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Organic, NonGMO, Natural, Labeling

Achieving Transparency in Organic and Natural Product Claims

By Lori Carlson
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Organic, NonGMO, Natural, Labeling

Consumer preference for organic and “all natural” foods remains on the rise, according to market trend research and retailer sales.1,2 The Organic Trade Association (OTA) recorded $40 billion in U.S. organic food sales for 2015, stating that sales have nearly doubled since 2008.3 Pair this with $21 billion in sales for Q1 2016 for non-GMO labeled foods and $1.6 billion in 2015 gluten-free sales and, it is hard to ignore this thriving market sector, which seeks to support consumers in their quest for fresh, healthy and transparently-labeled foods.4,5

As a result of these trends, the industry is experiencing a surge in natural food and beverage start-up companies as well as the acquisition of organic and natural product companies by manufacturing giants such as Campbell Soup Co., Danone and General Mills, Inc. But in complex—and especially global—supply chains, achieving transparency comes with hurdles for verifying product claims  such as “all-natural”, non-GMO, antibiotic-free, and other nutrient content or functional claims.

Organic and other natural food manufacturers are under increasing regulatory and consumer scrutiny for tracing claims back to the source for all ingredients. Failing to verify the authenticity or identity preservation (IP) status of materials, maintain chain of custody and ensure the accuracy of labels can have devastating consequences for a manufacturer, including regulatory action and consumer fraud class action law suits.6 It’s not just consumers demanding the “right to know” where food comes from, but manufacturers must also push this sentiment back through their supply chain to drive transparency for ensuring safety, brand protection and verifying product claims.

With the goal of meeting consumer demands for healthy food products, improved transparency in food production and clean labels, how can organic, non-GMO and natural food manufacturers stay ahead of the curve when it comes to ensuring that product claims provide the value consumers seek?

Consider the following tasks for achieving transparency in organic and natural product claims.

Analyze Your Ingredients for Risk

Get to know the pitfalls, which can affect the integrity of product claims. Many of these stem from cross contamination, authenticity or mislabeling issues for sourced materials. To prevent these pitfalls, analyze each ingredient for supply chain risks. Identifying potential risks, which may affect the integrity of claims creating liability for misbranding, is a critical step in achieving transparency.

For example, is there a potential for cross contamination from a non-organic source? This is a common risk where a supplier engages in the co-production of organic and non-organic materials. A lack of segregation and clear product identification during transportation, storage and processing activities can lead to commingling or cross-contamination, which affects material integrity and thus, any downstream product claims. Ensuring suppliers and the manufacturer have clear measures in place for segregation is an important consideration when determining risk.

Or, consider adulteration from a non-authentic material, which can affect the integrity of the claim. Identifying vulnerabilities within the supply chain is necessary to reduce opportunities for perpetrating food fraud. Materials such as organic products and some natural ingredients are at greater risk for fraud where limited availability is an issue and/or the material is a high-value commodity or product. Mislabeling, counterfeit production or economically motivated adulteration, such as the substitution or dilution of ingredients in a sourced material, has a significant impact on downstream product claims.

Unverified packaging and labels are other sources of risk with the potential to affect the integrity of product claims. Ensure your supplier’s labeling practices include controls to verify the correct packaging and labels when producing IP materials or other ingredients with nutrient content or functional claims.

With a clear understanding of material risks, what attributes of an ingredient should be prioritized, tested and/or verified when considering the integrity of finished product claims?

Once material risks are analyzed, establish clear specifications for raw materials, which are agreed upon between the supplier and manufacturer. This serves as the basis for verifying material claims and subsequently, downstream product claims. Where specifications are in place, material verification may be performed through a variety methods including: testing, mass balance, COA review and audits. Verifying materials against agreed upon specifications not only supports due diligence in product claims but also brings manufacturers closer to their suppliers, steering us towards the next task.

Get to Know Your Suppliers

At the heart of food production transparency is the relationship a manufacturer has with its suppliers. Even the simplest of manufactured foods have a handful of ingredients, which are typically sourced through a global supply chain network. Due to the seasonality of produce or supply chain risks such as market fluctuations, business disruptions, natural disasters, or transportation failures; manufacturers can’t rely on a single supplier for the sourcing of a particular ingredient.

This leads to reliance on multiple suppliers, which may be geographically dispersed. Sourcing from multiple suppliers—especially when this occurs for multiple ingredients across multiple products—can create hurdles to relationship building for enhanced transparency due to time and resource constraints for acquiring first-hand knowledge of a supplier’s operation. Thus, proactive supply chain management, which enables a manufacturer to learn about the supplier’s history and operation, is essential for transparency.

This can be accomplished by establishing supplier approval criteria to provide a baseline for getting to know your supplier and establish minimum criteria for sourcing. Building upon this, is the use of approved suppliers to solidify the relationship and develop out a stable supply chain network. And finally, it is best practice to visit the supplier’s site to learn more about operational practices and the people responsible for ensuring material specifications and identity status are consistently achieved.

Apply Supply Chain Management Best Practices

Effective management of suppliers to prevent or reduce risks, which can lead to mislabeling and false claims, relies on the risk assessment conducted for materials and suppliers, applied controls (e.g., segregation) and verification that the supplier’s controls consistently ensure material integrity.

GFSI benchmarked schemes paved the way for enhanced supply chain management and risk mitigation when it comes to sourcing materials to ensure food safety and legal status. Some schemes additionally require controls and verification activities such as the validation of health claims or verification of nutrient content to provide a framework for helping manufacturers develop a system, which ensures product integrity. For food sold in the United States, a GFSI-based system is now reinforced by the  FSMA Preventive Controls rule, which requires supply chain-applied controls to mitigate material risks along with additional controls to ensure that food is not adulterated or misbranded under the U.S. Food, Drug and Cosmetic (FD&C) Act.

It is important to note that while the FSMA Preventive Controls rule regulates most processors and manufacturers, organic raw agricultural commodities (RAC’s), dietary supplements and unprocessed meats are not covered by the rule as they are covered by other U.S. food regulations. Since these products may be included in organic and natural product formulations, manufacturers may want to consider applying a Preventive Controls methodology to their supply chain or pursue certification to a recognized food safety standard such as a GFSI benchmarked scheme where this is not already in place.

Simplify Your Supply Chain

Complex supply chains reduce visibility, add latency into monitoring, and increase opportunities for contamination or fraud.7,8

Simplifying your supply chain can take a variety of forms such as the sourcing of local or domestic materials.

Continue reading the article by clicking on page 2 below.

Dr. David Acheson is the Founder and CEO of The Acheson Group
Beltway Beat

A Mandatory GMO Labeling Ban—What Do You Think?

By Dr. David Acheson
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Dr. David Acheson is the Founder and CEO of The Acheson Group

We’ve said this already: 50 different methods for labeling U.S. food products just aren’t realistic from both a practical as well as a cost standpoint. Thus, it is not surprising that we continue to see activity in this space from Congress.

The latest round from Congress would pre-empt state efforts and put the responsibility on federal food agencies. The move is a result of the voice-vote passage of The Safe and Accurate Food Labeling Act of 2015 (H.R. 1599) by the House Agriculture Committee. This bill would stop state GMO-regulatory efforts and ban mandatory GMO labeling. FDA would also develop a non-GMO labeling standard, similar to that of USDA’s organic labeling.

The bill, which is a substitute amendment of the original bill, will go to the House (which is expected to pass it) and then to the Senate (where passage is less certain).

If approved by Congress and signed by President Obama, H.R. 1599 would:

  • Pre-empt state-level efforts to enact mandatory GMO labeling laws, overturning the state GMO-labeling laws recently passed and prohibiting local regulation of GMO crops.
  • Create a voluntary, consistent federal process of certifying and labeling food products as non-GMO, while prohibiting the mandating of labeling for all GMO foods.
  • Allow the Secretary to require labeling of a GMO food if “(A) there is a material difference in the functional, nutritional, or compositional characteristics, allergenicity, or other attributes between the food so produced and its comparable food; and (B) the disclosure of such material difference is necessary to protect public health and safety or to prevent the label or labeling of the food so produced from being false or misleading in any particular.”
  • Require that manufacturers have written FDA certification that a GMO product is safe.

While “right-to-know” activists are pushing GMO labeling, some on the other side are saying that this bill recognizes that right to know about a food’s origin and production is similar to the current labeling of organic foods. Rather than requiring that food manufacturers label their products as non-organic, the USDA National Organic Program allows approved products—and only NOP-approved products—to be labeled as organic. Similarly, as proposed in the bill, a standard to be developed by FDA would allow food manufacturers to label approved products—and only approved products—as GMO-free. Thus, like organic, those concerned with GMOs could purchase products fitting their needs.

This is an important difference, especially regarding the perceived safety of food products. Research conducted by the PEW Research Center reveals that although 88% of scientists from the American Association for the Advancement of Science say GMO foods are safe to consume, 57% of the general public believe these foods are unsafe. If more than half of your potential consumers mistakenly believe your product is unsafe, that would certainly have significant effect on your company’s business. Again, it is a similar argument as that of organic, where supporters often promote the food as healthier, despite USDA’s repeated assertion that “organic” simply means organic, not better or healthier.

In addition to the pro- and anti-labeling sides, the controversy has long been about who should have the authority. As we’ve said before, establishing state laws (i.e., those already passed by Vermont, Connecticut and Maine) would create a patchwork of rules, and food manufacturers would have to adapt to 50 different sets of laws.

Fundamentally, the consumers right to know what they are eating is not only understandable but, to me, totally appropriate. Where this goes off the rails is when it comes to complex labeling requirements and a push to require food companies to put information on labels that is nice to know but not critical to know. Regulations should be about protecting the consumer, and until (or unless) we have solid science indicating GMO foods are a problem that requires a warning, let’s keep mandatory labels where they belong and information for curious consumers in places where they can access it easily using modern technology.

Eating Organic Produce Lowers Pesticide Exposure

A recent study, published in the journal Environmental Health Perspectives, concluded that we consume fewer pesticides when we eat organic foods compared to their conventionally grown counterparts.

University of Washington’s Cynthia Curl and her fellow authors surveyed nearly 4,500 people about what they eat. They combined this information with average residue levels in those items from the U.S. Department of Agriculture’s Pesticide Data Program to estimate their intake of organophosphate pesticides (OPs). Organophosphates are a group of manufactured chemicals that are the most widely used insecticides today but are not allowed for use in organic farming.

Symptoms of sudden poisoning by organophosphates include headache, dizziness, weakness, diarrhea, nausea and vomiting, salivation, watery eyes and small pupils. Severe symptoms include seizures, slow pulse, difficulty breathing and coma.

Long-term exposure to organophosphates can cause confusion, anxiety, loss of memory, loss of appetite, disorientation, depression and personality changes. After exposure, people can also develop nervous system problems such as muscle weakness and numbness and tingling of the hands and feet, and some studies in adults and children have linked organophosphate exposure to lymphoma and leukemia.

In their study, Curl and her team also collected urine samples from 720 people to test for dialkylphosphate (DAP) metabolites — common byproducts of the body metabolizing most OPs. DAP concentrations supported the estimated pesticide exposure, and the researchers also found that the 240 participants who said they ate more organic produce had “significantly lower” DAP concentrations.

This isn’t the first study relating to chemical residues and food consumption, but it is the first to include information on organic food consumption habits. “The food composition — chemical residue method described in the present study may prove useful in future epidemiological studies of long-term dietary OP exposure, particularly if paired with information on organic food consumption, which may modify the observed exposure-response relationship,” the authors wrote. “As concern grows regarding potential effects of low-level OP exposures, the need increases for more sophisticated exposure assessment methods.”

Study: Organic Foods More Nutritious Than Conventional

By Michael Biros
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The study looked at an unprecedented 343 peer-reviewed publications comparing the nutritional quality and safety of organic and conventional plant-based foods.

The largest study of its kind has found that organic foods and crops are more nutritious than their conventional counterparts. The study, led by a team of scientists at Newcastle University in England, found that organic foods have more antioxidants, fewer pesticide residues, and lower levels cadmium and nitrogen compounds.

Published in the British Journal of Nutrition, the study looked at an unprecedented 343 peer-reviewed publications comparing the nutritional quality and safety of organic and conventional plant-based foods, including fruits, vegetables, and grains. The study team applied sophisticated meta-analysis techniques to quantify differences between organic and non-organic foods.

Washington State University research professor Chuck Benbrook was the only American co-author of the study.

According to a WSU press release about the findings, “consumers who switch to organic fruits, vegetables, and cereals would get 20 to 40 percent more antioxidants. That’s the equivalent of about two extra portions of fruit and vegetables a day, with no increase in caloric intake.”

Antioxidants are thought to help prevent a variety of diseases, including coronary heart disease, stroke and certain cancers.

Conventional crops had twice the amount of cadmium and were three to four times more likely to have pesticide residues than the organic versions, the Newcastle study found. Cadmium is a highly toxic heavy metal contaminant that has been linked to kidney failure, bone softening, liver failure, and lung cancer.

Organic Testing: What You Need to Know

By Food Safety Tech Staff
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Are you interested in labeling your product as organic? This article provides a comprehensive guide to understanding the USDA’s requirements for organic testing.

According to the United States Department of Agriculture (USDA), Organic is a labeling term that indicates that the food or other agricultural product has been produced through approved methods that integrate cultural, biological and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity. Synthetic fertilizers, sewage sludge, irradiation and genetic engineering may not be used. 

Where did the legal definition of organic originate from? The Organic Foods Production Act (OFPA), enacted under Title 21 of the 1990 Farm Bill, is the law that made “organic” a legal term. The intent of the OFPA of 1990 was to establish national standards for the production and handling of foods labeled as organic. The OFPA of 1990 authorized a new USDA National Organic Program (NOP) to set national standards for production, handling and processing of organically grown agricultural products. Additionally, the OFPA established the National Organic Standards Board (NOSB) which advises the Secretary of Agriculture in setting the standards upon which the NOP is based. 

The main goals of the OFPA of 1990 include:

  • Establish national standards governing the marketing of certain agricultural products as organically produced products; 
  • Assure consumers that organically products meet a consistent standard; and
  • Facilitate interstate commerce in fresh and processed food that is organically produced. 

What is the National Organic Standards Board?

The National Organic Standards Board (NOSB) is appointed by the Secretary of Agriculture, and is a Federal Advisory Committee comprised of the members listed below:  

  • Four farmers/growers; 
  • Three environmentalists/resource conservationists; 
  • Three consumer/public interest advocates; 
  • Two handlers/processors; 
  • One retailer; 
  • One scientist (toxicology, ecology, or biochemistry); and
  • One USDA accredited certifying agent.   

The responsibility of the NOSB is to recommend adding and/or removing materials from the National List (see next question). In general, synthetic substances are prohibited and non-synthetic substances are allowed. Additionally, the NOSB must review all materials every five years and recommend renewing, removing or changing each listing. The NOSB meets twice per year in a public forum to discuss the issues and vote on their final recommendations. All meetings are free and open to the public. Recommendations by the NOSB are not official policy until they are approved and adopted by the USDA. 

What is the National List?

A uniform National List of materials was mandated by Congress as part of the OFPA of 1990. The purpose of this list is to clarify which materials are acceptable and unacceptable to use in organic production, processing and handling in the United States. How has the Recent Final Ruling Published by the NOP on November 8, 2012, Affected the OFPA of 1990? On November 8, 2012, the NOP published a final ruling clarifying a provision of the OFPA of 1990 and the regulations regarding the requirement of periodic residue testing of organically produced agricultural products by accredited Certifying Agents. The final rule amends the USDA’s NOP regulations to clarify that “accredited certifying agents must conduct periodic residue testing of agricultural products that are to be sold, labeled or represented as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group (s)).” 

The final rule requires that Certifying Agents, on an annual basis, sample and conduct residue testing from a minimum of five percent of the operations that they certify. This action will help further ensure the integrity of products produced and handled under the NOP regulations.” The effective date of this final rule is January 1, 2013, and Certifying Agents must be fully compliant with the five percent requirement for the 2013 calendar year. The primary goal of this rule is to align the NOP regulations with the requirement for residue testing of organic products under the OFPA of 1990. Residue testing is a significant part of the organic certification process because it provides a quantitative means to monitor compliance with the NOP and discourages the mislabeling of agricultural products. 

Current methods of analysis for periodic residue testing

What are the current methods of analysis for periodic residue testing that meet the requirement of this recent ruling? The NOP uses monitoring data compiled by the USDA Agricultural Marketing Service (AMS), Science and Technology Program and United States state agricultural laboratories to evaluate the residual pesticides remaining on foods. The current method used to obtain this data is a modified QuEChERS (Quick, Easy, Cheap, Effective, Rugged and Safe) method. 

The NOP, USDA AMS and Science and Technology Program collaborated to create a “target” analyte list (NOP 2611-1) of all pesticides/metabolites/environmental contaminants that have been found in samples analyzed for the USDA Pesticide Data Program. Certifying Agents should use laboratories attempting to analyze as many compounds on the USDA’s Prohibited Pesticides for NOP Residue Testing list (NOP 2611-1). 

What are USDA’s laboratory selection criteria for testing organic products?

The criteria of the food testing laboratory that the USDA prefers a Certifying Agent performing the periodic residue testing for a Certifying Agent are listed below.

1. Laboratories should hold current accreditation to either: 

  • ISO/IEC 17025:2005, General Requirements for the Competence of Testing and Calibration Laboratories; or
  • An alternate standard approved by the NOP on a case-by-case basis. Certifying Agents should contact their NOP Accreditation Manager for additional information. A copy of the accreditation certificate should be provided to the certifying agent prior to shipping samples and should be attached to laboratory results when they are reported back to the Certifying Agent.  

2. Laboratories should participate in an international proficiency test program. A proficiency testing program is the determination of the calibration or testing performance of a laboratory by means of inter-laboratory comparison. A copy of the proficiency test results from the most recent round of proficiency testing should be available from the laboratory together with any corrective actions taken if the laboratory has failed the proficiency test.  

3. Laboratories should be capable of screening for the “target” analyte list of pesticides included on the document NOP 2611-1, analyzing the samples using gas chromatography (GC) and/or liquid chromatography coupled to a mass spectrometer (MS) or tandem mass spectrometer (MS/MS).  

4. Laboratories should provide evidence that their analytical method is appropriate for the submitted sample and that suitable validation data are available. Correspondence should be available to the certifying agent documenting that the method meets the laboratories’ minimum internal quality assurance requirements.

5. Certifying Agents should direct the laboratory to provide analytical results as follows:  

  • If no residue is detected, then the result should be provided as not detected (ND). The limit of detections should be provided.
  • If some residue is detected below the limit of quantification (LOQ), then the result should be provided as “Trace” or “BQL” (below quantifiable level). 
  • If residue is detected at or above the LOQ, then the result should be reported in parts per million 9ppm). Parts per million (ppm) is equivalent to milligrams per kilogram (mg/kg). 

References: 

  1. Federal Register Vol. 77, No. 218 Friday, November 9, 2012. Pages 67239-67532. Accessed at http://www.gpo.gov/fdsys/pkg/FR-2012-11-09/pdf/FR-2012-11-09.pdf on November 20, 2012.  
  2. Mary V. Gold. Organic Production/Organic Food: Information Access Tools. United States Department of Agriculture (USDA) National Agricultural Library. June 2007. Accessed at http://www.nal.usda.gov/afsic/pubs/ofp/ofp.shtml on December, 5 2012.  
  3. Organic Trade Association. Organic Foods Production Act Backgrounder. Accessed at http://www.ota.com/pp/legislation/backgrounder.html on December 5, 2012. 
  4. Public Law 101-624-November 28, 1990. Title XXI-Organic Certification. Accessed at http://nationalaglawcenter.org/assets/farmbills/1990-9.pdf on December 5, 2012. 
  5. United States Department of Agriculture (USDA) National Agricultural Library. Mary V. Gold. June 2007. Accessed at http://www.nal.usda.gov/afsic/pubs/ofp/ofp.shtml on December, 5 2012. 
  6. United States Department of Agriculture (USDA). NOP 2611 Laboratory Procedures for Residue Testing Rev02 November 08, 2012. Accessed at http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5088988 on November 20, 2012. 
  7. United States Department of Agriculture (USDA). National Organic Program. Accessed at http://www.ams.usda.gov/AMSv1.0/nop on November 20, 2012.  
  8. United States Department of Agriculture (USDA). National Organic Program, National Organic Standards Board (NOSB) Accessed aton November 20, 2012.