2004 IOIA/HOFA Organic PROCESS Inspector Training

Please write legibly. Test results are based on accuracy and completeness of answers. Use the back or additional sheets of paper if necessary and clearly identify which question you are answering. Please be as concise as possible. You will also receive a Certificate of Completion if your grade is over 75% and you pass the written assignment. Please use a black or blue pen only.


(Please write your name legibly as you want it to appear on your certificate.)Grader______

  1. Define Organic Control Points (OCP's). (3pts.)

Organic Control Points are any points or procedures in a food processing system where loss of control may result in a loss of organic integrity. P. 175 IOIA

  1. The processor uses a specific minor ingredient in his organic blended product, and is currently using a conventional product since he states that he cannot purchase the minor ingredient organically. The inspector knows that this minor ingredient is readily available from certified organic sources.


The inspector can

  1. Tell the processor that they must use all certified organic products or lose their certification.
  2. Tell the processor that you (the inspector) know of certified organic sources. The inspector gives them resources to aid them in the finding of this organic minor ingredient.
  3. Request to see proof that they tried to source this minor ingredient from at least two sources, using their company’sclear criteria of quality, volume and functionality.
  4. Do not discuss that there are sources for organic products at the time of the inspection, but do mention it in the certification report. Do not specifically mention the sources.
  5. Do not discuss that there are sources for organic products at the time of the inspection, but do mention it in the certification report. Specifically mention the sources.
  6. Do not discuss this issue at all in the report.

3. LIST at least 4 items the inspector should review to verify complete clean-outs occur prior to organic production at a facility that processes both conventional and organic products. (4 pts.)

(4 pts.)

1. Identify the OCP's or SSOPs and cleanout procedures, insures that employees understand them.

2. Assess the equipment for physical ability to be adequately cleaned, tools present for cleaning.P. 189-191

3. Review written cleanout procedures (posted signs, manuals, etc.)

4. Review equipment cleanout/sanitation logs.

5. Review production logs for the organic runs; verify there was clean out between conv and organic production.

6. Review documentation of equipment purges

4.What types of yeast are prohibited?(2 pts.)


5. List 4 boiler additives that are not allowed in organic production.(4 pts.)

Ammonium Hydroxide, Morpholine, Cyclohexylamine and Oxytadecyclamine, Diethyaminoethanol

6. What item is mandated on the label of a bulk nonretail organic agricultural product? (2 pts) Lot number

7. LIST 6 basic components of a successful structural pest management program. (6 pts.)

Good sanitation, exclusion, monitoring to know your pest problems,

understanding of pest ecology, correctly places traps, least toxic controls,

documentation, removal of harborage OR attractive nesting sites

Add: Inspection of incoming materials (IOIA Manual and 205.271.a.2

Also give credit for answers from 205.271.a.3. (Management of environmental factors such as temperature , light, humidity, atmosphere, and air circulation to prevent pest reproduction).

8. State whether the statements are True (T) or False (F) (5 pts.)

__F___ a. In order for the product to be label as “Organic” on the front panel of a product, at least 90% of the ingredients must be certified organic.

_F____ b. One of the labeling categories for organic livestock feed is “Made with organic…..”.

_T___ c. Water and salt are not included in the percentage calculation when determining the labeling category of a product.

__T___ d. SSOPs can include protocols that could jeopardize organic integrity.

__F___ e. Organic certification requirements supercede State and Federal food safety regulations.

9. According to the National List with OMRI as guidance, indicate with an X the status of the following materials that might be used in facilities where organic products are being processed. (12 pts.)

Allowed with

Approved Restrictions Prohibited

a. Peracetic acid______X____

b. Parrafin wax ______X____

c. Tocopherols as a preservative___X______

d. Detergents______X______

e. Ethylene gas to ripen CA apples______X_____

f. Carbon dioxide___X______

g. Rodent baits (anti-coagulant)______X______

h. Radiation (ionizing)______X____

i. Boric Acid______X______

j. Calcium Hydroxide____X______

k. Potassium Hydroxideto peel canned peaches____________X_____

l. Sodium silicate (post harvest handling)____X______

10. If a plant manager is concerned about releasing proprietary information during the inspection, LIST the actions the inspector could take in order to obtain the needed information. (2 pts.)

P. 170-171 IOIA

Discuss confidentiality statement that the inspector has on file with the certification agency.

Offer to sign an additional confidentiality statement provided by the company.

Try to assess the importance of the information and discuss that this information may be essential for the agency to make the certification decision.

Information could be sent directly to the agency, or the inspector could look at it, try to make a judgment on its’ importance. If it is important, the inspector should put this in the report. The agency can then determine if they want to get the information directly.

11. a. Explain the function of a product flow chart.

b. Describe in a short statement, its importance to an organic inspector. (4 pts.)

p. 195 IOIA

A product flow chart is a visual, schematic diagram that shows the flow of incoming ingredients through raw product storage, inhouse transport, production, inprocess storage, packaging and finished product storage.

(2 pts)

At least four of these to get 4 points

It should show where ingredients enter the system, where wastes are generated, and finished products exit.

Primary pieces of equipment should be identified.

Helps the inspector identify OCP's and equipment cleanouts.

Helps the inspector organize the flow of audit trail documents.

Product flow is verified as part of the inspection.

The flow chart is a valuable road map and reference point to help the certifier understand an inspection report.

12A. DESCRIBE in short statements, the actions you perform for a sample audit on one specific item, starting with finished product.

12B. LIST the specific audit trail DOCUMENTS you need to review, when you perform an audit trail review starting with the finished product sales record.

12A. Answer here(4 pts.)

1. Understand lot coding and documentation system for incoming, production and outgoing product.

2. Choose a finished lot # (from warehouse inventory or retail store product) and quantity to follow from sales, shipping or finished product inventory. May want to review incoming lot number also and track through process to finished product.

3. Review all audit trail papers relating to this entire lot back from finished product back through sales invoices, storage, processing, raw material storage, TCs, and receiving, to incoming ingredients to verify ability to track products back to raw ingredients. Check for proper identification and final labeling of organic product.

4. Verify ingredients purchased, lots, total quantity and outgoing finished products’ quantities. Include inventory factors. (Sample Balance Sheet)

5. Verify current organic certificates corresponding to incoming ingredients.

6. Collect copies of sample audit documents (optional).

12B. Answer here (4 pts.)

Shipping BOL, sales order, TCReceiving record

Raw Material Inventory

Finished product inventory/warehouse reportIncoming BOL/scale ticket

Production records/packaging reportIncoming purchase order/invoice/contract

Ingredients record with lot #Incoming organic certificate

13. According to the NOP rule, indicate with an X, which of the following substances are permitted to be used as ingredients and/or processing aids for organic products. (10 pts.)

______a. Modified cornstarch __X___ f. Trypsin

______b. Cellulose as anti-caking agent______g. Sorbic acid

___X__ c. Lactic acid ______h. Butylated hydroxyanisole (BHA)

___X__ d. Baking Soda______i. Chymosin

___X__ e. Citric Acid (micro fermentation of carbo. substrate) __X___ j. Carrageenan

14. LIST the procedures that could be followed by a manufacturer to prevent contamination of organic products by sanitizing chemicals used in a Clean In Place (CIP) pipeline system? (4 pts.)

P. 189 IOIA

1. Purging or flushing organic product through pipeline system. Product flushing should be documented (amounts), how much purged, and where used or sold. 2 points

2. Rinsing with potable water immediately prior to organic product run.2 points

15. What is a Julian Date? Give an example of a Julian Date and describe what your example means.


P. 194 IOIA

Julian Date is a 3 digit number corresponding to days of the year. 2 point

Example 001 is January 1. 365 is December 31. Julian dates are often used as codes for a specific day in a lot numbering system. 2 points

16.What does the USDA rule really say….True or False and Cite the Standard

All Organic and Made with Organic labeled products must prove nonorganic agricultural ingredients were not commercially available in an organic form, in order to use them. (2 pts.)

FALSE only Organic labeled products must prove noncommercial availability

17. Give an example where an inspector would help a producer overcome a barrier to certification. (3 pts)

18. You are inspecting a dairy plant and need to verify that specific ingredients (milk, cheese cultures and/or enzymes) are not genetically engineered.

LIST the documents you will need to review and what information these documents should provide. (3 pts)

Copies of labels that detail the total ingredients of the cultures and enzymes. 1 point

Letters from suppliers stating that the ingredients (cheese cultures and enzymes) were not genetically engineered; 1 point

Proof of current organic certification for organic ingredients (milk) 1 point

19.You are inspecting a meat slaughtering facility where lactic acid is sprayed on the hanging carcasses to control ecoli on the meat. The organic products are labeled as 100% organic meat. (4 pts)

Are all synthetic processing aids approved on the National List? / Yes / No
X / N/A / Comments
Lactic acid is allowed on the National List of synthetic substances, however, the product is labeled as a 100% organic product and lactic acid is not organically produced. The lactic acid would be allowed in an “organic” labeled product.
1 point for X on no, 3 points for comments.

20. Cite the specific section AND subsection numbers from the Federal Rule that are applicable to each of the issues listed below. (6 pts.)

____205.600 b 2___a. Synthetics are evaluated and can be approved for use as an ingredient in

organic products when this substance’s manufacture, use, and disposal do not have adverse effects on the environment.

___205.504 a 3 i __ b. Each certifying agent must have on the file a document listing the

qualifications, training and education of the inspectors they use.
____205.306 a 2___ c. Organic livestock feed may display the USDA organic seal.

205.310 a 2 b & 205.101.a __d. Agricultural products produced on an exempt or excluded operation must not be used in the processing of any multiingredient organically labeled products processed by another entity.

___205.403 d _____e. Organic inspectors must conduct exit interviews.

__205.272 b 2_____f. Assessment of the use or reuse of any bag or container for organic products

that had been in contact with substances that could compromise organic integrity.

21. Using the information provided, complete the table and answer the question below. (8 pts.)

Organic Commodities Company purchased raw organic soybeans from 2 certified organic farmers. The Feb. 24, 2004 weigh tickets from Jesse James showed tare weight of 49,792 pounds lot # JJ2S22402, and from Louis Good, 41,664 pounds lot # LG2234S01. Both loads were dumped into storage bin #3 which was empty at the time.

According to the handwritten production log, all the soybeans in bin 3 were cleaned on March 6, 2004, with an illegible volume of ___?__ 30 kg. bags of organic soybeans produced with screenings of 1,095 pounds due to cracked/split soybeans, hulls and other debris.

The sales BOL to Best Foods shows 900-30 kg. bags were shipped to Japan on March 15, 2004. Sales invoice shows 900-30 kg. bags of organic soybeans, lot #OS365, were invoiced. The plant manager showed the inspector a warehouse record that stated 486-30 kg bags of lot #OS365 were present after this one shipment.



For your calculations use this guide: 1 kg. = 2.205 lb.


Date / Commodity / Farmer name / Supplier lot number / Volume in /
Storage Location
Feb 24,2004 / Organic soybeans /

Jesse James



/ 49,792 pounds / Bin 3
Feb 24, 2004 / Organic
soybeans / Louis Good /


/ 41,664 pounds / Bin 3



/ Commodity / Raw Volume / Finished Volume / Waste Volume / Finished Lot Number
March 6, 2004 / Organic soybeans / 91,456 pounds / 90361 pounds or
1366 30-kg bags / 1095 pounds /


Shipping Record

Date / Commodity / Lot Number / Customer / Amount shipped / Balance Left in Lot number
March 15, 2004 / Organic
Soybeans /


/ Best Foods / 900 30 kg bags / 46630 kg bags is correct answer
NOT 486 30- kg bags

Does this sample audit balance the shipping record above, with the warehouse record shown to the inspector by the plant manager?

Process Test HI HB 2004 Page 1 of 5