materials, storage containers, or bins that contain
synthetic fungicides, preservatives, or fumigants; and the
use or reuse of any bag or container that has been in contact
with any substance that might compromise the integrity of
an organically produced product or ingredient. Such substances
and materials are allowed for non-organic food processing.
5. Residue Tolerances
Certifying agents may require pre-harvest or post-harvest
testing of any agricultural input or organic product, when
there is reason to believe that the input or product has come
into contact with a prohibited substance or has been produced
using excluded methods (genetic engineering).
If residue tests detect prohibited substances at levels greater
than 5 percent of the Environmental Protection Agency’s
tolerance for the specific substance detected or unavoidable
residual environmental contamination, the agricultural product
must not be sold as organic.
many provisions that require organic crop and livestock
producers and handling operations to reduce food safety
risks beyond those required of non-organic producers and
Though the NOP regulation is a process- rather than product-based
standard, there are many provisions that require organic crop
and livestock producers and handling operations to reduce
food safety risks beyond those required of non-organic producers
and handlers. These include strict requirements for traceability;
restrictions on the use of animal manure and compost; no contact
with prohibited toxic substances; and significantly lower
residue levels than allowed for non-organic foods.
Jim Riddle serves as vice-chair of the National Organic
Standards Board, which advises the USDA on organic agriculture
policies and regulations. He has been an organic farmer, gardener,
inspector, educator, policy analyst, author, and consumer.