It took 12 years–from 1990 to 2002–to pass comprehensive legislation establishing rules for organic labeling, certification, production and handling. The first five years of the National Organic Program (NOP) have witnessed court cases and a monumental shift in consumer preferences that have thrust this once small, niche category into the spotlight, and into Wal-Mart Stores Inc.

The mega-retailer’s entrance into organics turned a lot of heads, caused significant outcry and ushered in a new era of organic marketing, production and distribution.

In fact, recent organic headlines have focused on Wal-Mart’s involvement in the category and how it markets organic products.

The United States Department of Agriculture’s Agricultural Marketing Service (AMS) conducted a
compliance review of the mega-retailer after receiving a complaint that Wal-Mart misled customers by labeling an entire section of the store as “Wal-Mart Organics” without ensuring that only certified organic products were stocked in this section.

The review found no violation of the NOP, however, Wal-Mart agreed to redesign its marketing methods and use the USDA organic seal as shelf information to direct customers to products that have been certified organic.

This case highlights how the relative infancy of the NOP and the movement of organics into the mainstream has generated controversy. Some consumers, associations and companies believe Wal-Mart and other large companies are hijacking the organic industry.

This belief soared to new heights last month when USDA announced that it was considering adding non-organically produced agriculture products that may be used as ingredients in or on processed products labeled as “organic.” Ingredients in the list (see sidebar for full list) included everything from the casings of processed intestines to fish oils to konjac flour.

As of press time, the USDA has not acted on the new list. However, this inaction and overall controversy surrounding organic production, marketing and certification should not slow bakers’ efforts to move into this exciting category.

Organic certification
“We have seen steady growth in certifying bakeries, and not only new companies, but also third-part manufacturers making new lines,” says David Abney, Quality Assurance International’s (QAI) vice president and general manager. “The growth in the baking industry is coming from both dedicated [organic only] and split [organic and traditional] operations.”    

QAI provides third party certification of organic food systems to bakeries and other food manufacturers. The role of a certifying agency is simple. They make sure bakeries are complying with the NOP’s regulations.

This does not include consulting, which is prohibited under the regulations. However, several consulting agencies offer guidance for bakeries seeking to convert to organic production. For bakeries inexperienced with organic production, it may be beneficial to hire a consultant before applying for certification.
When a bakery is ready to apply for certification, they must fill out an application, which includes an organic system plan. This desk audit consists of a significant exchange of information, including formulas, percentages and other proprietary information. As a result, a bakery should always sign a confidentiality agreement with its certification agency.

After a bakery’s organic system plan and application have been approved, the certifying agency conducts an on-site facility inspection. Abney says this inspection can take anywhere from four hours to an entire day, depending on the size of the plants and number of organic products being produced.
During the facility audit, it is important to remember that the inspector is only observing the plant’s operation, and cannot consult or make certification decisions. All decisions occur during the technical review of the audit, which takes place at the certification agency.

“The auditor provides observations, and the certification agency determines compliance or non-compliance,” Abney says. “After the technical review, we issue a certification or non-compliance letter.”
For bakers receiving organic certification, they can expect annual on-site inspections and potential unannounced inspections. If a bakery receives a non-compliance letter, it has the opportunity to answer the compliance issues and obtain certification. QAI estimates the entire process takes about eight to 10 weeks.

Certification obstacles

Relaxing organic rules Proposed regulations from the United States Department of Agriculture seek to ease organic production by allowing certain non-organically produced agricultural products to be used as ingredients in foods labeled “organic.” As of press time, the USDA had not made an official ruling on the list of ingredients, which appears below. • Casings, from processed intestines • Celery powder • Chia (Salvia hispanica) • Colors derived from annatto extract (water and          oil  soluble), beet juice, beta-carotene derived          from carrots, black currant, black/purple carrot   juice, blueberry juice, carrot juice, cherry juice,   chokeberry-aronia juice, elderberry juice, grape   juice, grape skin extract, paprika, pumpkin juice,   purple potato juice, red cabbage extract, red rad   ish, saffron, turmeric • Dillweed oil • Fish oil–stabilized with organic ingredients or   only with ingredients on the National List • Fructooligosaccharides • Galangal, frozen • Gelatin • Gums, water extracted (arabic, guar, locust bean,   and carob bean) • Hops • Insulin–oligofructose enriched • Kelp, for use only as a thickener and dietary   supplement • Konjac flour • Lecithin, unbleached • Lemongrass, frozen • Orange shellac, unbleached • Pectin (high-methoxy) • Peppers (Chipotle chile) • Starches, including cornstarch (native),   unmodified rice starch, sweet potato starch for        bean thread production • Turkish bay leaves • Wakame seaweed (Undaria pinnatifada) • Whey protein concentrate

The three major obstacles to organic certification for bakeries, Abney says, are sanitation, pest control and documentation. Sanitation is especially difficult for bakers.

“There are contamination issues that are not a problem in traditional manufacturing, but are a problem in organic manufacturing,” Abney states. “Bakers are used to washing down equipment and leaving 100 parts per million residue on equipment, but that doesn’t work in organic production.”

In addition to sanitation, bakers also must review their pest control procedures and change them accordingly to comply with the regulation. Pest control may be managed, according to the regulation, through physical or mechanical means, such as nonsynthetic lures, traps and repellents.

Another common obstacle to organic certification is documentation. “There needs to be complete traceability, and there is a difference from saying you trace your ingredients to actually being audited,” Abney states.

To run a successful organic line or bakery, documentation is a must. Practices, procedures and ingredient lists must be maintained and followed religiously. With a comprehensive organic systems plan and the determination to follow it to the letter of the law, almost any high-volume bakery can achieve certification and produce organic bakery foods. Obstacles exist, but they can be overcome with the proper guidance and a good plan.