QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org Contents OHP 1: APPLICATION 1 OHP 2 A: ORGANIC PRODUCT PROFILE 4 OHP 2 B: ORGANIC PRODUCT PROFILE- NONORGANIC INGREDIENTS 6 OHP 2 C: ORGANIC PRODUCT PROFILE INGREDIENT & EXCLUDED METHODS DISCLOSURE 6 OHP 2D: ORGANIC PRODUCT PROFILE FLAVORS 8 OHP 3: Labeling of Product(s) 10 OHP 4: Product Process 15 OHP 5: Pest Management 16 OHP 6: Assurance of Organic Integrity 21 OHP 7: Record Keeping 29 OHP 8: Exemptions and Exclusions from Certification 31 OHP 9: QCS Certification and Mark Licensing Contract 32 OHP 10: US/Japan Export Arrangement Compliance Affirmation – Handler/Processor 35 OHP 11A: European Union (EC) 834/2007 & 889/2008 Regulation Compliance Affirmation –HANDLER/PROCESSOR 37 OHP 11B: US/European Union Equivalence 40 Not applying for export to the European Union 40 OHP 12: US-Canada Equivalence Arrangement -Compliance Affirmation - Handler/Processor 41 OHP 13: US-Taiwan Export Arrangement - Compliance Affirmation – HANDLER/PROCESSOR 42 OHP 14: US-Korea Export Arrangement - Compliance Affirmation – HANDLER/PROCESSOR 43 OHP 1: APPLICATION NOP Rule 205.401 All Organic System Plan changes must be notified to QCS and approved prior to implementation, including use of new lands, inputs, livestock or facility. Lands/facilities are not approved for use until added to Organic Certificate. Name: Operation Name: QCS No. CERTIFICATION CONTACT (Authorized Representative) Contact person: BILLING CONTACT Contact person: Address: Address: OHP, V3, R03, 3/20/15 Page 1 of 45 Date Same as certification contact QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 OHP 1: APPLICATION City: 352.377.8363 www.qcsinfo.org NOP Rule 205.401 State: Phone: F Zip: Fax: City: State: Phone: Email: Zip: Fax: Email: PLANT PHYSICAL LOCATION (To Appear on Certificate) Contact person: Address: City: State: Zip: Phone: Fax: Email: Driving Directions: Are all facilities requested for certification in the same physical location? Yes No If no, please attach a separate sheet providing complete physical location information and driving directions for all facilities requested for certification. Attachment CONSULTANTS Not Applicable (not using a consultant) 1. Consultant name and contact information: 2. Would you like QCS to: Communicate with consultant Communicate with you Send copies of all documents to consultant Other (specify) 3. Do you understand that QCS does not provide consultant services? Yes No (Please note that it is your responsibility to update QCS of any modifications to the consultant information). OPERATION’S LEGAL DESCRIPTION Attachment applicable documents showing legal description A Sole Proprietorship operating under an individual name or a fictitious name (dba) (if so, Attach a copy of Fictitious Name Filing if doing business as any name other than the name of the actual person who is owner. A Corporation (For Profit, Not for Profit, or LLC) (If so, attach a copy of Fictitious Name Filing if doing business as any name other than the name of the corporation as it appears on the corporate filings with the state of incorporation, and attach a copy of the Certificate of Incorporation issued by the state of incorporation, or other document providing the legal existence of the corporation and recognition of that fact by the state of incorporation. A Partnership (An unincorporated association of two or more persons or a joint venture) (If so, Attach a copy of the partnership agreement, if any, and attach a copy of partnership registration with state, or other document from state recognizing the legal existence of partnership, if any. Other unincorporated Association (If so, attach any formal document or agreement which establishes the rights and duties among members or other persons holding an equity, profit sharing, voting or management interest in the organization, and attach a copy of registration with state, or other document from state recognizing the legal existence of organization, if any. OHP, V3, R03, 3/20/15 Page 2 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F OHP 1: APPLICATION 352.377.8363 www.qcsinfo.org NOP Rule 205.401 A. GENERAL DESCRIPTION 1. Is your operation a primary or contract processor? (If marked contract processor, complete B. Contract Processor below) 2. Please provide a general description of the products you process: 3. Provide an estimate of organic production processed by your facility: % 4. Mark (x) the type(s) of process(s) involved in handling/processing the product(s): Cooking Separating Dehydrating Baking Distilling Freezing Curing Extracting Chilling Heating Drying Slaughtering Cleaning Mixing Grinding Cutting Fermenting Milling Wine Production Churning Preserving Manufacturing and packaging, canning, jarring or otherwise enclosing food in a container to process an organically produced agricultural product for the purpose of retarding spoilage or otherwise preparing the agricultural product for market. Other, please explain: B. CONTRACT PROCESSOR Not Applicable 1. Do you contract with any handling/processing facility(s)? Yes No 1a. If yes, name and describe the facility(s) 3. Is the facility certified organic? Yes No 3a. If yes, submit an organic certificate as an attachment. Attachment 4. If no, is the facility subcontracted to you? Yes No 4a. If no, submit a handling/processing application for facility. Attachment C. CERTIFICATION STATUS 1. Are you currently certified organic or previously been certified organic? 2. Year first certified: 3. Year when complete Organic System Plan Application was last submitted: 4. List previous organic certification by other agencies: 5. List current organic certification by other agencies: 6. Have you ever been denied certification? Yes No 6a. If yes, fully describe the circumstances in an attachment. Attachment 7. Has your certification ever been suspended or revoked? Yes No 7a. If yes, fully describe the circumstances in an attachment. Attachment 8. Were you issued noncompliance(s) with last year’s certification? Yes No 8a. If yes, have you received written confirmation that your noncompliance(s) have been corrected? Yes No D. EXEMPT/EXCLUDED 1. Is the operation exempt or excluded from certification? Yes No If yes complete OHP 8. 1a. If exempt or excluded, do you understand that certification is not required and applying is considered a voluntary process? E. EXPORT/INTERNATIONAL CERTIFICATION PROGRAMS Yes Not Applicable 1. Please indicate the countries to which you are seeking certification or compliance verification. European Union (complete OHP 11A) US-EU equiv. Arrangement (compete OHP 11B) Canadian certification (complete Canadian Organic Handler/Processor Plan) US-Canada Equiv. Arrangement (complete OHP 12) OHP, V3, R03, 3/20/15 Page 3 of 45 No QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 1: APPLICATION NOP Rule 205.401 US-Japan Export Arrangement (complete OHP 10) Arrangement (complete OHP 14) US-Taiwan Export Arrangement (complete OHP 13) US-Korea Export Name of Preparer: Does this form supersede one previously filed for this operation? Yes No By signing below, I attest, under penalty of law that the answers provided in this form are true to the best of my knowledge. Signature of Preparer: Date: OHP 2 A: ORGANIC PRODUCT PROFILE DATE: Please complete an organic product profile for each product requested for certification. Organic Product Profiles must be kept current throughout the year and any changes must be submitted to QCS for review and approval. If certification is requested for packaged finished products, please complete the organic product profile for each product. 1.Name of the Product Requested for Certification: 2.List ID Marks/Brands, UPC/SKU, and/or net wt. of products using this OPP: 3.1. This product is packaged for: 4. Attach proposed labels for all finished products for which this OPP is used Attachment retail and/or All labels must be reviewed and approved by QCS prior to printing. Non-retail sale. 5. Percentage of Organic Ingredients: 6. Check which labeling category this product meets. “100% Organic” ingredients) “Organic” (> 95% organic ingredients) “Made with organic ingredients or food group(s)” (> 70% organic 7. Does this product contain sulfites, nitrates or nitrites added during the production or handling process? 8. Section A: Mark one of the following: Product Processed and Handled OR Yes No List of Only Packaged Finished Products Instructions: List below all ingredients and/or processing aids (including water and salt) used in processing this product, check the applicable boxes and supply the requested information. Add more rows if necessary. To calculate the percentage of organic ingredients: divide the total net weight or volume of combined organic ingredients (excluding water and salt) by the total weight or volume of all ingredients (excluding water and salt). # DESCRIPTION Ingredient or Processing Aid 01 OHP, V3, R03, 3/20/15 Organic or Non Organic Name of Supplier(s) List more than one if applicable Ingredient Organic Attach organic certificate Processing Aid Non organic –Complete Section B Page 4 of 45 Certifying Agent of Supplier % of Finished Product QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B Ingredient Organic –Attach organic certificate Processing Aid Non organic –Complete Section B 352.377.0133 If you need additional rows, please supply an additional spreadsheet with similar columns as indicated above. OHP, V3, R03, 3/20/15 Page 5 of 45 F 352.377.8363 www.qcsinfo.org QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 2 B: ORGANIC PRODUCT PROFILE- NONORGANIC INGREDIENTS SECTION B: NONORGANIC Not Applicable Please refer to the following website for the current “National List of Allowed and Prohibited Substances”: http://www.ams.usda.gov/nop/NOP/standards/ListReg.html 1. Do you understand that non organic nonagricultural substances used as ingredients or processing aids are allowed only when produced in accordance with the restrictions specified in §205.605 of the National List?. Yes No 2. Do you understand that non organic agricultural substances used as ingredients or processing aids are allowed only when listed in §205.606 of the National List in accordance with the restrictions specified and only when an organic form is not commercially available? Yes No Please contact the QCS office for description of determination of commercial availability. 3. For each non organic agricultural ingredient or processing aid, supply written verification that the product was not commercially available organically. N/A Attachment 4. Do you understand that non organic ingredients or processing aids must be produced or handled with without the use of excluded methods (as defined in 7 CFR 205.2), ionizing radiation (as described in 21 CFR 179.26), and sewage sludge, and, must not contain sulfites, nitrates or nitrites added during the production or handling process (except wine which may contain added sulfur dioxide)? Yes No Your organic system plan must include documentation to verify that non organic substances meet the criteria of the National Organic Program as described in 7 CFR 205. 5. Have you obtained written verification from each supplier of each non organic ingredient or processing aid listed in Section A, in the form of written verification, including signature and date, attesting that the ingredient or processing aid was produced or handled 1) without the use of excluded methods (as defined in 205.2), ionizing radiation (as described in 21 CFR 179.26), sewage sludge; 2) in accordance with the restrictions specified in §205.605 of the National List; 3) in accordance with the restrictions specified in §205.606 of the National List; and 4) in products represented as organic, does not contain sulfites, nitrates or nitrites added during the production or handling process (except wine which may contain added sulfur dioxide)? Yes No 5a. If no, please send Section C, QCS Ingredient and Excluded Methods Disclosure, to each supplier to be returned to you and submitted to QCS for review and consideration. For flavors complete section D 5b. If yes, provide the documentation for each supplier of each organic ingredient and/or processing aid. Attachment Name of Preparer: Does this form supersede one previously filed for this operation? Yes No By signing below, I attest, under penalty of law that the answers provided in this form are true to the best of my knowledge. Signature of Preparer: Date: OHP 2 C: ORGANIC PRODUCT PROFILE INGREDIENT & EXCLUDED METHODS DISCLOSURE SECTION C: INGREDIENT AND EXCLUDED METHODS DISCLOSURE OHP, V3, R03, 3/20/15 Page 6 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org The Ingredient and Excluded Methods Disclosure must be completed by the manufacturer/supplier of non organic ingredients and processing aids. Similar documentation may be copied and sent. Once completed and returned to you by the manufacturer/supplier, submit this disclosure to QCS for review and consideration. Copy and paste to company letterhead for optimal usage of the form. A. Dear Vendor: RE: Ingredient and Excluded Methods Disclosure In order to maintain our organic certification and to market our finished product as “organic ”or “made with organic”, we are required to obtain information for nonorganic ingredients and processing aids to ensure the substance we purchased is allowed for use according to the description and annotations as defined under 7 CFR 205 of the National Organic Program. Please supply responses to the questions listed below. Company Name: Name of Ingredient/Vendor product no: Does this product contain ingredients, incidental ingredients, or processing aids that were produced and handled with the use of excluded methods (as defined in 7 CFR 205.2)? Yes No If yes, please choose one of the following: The product (including incidental ingredients and processing aids) contains genetically modified DNA and/or proteins derived from genetically modified DNA. Please describe below the source of the genetically modified DNA and/or proteins. The product (including incidental ingredients and processing aids) was derived from a genetically modified source material, but should not contain genetically modified DNA and/or the proteins derived from genetically modified DNA due to processing which removed them. Please identify the source and describe below the testing method used to verify the absence of GMO’s. B. Ingredient Disclosure. Attach Product Specification Sheet. 1. 2. Attachment Does the product meet the restriction specified in 7 CFR 205.605? N/A Yes No Does the product meet the restriction specified in 7 CFR 205.606? N/A Yes No Please contact the QCS office for the “Determination of Commercial Availability”. A report must be submitted to QCS for review before a nonorganic substance listed in 205.606 can be approved. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. Does this product contain synthetic ingredients? Yes No Does this product contain synthetic carriers? Yes No Does this product contain processing aids? Yes No Does this product contain any ingredients that have any processing aids? Yes No Does this product contain incidental food additives or incidental ingredients? Yes No Does this product contain preservatives? Yes No Does this product contain artificial flavors? Yes No Does this product contain artificial colors? Yes No Is this product produced using synthetic solvents (hydrocarbons, chlorinated, halogenated)? Yes No Has this product (including it constituents) been exposed to Irradiation (as defined in 21 CFR 179.26)? Yes No Have the agricultural components of this product been grown on land fertilized with sewage sludge (as defined in 7 CFR 205.2)? No 14. For Salt only: Does the salt contain any free flowing and anticaking agents? Yes No 15. If the product is a FLAVOR, please also complete part C below. This product is not a flavor. OHP, V3, R03, 3/20/15 Page 7 of 45 Yes QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org If you have responded “yes” to any of the above questions, please provide a further explanation. Please provide as much detail as possible. This questionnaire is only to be signed by a qualified technical person 1 Pursuant to 7CFR §205.605(a)(9) and §205.105(e)(f)(g), I, on behalf of the supplier, hereby attest that the information provided in this form is accurate and truthful to the best of my knowledge. To the best of my knowledge, the above information is true and complete and the ingredient meets the criteria of the USDA National Organic Program. Date /Signature / Title 1 Falsifying statements to ACA’s or the Secretary under the NOP will be subject to possible fines OHP 2D: ORGANIC PRODUCT PROFILE FLAVORS SECTION D. Flavors The USDA National Organic Program (NOP) allows the use of certain natural (non-synthetic) substances, including flavors, in products labeled as “Organic” or “Made with Organic…(specified ingredients or food groups)” providing they comply with provisions established in the USDA NOP (7 CFR Part 205). The NOP defines Non-synthetic (natural) in 7 CFR 205.2: a substance that is derived from mineral, plant or animal matter and does not undergo a synthetic process as defined in section 6502 (21) of the Act (7 U.S.C. 6502(21)). Under the terms of the Act, "synthetic" means a substance that is formulated or manufactured by a chemical process or by a process that chemically changes a substance extracted from naturally occurring plant, animal or mineral sources, except that such term shall not apply to substances created by naturally occurring biological processes. Non-synthetic Flavors authorized under the NOP, Section 205.605 (a) must be from non-synthetic sources only and must not be produced using synthetic solvents, carrier systems or any artificial preservative(s). In addition, Sections 205.105 (e)(f)(g) respectively prohibit so-called “excluded” methods (GMOs), ionizing radiation or sewage sludge, defined in 205.2, from being applied to any ingredients or products under the NOP. FDA Definition of Natural Flavors FDA 21 CFR Part 101.22(a)(3): “… natural flavor or natural flavoring means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional. Natural flavors include [but not exclusively] the natural essences or extractives obtained from plants listed in §§182.10, 182.20, 182.40, and 182.50 and part 184 of this chapter, and the substances listed in §172.510 of this chapter.” The use of this questionnaire is to determine compliance of a natural flavor for use in an “organic” or “made with organic…” product under the terms of the NOP. QCS may request additional information as needed. 1. Identification of Natural Flavor Product (code/Name): Supplier Name, Address: 1.a Type of flavor (select one or more as necessary): Compounded flavor Compounded WONF OHP, V3, R03, 3/20/15 Extracts Essential oil Page 8 of 45 Isolate Oleo resin QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 2D: ORGANIC PRODUCT PROFILE FLAVORS Distillate 2. Flavor constituents: Essential oil Isolate Other (e.g. single flavor chemical): Natural flavors authorized for use in NOP “organic” or “made with organic” products, in addition, must not be produced using synthetic extraction solvents. Extraction may only use nonsynthetic, non-petroleum based solvents. 2a.Do all of the flavor constituents in the natural flavor product named above meet the FDA definition of a natural flavor (see above)? No 2b.Is/are the natural flavor constituent(s) made using NOP-suitable extraction solvents*? Yes No Yes Not Applicable 2c.If the solvent used to extract the natural flavors is not listed as an example of one of the NOP-suitable extraction solvents please disclose: Not Applicable *Allowed natural extraction solvents include water, natural ethanol, super-critical carbon dioxide, authentic essential oil, and natural vegetable oils. No hydrocarbon solvents, or chlorinated, or halogenated solvents may be used. Propane, hexane, and freon are examples of solvents that are prohibited. 3. Non-flavor constituents and other ingredients: Natural flavors authorized for use in NOP “organic” or “made with organic” products must not contain any synthetic carrier systems or any artificial preservatives. This extends to synthetic processing aids, emulsifiers or antioxidants; i.e. prohibited substances include but are not limited to: propylene glycol, polyglycerol esters of fatty acids, mono- and di-glycerides, benzoic acid, polysorbate 80, medium chain triglycerides, BHT, BHA, triacetin, etc. 3a. Please list any carrier system(s) used in this Natural Flavor Product or attach an Ingredient Statement: No carrier system(s) used 3b. Please list any preservative(s), other additives or foodstuff ingredients used in this Natural Flavor Product or attach an Ingredient Statement: No preservative(s), or other additives used 3c. Are any of the NON-flavor constituent’s synthetic (see definition in Section C. above)? 3d. If synthetic, are they listed on the NOP National List at § 205.605(b)? 3e. Are any of the NON-flavor constituents USDA NOP certified Organic? 4. Glycerin used is produced by hydrolysis of fats and oils? Yes No N/A, none used 5. Maltodextrin used is hydrolyzed primarily by enzymes. Yes No N/A, none used 6. Citric acid used is produced primarily by fermentation of carbohydrates? Yes No Yes Yes Yes No No No N/A N/A N/A N/A, none used 7. Genetically Modified Organism (GMO) products may not be used at any stage in the process of making natural flavor products for NOP goods. GMO uses a variety of methods used to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes and are not considered compatible with organic production. Such methods include but are not limited to recombinant DNA technology (including gene deletion, gene doubling, introduction of a foreign gene, and changing the positions of genes when achieved by recombinant DNA technology); therefore, GMO-plant extracts may not be used nor may natural flavors be the product of GMO-yeast fermentation, for example. Was this Natural Flavor Product (including any solvents, carriers, preservatives or other processing aids used or contained therein) produced and handled using excluded (GMO) methods? Yes No OHP, V3, R03, 3/20/15 Page 9 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 2D: ORGANIC PRODUCT PROFILE FLAVORS 8. Ionizing Radiation is prohibited for all uses involving food preservation, pest control and pathogen control in NOP products. Other radiation uses, including food inspection, are permitted providing such use meets applicable FDA regulations, which establish limitations applicable to all (organic and non-organic) food products. Was ionizing radiation as described in 21 CFR 179.26 used in the processing of this natural flavor product? Yes No 9. Sewage Sludge (as a crop fertilizer) is solid, semisolid, or liquid residue generated during the treatment of domestic sewage in a treatment works. Sewage sludge includes but is not limited to: domestic septage; scum or solids removed in primary, secondary, or advanced wastewater treatment processes; and a material derived from sewage sludge. It is not permitted in the manufacture of any ingredients used in NOP products. Was this Natural flavor Product derived from products using sewage sludge in their agricultural production? Yes No This questionnaire is only to be signed by a qualified technical person 1 Pursuant to 7CFR §205.605(a)(9) and §205.105(e)(f)(g), I, on behalf of the supplier, hereby attest that the information provided in this form is accurate and truthful to the best of my knowledge. To the best of my knowledge, the above information is true and complete and the ingredient meets the criteria of the USDA National Organic Program. Date /Signature / Title 1 Falsifying statements to ACA’s or the Secretary under the NOP will be subject to possible fines OHP 3: Labeling of Product(s) NOP 205.303, 205.304, 205.307, 205.311 QCS clients are required to abide by the labeling requirements for retail and non-retail packaging. For all retail packaging, complete Section A, and for non-retail packaging, complete Section B. Section(s) C and D must be completed if the USDA and/or QCS seal is used on packaging. All labels submitted for products in OHP 2 that are used on retail packaging must be reviewed and approved by QCS prior to printing on packaging, stickers, etc. SECTION A: RETAIL Choose the applicable category(s), and answer the corresponding questions. A1: 100% ORGANIC Applicable Not Applicable 1. Do the product(s) contain by weight or fluid volume, (excluding water and salt) 100 % organically produced ingredients? (i.e. all ingredients are certified as 100% Organic) Yes 2. Do you use a processing aid? No Yes No If a processing aid is added during the production or handling process, it must be certified organic. OHP, V3, R03, 3/20/15 Page 10 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 OHP 3: Labeling of Product(s) 3. Is the processing aid certified organic? Yes F 352.377.8363 www.qcsinfo.org NOP 205.303, 205.304, 205.307, 205.311 No 4. Check, if applicable, the marketing claim(s) displayed on the package: 100% Organic Other 5. Do the package(s) display the statement “Certified Organic by (name of certification agency)” on the information panel, below the information identifying the handler or distributor of the product, with no printed material or information in between? 6. Is the USDA Seal displayed on the package(s)? Yes No Yes If yes, complete Section C. 7. Do the package(s) display the seals, logos or other identifying marks of the organic certifying agent? 7a. If yes, which mark? A2: ORGANIC No QCS Organic Seal (Complete Section D) Yes No Other Not Applicable 1. Do the product(s) contain by weight or fluid volume, (excluding water and salt) not less than 95 % organically produced ingredients? Yes No 1a. If yes, the remaining 5% ingredients in the product are (check all that apply): Nonagricultural (non organic) substance(s) listed in §205.605 (National List) Non-organically produced agricultural products listed in §205.606 (National List) Other 2. Is the percentage of organic ingredients in the product displayed on the package(s)? Yes No 2a. If yes, does the size of the percentage statement not exceed one-half the size of the largest type size on the panel on which the statement is displayed? Yes No 2b. If yes, does the percentage statement appear in its entirety in the same type size, style and color without highlighting? 3. Are all organic ingredients identified as “organic” in the ingredient statement? Yes Yes No No 3a. If yes, how are they identified? With the word “organic” With an asterisk or other reference mark which is defined below the ingredient statement to indicate the ingredient is organically produced. 4. Do you understand that water or salt may not be identified as organic? Yes No 5. Do the package(s) display the statement “Certified Organic by (name of certification agency)” on the information panel, below the information identifying the handler or distributor of the product, with no printed material or information in between? 6. Is the USDA Seal displayed on the package(s)? OHP, V3, R03, 3/20/15 Yes No If yes, complete Section C. Page 11 of 45 Yes No QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 OHP 3: Labeling of Product(s) 352.377.8363 www.qcsinfo.org NOP 205.303, 205.304, 205.307, 205.311 7. Do the package(s) display the seals, logos or other identifying marks of the organic certifying agent? 7a. If yes, which mark? F QCS Organic Seal (Complete Section D) A3: MADE WITH ORGANIC INGREDIENTS Applicable Yes No Other Not Applicable 1. Do the product(s) contain by weight or fluid volume, (excluding water and salt) at least 70 % organically produced ingredients? Yes No 1a. If yes, the remaining 30% of ingredients in the product are (check all that apply): Agricultural ingredients that are not organic Nonagricultural (non organic) substance(s) listed in §205.605 (National List) Non-organically produced agricultural products listed in §205.606 (National List) Other 2. Are the remaining 30% of ingredients produced without the use of any of the following (check all that apply): Excluded Methods (as defined in 7 CFR 205.2) Sewage Sludge Ionizing radiation 3. Do you understand that the USDA Seal must not be displayed on products labeled as “made with organic ……”? Yes No 4. Check, if applicable, the marketing claim(s) displayed on the package: The statement “Made with Organic (Specified Ingredients)” The percentage of organic ingredients The statement “Made with Organic (Specified Food Groups)” QCS organic Seal (complete Section D) Other 5. If the package displays the statement “Made with Organic (Specified Ingredients)”, does the statement list not more than (3) three organically produced ingredients? Yes No Not applicable 6. If the package displays the statement “Made with Organic (Specified Food Groups)”, does the statement list not more than (3) three of the following food groups: beans, fish, fruits, grains, herbs, meats, nuts, oils, poultry, seeds, spices, sweeteners, and vegetables or processed milk products? Yes No Not applicable 6a. Do you understand that all ingredients per food group must be organically produced? OHP, V3, R03, 3/20/15 Page 12 of 45 Yes No QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 3: Labeling of Product(s) 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP 205.303, 205.304, 205.307, 205.311 7. If the package displays “ Made with Organic (specific ingredients)” or “ Made with Organic “ Specific Food Groups)” does the size of the letter not exceed one half the size of the largest type on the panel in which statement is displayed and does the statement appear in its entirety in the same type size, style and color without highlighting? Yes No Not applicable 8. If the percentage of organic ingredients in the product is displayed on the package(s), does the size of the percentage statement not exceed one-half the size of the largest type size on the panel on which the statement is displayed? Yes No Not applicable 8a. Does the percentage statement appears in its entirety in the same type size, style and color without highlighting? 9. Are all organic ingredients identified as “organic” in the ingredient statement? 9a. If yes, how are they identified? With the word “organic” Yes Yes No No With an asterisk or other reference mark which is defined below the ingredient statement to indicate the ingredient is organically produced. 10. Do you understand that water or salt may not be identified as organic? Yes No 11. Do the package(s) display the statement “Certified Organic by (name of certification agency)” on the information panel, below or otherwise near the information identifying the handler or distributor of the product, with no printed material or information in between? SECTION B: NON-RETAIL Applicable Yes No Not Applicable Labeling of non-retail containers used to transport or store raw or processed product. 1. Do you understand that non-retail containers used for transport or storage of organic product must display the production lot number of the product? Yes No Not Applicable 1a. If applicable, check information that may be found on non-retail containers: Name of Certification Agency of final product Identification of product as organic Organic Integrity Special Handling Instructions USDA Seal Quality Certification Services seal or logo 2. Are any non-retail containers intended for export labeled in accordance with any requirements of the foreign country of destination or foreign contract buyer for transporting (air or ship) product for export? OHP, V3, R03, 3/20/15 Yes Page 13 of 45 No QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 3: Labeling of Product(s) 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP 205.303, 205.304, 205.307, 205.311 2b. If yes, what is the product and country of destination? 3. Provide regulations or transportation specifications: Attachment 4. Do you understand that transport containers and documents must accompany organic products and be marked “For Export Only”? Yes No 5. Do you understand that all product transported for export must have a sufficient audit trail that proves ingredients identified as organic were organically produced and handled, verifies the quantities produced from ingredients, and traceable back no less than 3 years beyond their creation? Yes No SECTION C: USE OF THE USDA SEAL Applicable Not Applicable 1. Do you understand that the USDA seal must replicate the form and design as described in §205.311, and must be printed legibly and conspicuously? Yes No 2. Check which design of the USDA Seal is marked on the product: White background with a brown outer circle and with the term “USDA,” in green overlaying a white upper semicircle and with the term, “organic,” in white overlaying the green lower half circle OR White or transparent background with a black outer circle and black “USDA,” on a white or transparent upper half of circle with a contrasting white or transparent “organic” on the black lower half circle. 3. If applicable, does the green or black lower half of the circle include four light lines running from left to right and disappearing at the point on the right horizon to resemble a cultivated field? Yes No The USDA seal can be downloaded from the following website: http://www.ams.usda.gov/nop/Consumers/Seal.html OHP, V3, R03, 3/20/15 Page 14 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 OHP 3: Labeling of Product(s) SECTION D: USE OF THE QCS SEAL F 352.377.8363 www.qcsinfo.org NOP 205.303, 205.304, 205.307, 205.311 Applicable Not Applicable 1. Do you understand that If the product label contains the certifying agents seal/mark, the seal/mark must be displayed less prominently than the USDA Seal? Yes No Name of Preparer: Does this form supersede one previously filed for this operation? Yes No By signing below, I attest, under penalty of law that the answers provided in this form are true to the best of my knowledge. Signature of Preparer: Date: OHP 4: Product Process NOP §205.270 A. PRODUCT FLOW 1. Provide a complete written description or schematic product flow chart which describes the movement of all organic products, from incoming/receiving, through production and to outgoing/shipping. Indicate where ingredients are added and/or processing aids are used. Identify equipment and storage areas. Attachment B. BY PRODUCTS 1. Will any by-products from the production process be sold as certified organic? Yes 1a. If yes, list all organic by-products and provide Organic Profile Sheets for each by-product. No Not applicable Attachment C. WATER 1. Check ways water is used in processing: product transport 2. Source of water: None used cleaning organic products municipal OHP, V3, R03, 3/20/15 on-site well ingredient cleaning equipment other, specify Page 15 of 45 processing aid other (specify) cooking cooling QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 OHP 4: Product Process F 352.377.8363 www.qcsinfo.org NOP §205.270 3. Does the water meet the Safe Drinking Water Act? Yes 4. What on-site water treatment processes are used? None No 5. Is steam used in the processing or packaging of organic products? Water Test Attached Yes No 5a. If yes, describe how steam is used. 5b. If steam has direct contact with organic products, do you use: steam filters condensate traps 6. List products used as boiler additives. testing of condensate No direct contact testing of finished products No boiler additives used other (specify) Attach MSDS and/or label information for boiler additives 7. Describe how you monitor water quality. 8. How often do you conduct water quality monitoring? weekly monthly annually as needed other (specify) Name of Preparer: Does this form supersede one previously filed for this operation? Yes No By signing below, I attest, under penalty of law that the answers provided in this form are true to the best of my knowledge. Signature of Preparer: Date: OHP 5: Pest Management NOP Rule 205.271 A. FACILITY MAP 1. Attach a facility map showing the location of interior and exterior traps and monitors, and submit MSDS and/or label information for substances used for pest control, if applicable. Pest Control Facility Map Attachment Pest Control MSDS/Label Attachments OHP, V3, R03, 3/20/15 Page 16 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 OHP 5: Pest Management F 352.377.8363 www.qcsinfo.org NOP Rule 205.271 B. PEST MANAGEMENT PLAN 1. Do you have a facility pest management plan in place to address §205.271 “Facility Pest Management Practice Standard” and §205.272 “Commingling and Contact with Prohibited Substance Prevention Practice Standard”? 1a. If yes, please attach a copy. Yes No Attachment 2. Do you work with a pest control company? Yes No 2a. If yes, give name and contact information. 3. What area of the plant does the pest control company cover? Exterior Interior Both 4. Have you notified the pest control company of the “Facility Pest Management Practice Standard” outlined in §205.271 and the “Commingling and Contact with Prohibited Substance Prevention Practice Standard” outlined in §205.272? Yes No 5. What are your problem pests? mice spiders birds No pest problems other pests (specify) flying insects crawling insects rodents gophers 6. Check all pest management measures used at your facility to prevent pests: Stage One good sanitation removal of exterior habitat/food sources removal of breeding areas clean up spilled product exclusion maintaining inhabitable temperatures sealed doors and/or windows repair of holes, cracks, etc. Screened windows, vents, etc. physical barriers sheet metal on sides of building exterior mowing air curtains air showers positive air pressure in facility monitoring incoming ingredient inspection for pests inspection zones around interior perimeter ultrasound/light devices sticky traps electrocutors mechanical traps scare eye balloons freezing treatments heat treatments vacuum treatments carbon dioxide nitrogen material recycling on-site dumpster daily pick-up of waste composting other (specify) Stage Two release of beneficials precipitated silica other (specify) OHP, V3, R03, 3/20/15 pheromone traps pyrethrum vitamin baits ryania boric acid rotenone Page 17 of 45 diatomaceous earth disodium octal tetrahydrate rats QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 5: Pest Management Stage Three fumigation fogging crack and crevice spray C. STAGE ONE: PEST PREVENTION PRACTICES NOP Rule 205.271 other (specify) Pest prevention practices must be the first and primary line of defense against pest infestation. Only upon documented use and failure of such measures to control pests may a nonsynthetic or synthetic substance consistent with the National List may be applied, i.e., Stage Two measures. STAGE ONE measures Not Applicable 1. Do you have records or supporting documentation demonstrating use of Stage One measures? Yes No D. STAGE TWO: NONSYNTHETIC SUBTANCES OR SYNTHETIC SUBSTANCES LISTED ON THE NATIONAL LIST. Stage Two measures may only be used when Stage One practices have failed to control the pest problem. Stage Two measures include the use of the following: 1) non-synthetic, non-prohibited pest control substances that are botanically derived and whose inert ingredients all are listed on the EPA List 4; and 2) synthetic substances that are listed on the National List (e.g., §205.601). STAGE TWO measures Not Applicable 1. Which Stage One Preventative Measure(s) proved ineffective? 2. Do you have records or supporting documentation demonstrating the ineffectiveness of Stage One measures? Yes No 3. Do you understand that Stage Two inputs can only be used when Stage One measures have been proven insufficient? Yes No 4. List the STAGE TWO Substances Used As a Line of Defense Against Infestation: Submit MSDS sheets for all substances listed below. OHP, V3, R03, 3/20/15 Attachment Page 18 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F OHP 5: Pest Management Substance 352.377.8363 www.qcsinfo.org NOP Rule 205.271 Target pest Location Method of where used Application Date of last application Status: approved(A) Restricted (R) Prohibited (P) 5. List all measures taken to prevent contact of organically produced products, ingredients, packaging materials, storage containers, etc. with the substances used. 6. Are these measures documented? OHP, V3, R03, 3/20/15 Yes No Page 19 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 352.377.0133 P F 352.377.8363 www.qcsinfo.org OHP 5: Pest Management NOP Rule 205.271 E. STAGE THREE: USE OF PEST CONTROL SUBSTANCES NOT LISTED ON NATIONAL LIST Stage Three measures may only be used when Stage One and Two measures have failed to control the pest problem. Stage Three measures include the use of a synthetic substance not listed on the National List, provided, that the handler and certifying agent agree on the substance, method of application, and measures to be taken to prevent contact of the organically produced products or ingredients with the substance used. STAGE THREE measures Not Applicable 1. Which Stage Two Measure(s) proved ineffective? 2. Do you have records or supporting documentation to demonstrate the ineffectiveness of Stage Three measures? Yes No 3. Do you understand that Stage Three measures can only be used when all other means have been proven insufficient? Yes No 4. Do you understand that you must contact the certifying agent for prior approval before using Stage Three Measures? Yes No 5. List the STAGE THREE Substances Used As a Line of Defense Against Infestation: Submit MSDS sheets for all substances listed below. Substance Target pest Attachment Location Method of where used application Date of last application Status: approved(A) Restricted (R) Prohibited (P) OHP, V3, R03, 3/20/15 Page 20 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 OHP 5: Pest Management F 352.377.8363 www.qcsinfo.org NOP Rule 205.271 6. List all measures taken to prevent contact of organically produced products, ingredients, packaging materials, storage containers, etc., with the substances used. 7. Are these measures documented? Yes No 8. If prohibited pest control products were used, what measures are you taking or planning to take to prevent their use in the future? 9. Are you required by local, State or Federal Law and regulation to use a prohibited substance? Yes No 9a. If yes, list substance(s)? Name of Preparer: Does this form supersede one previously filed for this operation? Yes No By signing below, I attest, under penalty of law that the answers provided in this form are true to the best of my knowledge. Signature of Preparer: Date: OHP 6: Assurance of Organic Integrity NOP Rule 205.201(a)(b), and 205.272 NOP Rule requires that handling practices and procedures present no contamination risk to organic products from commingling with non-organic products or contact with prohibited substances. Packaging materials, bins, and storage containers must not have contained synthetic fungicides, preservatives, or fumigants. Reusable bags or containers must be clean and pose no risk to the integrity of organic products. Procedures used to maintain organic integrity must be documented. OHP, V3, R03, 3/20/15 Page 21 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 6: Assurance of Organic Integrity 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP Rule 205.201(a)(b), and 205.272 A. PROCESS MONITORING PROGRAMS 1. Do you have an organic integrity program in place to address areas of potential commingling and/or contamination? Yes No 1a. If yes, please attach a copy of your organic integrity program, or list specific control points you have identified in your process and state how you have addressed them to protect organic integrity. Attachment 1b. If no, do you have plans to implement an organic integrity program? Yes No 2. Do you have a Quality Assurance program in place? Yes No 2a. If yes, what program do you use? ISO HACCP TQM 3. Are any outside quality assessment services used (e.g. AIB)? Yes other (specify) No 3a. If yes, name of company: 4. Check the type(s) of Product Testing: (Check all that apply) ingredients tested prior to purchase ingredients tested upon receipt finished products tested other (specify) 5. Do you have a product recall system in place? Yes products tested during production No B. EQUIPMENT 1. List all equipment used in processing. CHECK IF EQUIPMENT IS EQUIPMENT NAME OHP, V3, R03, 3/20/15 CLEANED PRIOR TO ORGANIC CHECK IF EQUIPMENT IS DEDICATED ORGANIC () PRODUCTION () CHECK IF THE EQUIPMENT IS PURGED PRIOR TO ORGANIC PRODUCTION () Page 22 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 6: Assurance of Organic Integrity 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP Rule 205.201(a)(b), and 205.272 2. If equipment is purged, describe purge procedures, and quantities purged. 3. Is purging of equipment documented? Yes No C. SANITATION 1. Using the options below complete the sanitation chart: sweeping scraping vacuuming compressed air steam cleaning sanitizing other (specify) manual washing 2. Are all areas food grade that come into direct contact with organic product? AREA TYPE OF CLEANING PRODUCTS USED Receiving area Ingredient storage Product transfer OHP, V3, R03, 3/20/15 Page 23 of 45 Yes clean in place (CIP) No FREQ CHECK IF CLEANING IS DOCUMENTED () QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 6: Assurance of Organic Integrity F 352.377.8363 www.qcsinfo.org NOP Rule 205.201(a)(b), and 205.272 Production area Production equipment Packaging area Finished product storage Loading dock Building exterior Accidental spills Other (specify) Other (specify) Other (specify) OHP, V3, R03, 3/20/15 352.377.0133 Page 24 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 6: Assurance of Organic Integrity 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP Rule 205.201(a)(b), and 205.272 D. CLEANING AND SANITIZING SUBSTANCES 1. For each cleanser and sanitizer product used to clean and sanitize surfaces in contact with organic products, attach the MSDS and/or product label. None Used MSDS/product label Attachment 2. Does an intervening event occur (such as a water rinse or pressure wash) after use of sanitizers? Yes No 3. Do you test food contact surfaces to ensure that the intervening event was sufficient to remove cleanser and sanitizer residues? No 3a. If yes, are the test results documented? Yes Yes No 3b. If yes, please explain process. 4. Where are cleaning/sanitizing materials stored? E. SUBSTANCES IN DIRECT CONTACT WITH ORGANIC PRODUCT DURING PRODUCTION 1. List products used as defoaming agents in water that has direct contact with organic products. 1a. For each defoaming agent, attach the MSDS and/or product label. No defoaming agents used Attachment 2. List products used to clean and/or sanitize that are in direct contact with organic products (e.g. substances added to wash water). used 2a. For each cleaning/sanitizing agent, attach the MSDS and/or product label. Attachment F. PACKAGING 1. Check types of packaging material used: paper cardboard wood glass metal foil plastic waxed paper aseptic natural fiber synthetic fiber other (specify) OHP, V3, R03, 3/20/15 Page 25 of 45 None QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 6: Assurance of Organic Integrity 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP Rule 205.201(a)(b), and 205.272 2. Do the packaging materials, storage containers or bins contain synthetic fungicides, preservatives, or fumigants? Yes No 2a. If yes, describe exposure, including name of products used, and measures taken to ensure that a prohibited substance does not come into contact with packaging materials. 3. Are packaging materials reused? Yes No 3a. If yes, describe how reusable packaging materials are cleaned prior to use. 4. Are any packaging materials dedicated organic? Yes No 5. Are any packaging materials provided by your client(s)? Yes No 6. Are any fungicides, fumigants, or pest control products used in this storage area? Yes No 6a. If yes, are measures implemented to protect packaging products from contact with prohibited substances? Yes No G. STORAGE 1. Provide information on your storage areas by completing the following table. Use LOCATION TYPE/CAPACIT IDENTIFICATION IS STORAGE UNIT COMMENTS ON POTENTIAL FOR CONTAMINATION OR Y NAME OR DEDICATED COMMINGLING PROBLEMS NUMBER ORGANIC? Ingredient storage Packaging material storage In-process storage Finished product storage Off-site storage Other (specify) H. OFF-SITE STORAGE 1. Provide name, address, phone number, contact person and type of products stored at off-site facility. OHP, V3, R03, 3/20/15 Page 26 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 6: Assurance of Organic Integrity 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP Rule 205.201(a)(b), and 205.272 2. Do you understand that off-site facilities may be inspected by QCS? Yes 3. Which of the following records do you keep for STORAGE? ingredient inventory reports finished product inventory reports No other (specify) I. TRANSPORTATION OF ORGANIC PRODUCTS INCOMING: 1. In what forms are incoming products received? dry bulk liquid bulk tote bags foil bags other (specify) tote boxes metal drums cardboard drums paper bags 2. How are incoming products transported? truck tanker rail overseas container 3. Do you arrange incoming product transport? Yes other (specify) No 4. If you use transport companies, have they been notified of organic handling requirements? Yes No 5. Are transport units used to carry nonorganic products or prohibited substances? Yes No 5a. If yes, do you ensure that inbound transport units are cleaned prior to loading organic products? Yes No 5b. If yes, is the inspection/cleaning process documented? Yes No 5c. If yes, check all steps taken to segregate organic products: use of separate pallets pallet tags identifying "organic" organic product shrink wrapped separate area in transport unit organic product sealed in impermeable containers other (specify) 6. Which of the following records do you keep for incoming products? Organic Certificates Transaction certificates purchase orders contracts invoices bills of lading Customs forms scale tickets quality test results Certificates of Analysis receiving records receiving summary log other (specify) IN-PROCESS: 1. How are in-process products transported? OHP, V3, R03, 3/20/15 Page 27 of 45 receipts QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 6: Assurance of Organic Integrity 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP Rule 205.201(a)(b), and 205.272 2. How do you ensure that in-process transport units are cleaned? 3. Is the inspection/cleaning process documented? Yes No 3a. If yes, which of the following records do you keep for IN-PROCESS? equipment clean-out logs sanitation logs ingredient inspection forms blending reports production reports packaging reports QA reports other (specify) TRANSPORTATION OF ORGANIC PRODUCTS (continued) OUTGOING FINISHED: 1. In what form are finished products shipped? dry bulk liquid bulk tote bags mesh bags cardboard cases plastic crates paper bags other (specify) 2. How are outgoing products transported? truck tanker rail overseas container other (specify) foil bags metal drums 3. Do you arrange outgoing product transport? Yes No 4. If you use transport companies, have they been notified of organic handling requirements? Yes No 5. Are transport units used to carry nonorganic products or prohibited materials? Yes No 5a. If yes, do you ensure that outgoing transport units are cleaned prior to loading organic products? 5b. If yes, is the inspection/cleaning process documented? Yes Yes cardboard drums No No 5c. If yes, check steps taken to segregate organic products: use of separate pallets separate area in transport unit pallet tags identifying "organic" organic product shrink wrapped organic product sealed in impermeable containers other (specify) 6. Which of the following records do you keep for OUTGOING FINISHED PRODUCT? shipping log clean truck affidavits bills of lading scale tickets OHP, V3, R03, 3/20/15 Page 28 of 45 purchase orders sales orders QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 6: Assurance of Organic Integrity sales invoices sales summary log phytosanitary certificates audit control register 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP Rule 205.201(a)(b), and 205.272 export declaration forms complaint log other (specify) shipping summary log J. LOT NUMBER 1. Describe your lot numbering system. 2. Can your record keeping system track the finished product back to all ingredients? 3. Can your record keeping system balance organic ingredients in and organic products out? Yes Yes No No Name of Preparer: Does this form supersede one previously filed for this operation? Yes No By signing below, I attest, under penalty of law that the answers provided in this form are true to the best of my knowledge. Signature of Preparer: Date: OHP 7: Record Keeping NOP 205.103 To facilitate a speedy review of your organic system plan and inspection of your facility, please remember to include the following, as applicable to your operation: APPLICATION (Submit to QCS office, as applicable) Attachment OHP 1 Driving Directions to all Locations requested for certification Attachment OHP 1 Legal Status of Organic Operation Attachment OHP 1 Organic Certificate(s) for Subcontracted Operations Attachment OHP 1 Application(s) for non-certified Subcontracted Operations Attachment OHP 1 Description of circumstances if previously denied organic certification Attachment OHP 1 Description of circumstances if previously suspended or revoked organic certification Attachment OHP 2 Proposed labels for all finished products for which this OPP is used Attachment OHP 2 Certificate(s) from each supplier of organic ingredients and/or processing aids Attachment OHP 2 For each non organic agricultural ingredient or processing aid, written verification that the product was not commercially available organically Attachment OHP 2 Written verification from each supplier of each nonorganic ingredient and/or processing aid, stating the material was not produced using prohibited methods or materials. Attachment OHP 2 Product Specification Sheet for ingredients OHP, V3, R03, 3/20/15 Page 29 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 7: Record Keeping NOP 205.103 Attachment OHP 3 Regulations for any non-retail containers intended for export labeled in accordance with any requirements of the foreign country of destination or foreign contract buyer for transporting (air or ship) product for export Attachment OHP 4 A complete written description or schematic product flow chart describing the movement of all organic products, from incoming/receiving, through production and to outgoing/shipping Attachment OHP 4 Organic Product Profile (OPP) Sheets for each by-product Attachment OHP 4 Water Test Attachment OHP 4 MSDS and/or product label for boiler additives Attachment OHP 5 Facility map showing the location of traps and monitors, and submit MSDS and/or label information for substances used for pest control Attachment OHP 5 MSDS and /or product label for pest control substances Attachment OHP 5 Facility pest management plan to address §205.271 “Facility Pest Management Practice Standard” and §205.272 “Commingling and Contact with Prohibited Substance Prevention Practice Standard” Attachment OHP 6 Organic integrity program, or list specific control points you have identified in your process and state how you have addressed them to protect organic integrity Attachment OHP 6 MSDS and/or product label for each cleanser and sanitizer used to clean and sanitize surfaces in contact with organic products Attachment OHP 6 MSDS and/or product label for de-foaming agent(s) Attachment OHP 6 MSDS and/or product label for each cleanser and sanitizer that directly contacts organic products Attachment OHP 10 Documentation from supplier’s certifying agent verifying compliance with US-Japan Export Arrangement Attachment OHP 11 EC 834/2004, 889/2008 organic certificate Attachment OHP 12 Documentation from supplier’s certifying agent verifying compliance with US-Canada Equivalence Arrangement Attachment OHP 13 Documentation from supplier’s certifying agent verifying compliance with US-Taiwan Export Arrangement Attachment OHP 14 Documentation from supplier’s certifying agent verifying compliance with US-Korea Equivalence Arrangement INSPECTION (Make available Upon Inspection, as applicable) Incoming Records In-process Records Out-going Records OHP, V3, R03, 3/20/15 Organic Certificates Transaction certificates purchase orders contracts bills of lading Customs forms scale tickets quality test results receiving records receiving summary log other (specify) equipment clean-out logs production reports sanitation logs packaging reports ingredient inspection forms QA reports shipping log clean truck affidavits bills of lading sales orders sales invoices phytosanitary certificates shipping summary log sales summary log audit control register Page 30 of 45 invoices receipts Certificates of Analysis blending reports other (specify) scale tickets purchase orders export declaration forms complaint log other (specify) QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 7: Record Keeping NOP 205.103 1. Do you understand that records must disclose all activities and transactions of the operation, be maintained for 5 years, and demonstrate compliance with the NOP Rule? Yes No 2. Do you understand that all relevant documents must identify products as "organic”? Yes No 3. Do you understand that all records must be available to the inspector, and NOP representatives for inspection and copying during normal business hours? Yes No Name of Preparer: Does this form supersede one previously filed for this operation? Yes No By signing below, I attest, under penalty of law that the answers provided in this form are true to the best of my knowledge. Signature of Preparer: Date: OHP 8: Exemptions and Exclusions from Certification NOP 205.101 Some operations may be exempt or excluded from certification. Complete OHP 8 only if you have responded “yes” to section “D. Exempt/Excluded” in OHP1: Application. A. EXEMPT FROM CERTIFICATION 1. Is the operation exempt from certification because the gross agricultural income from organic sales totals $5,000 or less annually? Yes Not Applicable 2. If yes, do you understand that products shall not be used as ingredients identified as organic in processed products produced by another operation? Yes No 3. Is the operation exempt from certification because it is a retail food establishment or portion of a retail food establishment that handles organically produced agricultural products but does not process them? Yes Not Applicable 4. Is the operation exempt from certification because it or portion of the handling operation only handles agricultural products that contain less than 70 percent organic ingredients by total weight of the finished product (excluding water and salt)? Yes Not Applicable 5. Is the operation exempt from certification because it is a handling operation or portion of a handling operation that only identifies organic ingredients on the information panel? Yes Not Applicable If you answered yes, to the above: 6. Do you understand that you must comply with the provisions for prevention of contact of organic products with prohibited substances set forth in 205.272 with respect to any organically produced ingredients used in an agricultural product? Yes (Submit OSH 6) No 7. Do you understand that you must comply with the labeling provisions of NOP §205.305 and 205.310? Yes (Submit OSH 3) No 8. Do you understand that you must maintain records sufficient to prove that ingredients identified as organic were organically produced and handled, verify quantities produced from such ingredients, and maintain records for no less than 3 years beyond their creation and the records must be available to the inspector and NOP representatives for inspection and copying during normal business hours? Yes No OHP, V3, R03, 3/20/15 Page 31 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 8: Exemptions and Exclusions from Certification 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP 205.101 B. EXCLUDED FROM CERTIFICATION 1. Is the product packaged or otherwise enclosed in a container prior to being received or acquired by the operation, and does the product remain in the same package or container and is not otherwise processed while in the control of the handling operation? Yes No 2. Is the operation excluded from certification because the handling operation is a retail food establishment or portion of a retail food establishment that processes on the premises of the retail food establishment, raw and ready-to-eat food from agricultural products that were previously labeled as “100 percent organic”, “organic”, or “made with organic (specified ingredients or food groups)”? Yes No 3. If you answered yes to any of the above: 4. Do you understand that you must comply with the provisions for prevention of contact of organic products with prohibited substances set forth in 205.272 with respect to any organically produced ingredients used in an agricultural product? Yes (Submit OSH 6) No 5. Do you understand that you must comply with the labeling provisions of NOP §205.310? Yes (Submit OSH 3) No Name of Preparer: Does this form supersede one previously filed for this operation? Yes No By signing below, I attest, under penalty of law that the answers provided in this form are true to the best of my knowledge. Signature of Preparer: Date: OHP 9: QCS Certification and Mark Licensing Contract NOP Rule 205.202 & 205.203.(b)-(c) Effective on the date which Florida Certified Organic Growers and Consumers, Inc., doing business as Quality Certification Services (QCS) issues a USDA National Organic Program certificate to ___________________ (Client), QCS and Client enter into this contract and agree to be bound by its provisions regarding the certification services provided by QCS and the authorized uses of the QCS certification mark and its variants. By signing this contract, Client and QCS agree to be bound by the following provisions: 1. Period of Performance: This contract becomes effective on the date on which QCS issues a USDA National Organic Program certificate to Client. The contract remains in effect until it is renewed through the execution of a new contract or is terminated or cancelled pursuant to the provisions of sections 6, 12, 13 and/or 14 of this contract. 2. USDA National Organic Program Final Rule Incorporated by Reference: The use of the term “organic” in the marketing or labeling of products in the United States is regulated by the United States Department of Agriculture (USDA) and governed by the provisions of the National Organic Program Final Rule (Rule) codified in 7 CFR Part 205 of the Federal Regulations. This agreement incorporates the current Rule and all future changes to the Rule published in the Federal Register. Both QCS and Client have an independent responsibility to obtain a current copy of the Rule, have a copy in their possession, and understand its provisions. QCS and Client agree to abide by and fulfill the OHP, V3, R03, 3/20/15 Page 32 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 9: QCS Certification and Mark Licensing Contract 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP Rule 205.202 & 205.203.(b)-(c) Rule, its provisions and all amendments and legally binding interpretations issued by the federal courts or the USDA as they apply to the respective rights and duties of QCS and Client. 3. Scope of NOP Certification by QCS: The receipt of NOP Certification through QCS warrants only that client is in compliance with the Rule as set forth in 7 CFR Part 205. NOP Certification through QCS does not warrant compliance with any other federal, state, local, or international law relating to the production, handling, processing, or marketing of agricultural products or the safety of Client’s practices and products. It is Client’s responsibility to identify and comply with all federal, state, and local laws, and obtain all required permits, applicable to Client’s operation. Client agrees to indemnify QCS and hold QCS harmless against any claims that may arise related to Client’s failure to comply with applicable federal, state, local, and international laws, permits, and food safety and handling regulations 4. Ownership of the QCS Mark and Variants: QCS has sole ownership of the QCS logo displayed in the letterhead of this contract and all variants of that logo (Marks). QCS also has sole ownership of the name Quality Certification Services, the abbreviation QCS, and the phrases “Certified Organic by Quality Certification Services,” “Certified Organic by QCS,” “Certified by Quality Certification Services,” and “Certified by QCS,” (Mark Phrases) as these phrases relate to organic certification. QCS has the exclusive right to license the use of QCS Marks and Mark Phrases to entities who have received certification by QCS and for the purpose of marketing and labeling organic products. Client does not have the right to use any of the QCS Marks or Mark Phrases except as described in section 5 of this contract. Client understands that QCS Marks and Mark Phrases are distinctive in the organic market and may not be altered or challenged in any way. 5. Use of QCS Marks and Mark Phrases: Client may use QCS Marks and Mark Phrases in the promotion, labeling, and marketing of products listed on Client’s Product Verification Form (Verification) issued by QCS in conjunction with a USDA National Organic Program certificate (Certificate). Client will not use QCS Marks or Mark Phrases in a confusing or misleading manner, or to market, label, or promote products that are not listed on Client’s current Verification. Client will not use QCS Marks or Mark Phrases to mislead or confuse consumers about Client’s identity, the relationship between Client and QCS, or in any manner that brings QCS into disrepute. Client will submit copies or illustrations of all labels, signs, advertisements, and other promotional materials bearing QCS Marks or Mark Phrases to QCS for approval prior to use. QCS will respond in a timely manner and will not unreasonably withhold approval if the use of the QCS Marks and Mark Phrases is consistent with the Rule and this contract. 6. Compliance with Organic System Plan: This contract is effective after QCS has reviewed the Organic System Plan (OSP) submitted by Client for compliance with the Rule. Client warrants that the information submitted in the OSP is complete and accurate. Upon issuance of a Certificate, QCS has determined that Client complies with the Rule or will be compliant after addressing all minor noncompliances issued in conjunction with the Certificate. Client will address all minor noncompliances within the timeline provided by QCS and to QCS’s reasonable satisfaction. Client’s operations will at all times be compliant with the OSP approved by QCS and any noncompliance resolutions approved by QCS. Client will inform QCS of any proposed changes to the OSP and will not implement those changes until approved by QCS. If Client believes that immediate changes to the OSP are necessary for safety, health, or compelling financial reasons, reasonably believes that such changes are compliant with the Rule, and assumes all risk that such changes may not be found compliant with the Rule, Client may effect the necessary changes in the OSP and inform QCS of the changes within 30 days. QCS will review the changes for compliance with the Rule. Client understands that, if said modifications to the OSP appear to violate the Rule, they will be handled in accordance with the noncompliance procedures in the Rule, including possible suspension, revocation and/or cancellation of Client’s Certificate and this contract. Client has an affirmative and ongoing duty to ensure that QCS has accurate, timely, and complete information about the OSP as well as any complaints or investigations which relate to the organic integrity of its operations. Client agrees to keep records of all complaints made known to them and to take appropriate action with respect to such complaints and any deficiencies found in products that affect compliance with the requirements for certification. Client will document these actions will provide copies of these records to QCS on request Providing false, misleading, or inaccurate information to QCS is a violation of this contract and the Rule, and may lead to the imposition of civil fines as described in the Rule. Client will make necessary arrangements for QCS to conduct the evaluation/inspections and surveillance (if required). This includes the examination of documentation and records, and providing access to the relevant equipment, location(s), area(s), personnel, and client’s subcontractors; investigation of complaints; and the participation of observers, if applicable; 7. Fees: Client has a duty to pay all applicable certification deposits and fees in a timely fashion and in accordance with QCS written policies and procedures and the applicable provisions of the Rule. The QCS fee structure in effect on the effective date of this contract governs the fees and deposits that must be paid to QCS for the services provided in this contract. QCS will provide Client 60 days’ written notice of any change in the fee structure. If Client fails to object in writing within 30 days of QCS mailing the notice, this contract and Client’s financial OHP, V3, R03, 3/20/15 Page 33 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P OHP 9: QCS Certification and Mark Licensing Contract 352.377.0133 F 352.377.8363 www.qcsinfo.org NOP Rule 205.202 & 205.203.(b)-(c) obligations to QCS are modified to incorporate the change in fee structure. If client delivers an objection in writing within 30 days after QCS mails the written notice, QCS may terminate this contract one-year from its effective date by mailing Client written notice of the termination. 8. Client’s Warranties and Indemnification: Client warrants that, to the best of Client’s knowledge, the operations and products described in the OSP submitted and approved by QCS are compliant with all federal, state, and local regulations, laws, codes, and ordinances in the jurisdiction in which the OSP provides goods or services. Client acknowledges that QCS’s approval of its OSP is solely a determination of Client’s compliance with the Rule and is made solely for the purpose of marketing organic products or services. Client agrees to only make claims regarding the certification consistent with the approved scope of certification and will not use the certification in a manner that is misleading or unauthorized and which will not bring QCS into disrepute. Client agrees to indemnify QCS, its employees, officers, owners, and subcontractors against third party claims arising from Client’s operations that do not involve the Rule or the scope of certification as described in section 3 of this contract. If any portion of the Client’s OSP includes areas open to the public in the normal course of business for the sale of produced, manufactured or processed goods or food, and Client maintains a liability insurance policy, Client will name QCS as an additional insured on said policy. 9. Confidentiality: QCS, its agents, and its subcontractors will maintain the confidentiality of Client’s confidential business information and not disclose such information without the approval of Client, except that QCS may disclose information requested pursuant to the apparent authority of a government agency or subpoena. Client will identify particularity what information is to be considered confidential business information. General information which appears on the Certificate and Verification, as well as contact information for Client, is not considered confidential business information. QCS and Client will maintain the confidentiality of all communications between Client and QCS and the contents of any inspection report written as a result of an onsite inspection. However, Client may disclose information to its agents, parent company, or subsidiaries and/or as requested pursuant to an apparent valid authority or government agency or subpoena. 10. Subcontractors: reserves the right to use subcontractors for the performance of inspections, soil testing, product testing, and other work related to certification. All subcontractors performing inspections and other work on behalf of QCS are subject to the confidentiality provisions of section 9 of this contract. 11. Certificate, Privileges, and Rights Not Assignable: The Client’s Certificate, the consequent privilege to use the term “organic” under the Rule, and the rights granted to Client under this contract are not transferable or assignable. Any attempt by Client to assign the Certificate, its privileges, or its rights under this contract is void. If providing copies of certification documents to others, Client agrees to reproduce and provide copies in their entirety. 12. Renewal by Execution of New Contract: No less than 60 days prior to the annual anniversary date of the effective date of this contract, QCS will mail Client annual update forms and a new Certification and Mark Licensing Contract. If Client wishes to commit to a new contract, Client will complete all of the annual update forms provided by QCS, sign a new contract, and submit to the conditions of continuing certification described in the Rule, including a new compliance determination and onsite inspection. The new contract may contain new or different terms and provisions. If a new contract is signed by both QCS and Client, the present contract is terminated on the effective date of the new contract. If Client does not deliver the annual update forms, a signed new contract, and applicable fees and deposits to QCS prior to the anniversary of the effective date of this contract, QCS may commence noncompliance procedures as described in the Rule. Such procedures may lead to the suspension or revocation of the Certificate and cancellation of this contract. 13. Termination of Contract: Client may request to terminate this contract at any time if Client has no outstanding financial obligation to QCS and no unresolved material noncompliances. Client may terminate this contract by mailing or faxing a written notice to QCS stating the following: 1) that Client wishes to surrender its Certificate; 2) that Client recognizes that it may no longer use the term “organic” in the marketing or labeling of products for sale (except that an exempt or excluded operation, as described in the Rule, need not provide this statement in the notice); 3) that Client will immediately cease using the QCS Mark and Mark Phrases. In addition, Client must return the original Certificate and Verification issued to Client by QCS. If QCS reasonably determines that Client has no unresolved material noncompliances or unpaid financial obligations, QCS will accept Client’s surrender of its Certificate, terminate this contract, and notify Client in writing of the termination. QCS will make this determination in a timely manner. QCS may terminate this contract based upon Client’s written objection to a proposed modification of the fee structure as described in section 7 of this contract. OHP, V3, R03, 3/20/15 Page 34 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 OHP 9: QCS Certification and Mark Licensing Contract F 352.377.8363 www.qcsinfo.org NOP Rule 205.202 & 205.203.(b)-(c) 14. Cancellation for Noncompliance: QCS may cancel this contract if Client does not comply with the Rule or the terms of this contract. Prior to cancellation of this contract and revocation or suspension of the Certificate, QCS will follow the due process provisions in the Rule, including the provision of Client with notice and the opportunity to respond, rebut, and/or correct any noncompliances. If QCS suspends or revokes Client’s Certificate in accordance with the procedures provided in the Rule, this contract is cancelled on the effective date of the effective date of the suspension or revocation of the Certificate. Upon termination of certification, Client will discontinue its use of all advertising matter that contains any references to organic or organic certification and takes all action as required by QCS. 15. Severability: The provisions of this contract are severable; should any provision be invalidated, the remaining provisions remain in effect. 16. Governing Law and Venue: This contract is governed by the laws of the State of Florida. Client and QCS will litigate any disputes which arise between them only in the courts of the Eighth Judicial Circuit Court of Florida located in Gainesville, Florida. 17. Modification of Contract: Any modification of this contract must be in writing and agreed to in writing by both Client and QCS. 18. Application to International Program. All provisions of this contract apply equally to clients who have requested one or more of the following international certification programs provided by QCS: EU 834/07 & 889/08, US/Canada Equivalence Agreement, US/Japan Export Arrangement, US/Taiwan Export Arrangement and US/Korea Equivalency Arrangement. This agreement incorporates by reference all applicable regulations and legally binding interpretations of those regulations. The receipt of any international certification through QCS warrants only that client is in compliance with the applicable equivalency or export agreement. Client agrees to indemnify QCS and hold QCS harmless against any claims that may arise related to Client’s failure to comply with international laws related to food production and handling. The following parties have read, understand and agree to be bound by this contract: CLIENT AGREEMENT AND ACKNOWLEDGEMENT Acknowledged and agreed to by on behalf of (Person Signing) on (Title of Person Signing) (Date) as (Client) (Signature of Client or Client’s Agent) CLIENT AGREEMENT AND ACKNOWLEDGEMENT Acknowledged and agreed to by on behalf of Quality Certification Services. (Person Signing) as on (Title of Person Signing) (Date) (Signature of Authorized QCS Employee) OHP 10: US/Japan Export Arrangement Compliance Affirmation – Handler/Processor List all products you wish to export to Japan. Check the corresponding box to indicate whether the product requested for export is submitted with the corresponding OPP (Organic Product Profile in section OHP2). Please submit an OPP for each product below that is marked as “No OPP”. NOT APPLYING FOR EXPORT TO JAPAN PRODUCTS FOR EXPORT TO JAPAN OHP, V3, R03, 3/20/15 OPP Page 35 of 45 No OPP QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org US/Japan Export Arrangement Verification: Do you have documentation from the supplier’s certifying agent for all ingredients used to manufacture products intended for export to Japan to verify the following: 1. Were the crops /products produced without the use of alkali-extracted humic acid? If yes, attach documentation. Yes Attachment 2. Were the crops/products produced without the use of lignin sulfonate as a flotation agent? Yes If yes, attach documentation. No No Attachment 3. Do you understand that for each product to be exported, an Export Affidavit for Japan must be completed by the client and signed by QCS prior to the export of product? Yes No Affirmation I affirm that all statements made in this US/Japan export arrangement compliance affirmation are true and correct. No prohibited materials under the US/Japan Export Arrangement have been used to produce any of the organic products listed above. I agree to provide further information as required by QCS and authorized representatives of the NOP. Signature: OHP, V3, R03, 3/20/15 Title: Page 36 of 45 Date: QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 11A: European Union (EC) 834/2007 & 889/2008 Regulation Compliance Affirmation – HANDLER/PROCESSOR Any producer of organically certified goods or those who are seeking first time certification and who intend to export organic products to the European Union, must complete an EU Compliance Plan in order for QCS to verify compliance with Regulation (EC) 834/2007 & 889/2008. Regulation (EC) 834/2007 & 889/2008is the legal basis for production, processing and trade of organic products in 25 countries of the European Union and only products certified according to this regulation can be labeled as "organic". Producers of crops, livestock and/or processed products, must comply with all applicable items of (EC) 834/2007 & 889/2008. Once we are notified in writing, QCS will provide the EU Regulation Compliance Plan and all other necessary forms to those clients who wish to export their organic products to any of the 25 countries listed in this guidance document (Table 1). The EU Regulation Compliance Plan must be provided along with the required Organic System Plan The following is a description of the policies and procedure that must be met prior to the authorization for export of organic goods certified as organic to the European Union. 1. Applicant request(s) in writing, either in your Organic System Plan or in a separate letter, your intention of exporting organic goods to the European Union. 2. Applicant complete(s) and submit(s) the EU Compliance Plan and any additional forms, as applicable, to QCS for review. 3. Certifying agent issue(s) an official EU Transaction/Export Certificate for requested organic products only after compliance with Regulation (EC) 834/2007 & 889/2008 has been fully verified. QCS is both USDA accredited for ISO guide 65 compliance and is an accredited certification program of the USDA National Organic Program. QCS is audited annually by USDA Certification Branch ISO Guide 65 auditors. Accreditation verifies that the certification program is operating according to our policies and procedures, and that we are certifying to the appropriate standard (e.g. (EC) 834/2007 & 889/2008 and USDA National Organic Program). EU REGULATION COMPLIANCE PLAN General Information Name of Operation: Contact Person: Processor/Handler Plan Information Please provide answers and information to all the following questions and items. List all the organic products you wish to export to EU: OHP, V3, R03, 3/20/15 Page 37 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 11A: European Union (EC) 834/2007 & 889/2008 Regulation Compliance Affirmation – HANDLER/PROCESSOR A. Certified Organic Ingredients Are all organic ingredients certified to the standards of (EC) 834/2007 & 889/2008 or grown in compliance with (EC) 834/2007 & 889/2008? Note: This can be stated on the organic certificate or a written declaration can be provided from the supplier’s certifier. Please note that the supplier’s certification body must satisfy the requirements laid down in the conditions of standard EN 45011, which is equivalent to ISO guide 65, according to EU regulation. Yes No 1. a If yes, please attach the documentation. Attachment B. Ingredients of Non-agricultural origin (reference Annex VIII, section A or B) Does the product contain non-agricultural ingredients? Yes No 2.a If yes, are the ingredients of non-agricultural origin listed in EU 889/2008 Annex VIII A or B, and are the ingredients used in accordance with the stated specific conditions? Please refer to the addendum titled “Annex VIII”. Note: If a non-agricultural ingredient is used that is not listed in Annex VI, section A, it must either be discontinued or the producer must be able to demonstrate that a recognized EU regulatory authority has granted a derogation (i.e., an allowed deviation from the standard) for use of that ingredient. Yes No C. Processing aids and other products which may be used for processing of ingredients of agricultural origin from organic production (reference Annex VIII, section B) Are processing aids or other substances used in the processing of the product? Yes No 3a. If yes, are the processing aids and other products which may be used for processing listed in Annex VIII, section B, and are the processing aids used in accordance with the stated specific conditions? Please refer to the addendum titled “Annex VIII”. Note: If a processing aid is used that is not listed in Annex VIII, section B, it must either be discontinued or the producer must be able to demonstrate that a recognized EU regulatory authority has granted a derogation (i.e., an allowed deviation from the standard) for use of that ingredient. Yes No D. Water for cleaning and sanitizing 1. After the use of cleaning and sanitizing substances on food contact surfaces, does an intervening event occur (i.e., hot water rinse or documented purge), so the substances do not come in contact with the organic food? Yes No 2. Are any substances added to the potable water during the handling and processing of the product? OHP, V3, R03, 3/20/15 Page 38 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 11A: European Union (EC) 834/2007 & 889/2008 Regulation Compliance Affirmation – HANDLER/PROCESSOR Yes No 5a. If yes, please list substances. Affirmation I affirm that all statements made in this EU Regulation Compliance Plan are true and correct. Only materials listed in Council Regulation (EC) 834/2007 & 889/2008 for the purposes indicated have been used to produce the organic products listed here. I agree to provide further information as required by QCS. I agree to, in cases where my operation and/or the subcontractors of my operation are certified by different certification bodies to EU standards, the exchange of information between those authorities or bodies; I agree in cases where my operation and/or the subcontractors may operation change organic certification body, to the transmission of my OSP and related certification documents to the subsequent certification body; I understand that if this operation withdraws from certification to the European Union (EC) 834/2007 & 889/2008 Regulation Compliance Program QCs shall maintain the operations certification documents for a period of at least five years and inform, without delay, the relevant competent authority and control authority or control body; I agree to inform the QCS without delay of any irregularity or infringement affecting the organic status of this operation’s product or organic products received from other operators or subcontractors. Signature: Title: Addendum. The Council Regulation (EEC) No. (EC) 834/2007 & 889/2008 can be found at the following website: 834/2007 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:189:0001:0023:EN:PDF 889/2008 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32008R0889:EN:NOT OHP 11A revised V3, R2, 2/27/15 OHP, V3, R03, 3/20/15 Page 39 of 45 Date: QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 11B: US/European Union Equivalence Not applying for export to the European Union A. Product Verification List all the organic products you wish to represent as organic in the European Union. Products OPP No OPP B. US-European Union Organic Equivalence Complete this section if you are located in the United States, or the final processing and packaging of your organic products occurs in the United States, and plan to export to the European Union under the terms of the US-European Union Organic Equivalence Arrangement. 1. Are you located in the United States, or export to the EU)? the final processing and packaging of organic products occurs in the United States (no direct 2. Do you produce apples or pears or products using ingredients derived from apples or pears? Yes 2a. If yes, were apples or pears produced using antibiotics (streptomycin)? Yes No No Crops produced using antibiotics (streptomycin for fire blight control in apples and pears) may not be represented as organic in the European Union. Affirmation I affirm that all statements made in this US/EU Equivalency section are true and correct. I agree to provide further information as required by QCS. Signature: OHP, V3, R03, 3/20/15 Title: Page 40 of 45 Date: QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 12: US-Canada Equivalence Arrangement -Compliance Affirmation - Handler/Processor If you are certified to the NOP and are located outside of Canada, please complete the list of products requested for certification below and section B. NOT APPLYING US-CANADA EQUIVALENCE ARRANGEMENT List all organic products that will be exported to Canada. All products requested for export must be listed in your current OPP. Please submit an OPP (Organic Product Profile in section OHP2) for each product below that is marked as “No OPP”. PRODUCTS OPP No OPP A. US-Canada Equivalence Arrangement (Only for NOP certified operations located outside of Canada). Materials Do you have documentation from all your ingredient supplier’s certifying agents confirming all ingredients used to manufacture products intended for export to Canada have been verified as compliant to the terms of the US-Canadian agreement? 1. Yes No If yes, attach documentation. Attachment Affirmation OHP, V3, R03, 3/20/15 Page 41 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org I affirm that all statements made in this US/Canada equivalence arrangement compliance affirmation are true and correct. No prohibited materials under US/Canada equivalence arrangement have been used to produce any of the organic products listed above. I agree to provide further information as required by QCS and authorized representatives of the NOP. Signature: Title: Date: OHP 13: US-Taiwan Export Arrangement - Compliance Affirmation – HANDLER/PROCESSOR List all organic products you wish to export to Taiwan. Check the corresponding box to indicate whether the product requested for export is submitted with the corresponding OPP (Organic Product Profile in section OHP2). Please submit an OPP for each product below that is marked as “No OPP”. NOT APPLYING FOR EXPORT TO PRODUCTS FOR EXPORT TO TAIWAN OPP No OPP TAIWAN US-Taiwan Export Arrangement Verification: 1. Can you demonstrate all ingredients were grown or processed without the use of NOP prohibited materials? Yes No 2. Can you demonstrate that any meat products used in processed product were from animals managed without the use of systemic pain killers or analgesics, including Lidocaine or Procaine? Yes No N/A no meat products used in exported products 2a. If yes, attach documentation from the supplier’s certifying agent. OHP, V3, R03, 3/20/15 Page 42 of 45 Attachment QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org Affirmation: 1) I affirm that all statements made in this Taiwan Standards Compliance Affirmation are true and correct. 2) No prohibited materials under NOP have been used to produce any of the organic products listed above. 3) I agree not to put up for sale any product for which I have requested certification; and bearing the word organic or its derivatives and the QCS s mark, for as long as I have not been informed of the decision made by the QCS stating that the products are certified; 4) I agree to reveal before hand to QCS, the identity of any other company for which I intend to manufacture products under license, and thus as a result can use the QCS’s mark (name and logo) on the label of the products that it intends to market under its own brand name even though it does not hold a compliance certificate for those products; 5) I agree to allow representatives from the NOP to access during normal working hours, documentation and sites used to produce certified products, for the purposes of examination and copying within as part of QCS’s assessment; 6) I agree to pay the corresponding fees requested by QCS; and 7) I agree to make all necessary arrangements for the processing of any complaints directed towards my operation; Signature: Title: Date: OHP 14: US-Korea Export Arrangement - Compliance Affirmation – HANDLER/PROCESSOR ist all organic products you wish to export to Korea. Check the corresponding box to indicate whether the product requested for export is submitted with the corresponding OPP (Organic Product Profile in section OHP2). Please submit an OPP for each product below that is marked as “No OPP”. PRODUCTS FOR EXPORT TO KOREA OPP No OPP NOT APPLYING FOR EXPORT TO KOREA OHP, V3, R03, 3/20/15 Page 43 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 14: US-Korea Export Arrangement - Compliance Affirmation – HANDLER/PROCESSOR US-Korea Export Arrangement Verification: 1. Do all products meet the Korean Food Code for Processed Food Processed food” refers to a food manufactured, processed and packaged by adding food or food additives to food raw materials (agricultural, forestry, livestock, or marine products), transforming food raw materials (such as grinding or cutting) till their original form cannot be recognized, or mixing such transformed ones or adding food or food additives to such mixture. However, where, without the use of food additives or other materials, the agricultural, forestry, livestock, or marine products are simply cut, peeled, salted, ripened, or heated (except the cases where heating is performed for sterilization or heating causes significant changes to those products) till their original forms can be recognized or where sanitary risks from treatment processes are not expected and food raw materials are simply treated so as to allow organoleptic identification of food quality, such food products are excluded from the definition of the processed food. Yes No , If not which products do not? 2. Is final packaging for Korean exported product done in the United States? Yes No , If not which do not? 3. Can you demonstrate that if any apple or pear ingredients are used in processed product they have been sourced from suppliers that have not used antibiotics? Yes No N/A – products do not contain appel or pear ingredients. 4. Can you demonstrate all ingredients were grown or processed without the use of NOP prohibited materials? Yes No Affirmation: 1) I affirm that all statements made in this Korea Standards Compliance Affirmation are true and correct. 2) No prohibited materials under NOP have been used to produce any of the organic products listed above. 3) I agree not to put up for sale any product for which I have requested certification; and bearing the word organic or its derivatives and the QCS’s mark, for as long as I have not been informed of the decision made by the QCS stating that the products are certified; 4) I agree to reveal before hand to QCS, the identity of any other company for which I intend to manufacture products under license, and thus as a result can use the QCS’s mark (name and logo) on the label of the products that it intends to market under its own brand name even though it does not hold a compliance certificate for those products; 5) I agree to allow representatives from the NOP to access during normal working hours, documentation and sites used to produce certified products, for the purposes of examination and copying within as part of QCS’s assessment; 6) I agree to pay the corresponding fees requested by QCS; and 7) I agree to make all necessary arrangements for the processing of any complaints directed towards my operation; OHP, V3, R03, 3/20/15 Page 44 of 45 QCS NOP ORGANIC HANDLER/PROCESSOR PLAN Quality Certification Services (QCS) PO Box 12311 Gainesville FL 32604 P 352.377.0133 F 352.377.8363 www.qcsinfo.org OHP 14: US-Korea Export Arrangement - Compliance Affirmation – HANDLER/PROCESSOR Signature: OHP, V3, R03, 3/20/15 Title: Page 45 of 45 Date: