USDA National Organic Standards became effective Feb. 20, 2001. However, an 18-month implementation period gives growers, processors, retailers, and others until Oct. 21, 2002 to comply with the Final Organic rule.

Using the USDA National Organic Program Final Rule and Regulations and American Organic Standards as a basis, the Organic Trade Association (OTA), the primary business group representing the organic industry in the US, has developed a 291-page copyrighted manual, CD-Rom disk and training workshops specifically designed to "aid store managers …in understanding and implementing practices that comply with the USDA Final Organic Rule and Regulations".

To give you an idea of the quality and detail covered, I have attached, with the permission of OTA, a copy of the Table of Contents and a brief description of each section. The OTA invested considerable resources in developing this manual which is available for $149.00 or OTA members and $295.00 for non members.

Table of Contents

Are You Ready?
How to Use this Manual

2.1 The Organic Foods Production Act of 1990 (OFPA)
2.2 USDA National Organic Program Final Rule and Regulations
    2.2.1 General Production, Handling and Labeling Requirements
    2.2.2 General Requirements for Retail Operations
2.3 Definition of Selected Terms
2.4 Rule and Federal Regulations for Non-certified Retail Stores
    2.4.1 Requirement for All Retail Stores
    2.4.2 Retail Store Exemption
    2.4.3 Retail Store Exclusion
    2.4.4 Labeling Requirements
    2.4.5 Record Keeping Requirements
    2.4.6 Civil Penalties
    2.4.7 Complaint Process
2.5 State Laws

SECTION 4. GOOD ORGANIC RETAILING PRACTICES

8.1 Overview
8.2 Receiving
8.3 Storage
8.4 Prepared Food Processing
    8.4.1 Cleaning Equipment and Areas
8.5 Ingredients
8.6 Labeling and Display
8.7 Employee Training
8.8 Documentation Recommended for Prepared Food

The USDA Final Organic Rule is effective February 20, 2001. There is an 18 month implementation period. All retail stores handling organic food need to be in compliance with the Rule by October 21, 2002. Are you ready?

Under the USDA Final Organic Rule, all retail stores need to meet certain requirements to protect the integrity of organic products:

This manual will aid store managers and department managers in understanding and implementing practices that comply with the USDA Final Organic Rule and Regulations. It will also help train department employees and maintenance staff to methods that prevent commingling and contact with prohibited products. The manual prepares you for voluntary organic certification. Finally, the manual gives you the tools to insure that your store is in compliance with the USDA Final Organic Rule and Regulations.

This manual serves as the basic curriculum material for a 3.5 hour training for retail store managers and employees. It can also be used for self study. Using IOIA organic inspection techniques, it is designed to help employees develop critical thinking skills to identify all areas in the store that are potential sources of contamination and to implement good organic retailing practices.

The manual follows the format provided in the OTA's Good Organic Retail Practices (GORP). Developed by retailers prior to the USDA Final Organic Rule, GORP is an excellent reference to implement the USDA Rule and Regulations. It outlines practices to prevent commingling and contact with prohibited substances, employee training, and record keeping. Because GORP contains more detailed requirements than the USDA Organic Rule, it is a useful tool for retail stores.

The manual contains examples of consumer information signs, Organic Control Point checklists, cleaning/pest control protocols, and employee training aids that you can modify to reflect the specific practices in your store. A CD Rom accompanies the manual that contains all of the forms, lists and aids. The documents are in .pdf format for easy translation to your computer system.

For stores that request voluntary organic certification, this manual is a valuable tool to understand the organic certification process and develop organic handling system plans.

Since all retail stores are not alike, the manual is divided into sections. Sections 1-4 have general information. Sections 5-9 are geared towards specific departments and can stand-alone for use as a specific department' s manual.

Section 1 aids all personnel in understanding organic farming and livestock operations, and what makes them different from other farming systems. It explains how organic products are processed, handled and packaged to protect their organic integrity. Store signage examples have been designed to help retailers educate their consumers. This section can be used as a reference to help workers answer customer questions and concerns. Section 1 should be read by all employees who handle organic products.

Section 2 reviews the Organic Foods Production Act of 1990 (OFPA) and details relevant portions of the USDA Final Organic Rule relevant to retail stores. Each retail store that handles organic products must comply with OFPA and the USDA Final Organic Rule and subsequent Regulations. This section should be read by store and department managers to be sure they understand compliance to these Rules and Regulations.

Section 3 reviews USDA Organic Final Rule requirements for the voluntary organic certification of retail stores. It also answers your questions on the organic certification process and provides a framework for your Organic Handling System Plan. Use this section in conjunction with other sections to prepare your store for organic certification. This section should be read by people in charge of preparing the store for organic certification.

This section is meant to help store managers, department managers, pest control and maintenance staff develop critical thinking skills to identify and address all areas in the store where the integrity of organic products may be compromised. USDA Rules and Regulations on organic handling, as well as the OTA's American Organic Standards and Good Organic Retailing Practices emphasize the basics of good organic retailing practices. For stores seeking organic certification, this section offers practical direction on how to implement an Organic Handling System Handling Plan. Section 2 should be read by all managers and those employees in charge of compliance with the USDA Organic Rule and Regulations.

Sections 5, 6, 7, 8, and 9: Produce, Bulk Foods, Meats, Prepared Foods and Prepackaged Grocery Department Good Organic Retailing Practices

These easy to read sections are to be used as an employee training guide for each of these departments. Many of the points addressed are the same for each department. However, these sections are meant to stand alone as the specific handling plan for each department. Included in this section are the particulars of each department's handling plan, including real life scenarios and practical solutions.

Checklists, forms and signage examples that can be modified, photocopied and laminated are offered as tools to help each department implement an organic handling system plan. Each section has a quiz to be used for employee training after they have read through both Sections 1 and their department section. The quiz can be given as either an open book test, with the reference materials available, or without the manual. The questions are meant to be educational. Managers can use this quiz to judge their employees' understanding of organic handling requirements. Managers and employees should read the pertinent sections for their department.

OTA's Good Organic Retailing Practices (GORP) is boxed for easy reference throughout the Manual. It is presented in its entirety in the Resource section. Final portions of the Appendix provide information about the Organic Trade Association, the Independent Organic Inspectors Association, and the Organic Materials Review Institute. The section concludes with a list of retail stores that participated in the development of this manual.

Should organic farmers have to pay mandatory commodity promotion assessments for commodities like peaches, apples, etc. that are assessed on all growers, conventional or organic? The 2002 Farm Bill contains a section, effective this October, exempting producers of certified organic products from paying mandatory commodity promotion assessments but may apply only on federal marketing orders and only to growers that produce only organic products.

Some Washington state apple growers have been paying $.25/box of organic apples to the Washington state Apple Commission but critics say such commissions have done little to promote organic products. On the other hand, commodity marketing boards probably generally benefit sales of specific commodities like apples and peaches, conventional or organic. It has also been suggested that commodity boards promote organic crops in proportion to the percent assessment contributed by organic farmers. A related issue is whether the Feds have the power to enjoin or direct state taxes. The Secretary of Agriculture is required to develop exemption and compliance requirements have to be defined within one year. The Packer

Federal Marketing Order No. 905 for Oranges, Grapefruit, Tangerines, and Tangelos Grown in Florida, "except for the area west of the Suwannee River" was first promulgated in 1939 and was last amended under formal rulemaking on September 8, 1989. The 1996-97 budget of $230,000 is based on an assessment rate of $0.0035 per 4/5 bushel carton of citrus.

However, according to the Citrus Administrative Committee, organic growers do not currently contribute to this marketing order and it will not apparently have any effect on them. The following marketing orders are also in effect:

Marketing Order No. 966: Florida Tomatoes
Marketing Order No. 967: Florida Celery
Marketing Order No. 967: Florida Celery

This is the text of the exemption in the 2002 Farm Bill which has become law.

SEC. 10607. EXEMPTION OF CERTIFIED ORGANIC PRODUCTS FROM ASSESSMENTS.

(a) IN GENERAL- Section 501 of the Federal Agriculture Improvement and Reform Act of 1996 (7 U.S.C. 7401) is amended by adding at the end the following:

(e) EXEMPTION OF CERTIFIED ORGANIC PRODUCTS FROM ASSESSMENTS

(1) IN GENERAL- Notwithstanding any provision of a commodity promotion law, a person that produces and markets solely 100 percent organic products, and that does not produce any conventional or nonorganic products, shall be exempt from the payment of an assessment under a commodity promotion law with respect to any agricultural commodity that is produced on a certified organic farm (as defined in section 2103 of the Organic Foods Production Act of 1990 (7 U.S.C. 6502).

(2) REGULATIONS- Not later than 1 year after the date of enactment of this subsection, the Secretary shall promulgate regulations concerning eligibility and compliance for an exemption under paragraph (1).