My slaughter house is considering getting organic certification. What issues should they be concerned about?
First, thoroughly read Sections 205.270 through 205.311 and Sections 205.605 and 205.606 of the National Organic Program (NOP) Final Rule. These sections detail processing and handling requirements for organic certification.
In general, commingling of organic products with non-organic products and contamination with prohibited substances are two of the biggest issues for all processing facilities.
In order to prevent commingling, slaughter facilities will: 1) isolate incoming animals in a separate pen (labeled "Organic Animals"); 2) slaughter organic animals first to ensure that equipment is free of remnants from processing conventional animals; 3) identify carcasses as "Organic"; and 4) keep records, tracked by ear tag numbers of incoming animals, of all organic slaughter activities. When carcasses are ready to be cut up or further processed, these activities are typically done first before other meat is cut, when equipment, knives and other tools are clean, and non-organic meat is not present.
To avoid contamination with prohibited substances, be sure that pest control products are used only on the outside of the facility, but not in the vicinity of the pens holding organic animals. Organic products, ingredients, and packaging materials used for organic products must not come into contact with pesticides. Develop a plan to move organic products and packaging materials in the event that the application of pesticides occurs in the facility. If a structural pest management plan is not already in place, the slaughter facility needs to develop a plan to prevent pest problems, compliant with 205.271. Records must be kept of all pesticide applications and measures must be taken to protect organic products from exposure.
Records are also needed to document the cleaning of equipment prior to organic meat processing. USDA-inspected slaughter facilities are required to have HAACP (Hazard Analysis Critical Control Points) plans in place. Use this plan as a starting point to help the slaughterhouse develop its own written "Organic Handling Plan."
Labeling organic products is also an issue. Design a label that meets both USDA’s Food Safety Inspection Service and NOP requirements. The label needs to be pre-approved by FSIS and your organic certifier. If you make sausage, hot dogs, jerky, or other multi-ingredient organic products, all ingredients and processing aids need to meet NOP requirements. Available label claims will depend on whether the products are 100% organic, contain at least 95% organic ingredients, or contain between 70-95% organic ingredients.