Organic Systems Plan (MOSA)
Organic Product Composition
NOS §§205.105, .301 .302
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The National Organic Standards require that all raw or processed agricultural products sold, labeled or represented as "100 percent organic,” "organic" or "made with organic (specified ingredients or food group(s))," and all organic ingredients in multi-ingredient agricultural products with less than 70% organically produced ingredients must be handled in compliance with all applicable organic standards. For processed products labeled as "organic" on the principal display panel, all agricultural ingredients must be certified organic or on the National List. Nonorganic ingredients and processing aids used must be allowed on the National List and must not comprise more than 5% of the finished product (excluding water and salt). All annotations and restrictions for ingredients used from the National List must be followed, and commercial unavailability documented when applicable. Products making "100% organic,” "organic" or "made with…" claims may not contain ingredients or processing aids subject to ionizing radiation or genetically engineered organisms and their derivatives, nor ingredients produced using sewage sludge. National Organic Standard §205.301 outlines other label-claim-specific and product composition requirements. National Organic Standard §205.2 defines an ingredient as any substance used in the preparation of an agricultural product that is still present in the final commercial product as consumed.
14. Submit completed Organic Product Profiles for all organic products requested for certification. Ingredient labels and/or specification sheets, as applicable, must also be provided for all ingredients. What is your procedure for sourcing organic agricultural ingredients?
Existing and continuing business relationships, supplier inspections and audits, verification of Organic certification.
15. How do you verify certification of organic ingredients?
Request a copy of supplier's Organic certification
16. How do you verify that ingredients and other inputs used have not been produced using genetic engineering, sewage sludge, or ionizing radiation and that National List annotations are followed?
Existing and continuing business relationships, supplier inspections and audits, verification of Organic certification.
17. Do any nonorganic ingredients used have annotations/restrictions for their use on the National List?
No.
18. If "yes," describe how you meet compliance. If you are uncertain about how to meet these requirements, please contact MOSA.
N/A
19. Reference the definition of Processing Aid in NOS §205.2. Processing aids must be noted on the Organic Product Profile submitted for each product requested for certification. Submit processing aid labels and/or specification sheets, as applicable. Do you use processing aids? If no processing aids are used, skip to the Contact Substances Section.
Yes.
20. If "yes," list what processing aids are used, and describe how and why they are used.
Nature Seal AS-5 and PS-10 for apples, carrots, and potatoes to extend shelf life and preserve color. SaniDate FD for water treatment in sanitizing solutions. Citric Acid for pH balance of municipal water source.
21. If any processing aids used have annotations/restrictions for their use on the National List, describe compliance.
Nature Seal and SaniDate FD processing aids are OMRI listed and current documentation is available for review. Citric Acid is generally recognized as safe (GRAS) under NOS §184.1033. Verification is also available showing that nonorganic ingredients were produced without the use of prohibited or excluded methods including genetic engineering, genetically manipulated organisms or ingredients, sewage sludge, or ionizing radiation.
22. Are any processing aids not on the National List? If "yes," explain.
No.
23. Identify any processing aids that have been produced, processed with or exposed to the following. Check all that apply. Ionizing radiation, sewage sludge, and genetic engineering.
None of these.
24. If "none," do you have verification?
Yes.
25. Contact substances are defined by the FDA as “any substance intended for use as a component of materials used in manufacturing, packing, packaging, transporting, or holding food if such use is not intended to have a technical effect in such food.” Note contact substances on the Handler Input Inventory. Are any contact substances used during organic or nonorganic processing?
No.
26. Any contact substances must have documentation to show that they meet the FDA definition. How is this documentation provided to MOSA?
N/A
27. Water used in processing/handling must meet potable water standards. For products that use culinary steam, boiler additives must not contaminate the organic products. List boiler additives on the Handler Input Inventory and submit product labels and ingredient information for inputs not OMRI listed or previously approved by MOSA. How is water used in processing? List all that apply.
Ingredient, processing aid, cooking, cooling, product transport, organic product cleaning, equipment cleaning.
28. If "other," explain.
N/A
29. List all sources of water (e.g. municipal, on-site well). Submit a water test for Coliform bacteria and nitrates for nonmunicipal water sources.
Municipal.
30. List any known water contaminants.
No known water contaminants. Water tests are secured from the City of Kalamazoo annually. Additional lab tests are performed annually as required. Municipal water averages between 8-9 pH.
31. What on-site water treatment processes are used? (e.g. filtration (specify type), chlorination (specify where used), softening.)
None.
32. Do you use water conservation strategies?
Yes.
33. How, and how often, do you monitor water quality?
Daily as needed in processing, annually for municipal water quality testing.
34. Is culinary steam used in the processing of organic products?
Yes.
35. Are any of the following used to prevent and/or monitor contamination from boiler additives? Steam filters, condensate traps, testing of condensate, testing of finished products, other (blow-down process, turning off chemical injection system, purging the system, etc.)
None.
36. If "other," explain.
N/A
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