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Organic System Plan Office Use Only

Received:

Marketer-Trader-
Broker-Distributor/Handler
Use this form if you are:
(a) Brokering/Distributing organic products (i.e. buying already-certified organic product, doing nothing to it while it is in storage,
and then re-selling the organic product intact with no re-labeling). This category includes distributors, wholesalers and marketers
who handle product that is enclosed in containers, but do not make any changes to the packaging. Also included are handlers of
bulk agricultural commodities (i.e. hay, cattle, bulk grains).
(b) Marketing/Trading organic products (i.e. handlers who do not physically manufacture, label or package a product, but may be
the owner of a private label or have other relations to the product). This includes private labelers who may use certified co-
packers to make the product for them according to their specifications.
If you are re-packing and/or re-labeling organic product, you must complete the Organic System Plan Processor/ Handler.
Attach Organic Product Profiles for all products requested for certification. Use additional sheets if necessary. If you are a new
applicant, attach a completed General Information form. Do not leave any applicable sections blank. Write none or not applicable
where appropriate. Remember to sign this form. Section numbers refer to National Organic Program regulations (7 CFR, Part 205).

SECTION 1: General Information 205.201


Company Name: Todays Date:

Address:

City: State: Zip code:

Primary contact person: Direct phone number of contact person, including extension:

List names, job titles, and phone numbers of all persons authorized to discuss certification matters with PCO:

Legal Status: Sole Proprietor Partnership Business Corporation Non-profit Corporation Trust or association
Other (specify):
Please check any of the following countries to which you intend to export organic products in the next 18 months:
Canada European Union Taiwan Japan
If you intend to export any of your organic products to Japan, Taiwan, the European Union or Canada, complete Section 10 of this
form.
List all products requested for organic certification. Attach an Organic Product Profile for each product.
Product Name Brand name Where processed/co-packed?

Pennsylvania Certified Organic 106 School Street, Suite 201 Spring Mills, PA 16875
(814) 422-0251 fax (814) 422-0255 www.paorganic.org pco@paorganic.org

Page 1 of 8 CERT A12 OSP Marketer-Trader-Handler V2, R1, 1/15/13


Organic System Plan Marketer-Trader- Broker-Distributor/ Handler

Complete table below for those who process (co-pack) your organic products. Co-packers must be certified:
Attach copies of co-packers current certification documentation. No co-packing

Co-Packer Address Phone No. Certified by

SECTION 2: Ingredients and Processing Aids 205.301


See 205.301 for composition requirements pertaining to your final proposed product label claim. Salt and water are excluded from
organic percentage calculations. Genetic modification, ionizing radiation, and sewage sludge may not be used in the production of
any ingredients or processing aids.

INGREDIENTS:
Fill out enclosed Organic Product Profiles for each organic product requested for certification.

1. Who is responsible for ingredient or product purchasing and ingredient or product certification documentation
maintenance:

Self / Own Company Co-Packer(s) Dually purchased/maintained by Self and Co-Packer(s)

SECTION 3: Production System 205.272


PRODUCT FLOW
Attach a schematic product flow chart that shows the movement of the organic product(s) from ingredient or product receiving
through final product sale. This should include the general locations for ingredient or product storage, processing, shipping between
operators, storage, and final shipping for sale. This flow chart should clearly demonstrate your operations part in the process, as well
as the co-packers.
SECTION 4: Record Keeping System 205.272
Audit control records must track finished organic products back to all ingredients. Ingredients must be verified as certified organic and
you must have certificates on file for the inspector. Amounts of organic finished products must balance with certified organic
ingredients purchased. All relevant documents must clearly identify products as organic.

2. Which of the following do you use to track organic products:


Incoming:

Purchase orders Contracts Invoices Receipts

Bills of lading Customs forms Scale tickets Quality test results

Certificates of Analysis Transaction Certificates Copies of Organic Certificates

Receiving records Receiving summary log (12 mos.) Other (specify):

Storage:

Finished product inventory reports Other (specify):

Outgoing:

Shipping logs Sales invoices Other (specify):

3. Do you utilize a lot coding system? If so, describe:

4. How often do you conduct Record Keeping / Audit Control System monitoring?
Weekly Monthly Annually As needed Other (specify):

Page 2 of 8 CERT A12 OSP Marketer-Trader-Handler V2, R1, 1/15/13


Organic System Plan Marketer-Trader- Broker-Distributor/ Handler

SECTION 5: Quality Assurance

5. Do you have a Quality Assurance (QA) program in place? Yes No


If No, skip to Section 6
If Yes, what program do you use? HACCP TQM Other (specify):

6. Are any outside quality assessment services used (e.g., AIB)? Yes No
If Yes, name of company:

7. Product testing: (check all applicable categories)

Ingredients prior to purchase Ingredients upon receipt During production Finished product

8. Are ingredient samples retained? Yes No


If Yes, how long?

9. Are finished product samples retained? Yes No


If Yes, how long?

10. Do you have a product recall system in place? Yes No


11. Describe how you monitor the effectiveness of your Quality Assurance System:

12. How often do you conduct Quality Assurance monitoring?


Weekly Monthly Annually As needed Other (specify):

SECTION 6: Facility Pest Management 205.271


Complete this section to describe pest control practices and materials used in any facility where organic products are
produced, handled and/or stored, including but not limited to storage areas, loading docks, warehouses and packing
areas.
We do not warehouse, distribute, or store organic products (if so, skip to Section 7)

13. What type of facility pest management system(s) do you use?

In-house: name of responsible person:

Contracted pest control service (name, address, phone no.)

14. Check all facility pest problems you generally have:

Flying insects Crawling insects Spiders Birds Rats Mice Other (specify):

15. Check all pest management practices you use. Note: All materials used for facility pest management must be listed on
your Materials Used Form.
Good sanitation Positive air pressure in facility Freezing treatments
Removal of exterior habitat/food Ingredient inspection for pests Heat treatments
sources Inspection zones around interior Vacuum treatments
Cleanup of spilled product perimeter Carbon dioxide
Mowing Electrocutors Nitrogen
Physical barriers Ultrasound/light devices Non-synthetic substances consistent with the
Monitoring devices Release of beneficials National List (e.g. pyrethrum)
Repair of holes, cracks, etc. Sticky traps Synthetic substance consistent with the National
Screened windows, vents, etc. Pheromone traps List (e.g. vitamin D3 bait)
Air curtains/ air showers Mechanical traps Synthetic substance NOT on the National List (e.g.
most commercially available rodent bait) *
Other (specify):

* If you want to use a synthetic substance not on the National List you must receive authorization from PCO prior to use.

Page 3 of 8 CERT A12 OSP Marketer-Trader-Handler V2, R1, 1/15/13


Organic System Plan Marketer-Trader- Broker-Distributor/ Handler

16. Describe monitoring, including frequency, used to determine effectiveness of management practices in #15:

17. If pest control materials are used where are they stored?

18. What records do you maintain to document pesticide use and measures taken to prevent contamination of organic
products?

Attach facility map showing location of pest traps and monitoring devices. Map Attached

SECTION 7: Packaging and Labeling 205.301, 205.303


Packaging materials must be free of prohibited substances and must not contaminate the organic product. Organic product labels
must meet National Organic Program labeling requirements.

A. PACKAGING:
19. Check types of packaging material used:

Bulk Paper Cardboard Wood Glass Metal Foil Plastic Waxed paper Aseptic

Natural fiber Synthetic fiber Other(specify):

20. Are all packaging materials food grade? Yes No

21. Are all packaging materials free of prohibited materials? Yes No

22. Are packaging materials returnable? Yes No

If Yes, how are they cleaned?

23. Are any products packaged, repackaged, or labeled by you after receipt from the co-packer(s)? Yes No
B. LABELING:
*Attach samples of all proposed organic product labels and include whether labels are for retail or non-retail use.

24. Do you use or plan to use the PCO logo on the label? Yes No
25. Do you intend to use the USDA Organic seal on the label? Yes No

SECTION 8: Storage
No commingling or contamination of organic products may occur during storage. All storage sites must be properly documented and
organic products clearly identified in storage. Off-site storage areas may need to be inspected and certified.
Storage information:
TYPE/ DEDICATED ORGANIC?
USE WHERE STORED? IDENTIFICATION
CAPACITY YES (Y) NO (N)

Ingredient
storage
Packaging material
storage
Finished product
storage
Off-site
storage*

26. If there is off-site storage, give name, address, phone number and contact person:

Page 4 of 8 CERT A12 OSP Marketer-Trader-Handler V2, R1, 1/15/13


Organic System Plan Marketer-Trader- Broker-Distributor/ Handler

SECTION 9: Transportation of Organic Products


The integrity of organic products must be preserved during transport.

27. In what forms are incoming products received?

Dry bulk Liquid bulk Tote bags Tote boxes Paper bags Foil bags Metal drums Mesh bags

Cardboard drums Cardboard cases Plastic crates Other (specify):

28. In what form are finished products shipped out?

Dry bulk Liquid bulk Tote bags Tote boxes Paper bags Foil bags Metal drums Mesh bags

Cardboard drums Cardboard cases Plastic crates Other (specify):

29. How are incoming products transported?

30. How are outgoing products transported?

31. Do you arrange incoming product transportation? Yes No

32. Do you arrange outgoing product transportation? Yes No

33. How do you insure that inbound/outgoing transport units are clean prior to loading organic products?

34. Is this documented with Clean Truck Affidavits? Yes No


35. Are transport units used to carry any prohibited materials?

Incoming: Yes No Dont know

Outgoing: Yes No Dont know

36. Have transport companies been notified of organic handling requirements?

Incoming: Yes No

Outgoing: Yes No

37. Are organic products shipped at the same time as non-organic in the same transport units?

Incoming: Yes No
Outgoing: Yes No

38. Check steps taken to segregate organic products:

Dedicated organic only Use of pallets Pallet tags Organic product shrink-wrapped
Separate area in transport unit Other(specify):
39. Describe how you monitor the effectiveness of your Organic Transportation Plan:

40. How often do you conduct Organic Transport monitoring?


Weekly Monthly Annually As needed Other (specify):

SECTION 10: International Export: Japan, Taiwan, the European Union, Canada

Page 5 of 8 CERT A12 OSP Marketer-Trader-Handler V2, R1, 1/15/13


Organic System Plan Marketer-Trader- Broker-Distributor/ Handler

Please provide the following information even if you do not currently intend to export any organic products to Canada,
European Union, Taiwan, or Japan in order for PCO to review this information. This will expedite any export verification
needs you or your customers may have in the future. However, this information is not required for your Organic System
Plan to be considered complete.
A. CANADA N/A
41. Have all ingredients been verified as compliant to NOP/Canada Arrangement? Yes No

42. Are you using any labels for products exported to Canada other than labels already approved by PCO? Yes No

If yes, attach labels for PCO to review.


*Note: The 100% Organic Label is not permitted in Canada. Labels must be bilingual (English and French).
Product Names Requested to Co-pack or Own Projected Volume to Export to
Brand Name
Ship to Canada Company Product? Canada

B. EUROPEAN UNION N/A


41. Are you using any labels for products exported to the European Union other than labels already approved by PCO?
*Note: The 100% Organic Label is not permitted in the European Union. Yes No
If yes, attach labels for PCO to review.

Product Names Requested to Brand Name Co-pack or Own Projected Volume to export to
Ship to the European Union Company Product the European Union

C. TAIWAN N/A
43. Are any products intended for export produced using any materials prohibited by the NOP National List? Yes No
If yes, list.
44. Do you have verification from ingredient suppliers that no materials prohibited by the NOP National List were used in the
production of the supplied ingredients? Yes No
45. If livestock products are used in the product exported to Taiwan, do you have verification from the ingredient supplier
that systemic painkillers or analgesics, including Lidocaine or Procaine were not used in the animals management?
Yes No N/A no animal products used in products exported to Taiwan.
Product Names Requested to Ship Co-pack or Own Projected Volume to Export to
Brand Name
to Taiwan Company Product? Taiwan

D. JAPAN N/A
46. Do you have verification from ingredient suppliers that the following inputs were not used in the ingredients
production?
a. Alkali-extracted humic acid? Yes No
b. Lignin sulfonate (used as a flotation agent)? Yes No
47. Does your facility use the following inputs in the products to be exported to Japan?
a. Alkali-extracted humic acid? Yes No
b. Lignin sulfonate (used as a flotation agent)? Yes No

Page 6 of 8 CERT A12 OSP Marketer-Trader-Handler V2, R1, 1/15/13


Organic System Plan Marketer-Trader- Broker-Distributor/ Handler

Product Names Requested to Ship Co-pack or Own Projected Volume to Export to


Brand Name
to Japan Company Product? Japan

SECTION 11: Conflict of Interest 205.501


48. Have you used any organic production consultants for your operation in the last 12 months? Yes No
(This does not refer to your inspector, certification specialist, or other PCO representative involved with your certification review.)

If yes, list the name and contact information for organic consultant(s) your operation has used in the last 12 months (7 CFR
205.501 (a) (11) (ii):

SECTION 12: Previous Organic Certification 205.401


49. List current organic certification by other agencies and dates:
If currently certified by another agency, submit a copy of your current certificate and verification of the items you are certified
to produce/sell.

50. If currently certified organic, has your operation received a non-compliance(s) or been issued a proposed suspension or
proposed revocation that has not yet been resolved?
Yes No
If yes, submit a copy of any adverse action notice including: notification of noncompliance, notification of proposed suspension
or proposed revocation issued to you and a description of any actions taken by you to correct the non-compliance(s) noted in the
adverse action notice, including evidence of such corrections and resolution letter from certifier, if any.

51. If previously certified, list names of agencies, dates, non-compliances and reasons for surrender or termination of
certification:

52. Have you ever been denied organic certification or has your organic certification ever been withdrawn, surrendered
suspended or revoked? Yes No
If yes, submit a copy of any adverse action notice, including suspension, revocation or denial of certification issued to you and a
description of any actions taken by you to correct the non-compliances noted in the notification, including evidence of such
corrections and resolution letter from certifier or the National Organic Program Administrator, if any. If certification was withdrawn
or surrendered, provide reason:

53. Gross organic sales of organic crops in previous calendar year: $


If none sold, enter 0.

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Organic System Plan Marketer-Trader- Broker-Distributor/ Handler

Section 13: Affirmation


Information provided on this application is held in strict confidence and will be used only for certification purposes. I affirm that all
statements made in this application are true and correct. I have made every effort to ensure that no prohibited products have been used,
applied or otherwise allowed to compromise the integrity of the organic products produced or sold by me.

I understand and agree as follows:


1. My operation may be subject to unannounced inspection and/or sampling for residues at any time as deemed appropriate to
ensure compliance with the National Organic Program.
2. Acceptance of this questionnaire in no way implies granting of certification by the certifying agent.
3. Failure to comply with the applicable regulations, policies or procedures, or giving false information may result in denial,
suspension, revocation or termination of certification.
4. Payment of all certification fees is a condition of certification.

As required by the National Organic Program, and as conditions of certification I agree to:

1. Cooperate with the certification process by completing all documentation requested.


2. Make every effort to ensure that no prohibited products have been used, applied or otherwise allowed to compromise the
integrity of the organic crops or products produced or sold by me.
3. Provide access to all areas and parts of my operation, including records, products and personnel.
4. Comply with the National Organic Program Rule (7 CFR Part 205) and Pennsylvania Certified Organic certification policies
and procedures.
5. Make appropriate certification claims, which accurately reflect the type of certification granted.
6. Ensure that my certificate or certification report is not used in a misleading manner and does not harm PCO.
7. Only use certification claims, or the PCO name and logo, to indicate that products are in compliance with PCO standards, and
use them correctly on advertising, marketing and packaging materials.
8. Discontinue use of certification claims, and PCO name and logo, upon surrender, suspension, revocation or termination of
certification, and return any certification documents or materials required by PCO.
9. Notify PCO of any significant changes to my operations organic system plan.
10. Notify PCO concerning any application, including drift, of a prohibited substance to any field, production unit, site, facility,
livestock, or product that is part of an operation.
11. Comply with all conditions of certification listed on Certification Reports or other certification documents.

I understand that failure to abide by the above requirements may result in denial, suspension or revocation of my organic certification,
prosecution for fraud or misrepresentation, denial of services, or any other remedy allowed by law.
I give permission for PCO to release information from my file to other recognized certification organizations for purposes of document
review. I understand that PCO will obtain a confidentiality statement from the requesting certifier before releasing any information.
PCO has my permission to obtain information, documents, or materials related to certification or de-certification from other certifiers

Your signature(s): Date:

If applicable:
Signature of Contracted Date:
Processor:

Required attachments: These records must be included with your application or it may be returned to you resulting in a
delay of the certification process.
General Information Form (if new applicant)
Product flow chart
Co-Packers Current Organic Certification Documentation
Organic Product Profiles
Proposed Organic Product Labels for your Products
Materials Used in Organic System Processor (if applicable)
Pest Management Map of Traps and Monitors (if applicable)

Page 8 of 8 CERT A12 OSP Marketer-Trader-Handler V2, R1, 1/15/13

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