Preventing Chemical Contamination in Organic Facilities
By Rick Martinez, CEO, Organic Education Solutions LLC
Pest control in the food manufacturing environment has always been a challenging task and in organic facilities. It is one of the most common organic compliance failure areas in organic certification. Controlling pest pressure -- while keeping pesticides from contaminating food -- is a constant balancing act for managers. The added requirements of organic regulations make things even more challenging for employees and pest control operators.
This year, the USDA National Organic Program (NOP) deputy administrator announced the "age of enforcement," signaling the government's plans to increase scrutiny of the organic industry. The NOP 7CFR Part 205 has very specific guidelines with a four-level hierarchy for pest control. Most certification agencies have further interpreted these into a strict set of rules for pest control within the organic manufacturing facility.
The four-level system in the NOP prohibits the use of most pesticides, prior to meeting certain criteria. The first requirement is that the facility must use non-chemical approaches, which emphasize integrated pest management and physical control measures Ð from rodent stations, insect lights, strips, to sealing cracks and gaps, controlling temperature and humidity. And of course, regular maintenance and sanitation programs to prevent the build up of food sources and harborage sites -- inside and out.
With organic facilities, if non-chemical measures used in the previous level are ineffective, then approved materials can be used. However, steps must be taken to insure that any pesticide applications are not a threat to the "organic integrity" of the organic products. This includes provisions to insure that organic ingredients, machinery and product packaging are protected, as well as finished product.
This is key for facilities that have been making conventional products and are adding organic products. Mixed program facilities must shift from traditionally oriented pesticide treatment programs to one that more closely matches the requirements and structural approaches outlined in the NOP.
Personnel at all levels make mistakes if they lack familiarity with the specific organic pest control regulations, and the related Standard Operating Procedures are not clearly defined. As such, employee training is necessary for successfully managing all of these variables.
First, all employees need to know what's acceptable and authorized during organic production. For in-house pest control programs, companies must develop training that is appropriate to the specific role and responsibility. Staff members need a good working knowledge of how the organic regulations affect the practical aspects of your facilities program, and necessary SOP's to meet the program requirements. And from the organic inspector's perspective, like everything else in food processing, if the programs are not documented, it did not happen.
For contracted PCO's, it pays to take a proactive approach. Most PCO's companies who contract to organic facilities will know the organic regulations. But as with any program or organization, there can be wide variations in understanding, interpretation and implementation among personnel. As such, it's useful to have an orientation program to assure that new PCOs understand your program. For the contractors who are routinely in your plant, it is necessary to provide a written update on all major production and facility changes, and review programs together.
Last but not least, routine management of contract Pest Control Operators is also part of the equation. Effective companies appoint a supervisor or manager, who has been trained on their company's organic SOPs and a good working knowledge of the chemical rules. This person is assigned to supervise, review and sign off on the PCO's service visits.
The foundation of a successful PC program is effective education, communication and cooperation among production personnel, in-house staff and your external pest-control management company. Training your key employees in becoming familiar with the respective requirements and how they relate to your pest control and organic manufacturing program will ensure your facility is compliant.
Organic Education Solutions LLC provides training to processors, distributors and retailers and has just developed "Keep It Organic: Best Practices for Production Personnel" the first employee training DVD for organic facilities. Sponsored by Silliker, this innovative DVD provides employees with critical training to help companies comply with organic regulations in the US and Canada. Employing colorful narrated multi-media presentations with video clips, graphics, and photographs, the bilingual programs (English and Spanish) help new and experienced employees understand the importance of proper handling of organic ingredients and products. Employees are introduced to key organic terms and regulations, and receive a succinct overview of organic best practices throughout the facility.
Understanding the X's and O's of Employee Training
Companies with successful food safety records understand highly motivated and knowledgeable employees play an integral role in preventing food borne illness and product recalls. Building a results-oriented program takes commitment and a long-term game plan, which acknowledges the mercurial nature of food safety.
Silliker understands the intricate "X's" and "O's" of effective employee training programs, and we offer a dynamic range of programs to help you meet your food safety management objectives. Our newly updated "Fall-Winter 2010 Food Safety Education and Training Catalog" provides a comprehensive overview of our programs, including:
Public Short Courses: Silliker short courses are offered throughout the year in the Chicago land area. Our offerings, taught by recognized food safety professionals, range from food sanitation to HACCP. Featured inside the catalog is a complete rundown of our upcoming "Implementing SQF 2000" and "BRC Global Standard for Food Safety Issue 5" short courses.
DVD and Multimedia Training: We feature an extensive library of professionally produced training programs, including the newly released "Keep It Organic: Best Practices for Production Personnel" DVD. This innovative program, produced by Organic Education Solutions and sponsored by Silliker, provides employees with critical training to help companies comply with organic regulations in the U.S. and Canada.
Customized on-site training: Our training specialists have designed customized programs for leading companies throughout North America, and we can tailor a program, in English and Spanish, for you. As part of our offerings, we can help your in-house instructors refine and improve their teaching skills through our "Food Safety Trainer" program.
SISTEMª Training Platform: Employing simple remote controls, this state-of-the-art automated system allows multiple students to be trained at the same time. Industry specific courses include: food allergens, GMPs, HACCP, plant sanitation, and workplace safety.
Using the most up-to-date scientific information and interactive learning techniques, we'll provide you with the tools and knowledge to address your most important safety challenges. To order a FREE copy of our catalog in a PDF format, please indicate your interest on the reader's response card.
Register for one of our public short courses by December 10, 2010 and receive a 10% discount. Please use the code EDUCAT1110 to receive your special savings.
Beginning Laboratory Methods in Food Microbiology
3/22/11 - 3/23/11 (Chicago, IL)
8/9/11 - 8/10/11 (Chicago, IL)
This two-day course teaches new lab technicians the basics of lab safety and how to use common laboratory tools and testing equipment, and proper techniques for conducting microbiological tests.
Advanced HACCP: Managing Your HACCP System
5/24/11 - 5/25/11 (Chicago, IL)
Our advanced course, the first advanced course in the U.S. to be accredited by the International HACCP Alliance, teaches you how to manage and improve your overall HACCP systems.
Microbiological Concerns in Food Plant Sanitation and Hygiene
3/22/11 - 3/24/11 (Chicago, IL)
5/17/11 - 5/19/11 (Chicago, IL)
Implementing and maintaining effective sanitation and environmental monitoring programs provide critical and timely data about your processes.
Practical HACCP for Food Processors
4/19/11 - 4/21/11 (Chicago, IL)
8/30/11 - 9/1/11 (Chicago, IL)
Accredited by the International HACCP Alliance, our two and one-half day course teaches food professionals how to develop, implement and manage the HACCP plan.
Pest control in the food manufacturing environment has always been a challenging task and in organic facilities. It is one of the most common organic compliance failure areas in organic certification. Controlling pest pressure -- while keeping pesticides from contaminating food -- is a constant balancing act for managers. The added requirements of organic regulations make things even more challenging for employees and pest control operators.
Companies with successful food safety records understand highly motivated and knowledgeable employees play an integral role in preventing food borne illness and product recalls. Building a results-oriented program takes commitment and a long-term game plan, which acknowledges the mercurial nature of food safety.