An Organic System Plan (OSP) is a written document that describes how your retail operation will meet the requirements of the National Organic Program. Developing an Organic System Plan at your operation is highly recommended and a great way to protect organic integrity. Retail staff that handle organic products, should all be educated, trained, and involved in protecting and maintaining organic integrity. Having a plan in place supports the training that must be done to protect organic products and helps you organize your best practices. It can also help you educate customers and thus, sell more organic products.
Filing the plan in a ring binder is an easy way to document departmental information that can be copied and used by individual departments. Keep the Organic System Plan up-to-date with examples of protocols and record keeping forms used to document organic product handling in your operation. This Good Organic Retail Practices document can form the foundation of your Organic System Plan.
Identify how products move through each department, and define where areas of potential contamination and commingling exist. Walk through the department, visually looking for potential contamination and commingling risks. Organic Control Points are any points or procedures in an organic packaging or handling system where there is a high probability that improper control may cause or contribute to the loss of organic integrity. These are listed in each department section below and may be posted in department work areas as a reminder to staff. Store employees must be aware of the potential places in their departments where commingling and contamination could occur in order to be vigilant in preventing problems.
- Establish methods and procedures that prevent commingling or contamination. Organic standards accept zero tolerance for commingling with non-organic products or contamination by prohibited substances.
- Post written protocols that prevent contamination and commingling. These should be posted for all staff to read so all affected employees can easily review them.
- Take appropriate action. If organic products are commingled or come in contact with prohibited substances, those products may no longer be labeled as organic. Employees must be trained and empowered to notice when commingling or contamination occurs and to then segregate and relabel that product.
- Maintain records. Retail establishments are expected to maintain records demonstrating the purchasing and receiving of organic foods in their systems, and in addition, keeping records of sales of those products so that they can be verified against quantities received. Usually, this can be accomplished through storing invoices that list organic products as line items, as well as movement reports from POS systems. Many establishments will need to have three years of data accessible for use upon request.
Implement an effective record keeping system to document activities. Good record keeping will allow for transparency if organic claims are ever questioned as well as give the retailer the tools to self-monitor their systems. Sanitation logs help employees in prep areas use clean equipment and have clean surfaces before getting organic products out of the cooler or other storage areas and should be retained as part of organic handling records.
- Monitor the systems. Management should check that employees are following these protocols. The checklists in each department section were developed as the basis for this monitoring.
