Organic Systems Plan (MOSA)
Audit Trail and Inventory Control System
NOS §§205.103, .201
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Audit trail and inventory control procedures must be adequate to trace all ingredients and products from the supplier(s) through the entire handling system, including packaging and storage, and on through distribution, sales and transport, using lot numbers, date codes, or a similar product tracking system. Organic handlers must retain valid proof of certification for all organic ingredients. Amounts of organic finished products must balance with purchased certified organic and other allowed ingredients (loss to shrinkage or spoilage should be documented). All relevant documents should identify products as "organic". Documents in your audit trail must be able to link to those preceding and following them in the record system. If lot numbers and/or other identification codes on documents change as products move through your operation, documents must remain auditable so product is traceable.
127. What documents do you use to track ingredients and products at receiving? Check all that apply. Please have all records identified in this section available at inspection. Submit sample records needed to show traceability.
Receiving records, invoices, organic certificates, other.
128. If "other," explain.
Receiving tag used for internal lot tracking.
129. What documents do you use to track ingredients and products while in process? List all that apply. Sanitation logs, production summary logs, blending reports, packaging reports, production reports, ingredient inspection forms, quality assurance reports, equipment cleaning logs, other.
Sanitation logs, production summary logs, production reports, equipment cleaning logs, other.
130. If "other," explain.
Receiving tag used for internal lot tracking, produce wash water log.
131. What documents do you use to track ingredients and products while in storage? List all that apply. Ingredient inventory report, finished product inventory reports, other.
Ingredient inventory report, finished product inventory reports.
132. If "other," explain.
N/A
133. What documents do you use to track ingredients and products at shipping? List all that apply. Shipping logs, sales receipts, other.
Other.
134. If "other," explain.
Invoices are used to track products at shipping.
135. Describe your lot numbering system.
12 digits which includes two letters designating the type of product (FH for fresh cut, FZ for frozen), the three digit product catalog identifier (025), julian date of processing (073) and year (2018). Example: FH0250732018. For certified Organic products the three digit product catalog identifier will begin with number 9 (925).
136. Describe how lot numbers and/or other specific identification used link documents to enable traceability.
This lot number is generated as part of our production planning and used on labels, records, online marketplace, and invoices from then on.
137. What other types of records do you maintain? List all that apply. Ingredient verifications, input labels/composition list, equipment cleaning records, labor records, pest control log, documentation showing lack of commercial availability, residue tests, other.
Equipment cleaning records, labor records, pest control log, other.
138. If "residue tests" or "other," explain.
Orders placed through online marketplace.
139. Can your recordkeeping system track the finished product in the marketplace back to all ingredients?
Yes.
140. Can your recordkeeping system balance organic product in and organic product out?
Yes.
141. Can your recordkeeping system verify prevention of contact with prohibited substances?
Yes.
142. If you answered no to any of the above three questions, what changes will you make to ensure these areas can be tracked/verified?
N/A
143. The National Organic Standards require that you keep a copy of all certification documents for a minimum of 5 years. How do you intend to maintain these records?
Both electronically and hard copy.
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