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National Organic Program
Compliance Checklist
   for Handlers
           November 2006




 This document was developed by the National Center for Appropriate Technology
 (NCAT) with funds provided by the USDA/National Organic Program (NOP). Dis-
 tribution is through NCAT’s ATTRA Project, the National Sustainable Agriculture
 Information Service.                                                              ATTRA
Acknowledgements:
This document was written and prepared by Holly Born, Assistant Project Leader and NCAT Program Specialist
(Lewis, IA), with the assistance of a stakeholder team representing the wider organic community, and formatted
by Cynthia Arnold, NCAT Administrative Assistant (Fayetteville, AR).

Stakeholder Team Members:
Katherine Adam, NCAT, Fayetteville, AR
Ann Baier, NCAT, Soquel, CA
Jo Ann Baumgartner, Wild Farm Alliance, Watsonville, CA
Brenda Book, Washington State Dept. of Agriculture, Olympia, WA
Cissy Bowman, Indiana Certified Organic, Clayton, IN
Mark Bradley, USDA National Organic Program, Washington, DC
Diane Collins, Organic Farm Marketing, Viroqua, WI
Lisa Cone, Waterfall Hollow Farm, Berryville, AR
Joyce E. Ford, Organic Independents, Winona, MN
John Foster, Oregon Tilth, McMinnville, OR
Lance Gegner, NCAT, Fayetteville, AR
Liana Hoodes, National Campaign for Sustainable Agriculture, Pine Bush, NY
Lisa Hummon, Defenders of Wildlife, Albuquerque, NM
George Kuepper, NCAT, Lewis, IA (Project Leader)
Nancy Matheson, NCAT, Helena, MT
Lisa McCrory, NOFA-VT, Randolph, VT
Nancy Ostiguy, The Pennsylvania State University, University Park, PA
Jim Riddle, University of Minnesota, Winona, MN
Pam Riesgraf, Organic Valley, Jordan, MN
Barbara C. Robinson, USDA/AMS, Washington, DC
Kelly Shea, Horizon Dairy, Colorado Springs, CO
Kathy Turner-Clifft, Doubletree Ranch LLC, Huntsville, AR
Sara Vickerman, Defenders of Wildlife, West Linn, OR
Ann Wells, Springpond Holistic Animal Health, Prairie Grove, AR
Katherine Withey, Washington State Dept. of Agriculture, Olympia, WA




Page 2                                                              Organic Compliance Checklist for Handlers
About This Document…
This Checklist has been created to help you evaluate your handling or processing operation to assess how it
complies with the National Organic Program Standards. In §205.2 of the Standards, a “handling operation” is
defined as
   Any operation or portion of an operation (except final retailers of agricultural products that do not process agricultural prod-
   ucts) that receives or otherwise acquires agricultural products and processes, packages, or stores such products.
The checklist structure and the language used is intended to make your work, and that of the certifier and inspec-
tor, a bit easier. However, this Checklist is a guidance document only. It does not replace the regulations of the
National Organic Program and may not reflect recent policy developments. National Organic Program regulations
and policy statements can be found on the National Organic Program website at: www.ams.usda.gov/nop/NOP/
NOPhome.html
The Checklist is divided into eight sections. Sections 2 through 7 correspond to the six categories of information
required in the Organic Production and Handling System Plan, as specified in the Organic Standard §205.201.
Each item in the Checklist is presented in the form of a question that can be answered by checking the “YES,”
“NO,” or “Not Applicable” box located adjacent to the question. A check made in a “NO” box indicates that you
may be out of compliance with the Federal Standard. In most instances, questions are accompanied by the cor-
responding section and paragraph number of the regulations.
Copies of the Checklist may be downloaded from the ATTRA website at: www.attra.ncat.org Additional print cop-
ies can be obtained by writing ATTRA at P.O. Box 3838, Butte, MT 59701, or by calling 1-800-346-9140.




Organic Compliance Checklist for Handlers                                                                               Page 3
Section 1: General: Must I Certify My Operation?
Subsection 1.a: Exempt Handling Operations
Check All That Apply:
           My operation sells less than $5,000 of organic product each year [§205.101(a)(1)].

           My operation is a retail food establishment that handles organic products, but does NOT process or repackage them
           [§205.101(a)(2)].

           I only handle products that contain less than 70% organic ingredients by weight (excluding water and salt) [§205.101(a)(3)].

           I only use the term “organic” on a label when identifying organic ingredients on the information panel of my product label
           [§205.101(a)(4)].

If you checked any of the above 4 items, you are exempt from certification. However, your operation must still comply with all NOP
regulations except for certification requirements and the submission of an organic systems plan. To assess your compliance with these,
please skip ahead to the questions in subsection 2.c.e on page 12. Then answer questions 1.a.1 through 1.a.5, if applicable.

1.a.1.    In completing subsection 2.c.e, did you answer all of the questions either with a                                               Yes      No
          “Yes” or “Not Applicable” [§205.310]?                                                                                           Not applicable

1.a.2.    Do your records provide proof that organic ingredients are certified organic [§205.101(c)(1)(i)]?                                Yes      No
                                                                                                                                          Not applicable

1.a.3.    Do your records verify the quantities of organic ingredients you use [§205.101(c)(1)(ii)]?                                      Yes      No
                                                                                                                                          Not applicable

1.a.4.    Have you or are you prepared to maintain your records for at least 3 years [§205.101(c)(2)]?                                    Yes      No
                                                                                                                                          Not applicable

1.a.5.    Are your records accessible to inspection by representatives of the Secretary of Agriculture                                    Yes      No
          or your State Organic Program during regular business hours [§205.101(c)(2)]?                                                   Not applicable


Subsection 1.b: Excluded Handling Operations
Check All That Apply:
          I sell only “100% organic,” “organic,” and “made with organic (specified ingredients or food groups)”1 products that
          were packaged before I received them, and which remain in their original packaging. I do NOT repackage or process them
          further [§205.101(b)(1)].

          My operation is a retail food establishment that prepares, on the premises, only raw and ready-to-eat food previously
          labeled “100% organic,” “organic,” and “made with organic (specified ingredients or food groups)”2 [§205.101(b)(2)].

If you checked either of the above 2 items, you are excluded from certification. However, there are still regulations that apply to
your operation. To assess your compliance with these, please proceed to Subsection 2.c.e and Section 6 of this document. Then
return and answer the following questions.

1.b.1.    In completing Subsection 2.c.e, did you answer all of the questions either with a                                               Yes      No
          “Yes” or “Not Applicable” [§205.310]?                                                                                           Not applicable

1.b.2.    In completing Section 6, did you answer all of the questions either with a                                                      Yes      No
          “Yes” or “Not Applicable” [§205.272]?                                                                                           Not applicable



1
 “Made with organic (specified ingredients or food groups)” refers to those products containing at least 70% organic ingredients by total weight (excluding salt and
  water). These may be labeled “Made with organic (specified ingredients or food groups).”
2
  Ibid.

Page 4                                                                                                Organic Compliance Checklist for Handlers
1.b.3.      As an excluded handler, are you careful NOT to affix the USDA seal to any products                              Yes      No
            [§205.310(a)(1)]?                                                                                              Not applicable

1.b.4.      As an excluded handler, are you careful NOT to claim to be certified and to NOT represent                       Yes      No
            any on-site processed raw or ready-to-eat products as certified organic [§205.310(a)(2)]?                       Not applicable

1.b.5.      As an excluded handler, are you careful that none of your products are identified as organic                    Yes      No
            ingredients in another handler’s products [§205.310(b)]?                                                       Not applicable


    You should know…

    “Exempt” operations are those that are specifically mentioned in the NOP regulations as being exempt from certification—small
    farmers, retailers, and handlers that do not process, and handlers with products below 70% organic content. “Excluded” opera-
    tions do not have to be certified according to the NOP regulations, even though they are not “exempt” from certification under
    the Organic Foods Production Act (OFPA).
    Both exempt and excluded operations do not need to be certified, but still have to comply with all NOP regulations except for
    the certification requirements and the submission of an organic system plan.


Subsection 1.c: Certified Organic Operations
            If you handle crops, livestock, livestock products, or other agricultural products that are intended to be sold, labeled, or
            represented as “100% organic,” “organic,” or “made with (specified ingredients or food groups),”3 you must be certified
            unless exempt or excluded from certification. (See Subsections 1A and 1B). If you must be certified, please proceed with
            answering the remaining questions posed in this checklist.

1.c.1.      Have you submitted an application(s) for organic certification to a certifying agent(s)?                        Yes      No
                                                                                                                           Not applicable

1.c.2.      Is/Are the certifier(s) accredited with the USDA’s National Organic Program (NOP)?                              Yes      No
                     A current list of accredited certifying agents is published on the NOP website at:                    Not applicable
                     www.ams.usda.gov/nop/

1.c.3.      Did you complete an organic production and handling system plan (also known as                          Yes      No
            the Organic System Plan (OSP)) [§205.201]?                                                              Not applicable
                    A complete Organic System Plan includes the following:
                    1) A description of practices and procedures to be performed and maintained, including
                         the frequency with which they will be performed;
                    2) A list of each substance to be used as a production or handling input, indicating its
                         composition, source, location(s) where it will be used, and documentation of commercial
                         availability, as applicable;
                    3) A description of the monitoring practices and procedures to be performed and
                         maintained, including the frequency with which they will be performed, to verify that
                         the plan is effectively implemented;
                    4) A description of the recordkeeping system implemented;
                    5) A description of the management practices and physical barriers established to prevent
                         commingling of organic and nonorganic products on a split operation and to prevent contact
                         of organic production and handling operations and products with prohibited substances;
                    6) Additional information deemed necessary by the certifying agent to evaluate compliance
                         with the regulations.




3
    Ibid.



Organic Compliance Checklist for Handlers                                                                                              Page 5
1.c.4.    Did you advise the certifier(s) of any previous applications for certification including the                                   Yes      No
          names of the certifiers, dates of application, and the outcomes of those applications                                         Not applicable
          [§205.401(c)]?

1.c.5.    Did you provide the certifier(s) with details of any prior noncompliances, noncompliance                                      Yes      No
          notices, denials of certification, suspensions, revocations, and actions taken to correct                                     Not applicable
          noncompliances [§205.401(c)]?

1.c.6.    Have you notified the certifier(s) of any deviations from the Organic System Plan or other                                     Yes      No
          actions that may affect compliance with federal organic regulations [§205.400(f)(2)]?                                        Not applicable

1.c.7.    Are all your organic products and handling operations available for inspection by the                                        Yes      No
          Administrator,4 the applicable State Organic Program’s governing State official, or the                                       Not applicable
          certifying agent [§205.670(a)]?


Section 2: Practices & Procedures
          A description of practices and procedures to be performed and maintained, and the frequency with which they will be per-
          formed is required as part of your Organic System Plan [§205.201(a)(1)].


Subsection 2.a: General
2.a.1.    If you process products for sale as organic, are you using only allowed methods?                                             Yes      No
                   Processes allowed include mechanical or biological methods such as cooking, baking,                                 Not applicable
                   curing, heating, drying, mixing, grinding, churning, separating, distilling, extracting,
                   slaughtering, cutting, fermenting, eviscerating, preserving, dehydrating, freezing, chilling,
                   and the packaging, canning, jarring, or otherwise enclosing of a product in a container
                   [§205.2 & §205.270(a)].

2.a.2.    If you process products for sale as organic and use nonorganic agricultural ingredients, are                                 Yes      No
          those items on the National List of nonorganically produced agricultural products allowed                                    Not applicable
          as ingredients…5 [§205.270(b)]?

2.a.3.    If you process products for sale as organic and use nonagricultural ingredients,                                             Yes      No
          are those items on the National List of nonagricultural substances allowed                                                   Not applicable
          as ingredients…6 [§205.270(b)]?
                   After June 9, 2007, ingredients listed in Section §205.606 of the National List may only
                   be used as ingredients if their organic equivalent is not commercially available.

2.a.4.    Do you exclude the use of ionizing radiation in the production or on-farm processing of any                                  Yes      No
          ingredient or product you market as “100% organic,” “organic,” or “made with (specified                                       Not applicable
          ingredients or food groups)” [§205.105(f)]?


Subsection 2.b: Product Composition
2.b.1.    Are you using the term “organic” correctly?                                                                                  Yes      No
                  The term “organic” may only be used on labels and in labeling of raw or processed                                    Not applicable
                  agricultural products, including ingredients, which have been produced and handled
                  in accordance with the National Organic Standards 7 CFR Part 205.

2.b.2.    Are you sure that you are not using the term “organic” in a product name to modify a                                         Yes      No
          nonorganic ingredient in the product [§205.300(a)]?                                                                          Not applicable
                  For example, you cannot call a product “Organic Cherry Ice Cream” if the cherries
                  are nonorganic.
4
 The administrator for the USDA’s Agricultural Marketing Service (AMS) or an authority that has been designated to act in his/her stead [§205.2].
5
  §205.606 Nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as “organic” or “made with organic [speci-
  fied ingredients or food groups(s)].”
6
  §205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic [specified
  ingredients or food groups(s)].”
Page 6                                                                                              Organic Compliance Checklist for Handlers
2.b.3.     If you are selling, labeling, or representing a product as “100 percent organic,” does the                                          Yes      No
           product contain (by weight or fluid volume) 100 percent certified organic ingredients                                                 Not applicable
           (excluding water and salt) [§205.301(a)]?
                    Note that each ingredient must be 100% certified organic itself.

2.b.4.     If you are selling, labeling, or representing a product as “100 percent organic,” and any                                           Yes      No
           processing aids7 were required, were the processing aids certified organic [§205.301(f)(4)]?                                         Not applicable

2.b.5.     If you are selling, labeling, or representing a product as “organic,” does the product contain                                      Yes      No
           (by weight or fluid volume) at least 95 percent organically produced ingredients (excluding                                          Not applicable
           water and salt) [§205.301(b)]?

2.b.6.     If you are selling, labeling, or representing a product as “organic,” are the non-organic                                           Yes      No
           agricultural ingredients on the National List under §205.6068, and have you documented                                              Not applicable
           that they are not commercially available as organic [§205.301(b)]?
                     “Commercially available” is defined as the ability to obtain a production input in an
                     appropriate form, quality, or quantity to fulfill an essential function in a system of organic
                     production or handling, as determined by the certifying agent in the course of reviewing the
                     organic plan.

2.b.7.     If you are selling, labeling, or representing a product as “made with organic (specified                                             Yes      No
           ingredients or food groups),” does the product contain (by weight or fluid volume) at least                                          Not applicable
           70 percent organically produced ingredients (excluding water and salt) [§205.301(c)]?

2.b.8.     If you are selling, labeling, or representing a product as “made with organic (specified                                             Yes      No
           ingredients or food groups),” can you verify or document that all nonorganically produced                                           Not applicable
           ingredients produced without use of sewage sludge, ionizing radiation, or genetically
           modified organisms [§205.301(c)]?

2.b.9.     If you are selling, labeling, or representing a product as “organic,” and processing aids                                           Yes      No
           were used, were they either organically produced or on the National List under §205.605                                             Not applicable
           or §205.6069?

2.b.10. If you are selling, labeling, or representing a product as “organic,” can you verify or                                                Yes      No
        document that sulfites, nitrates, or nitrites are NOT added during the production or                                                    Not applicable
        handling process [§205.301(f)(5)]10?

2.b.11. If you are selling, labeling, or representing a product as “organic,” can you verify or document                                       Yes      No
        that the product is NOT produced using nonorganic ingredients when organic ingredients are                                             Not applicable
        available [§205.301(f)(6)]?

2.b.12. If you are selling, labeling, or representing a product as “organic,” or “made with organic                                            Yes      No
        (specified ingredients or food groups),” can you verify or document that the product does                                               Not applicable
        NOT contain organic and nonorganic forms of the same ingredient [§205.301(f)(7)]?

2.b.13. If you are selling, labeling, or representing a livestock feed product as “100 percent organic,”                                       Yes      No
        does that product contain (by weight or fluid volume, excluding water and salt) no less than                                            Not applicable
        100 percent organically produced raw or processed agricultural product [§205.301(e)(1)]?



7
 §205.2 “Processing aids” are defined as
  1) Substances that are added to a food during the processing of such food but are removed in some manner from the food before it is packaged in its finished form;
  2) Substances that are added to a food during processing which are converted into constituents normally present in the food, and do not significantly increase the
     amount of the constituents naturally found in the food;
  3) Substances that are added to a food for their technical or functional effect in the processing but are present in the finished food at insignificant levels and do not
     have any technical or functional effect on the food.
8
  See footnote 5 on page 6.
9
  See footnotes 5 and 6 on page 6.
10
   Note: Wine containing added sulfites may only be labeled as “made with organic grapes.”


Organic Compliance Checklist for Handlers                                                                                                                    Page 7
2.b.14. If you are selling, labeling, or representing a livestock feed product as “organic,”                                                Yes      No
        can you verify or document that:                                                                                                    Not applicable
                 all agricultural ingredients are certified organic [§205.237(a)]?
                 any synthetic ingredients are on the National List under §205.603 [§205.237(a)]?
                 no animal drugs or synthetic hormones are included [§205.237(b)(1)]?
                 no plastic pellets are added [§205.237(b)(3)]?
                 no manure or urea is added [§205.237(b)(4)]?
                 no mammalian or poultry by-products are included [§205.237(b)(5)]?
                 use of any feed, feed additives, or feed supplements does NOT violate the Federal
                 Food, Drug, and Cosmetic Act [§205.237(b)(6)]?

2.b.15. For all of your products labeled “100% organic,” “organic,” “made with organic (specified                   Yes      No
        ingredients or food groups),” or that include organic ingredients, do you calculate the                    Not applicable
        percentage of organic ingredients using the method required by the National Organic
        Standard11, which is:
                  1) Divide the total net weight (excluding water and salt) of combined organic ingredients
                      at formulation by the total weight (excluding water and salt) of all ingredients
                      [§205.302(a)(1)].
                  2) Divide the fluid volume of all organic ingredients (excluding water and salt) by the
                      fluid volume of all ingredients (excluding water and salt) if the product and ingredients
                      are liquid. If the liquid product is identified on the principal display panel or information
                      panel as being reconstituted from concentrates, the calculation should be made on the basis
                      of single-strength concentrations of the ingredients [§205.302(a)(2)].
                  3) For products containing organically produced ingredients in both solid and liquid form,
                      divide the combined weight of the solid ingredients and the weight of the liquid ingredients
                      (excluding water and salt) by the total weight (excluding water and salt) of all ingredients
                      [§205.302(a)(3)].

2.b.16. When calculating the percentage of organic ingredients, do you always round down to the                                             Yes      No
        nearest whole number [§205.302(b)]?                                                                                                 Not applicable

2.b.17. Do you and/or another principal in your operation calculate the percentage of organic                                               Yes      No
        ingredients in your products, and are the same individuals responsible for that information                                         Not applicable
        on the product labels [§205.302(c)]?

2.b.18. Does your certifier verify your label and calculation procedure?12                                                                   Yes      No
                                                                                                                                            Not applicable


Subsection 2.c: Labels and Labeling
Subsection 2.c.a: Products Labeled as “100% Organic” and “Organic”
2.c.a.1. If you label packaged products “organic,” do you identify each organic ingredient in the                                           Yes      No
         ingredient statement with the word “organic” or with an asterisk or other reference mark                                           Not applicable
         which is defined below the ingredient statement to indicate the ingredient is organically
         produced [§205.303(b)(1)]?
                   Note: Water or salt included as ingredients cannot be identified as organic.




11
  The method to calculate percentage of organic ingredients in the National Organic Standard Final Rule was incorrect. This has been corrected in the National
  Organic Program Audit Checklist, which can be found at: www.ams.usda.gov/nop/NOP/NOPEnglishAuditChecklistCOMEX.pdf The correct method is shown in this
  document.
12
   Review of labels and verifying calculations of organic ingredients are included in the organic system plan, which must be approved by the certifying agent prior to
  scheduling inspections.

Page 8                                                                                                 Organic Compliance Checklist for Handlers
2.c.a.2. If you label packaged products “100 percent organic” or “organic,” do you include on                                              Yes      No
         the information panel, below the information identifying the handler or distributor of                                            Not applicable
         the product and preceded by the statement “Certified organic by…” (or similar phrase),
         the name of the certifying agent that certified the handler of the finished product
         [§205.303(b)(2)]13?

2.c.a.3. If you label packaged products “organic” and display the percentage of organic ingredients                                        Yes      No
         in the product, is the size of the percentage statement less than or equal to one-half the size                                   Not applicable
         of the largest type size on the panel on which the statement is displayed and does the percentage
         statement appear in its entirety in the same type size, style, and color without highlighting
         [§205.303(b)(2)]?

2.c.a.4. If you label packaged products “100 percent organic” or “organic,” and display the seal, logo,                                    Yes      No
         or other identifying mark of the certifying agent(s)* can you document that the handler producing                                 Not applicable
         the finished product maintains records verifying that the operations producing the ingredients are
         certified [§205.303(a)(5)]?
                   *Refers to the certifying agent that certified either the production of the finished
                   product, or the raw products or ingredients that were used in the finished product.

2.c.a.5. If you label packaged products “100 percent organic” or “organic,” and display the seal, logo,                                    Yes      No
         or other identifying mark of the certifying agent(s)*, do you ensure that such seals or marks are                                 Not applicable
         NOT individually displayed more prominently than the USDA seal [§205.303(a)(5)]?
                   *Refers to the certifying agent that certified either the production of the finished product,
                   or the raw products or ingredients that were used in the finished product.

2.c.a.6. If you label livestock feed products as “100 percent organic” or “organic,” does the                                              Yes      No
         information panel below the identification of the handler or distributor of the product and                                        Not applicable
         preceded by the statement “Certified organic by...” or similar phrase, display the
         name of the certifying agent that certified the handler of the finished product [§205.306(b)(1)]?14

2.c.a.7. If you label livestock feed products as “100 percent organic” or “organic,” does the label                                        Yes      No
         comply with other Federal agency or State feed labeling requirements, as applicable                                               Not applicable
         [§205.306(b)(2)]?

2.c.a.8. If you label livestock feed products as “100 percent organic” or “organic,” and display on                                        Yes      No
         any package panel the seal, logo, or other identifying market of the certifying agent that                                        Not applicable
         certified the production or handling operation producing the raw or processed organic
         ingredients used in the finished product, do you ensure that such seals or marks are NOT
         displayed more prominently than the USDA seal [§205.306(a)(3)]?


Subsection 2.c.b: Products Labeled as “Made With Organic (Specified Ingredients Or
Food Group(s))”
2.c.b.1. If you label packaged products “made with organic (specified ingredients or food                                                   Yes      No
         group(s))”, do you identify each organic ingredient in the ingredient statement with                                              Not applicable
         the word “organic” or with an asterisk or other reference mark which is defined below
         the ingredient statement to indicate the ingredient is organically produced [§205.304(b)(1)]?
                      Note: Water or salt included as ingredients cannot be identified as organic.




13
   You may also display the business address, Internet address, or telephone number of the certifying agent on the information panel below the information identify-
  ing the handler or distributor of the product.
14
  The business address, Internet address, or telephone number of the certifying agent may be included on the label.


Organic Compliance Checklist for Handlers                                                                                                               Page 9
2.c.b.2. If you label packaged products “made with organic (specified ingredients or food                                                   Yes      No
         group(s)),” do you, on the information panel below the information identifying the handler                                        Not applicable
         or distributor of the product and preceded by the statement “Certified organic by…”
         (or similar phrase), identify the name of the certifying agent that certified the handler of the
         finished product [§205.304(b)(2)]?15

2.c.b.3. If you label packaged products “made with organic (specified ingredients or food group(s)),”                                       Yes      No
         do you ensure that the USDA seal does NOT appear on the package [§205.304(c)]?                                                    Not applicable

2.c.b.4. If you label packaged products “made with organic (specified ingredients),” and use the                                            Yes      No
         statement “made with organic (specified ingredients)” on the label*, do you ensure that the                                        Not applicable
         statement does NOT list more than three organically produced ingredients or more than three
         of the following food groups: fruits, grains, herbs, meats, nuts, oils, poultry, seeds, spices,
         sweeteners, and vegetables or processed milk products [§205.304(a)(1)(i)] and [§205.304(a)(1)(ii)]?
                   *”Label,” in this instance, includes the principal display panel, information panel, and
                   any other panel of the package and on any other labeling or market information concerning
                   the product.

2.c.b.5. If you use the statement “made with organic (specified ingredients)” or “made with organic                                         Yes      No
         (specified food groups),” do you ensure that it appears in letters that do NOT exceed one-half                                     Not applicable
         of the size of the largest type size on the panel and appears in its entirety in the same type size,
         style, and color without highlighting [§205.304(a)(1)(iii)]?

2.c.b.6. If you label packaged products “made with organic (specified ingredients or food group(s)),”                                       Yes      No
         and display the percentage of organic ingredients in the product, is the size of the percentage                                   Not applicable
         statement less than or equal to one-half the size of the largest type size on the panel on which
         the statement is displayed and does the percentage statement appear in its entirety in the same
         type size, style, and color without highlighting [§205.304(a)(2)]?16


Subsection 2.c.c: Products Containing Less Than 70% Organically Produced
Ingredients
2.c.c.1. If you label packaged products with LESS than 70 percent organically produced ingredients,                                        Yes      No
         does your label ONLY identify the organic content of the product by identifying each organically                                  Not applicable
         produced ingredient in the ingredient statement with the word “organic,” or with an asterisk or
         other reference mark (defined below the ingredient statement) to indicate the ingredient is
         organically produced [§205.305(a)(1)]?

2.c.c.2. If you label packaged products with LESS than 70 percent organically produced ingredients,                                        Yes      No
         and you display the percentage of organic contents on the information panel, are the organically                                  Not applicable
         produced ingredients identified in the ingredient statement [§205.305(a)(2)]?

2.c.c.3. If you label packaged products with LESS than 70 percent organically produced ingredients,                                        Yes      No
         do you refrain from displaying the USDA seal [§205.305(b)(1)]?                                                                    Not applicable

2.c.c.4 If you label packaged products with LESS than 70 percent organically produced ingredients,                                         Yes      No
        do you refrain from displaying any certifying agent seal, logo, or other identifying mark which                                    Not applicable
        represents organic certification of a product or product ingredients [§205.305(b)(2)]?




15
   You may also display the business address, Internet address, or telephone number of the certifying agent on the information panel below the information identify-
  ing the handler or distributor of the product.
16
   You may also display on the principal display panel, information panel, and any other panel of the package and on any labeling or market information concerning
  the product, the seal, logo, or other identifying mark of the certifying agent that certified the handler of the finished product [§205.304(a)(3)].


Page 10                                                                                               Organic Compliance Checklist for Handlers
Subsection 2.c.d: Organic Products Sold in Bulk

 You should know…

 If you label non-retail containers used only for shipping or storage of raw or processed agricultural products labeled as “100
 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s)), you may display the following terms
 or marks on the container:
     1) The name and contact information of the certifying agent which certified the handler which assembled the final
        product [§205.307(a)(1)]
     2) Identification of the product as organic[§205.307(a)(2)]
     3) Special handling instructions needed to maintain the organic integrity of the product[§205.307(a)(3)]
     4) The USDA seal[§205.307(a)(4)] (Note: For “100% organic” and “organic” products only)
     5) The seal, logo, or other identifying mark of the certifying agent that certified the organic production or handling
        operation that produced or handled the finished product [§205.307(a)(5)]

2.c.d.1. If you label non-retail containers used only for shipping or storage of raw or processed            Yes      No
         agricultural products as “100 percent organic,” “organic,” or “made with organic                    Not applicable
         (specified ingredients or food group(s)),” do the containers display the production lot
         number of the product [§205.307(b)]?

2.c.d.2. If you label shipping containers of domestically produced product labeled as organic intended       Yes      No
         for export to international markets, and label these containers in accordance with shipping         Not applicable
         container labeling requirements of the foreign country of destination or the container labeling
         specifications of a foreign contract buyer, are the shipping containers and shipping documents
         accompanying such organic products clearly marked “For Export Only” [§205.307(c)]?

2.c.d.3. If you are an exempt or excluded operation, and label shipping containers as organic for            Yes      No
         export, do you maintain proof of such container marking and export as part of your                  Not applicable
         records [§205.307(c)]?

2.c.d.4. If you sell, label, or represent agricultural products as “100 percent organic” or “organic”        Yes      No
         in other than packaged form at the point of retail sale (bulk sales), do you follow labeling        Not applicable
         requirements [§205.308]?

 You should know…

 You may use the term “100 percent organic” or “Organic” to modify the name of the product in retail display, label-
 ing, and display containers provided that the term “organic” is used to identify the organic ingredients listed in the ingre-
 dient statement [§205.308(a)]. If the product is prepared in a certified facility, the retail display, labeling, and display con-
 tainers may use the USDA seal [§205.308(b)(1)] and the seal, logo, or other identifying mark of the certifying agent(s)*,
 provided that such seals or marks are NOT individually displayed more prominently than the USDA seal [§205.308(b)(2)].
         *Refers to the certifying agent that certified either the production of the finished product, or the raw products or
         ingredients that were used in the finished product.

2.c.d.5. If you handle agricultural products in bulk containing between 70 and 95 percent organically        Yes      No
         produced ingredients and label them “made with organic [specified ingredients or food                Not applicable
         groups(s)], does your label statement list no more than three organic ingredients or food
         groups [§205.309(a)(1)]?

2.c.d.6. If you handle agricultural products in bulk containing between 70 and 95 percent organically        Yes      No
         produced ingredients and label them “made with organic [specified ingredients or food                Not applicable
         groups(s)],” does the label indicate all organically produced ingredients as “organic”
         [§205.309(a)(2)]?



Organic Compliance Checklist for Handlers                                                                               Page 11
You should know…
 If a bulk product containing between 70 and 95 percent organic ingredients is prepared in a certified facility, and is labeled
 “made with organic [specified ingredients or food groups(s)]” in retail displays, display containers, and market information, it
 may feature the certifying agent’s seal, logo, or other identifying mark [§205.309(b)].

Subsection 2.c.e: Sale of Products Produced On An Exempt Or Excluded Operation
2.c.e.1. If you sell agricultural products produced on an exempt or excluded operation, do you                                       Yes      No
         refrain from displaying the USDA seal or any certifying agent’s seal or other identifying                                   Not applicable
         mark which represents the exempt or excluded operation as a certified organic operation
         [§205.310(a)(1)]?

2.c.e.2. If you sell agricultural products produced on an exempt or excluded operation, do you                                       Yes      No
         ensure that the product is NOT represented as a certified organic product or certified                                        Not applicable
         organic ingredient [§205.310(a)(2)]?

 You should know…
 An agricultural product organically produced or handled on an exempt or excluded operation may be identified as an organic
 product or organic ingredient in a multiingredient product produced by the exempt or excluded operation. Such product or
 ingredient must NOT be identified or represented as “organic” in a product processed by others [§205.310(b)].


2.c.e.3. If you are selling agricultural products produced on an exempt or excluded operation, can            Yes      No
         you verify and/or document that the product:                                                         Not applicable
                  is labeled correctly. The term “organic” may NOT be used in a product name to modify
                  a non-organic ingredient [§205.300(a)].
                  has NOT been produced using excluded methods17 [§205.301(f)(1)]
                  has NOT been produced using sewage sludge [§205.301(f)(2)]
                  has NOT been produced using ionizing radiation [§205.301(f)(3)]
                  has NOT been processed using processing aids that were NOT organically produced or are
                  NOT on the National List [§205.301(f)(4)]
                  does NOT contain added sulfites, nitrates, or nitrites [§205.301(f)(5)]
                  has NOT been produced using nonorganic ingredients when organic ingredients were available [§205.301(f)(6)]
                  does NOT include organic and non-organic forms of the same ingredient [§205.301(f)(7)]
                  is NOT used as an organic ingredient by anyone who is not either an exempt or excluded handler [§205.310(b)]
 You should know…

                                        The USDA seal may only be used on products that are labeled “100% organic” or “organic” as
                                        per §205.301(a); §205.301(b); §205.301(e)(1); §205.301(e)(2). The USDA seal must replicate the
                                        form and design of the example in figure 1 and must be printed legibly and conspicuously
                                        1) On a white background with a brown outer circle and with the term “USDA” in green over-
                                           laying a white upper semicircle with the term “organic” in white overlaying the green lower
                                           half circle [§205.311(b)(1)]; or
                                        2) On a white or transparent background with black outer circle and black “USDA” on a white
                                           or transparent upper half of the circle with a contrasting white or transparent “organic” on
                                           the black lower half circle [§205.311(b)(2)].
                                        3) The green or black lower half circle may have four light lines running from left to right and dis-
                                           appearing at the point on the right horizon to resemble a cultivated field [§205.311(b)(3)].




 Excluded methods are defined as a variety of methods used to genetically modify organisms or influence their growth and development by means that are not pos-
17

 sible under natural conditions or processes and are not considered compatible with organic production. Such methods include cell fusion, microencapsulation
 and macroencapsulation, and recombinant DNA technology [§205.2].

Page 12                                                                                           Organic Compliance Checklist for Handlers
Subsection 2.d: Facility Pest Management
 You should know…
 Preventative practices, such as removal of pest habitat, food sources, and breeding areas, prevention of access to handling
 facilities, and management of environmental factors such as temperature, light, humidity, atmosphere, and air circulation to
 prevent pest reproduction are required [§205.271(a)(1)(2)(3)]. If these preventative practices fail to control pests, handlers may
 manage them using
          1) Mechanical or physical controls such as traps, light or sound [§205.271(b)(1)]
          2) Lures and repellents using nonsynthetic or synthetic substances consistent with the National List [§205.271(b)(2)]
 If these alternatives are also insufficient, a nonsynthetic or synthetic substance consistent with the National List may be used
 [§205.271(c)].


2.d.1.        If you need to apply a synthetic substance not on the National List in order to achieve                      Yes      No
              adequate pest control, do you confer with your certifying agent to agree on the substance                    Not applicable
              to be used, method of application, and measures to be taken to prevent contact of the
              organically produced products or ingredients with the substance used [§205.271(d)]?

2.d.2.        If you need to apply any nonsynthetic or synthetic substance(s) to control pests, do you                     Yes      No
              update your organic handling plan to reflect the use of such substances and methods of                        Not applicable
              application and does the updated organic plan include a list of all measures taken to prevent
              contact of the organically produced products or ingredients and packaging with the substance
              used [§205.271(e)]?
                       A handler may use substances to prevent or control pests as required by Federal,
                       State, or local laws and regulations, provided that measures are taken to prevent
                       contact of the organically produced products or ingredients with the substance used
                       [§205.271(f)].


Section 3: Inputs
              A list of each substance to be used as a production or handling input—including its composition, source, location(s)
              where it will be used—and documentation of commercial availability must be provided as part of your Organic System
              Plan [§205.201(a)(2)]. Allowed substances also include certain nonsynthetic nonagricultural materials as specifically
              listed in §205.605(a) and certain synthetic materials as specifically listed in §205.605(b). If the substance is synthetic,
              it must be on the National List to be used.

              A comprehensive listing of allowed and prohibited materials is not provided here. As a handler/processor, you should
              read the appropriate sections of the National List (§205.605 and §205.606) and confer with your certifier when in
              doubt. Note that many products and materials represented as “natural” or “organically acceptable” might not be
              allowed under the National Standard. Always check with your certifier before using any new or questionable material.


Subsection 3.a: Food Ingredients
3.a.1.        If you process products for sale as organic and must use nonorganic agricultural ingredients,                Yes      No
              are those items listed on the National List of nonorganically produced agricultural products                 Not applicable
              allowed as ingredients in §205.60618 [§205.270(b)]?

3.a.2.        If you process products for sale as organic and must use nonagricultural ingredients, are                    Yes      No
              those items listed on the National List of nonagricultural substances allowed as ingredients                 Not applicable
              in §205.60519 [§205.270(b)]?



18
     See footnotes on page 6 for more information on the National List.
19
     See footnotes on page 6 for more information on the National List.

Organic Compliance Checklist for Handlers                                                                                              Page 13
Subsection 3.b: Processing Aids
3.b.1.    If you process products for sale as organic and must use processing aids, are the constituents                                   Yes      No
          of the processing aids either certified organic, listed on the National List of nonorganically                                    Not applicable
          produced agricultural products in §205.606, or listed as nonagricultural ingredients allowed
          as processing aids in §205.605 [§205.270(b)]?


Subsection 3.c: Sanitizers
3.c.1.    If you process products for sale as organic and use cleaning/sanitizing products, are the                                        Yes      No
          constituents of the cleaning/sanitizing products certified organic, or listed on the National                                     Not applicable
          List of nonorganically produced agricultural substances in §205.606 or nonagricultural
          ingredients in §205.605 [§205.270(b)]?


Subsection 3.d: Facility Pest Management
3.d.1.    If you were obliged to use a synthetic pest control material for managing pests in or around                                     Yes      No
          buildings or facilities, was it because management strategies and allowed materials were                                         Not applicable
          inadequate [§205.271(d)]?20
                   The handler and the certifying agent must agree on the substance to be used, method
                   of application, and measures to be taken to prevent contact of the organically produced
                   products or ingredients with the substance used. The organic handling plan must be
                   updated to reflect the use of the substance and the methods of application [§205.271(d)].

3.d.2.    If you were obliged to use a synthetic pest control material for managing pests in or                                            Yes      No
          around buildings or facilities, were stringent measures taken to prevent contact of                                              Not applicable
          organically produced products or ingredients and packaging with the substance used
          [§205.271(d) and §205.272(b)(1)]?

3.d.3.    If you were obliged to use a synthetic pest control material for managing pests in or                                            Yes      No
          around buildings or facilities, did you update the your operation’s Organic System                                               Not applicable
          Plan to reflect the use of such substances and methods of application, plus all measures
          taken to prevent contact with the organically produced products or ingredients and
          packaging [§205.271(e) and §205.272(b)(1)]?


Section 4: Monitoring Practices & Procedures
          A description of the monitoring practices and procedures to be performed and maintained, including the frequency
          with which they will be performed, to verify that the plan is effectively implemented is required in your Organic System
          Plan [§205.201(a)(3)].

4.1.      Do you monitor pests in storage and other facilities to guide your management                                                    Yes      No
          decisions [§205.271(c)]?                                                                                                         Not applicable
                   Biological and botanical pest control substances, and pest control agents included on the
                   National List may be used only when environmental management, sanitation, barriers,
                   and mechanical controls are insufficient to keep a pest problem in check [§205.271(c)].
                   Some form of monitoring must be used to trigger and justify the use of these materials.
                   The conditions for using such materials must be described in the Organic System
                   Plan [§205.271(e)].

4.2.      Do you describe your monitoring procedures and conditions for using pest control methods                                         Yes      No
          in your Organic System Plan [§205.271(e)]?                                                                                       Not applicable



 You are allowed to use otherwise prohibited pest control materials for facility pest management if so-required by Federal, State, or local laws and regulations.
20

 However, measures must be taken to prevent the contamination of organic products and ingredients [§205.271(f)].

Page 14                                                                                                Organic Compliance Checklist for Handlers
4.3.      Do you describe your monitoring procedures for cleaning and purging machinery and                                                 Yes      No
          equipment to prevent commingling and contamination in your Organic System Plan                                                    Not applicable
          [§205.272(a)]?


Section 5: Recordkeeping
          A description of your recordkeeping system must be provided in your Organic System Plan [§205.201(a)(4)].

5.1.      Do you maintain a complete set of operation records covering handling of all agricultural                                         Yes      No
          products that you intend to be sold, labeled, or represented as organic [§205.103(a)]?                                            Not applicable

5.2.      Is your recordkeeping system appropriate and well-adapted to the needs of your organic                                            Yes      No
          operation [§205.103(b)(1)]?                                                                                                       Not applicable

5.3.      Does your recordkeeping system fully disclose all activities and transactions, such as                                            Yes      No
          ingredient purchases and product sales, in sufficient detail so as to be readily                                                   Not applicable
          understood and audited [§205.103(b)(2)]?

5.4.      Do you retain or are you preparing to retain all records applicable to your organic                                               Yes      No
          operation for at least 5 years [§205.400(d) & §205.103(b)(3)]?                                                                    Not applicable

5.5.      Is your recordkeeping system sufficient to demonstrate compliance with organic                                                     Yes      No
          regulations and the Organic Foods Production Act [§205.103(b)(4)]?                                                                Not applicable

5.6.      Are your records available for inspection and copying during normal business hours                                                Yes      No
          by authorized representatives of the Secretary,21 the State Organic Program, and/or                                               Not applicable
          the certifying agent [§205.103(c)]?


Section 6: Commingling and Contamination
          A description of your management practices and the physical barriers you’ve established to prevent commingling of organic
          and nonorganic products on a split operation and to prevent contact of organic production operations and products with
          prohibited substances must be provided in your Organic System Plan [§205.201(a)(5)].

6.1.      During handling and storage, do you take adequate measures to prevent contact of organic                                          Yes      No
          crops, livestock, and products with prohibited substances [§205.272(a)]?                                                          Not applicable

6.2.      Are all your packaging materials, bins, and storage containers free of synthetic fungicides,                                      Yes      No
          preservatives, and/or fumigants [§205.272(b)(1)]?                                                                                 Not applicable

6.3.      If you re-use any bags or containers, do you take measures to ensure that there is no risk                                        Yes      No
          of commingling with nonorganic products or of contamination with a prohibited substance                                           Not applicable
          [§205.272(b)(2)]?


Section 7: Additional Information Required
          Additional information deemed necessary by the certifying agent to evaluate compliance with the regulations must be
          provided in your Organic System Plan [§205.201(a)(6)].

7.1.      If you have been or were required to cooperate with additional testing or provide further                                         Yes      No
          information about any inputs to your organic operation by the Administrator,22 your State                                         Not applicable
          Organic Program, or your certifier, have you done so [§205.670(b)]?23



21
  The Secretary of Agriculture or his/her delegate [§205.2].
22
   The administrator for the USDA’s Agricultural Marketing Service (AMS) or an authority that has been designated to act in his/her stead [§205.2].
23
   Additional testing may be required when there is reason to believe that the agricultural input contains an unacceptable level of prohibited substances or has been
  produced using excluded methods. Such tests must be conducted by the applicable State Organic Program’s governing State official or the certifying agent at the
  official’s or certifying agent’s own expense [§205.670(b)].


Organic Compliance Checklist for Handlers                                                                                                                Page 15
7.2.      If you were required to cooperate with additional testing or provide further information                                        Yes      No
          about any of your organic products by the Administrator,24 your State Organic Program,                                          Not applicable
          or your certifier, have you done so [§205.670(b)]?25

7.3       Are you prepared to immediately notify your certifier concerning application of a prohibited                                     Yes      No
          substance or change in the operation that may affect compliance with the National Organic                                       Not applicable
          Standards [§205.400(f)]?

7.4       Have you submitted applicable fees to your certifier [§205.400(e)]?                                                              Yes      No
                                                                                                                                          Not applicable




 The administrator for the USDA’s Agricultural Marketing Service (AMS) or an authority that has been designated to act in his/her stead [§205.2].
24

 Additional testing may be required when there is reason to believe that the product has come into contact with a prohibited substance or has been produced using
25

 excluded methods. Such tests must be conducted by the applicable State Organic Program’s governing State official or the certifying agent at the official’s or certi-
 fying agent’s own expense [§205.670(b)].



Page 16                                                                                               Organic Compliance Checklist for Handlers
Notes




Organic Compliance Checklist for Handlers   Page 17
Notes




Page 18   Organic Compliance Checklist for Handlers
Feedback
                   Please detach, complete, and return to the address shown below.




    1) Did you find the Checklist helpful?                                             Yes   No


    2) How might the Checklist be changed to be more useful to you?




    3) Did you read any information in the Checklist that you believe is incorrect?   Yes   No
              If “Yes,” please indicate where you found the error.




    4) I am a:        producer
                      certifier
                      inspector
                      educator/information provider
                      other        Please describe



                               Thank you for your valuable feedback.



       Fold and mail this form to:                    Holly Born
                                                      NCAT/ATTRA
                                                      53020 Hitchcock Avenue
                                                      Lewis, IA 51544




Organic Compliance Checklist for Handlers                                                    Page 19
National Organic Program Compliance Checklist for
          Handlers
          By Holly Born
          NCAT Agriculture Specialist
          ©2006 NCAT
          Paul Driscoll, Editor
          Cynthia Arnold, Production
          This publication is available on the Web at:
          www.attra.ncat.org/attra-pub/organic_handlers.html
          and
          www.attra.ncat.org/attra-pub/PDF/organic_handlers.pdf
          IP301
          Slot 296
          Version 122906


Page 20

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National Organic Program Compliance Checklist for Handlers

  • 1. National Organic Program Compliance Checklist for Handlers November 2006 This document was developed by the National Center for Appropriate Technology (NCAT) with funds provided by the USDA/National Organic Program (NOP). Dis- tribution is through NCAT’s ATTRA Project, the National Sustainable Agriculture Information Service. ATTRA
  • 2. Acknowledgements: This document was written and prepared by Holly Born, Assistant Project Leader and NCAT Program Specialist (Lewis, IA), with the assistance of a stakeholder team representing the wider organic community, and formatted by Cynthia Arnold, NCAT Administrative Assistant (Fayetteville, AR). Stakeholder Team Members: Katherine Adam, NCAT, Fayetteville, AR Ann Baier, NCAT, Soquel, CA Jo Ann Baumgartner, Wild Farm Alliance, Watsonville, CA Brenda Book, Washington State Dept. of Agriculture, Olympia, WA Cissy Bowman, Indiana Certified Organic, Clayton, IN Mark Bradley, USDA National Organic Program, Washington, DC Diane Collins, Organic Farm Marketing, Viroqua, WI Lisa Cone, Waterfall Hollow Farm, Berryville, AR Joyce E. Ford, Organic Independents, Winona, MN John Foster, Oregon Tilth, McMinnville, OR Lance Gegner, NCAT, Fayetteville, AR Liana Hoodes, National Campaign for Sustainable Agriculture, Pine Bush, NY Lisa Hummon, Defenders of Wildlife, Albuquerque, NM George Kuepper, NCAT, Lewis, IA (Project Leader) Nancy Matheson, NCAT, Helena, MT Lisa McCrory, NOFA-VT, Randolph, VT Nancy Ostiguy, The Pennsylvania State University, University Park, PA Jim Riddle, University of Minnesota, Winona, MN Pam Riesgraf, Organic Valley, Jordan, MN Barbara C. Robinson, USDA/AMS, Washington, DC Kelly Shea, Horizon Dairy, Colorado Springs, CO Kathy Turner-Clifft, Doubletree Ranch LLC, Huntsville, AR Sara Vickerman, Defenders of Wildlife, West Linn, OR Ann Wells, Springpond Holistic Animal Health, Prairie Grove, AR Katherine Withey, Washington State Dept. of Agriculture, Olympia, WA Page 2 Organic Compliance Checklist for Handlers
  • 3. About This Document… This Checklist has been created to help you evaluate your handling or processing operation to assess how it complies with the National Organic Program Standards. In §205.2 of the Standards, a “handling operation” is defined as Any operation or portion of an operation (except final retailers of agricultural products that do not process agricultural prod- ucts) that receives or otherwise acquires agricultural products and processes, packages, or stores such products. The checklist structure and the language used is intended to make your work, and that of the certifier and inspec- tor, a bit easier. However, this Checklist is a guidance document only. It does not replace the regulations of the National Organic Program and may not reflect recent policy developments. National Organic Program regulations and policy statements can be found on the National Organic Program website at: www.ams.usda.gov/nop/NOP/ NOPhome.html The Checklist is divided into eight sections. Sections 2 through 7 correspond to the six categories of information required in the Organic Production and Handling System Plan, as specified in the Organic Standard §205.201. Each item in the Checklist is presented in the form of a question that can be answered by checking the “YES,” “NO,” or “Not Applicable” box located adjacent to the question. A check made in a “NO” box indicates that you may be out of compliance with the Federal Standard. In most instances, questions are accompanied by the cor- responding section and paragraph number of the regulations. Copies of the Checklist may be downloaded from the ATTRA website at: www.attra.ncat.org Additional print cop- ies can be obtained by writing ATTRA at P.O. Box 3838, Butte, MT 59701, or by calling 1-800-346-9140. Organic Compliance Checklist for Handlers Page 3
  • 4. Section 1: General: Must I Certify My Operation? Subsection 1.a: Exempt Handling Operations Check All That Apply: My operation sells less than $5,000 of organic product each year [§205.101(a)(1)]. My operation is a retail food establishment that handles organic products, but does NOT process or repackage them [§205.101(a)(2)]. I only handle products that contain less than 70% organic ingredients by weight (excluding water and salt) [§205.101(a)(3)]. I only use the term “organic” on a label when identifying organic ingredients on the information panel of my product label [§205.101(a)(4)]. If you checked any of the above 4 items, you are exempt from certification. However, your operation must still comply with all NOP regulations except for certification requirements and the submission of an organic systems plan. To assess your compliance with these, please skip ahead to the questions in subsection 2.c.e on page 12. Then answer questions 1.a.1 through 1.a.5, if applicable. 1.a.1. In completing subsection 2.c.e, did you answer all of the questions either with a Yes No “Yes” or “Not Applicable” [§205.310]? Not applicable 1.a.2. Do your records provide proof that organic ingredients are certified organic [§205.101(c)(1)(i)]? Yes No Not applicable 1.a.3. Do your records verify the quantities of organic ingredients you use [§205.101(c)(1)(ii)]? Yes No Not applicable 1.a.4. Have you or are you prepared to maintain your records for at least 3 years [§205.101(c)(2)]? Yes No Not applicable 1.a.5. Are your records accessible to inspection by representatives of the Secretary of Agriculture Yes No or your State Organic Program during regular business hours [§205.101(c)(2)]? Not applicable Subsection 1.b: Excluded Handling Operations Check All That Apply: I sell only “100% organic,” “organic,” and “made with organic (specified ingredients or food groups)”1 products that were packaged before I received them, and which remain in their original packaging. I do NOT repackage or process them further [§205.101(b)(1)]. My operation is a retail food establishment that prepares, on the premises, only raw and ready-to-eat food previously labeled “100% organic,” “organic,” and “made with organic (specified ingredients or food groups)”2 [§205.101(b)(2)]. If you checked either of the above 2 items, you are excluded from certification. However, there are still regulations that apply to your operation. To assess your compliance with these, please proceed to Subsection 2.c.e and Section 6 of this document. Then return and answer the following questions. 1.b.1. In completing Subsection 2.c.e, did you answer all of the questions either with a Yes No “Yes” or “Not Applicable” [§205.310]? Not applicable 1.b.2. In completing Section 6, did you answer all of the questions either with a Yes No “Yes” or “Not Applicable” [§205.272]? Not applicable 1 “Made with organic (specified ingredients or food groups)” refers to those products containing at least 70% organic ingredients by total weight (excluding salt and water). These may be labeled “Made with organic (specified ingredients or food groups).” 2 Ibid. Page 4 Organic Compliance Checklist for Handlers
  • 5. 1.b.3. As an excluded handler, are you careful NOT to affix the USDA seal to any products Yes No [§205.310(a)(1)]? Not applicable 1.b.4. As an excluded handler, are you careful NOT to claim to be certified and to NOT represent Yes No any on-site processed raw or ready-to-eat products as certified organic [§205.310(a)(2)]? Not applicable 1.b.5. As an excluded handler, are you careful that none of your products are identified as organic Yes No ingredients in another handler’s products [§205.310(b)]? Not applicable You should know… “Exempt” operations are those that are specifically mentioned in the NOP regulations as being exempt from certification—small farmers, retailers, and handlers that do not process, and handlers with products below 70% organic content. “Excluded” opera- tions do not have to be certified according to the NOP regulations, even though they are not “exempt” from certification under the Organic Foods Production Act (OFPA). Both exempt and excluded operations do not need to be certified, but still have to comply with all NOP regulations except for the certification requirements and the submission of an organic system plan. Subsection 1.c: Certified Organic Operations If you handle crops, livestock, livestock products, or other agricultural products that are intended to be sold, labeled, or represented as “100% organic,” “organic,” or “made with (specified ingredients or food groups),”3 you must be certified unless exempt or excluded from certification. (See Subsections 1A and 1B). If you must be certified, please proceed with answering the remaining questions posed in this checklist. 1.c.1. Have you submitted an application(s) for organic certification to a certifying agent(s)? Yes No Not applicable 1.c.2. Is/Are the certifier(s) accredited with the USDA’s National Organic Program (NOP)? Yes No A current list of accredited certifying agents is published on the NOP website at: Not applicable www.ams.usda.gov/nop/ 1.c.3. Did you complete an organic production and handling system plan (also known as Yes No the Organic System Plan (OSP)) [§205.201]? Not applicable A complete Organic System Plan includes the following: 1) A description of practices and procedures to be performed and maintained, including the frequency with which they will be performed; 2) A list of each substance to be used as a production or handling input, indicating its composition, source, location(s) where it will be used, and documentation of commercial availability, as applicable; 3) A description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed, to verify that the plan is effectively implemented; 4) A description of the recordkeeping system implemented; 5) A description of the management practices and physical barriers established to prevent commingling of organic and nonorganic products on a split operation and to prevent contact of organic production and handling operations and products with prohibited substances; 6) Additional information deemed necessary by the certifying agent to evaluate compliance with the regulations. 3 Ibid. Organic Compliance Checklist for Handlers Page 5
  • 6. 1.c.4. Did you advise the certifier(s) of any previous applications for certification including the Yes No names of the certifiers, dates of application, and the outcomes of those applications Not applicable [§205.401(c)]? 1.c.5. Did you provide the certifier(s) with details of any prior noncompliances, noncompliance Yes No notices, denials of certification, suspensions, revocations, and actions taken to correct Not applicable noncompliances [§205.401(c)]? 1.c.6. Have you notified the certifier(s) of any deviations from the Organic System Plan or other Yes No actions that may affect compliance with federal organic regulations [§205.400(f)(2)]? Not applicable 1.c.7. Are all your organic products and handling operations available for inspection by the Yes No Administrator,4 the applicable State Organic Program’s governing State official, or the Not applicable certifying agent [§205.670(a)]? Section 2: Practices & Procedures A description of practices and procedures to be performed and maintained, and the frequency with which they will be per- formed is required as part of your Organic System Plan [§205.201(a)(1)]. Subsection 2.a: General 2.a.1. If you process products for sale as organic, are you using only allowed methods? Yes No Processes allowed include mechanical or biological methods such as cooking, baking, Not applicable curing, heating, drying, mixing, grinding, churning, separating, distilling, extracting, slaughtering, cutting, fermenting, eviscerating, preserving, dehydrating, freezing, chilling, and the packaging, canning, jarring, or otherwise enclosing of a product in a container [§205.2 & §205.270(a)]. 2.a.2. If you process products for sale as organic and use nonorganic agricultural ingredients, are Yes No those items on the National List of nonorganically produced agricultural products allowed Not applicable as ingredients…5 [§205.270(b)]? 2.a.3. If you process products for sale as organic and use nonagricultural ingredients, Yes No are those items on the National List of nonagricultural substances allowed Not applicable as ingredients…6 [§205.270(b)]? After June 9, 2007, ingredients listed in Section §205.606 of the National List may only be used as ingredients if their organic equivalent is not commercially available. 2.a.4. Do you exclude the use of ionizing radiation in the production or on-farm processing of any Yes No ingredient or product you market as “100% organic,” “organic,” or “made with (specified Not applicable ingredients or food groups)” [§205.105(f)]? Subsection 2.b: Product Composition 2.b.1. Are you using the term “organic” correctly? Yes No The term “organic” may only be used on labels and in labeling of raw or processed Not applicable agricultural products, including ingredients, which have been produced and handled in accordance with the National Organic Standards 7 CFR Part 205. 2.b.2. Are you sure that you are not using the term “organic” in a product name to modify a Yes No nonorganic ingredient in the product [§205.300(a)]? Not applicable For example, you cannot call a product “Organic Cherry Ice Cream” if the cherries are nonorganic. 4 The administrator for the USDA’s Agricultural Marketing Service (AMS) or an authority that has been designated to act in his/her stead [§205.2]. 5 §205.606 Nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as “organic” or “made with organic [speci- fied ingredients or food groups(s)].” 6 §205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic [specified ingredients or food groups(s)].” Page 6 Organic Compliance Checklist for Handlers
  • 7. 2.b.3. If you are selling, labeling, or representing a product as “100 percent organic,” does the Yes No product contain (by weight or fluid volume) 100 percent certified organic ingredients Not applicable (excluding water and salt) [§205.301(a)]? Note that each ingredient must be 100% certified organic itself. 2.b.4. If you are selling, labeling, or representing a product as “100 percent organic,” and any Yes No processing aids7 were required, were the processing aids certified organic [§205.301(f)(4)]? Not applicable 2.b.5. If you are selling, labeling, or representing a product as “organic,” does the product contain Yes No (by weight or fluid volume) at least 95 percent organically produced ingredients (excluding Not applicable water and salt) [§205.301(b)]? 2.b.6. If you are selling, labeling, or representing a product as “organic,” are the non-organic Yes No agricultural ingredients on the National List under §205.6068, and have you documented Not applicable that they are not commercially available as organic [§205.301(b)]? “Commercially available” is defined as the ability to obtain a production input in an appropriate form, quality, or quantity to fulfill an essential function in a system of organic production or handling, as determined by the certifying agent in the course of reviewing the organic plan. 2.b.7. If you are selling, labeling, or representing a product as “made with organic (specified Yes No ingredients or food groups),” does the product contain (by weight or fluid volume) at least Not applicable 70 percent organically produced ingredients (excluding water and salt) [§205.301(c)]? 2.b.8. If you are selling, labeling, or representing a product as “made with organic (specified Yes No ingredients or food groups),” can you verify or document that all nonorganically produced Not applicable ingredients produced without use of sewage sludge, ionizing radiation, or genetically modified organisms [§205.301(c)]? 2.b.9. If you are selling, labeling, or representing a product as “organic,” and processing aids Yes No were used, were they either organically produced or on the National List under §205.605 Not applicable or §205.6069? 2.b.10. If you are selling, labeling, or representing a product as “organic,” can you verify or Yes No document that sulfites, nitrates, or nitrites are NOT added during the production or Not applicable handling process [§205.301(f)(5)]10? 2.b.11. If you are selling, labeling, or representing a product as “organic,” can you verify or document Yes No that the product is NOT produced using nonorganic ingredients when organic ingredients are Not applicable available [§205.301(f)(6)]? 2.b.12. If you are selling, labeling, or representing a product as “organic,” or “made with organic Yes No (specified ingredients or food groups),” can you verify or document that the product does Not applicable NOT contain organic and nonorganic forms of the same ingredient [§205.301(f)(7)]? 2.b.13. If you are selling, labeling, or representing a livestock feed product as “100 percent organic,” Yes No does that product contain (by weight or fluid volume, excluding water and salt) no less than Not applicable 100 percent organically produced raw or processed agricultural product [§205.301(e)(1)]? 7 §205.2 “Processing aids” are defined as 1) Substances that are added to a food during the processing of such food but are removed in some manner from the food before it is packaged in its finished form; 2) Substances that are added to a food during processing which are converted into constituents normally present in the food, and do not significantly increase the amount of the constituents naturally found in the food; 3) Substances that are added to a food for their technical or functional effect in the processing but are present in the finished food at insignificant levels and do not have any technical or functional effect on the food. 8 See footnote 5 on page 6. 9 See footnotes 5 and 6 on page 6. 10 Note: Wine containing added sulfites may only be labeled as “made with organic grapes.” Organic Compliance Checklist for Handlers Page 7
  • 8. 2.b.14. If you are selling, labeling, or representing a livestock feed product as “organic,” Yes No can you verify or document that: Not applicable all agricultural ingredients are certified organic [§205.237(a)]? any synthetic ingredients are on the National List under §205.603 [§205.237(a)]? no animal drugs or synthetic hormones are included [§205.237(b)(1)]? no plastic pellets are added [§205.237(b)(3)]? no manure or urea is added [§205.237(b)(4)]? no mammalian or poultry by-products are included [§205.237(b)(5)]? use of any feed, feed additives, or feed supplements does NOT violate the Federal Food, Drug, and Cosmetic Act [§205.237(b)(6)]? 2.b.15. For all of your products labeled “100% organic,” “organic,” “made with organic (specified Yes No ingredients or food groups),” or that include organic ingredients, do you calculate the Not applicable percentage of organic ingredients using the method required by the National Organic Standard11, which is: 1) Divide the total net weight (excluding water and salt) of combined organic ingredients at formulation by the total weight (excluding water and salt) of all ingredients [§205.302(a)(1)]. 2) Divide the fluid volume of all organic ingredients (excluding water and salt) by the fluid volume of all ingredients (excluding water and salt) if the product and ingredients are liquid. If the liquid product is identified on the principal display panel or information panel as being reconstituted from concentrates, the calculation should be made on the basis of single-strength concentrations of the ingredients [§205.302(a)(2)]. 3) For products containing organically produced ingredients in both solid and liquid form, divide the combined weight of the solid ingredients and the weight of the liquid ingredients (excluding water and salt) by the total weight (excluding water and salt) of all ingredients [§205.302(a)(3)]. 2.b.16. When calculating the percentage of organic ingredients, do you always round down to the Yes No nearest whole number [§205.302(b)]? Not applicable 2.b.17. Do you and/or another principal in your operation calculate the percentage of organic Yes No ingredients in your products, and are the same individuals responsible for that information Not applicable on the product labels [§205.302(c)]? 2.b.18. Does your certifier verify your label and calculation procedure?12 Yes No Not applicable Subsection 2.c: Labels and Labeling Subsection 2.c.a: Products Labeled as “100% Organic” and “Organic” 2.c.a.1. If you label packaged products “organic,” do you identify each organic ingredient in the Yes No ingredient statement with the word “organic” or with an asterisk or other reference mark Not applicable which is defined below the ingredient statement to indicate the ingredient is organically produced [§205.303(b)(1)]? Note: Water or salt included as ingredients cannot be identified as organic. 11 The method to calculate percentage of organic ingredients in the National Organic Standard Final Rule was incorrect. This has been corrected in the National Organic Program Audit Checklist, which can be found at: www.ams.usda.gov/nop/NOP/NOPEnglishAuditChecklistCOMEX.pdf The correct method is shown in this document. 12 Review of labels and verifying calculations of organic ingredients are included in the organic system plan, which must be approved by the certifying agent prior to scheduling inspections. Page 8 Organic Compliance Checklist for Handlers
  • 9. 2.c.a.2. If you label packaged products “100 percent organic” or “organic,” do you include on Yes No the information panel, below the information identifying the handler or distributor of Not applicable the product and preceded by the statement “Certified organic by…” (or similar phrase), the name of the certifying agent that certified the handler of the finished product [§205.303(b)(2)]13? 2.c.a.3. If you label packaged products “organic” and display the percentage of organic ingredients Yes No in the product, is the size of the percentage statement less than or equal to one-half the size Not applicable of the largest type size on the panel on which the statement is displayed and does the percentage statement appear in its entirety in the same type size, style, and color without highlighting [§205.303(b)(2)]? 2.c.a.4. If you label packaged products “100 percent organic” or “organic,” and display the seal, logo, Yes No or other identifying mark of the certifying agent(s)* can you document that the handler producing Not applicable the finished product maintains records verifying that the operations producing the ingredients are certified [§205.303(a)(5)]? *Refers to the certifying agent that certified either the production of the finished product, or the raw products or ingredients that were used in the finished product. 2.c.a.5. If you label packaged products “100 percent organic” or “organic,” and display the seal, logo, Yes No or other identifying mark of the certifying agent(s)*, do you ensure that such seals or marks are Not applicable NOT individually displayed more prominently than the USDA seal [§205.303(a)(5)]? *Refers to the certifying agent that certified either the production of the finished product, or the raw products or ingredients that were used in the finished product. 2.c.a.6. If you label livestock feed products as “100 percent organic” or “organic,” does the Yes No information panel below the identification of the handler or distributor of the product and Not applicable preceded by the statement “Certified organic by...” or similar phrase, display the name of the certifying agent that certified the handler of the finished product [§205.306(b)(1)]?14 2.c.a.7. If you label livestock feed products as “100 percent organic” or “organic,” does the label Yes No comply with other Federal agency or State feed labeling requirements, as applicable Not applicable [§205.306(b)(2)]? 2.c.a.8. If you label livestock feed products as “100 percent organic” or “organic,” and display on Yes No any package panel the seal, logo, or other identifying market of the certifying agent that Not applicable certified the production or handling operation producing the raw or processed organic ingredients used in the finished product, do you ensure that such seals or marks are NOT displayed more prominently than the USDA seal [§205.306(a)(3)]? Subsection 2.c.b: Products Labeled as “Made With Organic (Specified Ingredients Or Food Group(s))” 2.c.b.1. If you label packaged products “made with organic (specified ingredients or food Yes No group(s))”, do you identify each organic ingredient in the ingredient statement with Not applicable the word “organic” or with an asterisk or other reference mark which is defined below the ingredient statement to indicate the ingredient is organically produced [§205.304(b)(1)]? Note: Water or salt included as ingredients cannot be identified as organic. 13 You may also display the business address, Internet address, or telephone number of the certifying agent on the information panel below the information identify- ing the handler or distributor of the product. 14 The business address, Internet address, or telephone number of the certifying agent may be included on the label. Organic Compliance Checklist for Handlers Page 9
  • 10. 2.c.b.2. If you label packaged products “made with organic (specified ingredients or food Yes No group(s)),” do you, on the information panel below the information identifying the handler Not applicable or distributor of the product and preceded by the statement “Certified organic by…” (or similar phrase), identify the name of the certifying agent that certified the handler of the finished product [§205.304(b)(2)]?15 2.c.b.3. If you label packaged products “made with organic (specified ingredients or food group(s)),” Yes No do you ensure that the USDA seal does NOT appear on the package [§205.304(c)]? Not applicable 2.c.b.4. If you label packaged products “made with organic (specified ingredients),” and use the Yes No statement “made with organic (specified ingredients)” on the label*, do you ensure that the Not applicable statement does NOT list more than three organically produced ingredients or more than three of the following food groups: fruits, grains, herbs, meats, nuts, oils, poultry, seeds, spices, sweeteners, and vegetables or processed milk products [§205.304(a)(1)(i)] and [§205.304(a)(1)(ii)]? *”Label,” in this instance, includes the principal display panel, information panel, and any other panel of the package and on any other labeling or market information concerning the product. 2.c.b.5. If you use the statement “made with organic (specified ingredients)” or “made with organic Yes No (specified food groups),” do you ensure that it appears in letters that do NOT exceed one-half Not applicable of the size of the largest type size on the panel and appears in its entirety in the same type size, style, and color without highlighting [§205.304(a)(1)(iii)]? 2.c.b.6. If you label packaged products “made with organic (specified ingredients or food group(s)),” Yes No and display the percentage of organic ingredients in the product, is the size of the percentage Not applicable statement less than or equal to one-half the size of the largest type size on the panel on which the statement is displayed and does the percentage statement appear in its entirety in the same type size, style, and color without highlighting [§205.304(a)(2)]?16 Subsection 2.c.c: Products Containing Less Than 70% Organically Produced Ingredients 2.c.c.1. If you label packaged products with LESS than 70 percent organically produced ingredients, Yes No does your label ONLY identify the organic content of the product by identifying each organically Not applicable produced ingredient in the ingredient statement with the word “organic,” or with an asterisk or other reference mark (defined below the ingredient statement) to indicate the ingredient is organically produced [§205.305(a)(1)]? 2.c.c.2. If you label packaged products with LESS than 70 percent organically produced ingredients, Yes No and you display the percentage of organic contents on the information panel, are the organically Not applicable produced ingredients identified in the ingredient statement [§205.305(a)(2)]? 2.c.c.3. If you label packaged products with LESS than 70 percent organically produced ingredients, Yes No do you refrain from displaying the USDA seal [§205.305(b)(1)]? Not applicable 2.c.c.4 If you label packaged products with LESS than 70 percent organically produced ingredients, Yes No do you refrain from displaying any certifying agent seal, logo, or other identifying mark which Not applicable represents organic certification of a product or product ingredients [§205.305(b)(2)]? 15 You may also display the business address, Internet address, or telephone number of the certifying agent on the information panel below the information identify- ing the handler or distributor of the product. 16 You may also display on the principal display panel, information panel, and any other panel of the package and on any labeling or market information concerning the product, the seal, logo, or other identifying mark of the certifying agent that certified the handler of the finished product [§205.304(a)(3)]. Page 10 Organic Compliance Checklist for Handlers
  • 11. Subsection 2.c.d: Organic Products Sold in Bulk You should know… If you label non-retail containers used only for shipping or storage of raw or processed agricultural products labeled as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s)), you may display the following terms or marks on the container: 1) The name and contact information of the certifying agent which certified the handler which assembled the final product [§205.307(a)(1)] 2) Identification of the product as organic[§205.307(a)(2)] 3) Special handling instructions needed to maintain the organic integrity of the product[§205.307(a)(3)] 4) The USDA seal[§205.307(a)(4)] (Note: For “100% organic” and “organic” products only) 5) The seal, logo, or other identifying mark of the certifying agent that certified the organic production or handling operation that produced or handled the finished product [§205.307(a)(5)] 2.c.d.1. If you label non-retail containers used only for shipping or storage of raw or processed Yes No agricultural products as “100 percent organic,” “organic,” or “made with organic Not applicable (specified ingredients or food group(s)),” do the containers display the production lot number of the product [§205.307(b)]? 2.c.d.2. If you label shipping containers of domestically produced product labeled as organic intended Yes No for export to international markets, and label these containers in accordance with shipping Not applicable container labeling requirements of the foreign country of destination or the container labeling specifications of a foreign contract buyer, are the shipping containers and shipping documents accompanying such organic products clearly marked “For Export Only” [§205.307(c)]? 2.c.d.3. If you are an exempt or excluded operation, and label shipping containers as organic for Yes No export, do you maintain proof of such container marking and export as part of your Not applicable records [§205.307(c)]? 2.c.d.4. If you sell, label, or represent agricultural products as “100 percent organic” or “organic” Yes No in other than packaged form at the point of retail sale (bulk sales), do you follow labeling Not applicable requirements [§205.308]? You should know… You may use the term “100 percent organic” or “Organic” to modify the name of the product in retail display, label- ing, and display containers provided that the term “organic” is used to identify the organic ingredients listed in the ingre- dient statement [§205.308(a)]. If the product is prepared in a certified facility, the retail display, labeling, and display con- tainers may use the USDA seal [§205.308(b)(1)] and the seal, logo, or other identifying mark of the certifying agent(s)*, provided that such seals or marks are NOT individually displayed more prominently than the USDA seal [§205.308(b)(2)]. *Refers to the certifying agent that certified either the production of the finished product, or the raw products or ingredients that were used in the finished product. 2.c.d.5. If you handle agricultural products in bulk containing between 70 and 95 percent organically Yes No produced ingredients and label them “made with organic [specified ingredients or food Not applicable groups(s)], does your label statement list no more than three organic ingredients or food groups [§205.309(a)(1)]? 2.c.d.6. If you handle agricultural products in bulk containing between 70 and 95 percent organically Yes No produced ingredients and label them “made with organic [specified ingredients or food Not applicable groups(s)],” does the label indicate all organically produced ingredients as “organic” [§205.309(a)(2)]? Organic Compliance Checklist for Handlers Page 11
  • 12. You should know… If a bulk product containing between 70 and 95 percent organic ingredients is prepared in a certified facility, and is labeled “made with organic [specified ingredients or food groups(s)]” in retail displays, display containers, and market information, it may feature the certifying agent’s seal, logo, or other identifying mark [§205.309(b)]. Subsection 2.c.e: Sale of Products Produced On An Exempt Or Excluded Operation 2.c.e.1. If you sell agricultural products produced on an exempt or excluded operation, do you Yes No refrain from displaying the USDA seal or any certifying agent’s seal or other identifying Not applicable mark which represents the exempt or excluded operation as a certified organic operation [§205.310(a)(1)]? 2.c.e.2. If you sell agricultural products produced on an exempt or excluded operation, do you Yes No ensure that the product is NOT represented as a certified organic product or certified Not applicable organic ingredient [§205.310(a)(2)]? You should know… An agricultural product organically produced or handled on an exempt or excluded operation may be identified as an organic product or organic ingredient in a multiingredient product produced by the exempt or excluded operation. Such product or ingredient must NOT be identified or represented as “organic” in a product processed by others [§205.310(b)]. 2.c.e.3. If you are selling agricultural products produced on an exempt or excluded operation, can Yes No you verify and/or document that the product: Not applicable is labeled correctly. The term “organic” may NOT be used in a product name to modify a non-organic ingredient [§205.300(a)]. has NOT been produced using excluded methods17 [§205.301(f)(1)] has NOT been produced using sewage sludge [§205.301(f)(2)] has NOT been produced using ionizing radiation [§205.301(f)(3)] has NOT been processed using processing aids that were NOT organically produced or are NOT on the National List [§205.301(f)(4)] does NOT contain added sulfites, nitrates, or nitrites [§205.301(f)(5)] has NOT been produced using nonorganic ingredients when organic ingredients were available [§205.301(f)(6)] does NOT include organic and non-organic forms of the same ingredient [§205.301(f)(7)] is NOT used as an organic ingredient by anyone who is not either an exempt or excluded handler [§205.310(b)] You should know… The USDA seal may only be used on products that are labeled “100% organic” or “organic” as per §205.301(a); §205.301(b); §205.301(e)(1); §205.301(e)(2). The USDA seal must replicate the form and design of the example in figure 1 and must be printed legibly and conspicuously 1) On a white background with a brown outer circle and with the term “USDA” in green over- laying a white upper semicircle with the term “organic” in white overlaying the green lower half circle [§205.311(b)(1)]; or 2) On a white or transparent background with black outer circle and black “USDA” on a white or transparent upper half of the circle with a contrasting white or transparent “organic” on the black lower half circle [§205.311(b)(2)]. 3) The green or black lower half circle may have four light lines running from left to right and dis- appearing at the point on the right horizon to resemble a cultivated field [§205.311(b)(3)]. Excluded methods are defined as a variety of methods used to genetically modify organisms or influence their growth and development by means that are not pos- 17 sible under natural conditions or processes and are not considered compatible with organic production. Such methods include cell fusion, microencapsulation and macroencapsulation, and recombinant DNA technology [§205.2]. Page 12 Organic Compliance Checklist for Handlers
  • 13. Subsection 2.d: Facility Pest Management You should know… Preventative practices, such as removal of pest habitat, food sources, and breeding areas, prevention of access to handling facilities, and management of environmental factors such as temperature, light, humidity, atmosphere, and air circulation to prevent pest reproduction are required [§205.271(a)(1)(2)(3)]. If these preventative practices fail to control pests, handlers may manage them using 1) Mechanical or physical controls such as traps, light or sound [§205.271(b)(1)] 2) Lures and repellents using nonsynthetic or synthetic substances consistent with the National List [§205.271(b)(2)] If these alternatives are also insufficient, a nonsynthetic or synthetic substance consistent with the National List may be used [§205.271(c)]. 2.d.1. If you need to apply a synthetic substance not on the National List in order to achieve Yes No adequate pest control, do you confer with your certifying agent to agree on the substance Not applicable to be used, method of application, and measures to be taken to prevent contact of the organically produced products or ingredients with the substance used [§205.271(d)]? 2.d.2. If you need to apply any nonsynthetic or synthetic substance(s) to control pests, do you Yes No update your organic handling plan to reflect the use of such substances and methods of Not applicable application and does the updated organic plan include a list of all measures taken to prevent contact of the organically produced products or ingredients and packaging with the substance used [§205.271(e)]? A handler may use substances to prevent or control pests as required by Federal, State, or local laws and regulations, provided that measures are taken to prevent contact of the organically produced products or ingredients with the substance used [§205.271(f)]. Section 3: Inputs A list of each substance to be used as a production or handling input—including its composition, source, location(s) where it will be used—and documentation of commercial availability must be provided as part of your Organic System Plan [§205.201(a)(2)]. Allowed substances also include certain nonsynthetic nonagricultural materials as specifically listed in §205.605(a) and certain synthetic materials as specifically listed in §205.605(b). If the substance is synthetic, it must be on the National List to be used. A comprehensive listing of allowed and prohibited materials is not provided here. As a handler/processor, you should read the appropriate sections of the National List (§205.605 and §205.606) and confer with your certifier when in doubt. Note that many products and materials represented as “natural” or “organically acceptable” might not be allowed under the National Standard. Always check with your certifier before using any new or questionable material. Subsection 3.a: Food Ingredients 3.a.1. If you process products for sale as organic and must use nonorganic agricultural ingredients, Yes No are those items listed on the National List of nonorganically produced agricultural products Not applicable allowed as ingredients in §205.60618 [§205.270(b)]? 3.a.2. If you process products for sale as organic and must use nonagricultural ingredients, are Yes No those items listed on the National List of nonagricultural substances allowed as ingredients Not applicable in §205.60519 [§205.270(b)]? 18 See footnotes on page 6 for more information on the National List. 19 See footnotes on page 6 for more information on the National List. Organic Compliance Checklist for Handlers Page 13
  • 14. Subsection 3.b: Processing Aids 3.b.1. If you process products for sale as organic and must use processing aids, are the constituents Yes No of the processing aids either certified organic, listed on the National List of nonorganically Not applicable produced agricultural products in §205.606, or listed as nonagricultural ingredients allowed as processing aids in §205.605 [§205.270(b)]? Subsection 3.c: Sanitizers 3.c.1. If you process products for sale as organic and use cleaning/sanitizing products, are the Yes No constituents of the cleaning/sanitizing products certified organic, or listed on the National Not applicable List of nonorganically produced agricultural substances in §205.606 or nonagricultural ingredients in §205.605 [§205.270(b)]? Subsection 3.d: Facility Pest Management 3.d.1. If you were obliged to use a synthetic pest control material for managing pests in or around Yes No buildings or facilities, was it because management strategies and allowed materials were Not applicable inadequate [§205.271(d)]?20 The handler and the certifying agent must agree on the substance to be used, method of application, and measures to be taken to prevent contact of the organically produced products or ingredients with the substance used. The organic handling plan must be updated to reflect the use of the substance and the methods of application [§205.271(d)]. 3.d.2. If you were obliged to use a synthetic pest control material for managing pests in or Yes No around buildings or facilities, were stringent measures taken to prevent contact of Not applicable organically produced products or ingredients and packaging with the substance used [§205.271(d) and §205.272(b)(1)]? 3.d.3. If you were obliged to use a synthetic pest control material for managing pests in or Yes No around buildings or facilities, did you update the your operation’s Organic System Not applicable Plan to reflect the use of such substances and methods of application, plus all measures taken to prevent contact with the organically produced products or ingredients and packaging [§205.271(e) and §205.272(b)(1)]? Section 4: Monitoring Practices & Procedures A description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed, to verify that the plan is effectively implemented is required in your Organic System Plan [§205.201(a)(3)]. 4.1. Do you monitor pests in storage and other facilities to guide your management Yes No decisions [§205.271(c)]? Not applicable Biological and botanical pest control substances, and pest control agents included on the National List may be used only when environmental management, sanitation, barriers, and mechanical controls are insufficient to keep a pest problem in check [§205.271(c)]. Some form of monitoring must be used to trigger and justify the use of these materials. The conditions for using such materials must be described in the Organic System Plan [§205.271(e)]. 4.2. Do you describe your monitoring procedures and conditions for using pest control methods Yes No in your Organic System Plan [§205.271(e)]? Not applicable You are allowed to use otherwise prohibited pest control materials for facility pest management if so-required by Federal, State, or local laws and regulations. 20 However, measures must be taken to prevent the contamination of organic products and ingredients [§205.271(f)]. Page 14 Organic Compliance Checklist for Handlers
  • 15. 4.3. Do you describe your monitoring procedures for cleaning and purging machinery and Yes No equipment to prevent commingling and contamination in your Organic System Plan Not applicable [§205.272(a)]? Section 5: Recordkeeping A description of your recordkeeping system must be provided in your Organic System Plan [§205.201(a)(4)]. 5.1. Do you maintain a complete set of operation records covering handling of all agricultural Yes No products that you intend to be sold, labeled, or represented as organic [§205.103(a)]? Not applicable 5.2. Is your recordkeeping system appropriate and well-adapted to the needs of your organic Yes No operation [§205.103(b)(1)]? Not applicable 5.3. Does your recordkeeping system fully disclose all activities and transactions, such as Yes No ingredient purchases and product sales, in sufficient detail so as to be readily Not applicable understood and audited [§205.103(b)(2)]? 5.4. Do you retain or are you preparing to retain all records applicable to your organic Yes No operation for at least 5 years [§205.400(d) & §205.103(b)(3)]? Not applicable 5.5. Is your recordkeeping system sufficient to demonstrate compliance with organic Yes No regulations and the Organic Foods Production Act [§205.103(b)(4)]? Not applicable 5.6. Are your records available for inspection and copying during normal business hours Yes No by authorized representatives of the Secretary,21 the State Organic Program, and/or Not applicable the certifying agent [§205.103(c)]? Section 6: Commingling and Contamination A description of your management practices and the physical barriers you’ve established to prevent commingling of organic and nonorganic products on a split operation and to prevent contact of organic production operations and products with prohibited substances must be provided in your Organic System Plan [§205.201(a)(5)]. 6.1. During handling and storage, do you take adequate measures to prevent contact of organic Yes No crops, livestock, and products with prohibited substances [§205.272(a)]? Not applicable 6.2. Are all your packaging materials, bins, and storage containers free of synthetic fungicides, Yes No preservatives, and/or fumigants [§205.272(b)(1)]? Not applicable 6.3. If you re-use any bags or containers, do you take measures to ensure that there is no risk Yes No of commingling with nonorganic products or of contamination with a prohibited substance Not applicable [§205.272(b)(2)]? Section 7: Additional Information Required Additional information deemed necessary by the certifying agent to evaluate compliance with the regulations must be provided in your Organic System Plan [§205.201(a)(6)]. 7.1. If you have been or were required to cooperate with additional testing or provide further Yes No information about any inputs to your organic operation by the Administrator,22 your State Not applicable Organic Program, or your certifier, have you done so [§205.670(b)]?23 21 The Secretary of Agriculture or his/her delegate [§205.2]. 22 The administrator for the USDA’s Agricultural Marketing Service (AMS) or an authority that has been designated to act in his/her stead [§205.2]. 23 Additional testing may be required when there is reason to believe that the agricultural input contains an unacceptable level of prohibited substances or has been produced using excluded methods. Such tests must be conducted by the applicable State Organic Program’s governing State official or the certifying agent at the official’s or certifying agent’s own expense [§205.670(b)]. Organic Compliance Checklist for Handlers Page 15
  • 16. 7.2. If you were required to cooperate with additional testing or provide further information Yes No about any of your organic products by the Administrator,24 your State Organic Program, Not applicable or your certifier, have you done so [§205.670(b)]?25 7.3 Are you prepared to immediately notify your certifier concerning application of a prohibited Yes No substance or change in the operation that may affect compliance with the National Organic Not applicable Standards [§205.400(f)]? 7.4 Have you submitted applicable fees to your certifier [§205.400(e)]? Yes No Not applicable The administrator for the USDA’s Agricultural Marketing Service (AMS) or an authority that has been designated to act in his/her stead [§205.2]. 24 Additional testing may be required when there is reason to believe that the product has come into contact with a prohibited substance or has been produced using 25 excluded methods. Such tests must be conducted by the applicable State Organic Program’s governing State official or the certifying agent at the official’s or certi- fying agent’s own expense [§205.670(b)]. Page 16 Organic Compliance Checklist for Handlers
  • 17. Notes Organic Compliance Checklist for Handlers Page 17
  • 18. Notes Page 18 Organic Compliance Checklist for Handlers
  • 19. Feedback Please detach, complete, and return to the address shown below. 1) Did you find the Checklist helpful? Yes No 2) How might the Checklist be changed to be more useful to you? 3) Did you read any information in the Checklist that you believe is incorrect? Yes No If “Yes,” please indicate where you found the error. 4) I am a: producer certifier inspector educator/information provider other Please describe Thank you for your valuable feedback. Fold and mail this form to: Holly Born NCAT/ATTRA 53020 Hitchcock Avenue Lewis, IA 51544 Organic Compliance Checklist for Handlers Page 19
  • 20. National Organic Program Compliance Checklist for Handlers By Holly Born NCAT Agriculture Specialist ©2006 NCAT Paul Driscoll, Editor Cynthia Arnold, Production This publication is available on the Web at: www.attra.ncat.org/attra-pub/organic_handlers.html and www.attra.ncat.org/attra-pub/PDF/organic_handlers.pdf IP301 Slot 296 Version 122906 Page 20