Food Safety: USDA NOP Update, Contamination (4 of 6)

Food safety of organic products in systems where it is possible to grow and harvest both "traditional" and certified organic options poses the need to require some regulation regarding the commingling and contamination of said organic product with the chemistry or product of any other sort of operation.

It is possible to have a dedicated space to organic practice in a large farming operation; or possibly a farming operation may be making the switch from the oily bath of "traditional" farming to an less filmy organic program, in which case some products will need to be completely separated until the soil has been leached of past chemicals and been rebuilt to organic standards.

The guidance draft document for Commingling and Contamination is rather brief in scope, but still right to the point.  Commingling is defined as "Physical contact between unpackaged organically produced and nonorganically produced agricultural products during production, processing, transportation, storage or handling, other than during the manufacture of a multi-ingredient product containing both types of ingredients."

Comments on the draft guidance are welcomed and required to be submitted by December 13, 2010. Please see the Series Introduction for details.

The scenario must be in abundant existence or the guidance document never would have been drafted. As the Inspector General's Office has made clear that these drafts were drawn in effort to reconcile general oversights within the system.

Further investigation located this document by James Riddle, from the First World Congress on Organic Food in 2004, which states, "Organic livestock producers must not feed mammalian or poultry slaughter by-products to mammals or poultry. The feeding of manure is also prohibited. While the FDA banned the feeding of cattle brain and spinal tissue to cattle in 1997, and recently banned the feeding of blood, blood products, human food waste, and poultry litter, but they still allow the following materials to be fed to non-organic cattle."

This might lead one to believe that in the last six years it is possible (or even likely) that at least some certified organic products have been contaminated enough to make the Inspector General's Office require these standards to be more strictly enforced. What's bothersome is that the rules were made, at minimum, in 2004, so for the last six years the rules have been overlooked or mismanaged at best.

Despite the management practices, however, it still seems that more often than not organic food isn't recalled much by the USDA or FSIS. In looking over the last 4 years of recalls, I was only able to locate one instance of an organic product being recalled, and it had pork in it.

And further, for all the food we manufacture and export, we still have a surprisingly low level of recalls, most of which concentrate around the meat industry. It might be a strong enough case to move to a closer-to-than-not vegetarian lifestyle to keep food safety a primary focus in one's life.