GUIDE TO ASSESS BASIC HYGIENE AND PEST

CONTROL DURING ORGANIC PROCESS AUDITS

29/05/19
 PEST CONTROL MANAGEMENT
Does the operator use management practices to prevent pests in the organic facility?

Verifiers How to verify conformity Expected evidence

Visual inspection: The facility should be clean, well maintained, and with and *Cleaning Procedures and
adequate food waste management. Cleaning Records of the
Cleaning and Waste Management Procedures should be followed by the facility
workers. Interview personnel in charge of. *Cleanliness of the Facility.
Verify if there are signs of presence of pests (feces, animal hairs, nests). *Food Waste Management
Procedure
*Condition of the Facility
*Environmental factors
management (if applicable)
* Pest monitoring
 PEST CONTROL MANAGEMENT
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CHECKLIST E1.3 Procedures declared in OSP are well U1.1e Procedures declared in J1.4 Procedures declared in R3.4 Procedures declared in
described, according to interviews and OSP are well described, OSP are well described, OSP are well described,
what is observed (Implementation and according to interviews and according to interviews and according to interviews and
procedures). what is observed. what is observed what is observed .
(Implementation and
U7.1 Practices implemented procedures) R1.7 Practices implemented

REGULATION EC 834/2007 Art. 4 NOP 205.271 JAS Not. 1606 Art 4 Art. 58 Las plagas deben ser evitadas a través
Organic production shall be based on the following principles: Facility pest management practice standard. Managment corcerning manufacturing de buenas prácticas en los procesos. Esto
(a) the appropriate design and management of biological (a) The producer or handler of an organic processing, packaging storege and other incluye limpieza general e higiene. Los
processes based on ecological systems using natural resources facility must use management practices to processes. tratamientos con agentes de regulación de
which are internal to the system by methods that: (i) use living prevent pests, including 3. Only physical method or method using plagas deben, por lo tanto, ser considerados
organisms and mechanical production methods; but not limited to: biological function (except for the method como la última medida a aplicar siempre que
(ii) practice land-related crop cultivation and livestock production (1) Removal of pest habitat, food sources, and using recombinant DNA technology) shall be estén aprobados por el organismo de
or practice aquaculture which complies with the principle of breeding areas; used for pest and disease control. In the case certificación.
sustainable exploitation of fisheries; (iii) exclude the use of GMOs (2) Prevention of access to handling facilities; that ordinary means are not effective
and products produced from or by GMOs with the exception of and (3) Management of environmental factors, enough, chemical agents listed in Attached
veterinary medicinal products; (iv) are based on risk assessment, such as temperature, light, humidity, Table 2 may be used. When those prescribed
and the use of precautionary and preventive measures, when atmosphere, and air circulation, to prevent in Attached Table 2 are used, mixture with
appropriate; (b) the restriction of the use of external inputs. pest reproduction. those and ingredients and products shall be
Where external inputs are required or the appropriate prevented.
management practices and methods referred to in paragraph (a)
do not exist, these shall be limited to: (i) inputs from organic
production; (ii) natural or naturally-derived substances; (iii) low
solubility mineral fertilisers (c) the strict limitation of the use of
Chemically synthesised inputs to exceptional cases these being: (i)
where the appropriate management practices do not exist; and
(ii) the external inputs referred to in paragraph (b) are not
available on the market; or (iii) where the use of external inputs
referred to in paragraph (b) contributes to unacceptable
environmental impacts; (d) the adaptation, where necessary, and
within the framework of this Regulation, of the rules of organic
production taking account of sanitary status, regional differences
in climate and local conditions, stages of development and
specific husbandry practices.
 PEST CONTROL MANAGEMENT
If preventive practices are not sufficient for pest control, are physical/mechanical controls, or approved
lures and repellents used?

Verifiers How to verify conformity Expected evidence

*Technical Data Sheet/MSDS/Label: The auditor needs to evaluate if the inputs used as lures or *Technical Data Sheet/MSDS/Label
repellents are complying with the regulations and is being used according the manufacturer of Lures and Repellents
recommendations. *Information about how Lures and
Repellents are used and locations
*Visual inspection: check if physical/mechanical and traps (lures/baits) control is in place as stated on facility.
by the client. Information about physical and
mechanical control.
* Control practices must demonstrate that preventive measures where not effective. * Pest monitoring
 PEST CONTROL MANAGEMENT

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CHECKLIST E1.3 Procedures declared in OSP are well U1.1e Procedures declared in J1.4 Procedures declared R3.4 Procedures declared in
described, according to interviews and what is OSP are well described, in OSP are well described, OSP are well described,
observed (Implementation and procedures). according to interviews and according to interviews according to interviews and
what is observed. and what is observed. what is observed .

U7.2a Practices implemented J4.3a Practices R1.7 Practices implemented

implemented
REGULATION EC 834/2007 Art. 4 NOP 205.271 JAS Not. 1606 Art 4 Art. 59 Están prohibidos la irradiación y el uso
Organic production shall be based on the following principles: Facility pest management practice standard. Managment corcerning manufacturing de pesticidas y desinfectantes persistentes o
(a) the appropriate design and management of biological processes based (b) Pests may be controlled through: processing, packaging storege and cancerígenos para el control de plagas. Los
on ecological systems using natural resources which are internal to the (1) Mechanical or physical controls including other processes. tratamientos recomendados para el control
system by methods that: (i) use living organisms and mechanical but not limited to traps, 3. Only physical method or method de plagas incluyen: barreras físicas, sonido,
production methods; light, or sound; or using biological function (except for ultrasonido, luz solar normal y ultravioleta,
(ii) practice land-related crop cultivation and livestock production or (2) Lures and repellents using nonsynthetic or the method using recombinant DNA trampas (incluyendo las de feromonas y de
practice aquaculture which complies with the principle of sustainable synthetic substances consistent technology) shall be used for pest and cebos estáticos), control de la temperatura,
exploitation of fisheries; (iii) exclude the use of GMOs and products with the National List. disease control. In the case that atmósfera controlada y tierra de diatomeas.
produced from or by GMOs with the exception of veterinary medicinal ordinary means are not effective Pudiendo considerarse además:
products; (iv) are based on risk assessment, and the use of precautionary enough, chemical agents listed in
and preventive measures, when appropriate; (b) the restriction of the use Attached Table 2 may be used. When - Métodos preventivos como la eliminación
of external inputs. Where external inputs are required or the appropriate those prescribed in Attached Table 2 del hábitat de las plagas y limitar el acceso a
management practices and methods referred to in paragraph (a) do not are used, mixture with those and las instalaciones.
exist, these shall be limited to: (i) inputs from organic production; (ii) ingredients and products shall be - Métodos mecánicos, físicos y biológicos.
natural or naturally-derived substances; (iii) low solubility mineral prevented. - Sustancias pesticidas incluidas en los anexos
fertilisers(c) the strict limitation of the use of Chemically synthesised de este reglamento.
inputs to exceptional cases these being: (i) where the appropriate - Otras sustancias usadas en trampas.
management practices do not exist; and (ii) the external inputs referred to
in paragraph (b) are not available on the market; or (iii) where the use of
external inputs referred to in paragraph (b) contributes to unacceptable
environmental impacts; (d) the adaptation, where necessary, and within
the framework of this Regulation, of the rules of organic production taking
account of sanitary status, regional differences in climate and local
conditions, stages of development and specific husbandry practices.
 PEST CONTROL MANAGEMENT
If preventive and physical and mechanical practices indicated are not sufficient for pest control, the
substances used are in compliance with the regulations?
Verifiers How to verify conformity Expected evidence
*Technical Data Sheet/MSDS/Label of the substance: Has to be evaluated to know if it is in compliance with *Technical Data Sheet/MSDS/Label
the NOP regulation and used according the manufacturer recommendations. of the substance.
*Fumigation Procedure: Must include clear information about the measures taken to prevent contact of the *Fumigation Procedure
substance with organic products, organic raw materials, other ingredients, additives or processing aids used in *Fumigation Records
organic processing, packaging material, etc. *Training of persons in charge
*Fumigation records: Must include information about the application date, substance use, how was applied, * Pest monitoring
zones of the plant fumigated, personnel in charge of fumigation. Also is important to include the measures
applied to avoid contamination of the inputs used for organic (if applicable).
*Interview personnel in charge of the fumigation in order to evaluate if they are performing the contamination
prevention measures in an adequate manner.
*Training records: about Fumigation Procedure and Records.
* Control practices must demonstrate that preventive measures where not effective.
 PEST CONTROL MANAGEMENT

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CHECKLIST NOT APPLICABLE U7.2b National List J4.3b Tab 2 R1.7 Annex 2

REGULATION EU DOES NOT HAVE AN ANNEX FOR PEST
INPUTS IN FACILITIES.
NOP 205.271
Facility pest management practice standard.
(c) If the practices provided for in paragraphs
(a) and (b) of this section are not effective to
prevent or control
pests, a non-synthetic or synthetic substance
consistent with the National List may be
applied.
JAS Not. 1606 Art 4 Art. 59
Management concerning manufacturing
processing, packaging storage and other
processes.
3. Only physical method or method using
biological function (except for the method
using recombinant DNA technology) shall
be used for pest and disease control. In the
case that ordinary means are not effective
enough, chemical agents listed in Attached
Table 2 may be used. When those
prescribed in Attached Table 2 are used,
mixture with those and ingredients and
products shall be prevented.
 PEST CONTROL MANAGEMENT
If practices and substances used are not sufficient for pest control, and there is a need to use other substances, Does
the operator have proper procedures (in line with the regulations) to avoid contamination of organic products, and
the substances are approved by the CB before their use?

Verifiers How to verify conformity Expected evidence

*Technical Data Sheet/MSDS/Label of the substance: Has to be evaluated to know if it is a *Technical Data Sheet/MSDS/Label of
substance approved to be applied in food facilities and used according the manufacturer the substance.
recommendations. *Fumigation Procedure
*Fumigation Procedure: Must include clear information about the measures taken to *Fumigation Records
prevent contact of the substance with organic products, organic raw materials, other *Training of persons in charge
ingredients, additives or processing aids used in organic processing, packaging material, etc. * Pest monitoring
*Fumigation records: Must include information about the application date, substance use,
how was applied, zones of the plant fumigated, personel in charge of fumigation. Also is
important to include the measures applied to avoid contamination of the inputs used for
organic (if applicable).
*Interview personel in charge of the fumigation in order to evaluate if they are performing
the contamination prevention measures in an adequate manner.
*Training records: about Fumigation Procedure and Records.
* Control practices must demonstrate that preventive measures where not effective.
 PEST CONTROL MANAGEMENT
CONTROL EU NOP JAS RTPO
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CHECKLIST E1.3 Procedures declared in OSP are well described, U7.3a – Evidence that preventive or physical/ J1.4 Procedures declared in OSP are R1.7 Practices implemented
according to interviews and what is observed mecanical measures is not effective well described, according to interviews
(Implementation and procedures). U7.3b – Preventive measures implemented, and what is observed
products approved by CUC
J4.4c Implementation and
procedures)
NOP 205.271 JAS Not. 1606 Art 4
REGULATION EC 834/2007 Art. 4 Art. 58
Facility pest management practice standard. Management concerning manufacturing
Organic production shall be based on the following principles:
(d) If the practices provided for in paragraphs (a), (b), processing, packaging storage and other
(a) the appropriate design and management of biological
and (c) of this section are not effective to prevent or processes.
processes based on ecological systems using natural resources
control facility pests, a synthetic substance not on the 3. Only physical method or method using
which are internal to the system by methods that: (i) use living
National List may be applied: Provided, That, the biological function (except for the method using
organisms and mechanical production methods;
handler and certifying agent agree on the substance, recombinant DNA technology) shall be used for
(ii) practice land-related crop cultivation and livestock
method of application, and measures to be taken to pest and disease control. In the case that ordinary
production or practice aquaculture which complies with the
prevent contact of the organically produced products means are not effective enough, chemical agents
principle of sustainable exploitation of fisheries; (iii) exclude the
or ingredients with the substance used. listed in Attached Table 2 may be used. When
use of GMOs and products produced from or by GMOs with the
(e) The handler of an organic handling operation who those prescribed in Attached Table 2 are used,
exception of veterinary medicinal products; (iv) are based on risk
applies a non-synthetic or synthetic substance to mixture with those and ingredients and products
assessment, and the use of precautionary and preventive
prevent or control pests must update the operation’s shall be prevented.
measures, when appropriate; (b) the restriction of the use of
organic handling plan to reflect the use of such 4. In case of insufficient effect of pest and disease
external inputs. Where external inputs are required or the
substances and methods of application. The update control only by method prescribed in 3, except
appropriate management practices and methods referred to in
organic plan must include a list of all measures taken for period of manufacturing or storing of organic
paragraph (a) do not exist, these shall be limited to: (i) inputs
to prevent contact of the organically produced processed foods, chemical agents not listed in
from organic production; (ii) natural or naturally-derived
products or ingredients with the substance used. Attached Table 2 may be used. When used, those
substances; (iii) low solubility mineral fertilizers(c) the strict
(f) Notwithstanding the practices provided for in agents shall be removed before starting
limitation of the use of Chemically synthesized inputs to
paragraphs (a), (b), (c), and (d) of this section, a manufacturing organic processed foods.
exceptional cases these being: (i) where the appropriate
handler may 5 Ionizing radiation shall not be used for pest and
management practices do not exist; and (ii) the external inputs
otherwise use substances to prevent or control pests disease control, the foods preservation or
referred to in paragraph (b) are not available on the market; or
as required by Federal, State, or local laws and sanitation.
(iii) where the use of external inputs referred to in paragraph (b)
regulations: Provided, That, measures are taken to 6 Foods produced or processed in accordance
contributes to unacceptable environmental impacts; (d) the
prevent contact of the organically produced products with the criteria of “ “Ingredients“” and provisions
adaptation, where necessary, and within the framework of this
or ingredients with the substance used. from 1 to 4 on the above shall be controlled to
Regulation, of the rules of organic production taking account of
avoid exposure to substances for plant pest and
sanitary status, regional differences in climate and local
disease control, detergent, disinfectant and other
conditions, stages of development and specific husbandry
agents.
practices.
 CLEANING OF FACILITIES
Are storage/processing rooms used for storing organic and non-organic products cleaned before
the organic storage/processing?
Verifiers How to verify conformity Expected evidence
*Cleaning Procedure: Must indicate how the cleaning is done, substances used, *Cleaning Procedure
records used, and how is the process of verification of effectiveness to approve *Cleaning Record
that organic products can be stored. *Training Records
*Cleaning records: Must indicate Date, Description of the storage room *incoming Records
cleaned, substances used, name of responsible of the cleaning, and the name of
the person responsible of confirming the effectiveness of such cleaning, with
date and signature.
*Training records for the persons involved in the cleaning and in the verification
(of effectiveness).
*incoming records of organic raw materials or products: if the client use the
same storage room for organic and non-organic, and the operator receive
organic raw materials or products in their facilities, they should have a cleaning
record and the verification of the cleaning effectiveness before storing it. Cross
check incoming dates it with cleaning records dates.
*Visual inspection on the cleanliness of the facilities and equipments
 CLEANING OF FACILITIES
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CHECKLIST E3.5a, E3.5b For storages and records U2.1 Avoid commingling or J6.1 Cleaning of the facilities R1.5 Cleaning and records
E4.6a, E4.6b For process facilities and records contamination

EC 889/2008 Art. 26 §205.272 JAS, Not. 1831

REGULATION 2. Operators producing processed feed or food shall establish Commingling and contact with prohibited I. Facilities for Production and Storage D.S. 044-2006-AG
and update appropriate procedures based on a systematic substance prevention practice standard. Facilities for manufacturing, processing, packaging, storage and Art 56: Limpieza de instalaciones
identification of critical processing steps. (a) The handler of an organic handling operation other processes for organic processed foods and organic feeds El operador debe utilizar los medios y
3. The application of the procedures referred to in paragraph must implement measures necessary to prevent (limited to those processed; hereinafter the same) shall comply medidas permitidos o recomendados
2 shall guarantee at all times that the produced processed the commingling of organic and nonorganic with the criteria of “Management concerning manufacturing, en el presente Reglamento Técnico
products comply with the organic production rules. products and protect organic products from contact processing, packaging, storage and other processes” in Article 4 of
para la descontaminación, limpieza o
4. Operators shall comply with and implement the with prohibited substances. the Japanese Agricultural Standard of organic processed foods
procedures referred to in paragraph 2. In particular, (Notification No. 1606 of the Ministry of Agriculture, Forestry and desinfección de todas las instalaciones
operators shall: Fisheries of October 27, 2005; hereinafter referred to as the “JAS donde se mantenga, maneje,
(a) take precautionary measures to avoid the risk of for organic processed foods”) and “Management of slaughter, transforme o almacene los productos
contamination by unauthorized substances or products; selection, processing, cleaning, storage, packaging and other orgánicos.
(b) implement suitable cleaning measures, monitor their processes” in Article 4 of the Japanese
effectiveness and record these operations; Agricultural Standard for organic feed (Notification No. 1607 of
EC 889/2008 Art 63 the Ministry of Agriculture, Forestry and Fisheries of October 27,
Control arrangements and undertaking by the operator. 2005; hereinafter referred to as the “JAS for organic feeds”)
1. When the control arrangements are first implemented, the respectively, and shall be provided with such broadness, structure
operator shall draw up and subsequently maintain: and brightness not as interfering the management and shall be
(c) the precautionary measures to be taken in order to cleaned appropriately.
reduce the risk of contamination by unauthorized products
or substances and the cleaning measures to be taken in
storage places and throughout the operator's production
chain.
EC 889/2008 Art 35
4. In case where operators handle both non-organic products
and organic products and the latter are stored in storage
facilities in which also other agricultural products or
foodstuffs are stored:
(c) suitable cleaning measures, the effectiveness of which has
been checked, have been carried out before the storage of
organic products; operators shall record these operations
 CLEANING OF FACILITIES
Are the principles of Good Manufacturing Practices respected during the Process?

Verifiers How to verify conformity Expected evidence

* To have available for employees and visits water and soap to wash hands Adequate procedures followed.
after using restrooms and before to enter the process/storage unit.
* Cross check the functionality of the washing implements. Training records
* Interview employees about washing hands procedures, this must be Written Procedures
according with internal procedures about this topic. Following written Procedures
* Protective clothing according to internal procedures Validating work
* Visual observation of the compliance of procedures or signals about
protection (caps, gloves, lid mouths, etc) or prohibition (eating, animals, etc)
 CLEANING OF FACILITIES

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CHECKLIST E4.8 U2.1 Avoid commingling or J4.b R1.4

contamination

REGULATION 05.272 Commingling and contact with JAS Technical Criteria 1831 I: Art. 55
889/2008 Art. 26 prohibited substance prevention 1. Facilities for manufacturing, processing, packaging,
El operador debe contar con
1. Operators preserving products or producing practice standard. storage and other processes for organic processed foods
procedimientos documentados sobre
processed feed or food shall establish and update and organic feeds (limited to those processed;
Prohibited substance. A substance, the el proceso de transformación, los
appropriate procedures based on a systematic hereinafter the same) shall comply with the criteria of
use of which in any aspect of organic mismos que deben incluir
identification of critical processing steps. The “Management concerning manufacturing, processing,
disposiciones para prevenir y controlar
application of those procedures shall guarantee at all production or handling is prohibited or packaging, storage and other processes” in Article 4 of
la contaminación, durante todo el
times that preserved or processed products comply not provided for in the Act or the the Japanese Agricultural Standard of organic processed
proceso incluyendo el transporte y
with the organic production rules. 2. Operators shall regulations of this part. foods (Notification No. 1606 of the Ministry of
almacenamiento.
comply with and implement the procedures referred Agriculture, Forestry and Fisheries of October 27, 2005;
to in paragraph 1. In particular, operators shall: (a) hereinafter referred to as the “JAS for organic processed
take precautionary measures to avoid the risk of foods”) and “Management of slaughter, selection,
contamination by unauthorised substances or processing, cleaning, storage, packaging and other
products; (b) implement suitable cleaning measures, processes” in Article 4 of the Japanese Agricultural
monitor their effectiveness and record those Standard for organic feed (Notification No. 1607 of the
measures; Ministry of Agriculture, Forestry and Fisheries of
October 27, 2005; hereinafter referred to as the “JAS for
organic feeds”) respectively, and shall be provided with
such broadness, structure and brightness not as
interfering the management and shall be cleaned
appropriately.