Preventing Commingling & Contamination in Organic Handling
Commingling — the mixing of certified organic and non-certified products — and prohibited substance contact are the two most consequential compliance risks in organic handling operations. Either can result in a Notice of Noncompliance, loss of organic status for affected product lots, and in serious cases, suspension of organic handling certification. NOP regulations (7 CFR § 205.272) require certified organic handlers to implement a system that prevents commingling and contamination throughout the handling process: from the moment organic ingredients arrive at your facility through processing, packaging, storage, and shipment. This system must be documented in your Organic System Plan and verified during your annual inspection.
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