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F ARM M ADE : A Guide to On-Farm Processing for Organic Producers An Overview and Four Example Enterprises: Sorghum Syrup Packaged Fresh Salad Greens Jams, Jellies, and Spreads Table Eggs Published by the Kerr Center for Sustainable Agriculture Co-distributed by the Kerr Center for Sustainable Agriculture and ATTRA—The National Sustainable Agriculture Information Service Funding provided by the Organic Farming Research Foundation by George Kuepper, Holly Born and Anne Fanatico 2009

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Page 1: Farm Made: A Guide to On-Farm Processing for Organic Producerskerrcenter.com/wp-content/uploads/2014/04/FarmMadeReport09.pdf · FARM MADE: A Guide to On-Farm Processing for Organic

FARM MADE:A Guide to On-Farm Processing

for Organic Producers

An Overview andFour Example Enterprises:■ Sorghum Syrup■ Packaged Fresh Salad Greens■ Jams, Jellies, and Spreads■ Table Eggs

Published by the Kerr Center for Sustainable Agriculture

Co-distributed by the Kerr Center for Sustainable Agriculture and

ATTRA—The National Sustainable Agriculture Information ServiceFunding provided by the Organic Farming Research Foundation

by George Kuepper,Holly Born and Anne Fanatico

2009

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Farm Made: A Guide to On-Farm Processing

for Organic Producers

An Overview and Four Example Enterprises: Sorghum Syrup

Packaged Fresh Salad GreensJams, Jellies, and Spreads

Table Eggs

George KuepperHolly Born

andAnne Fanatico

2009

Published by the Kerr Center for Sustainable Agriculture Co-distributed by the Kerr Center for Sustainable Agriculture

and ATTRA—The National Sustainable Agriculture Information ServiceFunding provided by the Organic Farming Research Foundation

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Copyright © 2009 Kerr Center for Sustainable Agriculture

Acknowledgements

Editing, Design and Production

For the Kerr Center:

Editor: Maura McDermottCopyediting: Wylie HarrisDesign: Tracy Clark, Argus DesignWorks, Albuquerque, New MexicoPhoto credits: Maura McDermott, pgs. 3, 9 top, 12, 20, 24, 34, 40, 41Printed by: Calvert-McBride Printing Company, Ft. Smith, Arkansas

Special thanks for reviews and comments to:

Chuck Willoughby, Robert M. Kerr Food & Agricultural Products Center atOklahoma State University; Stan Hildebrand, Sandhill Farm, Rutledge, Missouri; Janet Bachmann, Riverbend Farm, Fayetteville, Arkansas.

For more information, contact:

Kerr Center for Sustainable AgricultureP.O. Box 588, Poteau, OK 74953918-647-9123; 918-647-8712 faxwww.kerrcenter.com, [email protected]

The National Center for Appropriate Technology (NCAT)P.O. Box 3657, Fayetteville, AR 72702800-346-9140; 479-442-9842 faxwww.attra.ncat.org

Organic Farming Research FoundationP.O. Box 440Santa Cruz, CA 95061831.426.6606; 831.426.6670 [email protected]

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CERSTable of Contents

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

About the Authors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Section I: Organic Certification and Food Processing: An Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Requirements for Organic Certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Organic Processing and Handling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Food Processing Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Labeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

General Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Section II: Four Enterprises . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Section II, Enterprise 1: Sorghum Syrup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Sorghum Syrup: The Basics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Organic Production Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Organic Processing Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Sweet Sorghum: Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Section II, Enterprise 2: Packaged Fresh Salad Greens (Salad Mix) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Packaged Fresh Salad Greens (Salad Mix): The Basics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Organic Production Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Organic Handling Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Marketing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Regulatory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Packaged Fresh Salad Greens: Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Section II, Enterprise 3: Jams, Jellies, and Spreads . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Jams, Jellies, and Spreads: The Basics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Organic Production Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Organic Processing Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Regulatory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Jams, Jellies and Spreads: Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Section II, Enterprise 4: Table Eggs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Table Eggs: The Basics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Organic Production Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Organic Processing Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

Labeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

Additional Regulatory Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

Table Eggs: Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

End Notes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

iii

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Organic management can bring manybenefits to the farm. One of these is betternet income. A major contributing factor to animproved bottom line is the premium thatorganic commands in most markets.However, as production increases andorganic products go mainstream, premiumsare likely to decline, and organic farmers arelikely to face the same economic pressures astheir conventional neighbors. One way toavert this is by adding value to organic cropsthrough on-farm organic processing.

The examples are really endless. Some ofthe more obvious include converting:

• organic wheat to organic flour

• organic peppers and tomatoes toorganic salsa

• organic apples to organic apple cider

• organic okra to organic okra pickles

No doubt, adding a processing enterpriseto any farm is a serious undertaking, onethat requires sound research and planning.Organic farmers need to jump through thesame hoops any other business personwould in starting a food business, and atleast one more—organic certification.

Farm-Made is intended for the organicfarmer, or prospective organic farmer, who isconsidering adding a processing enterprise andneeds to know the additional challenges andrequirements that organic certification presents,as well as some of the unique opportunities.

Here we provide an overview of thegeneral requirements for organic certification

and for food processing facilities. We followthat with a discussion of four different on-farm enterprises—sorghum syrup, packagedfresh salad greens, table eggs, and cannedfruit products (jams, jellies, and preserves).With each, we outline the basic productionand processing requirements, and follow withdetails unique to organic management. A listof resources is provided in each chapter.

About the Authors

George Kuepper (Sorghum Syrup, TableEggs) is Sustainable Agriculture Specialistand Intern Program Coordinator at the KerrCenter for Sustainable Agriculture, inPoteau, Oklahoma.

Holly Born (Packaged Fresh SaladGreens; Jams, Jellies and Spreads) is aCertification Specialist for Processing withMidwest Organic Services Association, inViroqua, Wisconsin.

Anne Fanatico (Table Eggs) is the formerSoutheast Regional Director for the NationalCenter for Appropriate Technology (NCAT)and Poultry Specialist for its ATTRA Projectin Fayetteville, Arkansas. She is currentlywith USDA/ARS, at the University ofArkansas’ Fayetteville campus.

1

Introduction

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Requirements for Organic Certification

Except for operations that sell less than

$5,000 of organic products each year, all

production and handling operations must be

certified. (Handling entails selling, processing,

and/or packaging agricultural products.)

[NOP §205.2]

The first step in becoming certified is to

contact a USDA accredited certifier. Certifiers

either have, or can direct one to, the needed

information. There is a current list of certifiers

on the National Organic Program (NOP)

website (see General Resources). Also see

General Resources for sources of information

on the certification process.

An Organic System Plan (OSP) will be

required as part of the application for certifi-

cation. The OSP is the management plan for

the operation. It explains to the certifier what

will be done to comply with the National

Organic Standard (i.e., the USDA Organic

Regulations). The OSP details practices and

procedures, inputs and ingredients, monitoring

methods, and recordkeeping system, as well as

other information the certifier might deem

necessary to fully evaluate the operation.

Typically, the application form one

completes when applying for certification

collects and organizes all or most of the infor-

mation required for the OSP. An organic farm

with an on-farm processing/handling enter-

prise will need to submit two OSPs—one for

the farming or production enterprise, and one

for the handling enterprise.

Exempt operations (< $5,000 in annualorganic sales) are also required to develop anOSP, in the event they must demonstrate to abuyer, market manager, or governmentofficial that they are, in fact, managing organi-cally. Kerr Center’s Small Scale Organics: A

Guidebook for the Non-certified Organic Grower

features a short and convenient OSP template,as well as abbreviated recordkeeping forms(see General Resources).

Following a review of the application(s),the farm and handling operation will beinspected. If there are no major problems,certification will be granted, though it is oftencontingent on correcting small non-compliancesidentified by the certifier. OSPs must beupdated every year, and inspections also re-occur annually. ATTRA’s Preparing for anOrganic Inspection: Steps and Checklists isrecommended (see General Resources).

The annual costs of certification vary withthe size and complexity of the operation(s), aswell as the individual certifier. It is wise toshop around and ask a lot of questions. Forguidance, read How to Choose an Organic

Certification Agency from the Midwest Organicand Sustainable Education Service (MOSES).(See General Resources.) Also be aware thatthere are two different federal programs thatcan reimburse some of the costs of certification.The certifier will know which programs areavailable and how to apply in a given state.Be sure to ask!

SECTION I

Organic Certification and Food Processing:An Overview

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Organic Processing/Handling

In general, organic processing/handlingrequires:

• the use of organic agricultural ingredients,produced either by the organic processor/handler or by another certified grower. Allowedingredients from the Organic Program’sNational List of Allowed and ProhibitedSubstances (hereafter National List) mayalso be used (see General Resources).

• only allowed processing or handlingprocedures and methods. These include:“…cooking, baking, curing, heating, drying,mixing, grinding, churning, separating,extracting, slaughtering, cutting, fermenting,distilling, eviscerating, preserving, dehydrating,freezing, chilling, or otherwise manufacturingand includes the packaging, canning, jarring,or otherwise enclosing food in a container.”[NOP §205.2] Irradiation is prohibited, as isthe use of genetically-engineered organismsas ingredients or processing aids. [NOP§205.105]

• management and procedures thatprevent contamination with prohibitedsubstances and/or commingling with nonor-ganic products.

• proper recordkeeping and audit controlprocedures.

These requirements will all be addressedduring the process of certification. The certi-fier will point out any non-compliances thatneed to be corrected.

Food Processing Facilities

General Requirements

Any facility where food is processed mustmeet federal guidelines for such facilities. Inmost cases, however, the state health depart-ment is responsible for inspection, licensing,and enforcement. There will be many regula-tions that are enterprise-specific; however,some generalizations can be made:

• All food products produced for thepublic must be prepared in an approvedstate-licensed facility.

• Because living quarters must be physi-cally separate from food preparation areas,home kitchens can rarely be licensed.

• Adequate water and sewer capacitymust be available, as well as proper sanitationfacilities for anyone working in the facility.

• Needed processing equipment shouldhave NSF (National Sanitation Foundation)certification or its equivalent.

• The processing area—floors, walls, andequipment—must be easily cleaned.

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• Access must be controlled to restrictpets, children, and casual visitors.

• Pests and rodents should be excludedor otherwise controlled.

• A HACCP (Hazard Analysis CriticalControl Points) plan should be considered. AHACCP plan establishes where problems withfood safety are most likely to occur, and proto-cols for prevention. HACCP plans are requiredwhere meat and seafood are processed.

• If the operation falls within city limits,zoning regulations may limit or preventsetting up a processing facility.

• The Bioterrorism Act, passed after 9/11,requires all food manufacturers to registerwith the Food and Drug Administration(FDA). Details are on the FDA website atwww.access.fda.gov.

• Recordkeeping is critical, including aproper audit trail with a lot and/or batchnumbering system.

Organic Requirements

• All facilities that are part of the organichandling operation must be identified in theOSP and be covered in the annual inspection.

• Unless an intervening event such as aclear water rinse or the proper passage oftime serves to remove residues of a prohibit-ed cleaner, sanitizer, or other substance, suchmaterials may not be used. Alternatively,chlorine materials, ozone, and other materi-als on the National List under §205.605 maybe employed.

• Pest and rodent management mustbegin with preventive practices, such as sani-

tation and screen barriers. Where these arenot adequate, mechanical methods such astraps and repellents may be used. Shouldthese practices also be inadequate, nonsyn-thetic or synthetic pesticides on the NationalList may be used. As a last resort, otherwiseprohibited materials may be used if appliedin a manner that precludes contamination oforganic ingredients or products, and the OSPis properly updated. Details on facility pestmanagement are under §205.271 of theNational Organic Standard.

It is recommended that every foodproduction facility have a HACCP plan,which identifies critical control points wherefood safety can be compromised. Likewise,every organic facility should identify “organic”control points. Organic control points arespecific circumstances or locations whereorganic integrity can be compromised bycontamination or commingling. Protocols forensuring organic integrity at these pointsshould be established and become standardoperating procedure.

Labeling

General Requirements

As with the licensing of facilities,labeling regulations are overseen by the statehealth department. All product labels mustaddress the “big five:” 1) name of theproduct, 2) ingredients, 3) net quantity, 4)manufacturer name and address, 5) allergenstatement. The state health department canprovide the necessary information on all ofthese requirements. (Hint: Have the healthdepartment review the label before printingin volume!)

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Organic Requirements

There are four levels of organic labelingallowed under the National OrganicStandard. In summary, these are:

I. 100% Organic. May be used when theproduct contains 100% organically producedingredients, not counting salt and water.

II. Organic. May be used when theproduct contains a minimum of 95% organicingredients, not counting salt and water. Theremaining 5% may only be comprised ofsubstances allowed on the National Listunder §§205.605–205.606, and may notinclude sulfites.

III. Made with Organic Ingredients. May beused when the product contains at least 70%organic ingredients, not counting salt andwater. The remaining 30% may be comprisedof nonorganically produced agriculturalingredients and/or substances on theNational List under §§205.605–205.606, butmay not include sulfites.

IV. Listing organic ingredients on the ingre-

dient statement. Products having less than70% organic ingredients, excluding salt andwater, may indicate specific organic ingredi-ents on the ingredient statement.

Labeled products in categories I, II, & III,must:

• have ingredient statements when thefinal product is comprised of more than oneingredient.

• NOT identify salt or water as organic.

• include a statement “Certified by[Certifying Agent]. This statement must beplaced below the name and address of themanufacturer.

Only 100% Organic and Organic (cate-gories I & II) may use the USDA organic sealon the label.

Full details on labeling requirements arein the National Organic Standard under§§205.300–205.311. A summary is availableon the NOP website at:www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3004446&acct=nopgeninfo

USDA Organic Seal

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General Resources

Organic, General

National Organic Program (NOP)Barbara Robinson (Acting Director),Deputy AdministratorUSDA-AMS-TMPRoom 4008-South Building1400 Independence Avenue, SWWashington, DC 20250-0020Tel: 202.720.3252Fax: 202.205.7808Email: [email protected] www.ams.usda.gov/nop

Behar, Harriet. 2007. What Is OrganicAgriculture? MFS 612. MOSES,Spring Valley, WI. February.www.mosesorganic.org/attachments/productioninfo/fswhatis.html

Padgham, Jody. 2005. What Is OrganicAgriculture? A3811-8. University of WisconsinCooperative Extension, Madison, WI.www.mosesorganic.org/attachments/produc-tioninfo/uworganicag.pdf

Organic Certification

Anon. 2008. Organic Certification. NationalOrganic Program, Washington, DC. April.www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3004346&acct=nopgeninfo

ATTRA’s “Organic System Plan Guides.”ATTRA. Call 800.346.9140.

At the time of this writing, NCAT/ATTRA

is drafting three guides illustrating how to

complete an organic system plan. Guides are

being written for cropping farms, market

gardens, and mixed livestock operations.

The livestock guide includes an example

OSP for a table egg operation.

Anon. No date. How to Choose an OrganicCertification Agency. FS601. MOSES, SpringValley, WI. www.mosesorganic.org/attach-ments/productioninfo/fsagency.pdf

Baier, Ann. 2005. Preparing for an OrganicInspection: Steps and Checklists. ATTRA.January. www.attra.ncat.org/attra-pub/organic_inspection.html

Kuepper, George. 2002. Organic FarmCertification and the National OrganicProgram. ATTRA. www.attra.ncat.org/attra-pub/organcert.html

Kuepper, George. 2007. Small Scale Organics:

A Guidebook for the Non-certified Organic Grower.Kerr Center for Sustainable Agriculture,Poteau, OK. www.kerrcenter.com/publications/small-scale-organics.pdf

by George Kuepper

THE KERR CENTER FOR SUSTAINABLE AGRICULTURE

Serving Oklahoma's Farmers and Ranchers since 1965

Small Scale Organics:A Guidebook for the Non-certified Organic Grower

(Includes Guidelines and an Organic System Plan)

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Padgham, Jody, and Harriet Behar. 2008.Guidebook for Organic Certification, 3rd ed.MOSES, Spring Valley, WI. June.www.mosesorganic.org/guidebook.pdf

Organic Handling

Anon. 2006. Understanding Farm LotNumbers. MOSES, Spring Valley, WI.www.mosesorganic.org/attachments/productioninfo/fslotnumbers.html

Born, Holly. 2006. National Organic ProgramCompliance Checklist for Handlers. ATTRA.November. www.attra.ncat.org/attra-pub/PDF/organic_handlers.pdf

Menken, Michelle. No date. Organic LivestockFeed Processing Basics. Minnesota Departmentof Agriculture, St. Paul, MN.www.mosesorganic.org/attachments/productioninfo/08mnfeedprocess.pdf

Menken, Michelle. No date. Organic FoodProcessing Basics. Minnesota Department ofAgriculture, St. Paul, MN. www.mosesorganic.org/attachments/produc-tioninfo/08mnfoodprocess.pdf

National Organic Program. The National Listof Allowed and Prohibited Substanceswww.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5068682&acct=nopgeninfo

Organic Processing Magazine is publishedquarterly by The Target Group, Inc.To subscribe, visitwww.organicprocessing.com.

Labeling

Anon. 2003. Labeling Packaged Products.USDA National Organic Program, Washington,DC. January.www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3004323&acct=nopgeninfo

Scott, Darren D., Timothy J. Bowser, andWilliam G. McGlynn. November 2005. FoodProduct Labeling Basics. FAPC-140. OklahomaState University, Stillwater, OK.pods.dasnr.okstate.edu/docushare/dsweb/Get/Document-3020/FAPC-140web.pdf

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Introduction

This section provides a brief look atfour on-farm processing enterprises andthe specific challenges to making themorganic.

The enterprises—sorghum syrup,packaged fresh salad greens, table eggs,and jams, jellies and spreads—wereselected for a variety of reasons. Chiefamong them is their suitability to on-farm processing. In each case, the stepsfrom production to processing arestraightforward and manageable forsmall- and mid-sized organic farms.

Another reason for selecting thesefour enterprises is their innate diversity,which yields a wide array of circum-stances, challenges, and examples fordiscussion—most of them common to ahost of other possible enterprises.

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What is sorghum syrup?

Sweet sorghum syrup is made from thesugar-rich juice of a particular type ofsorghum (Sorghum bicolor (L.) Moench) calledsorgo, sorghum cane, or simply, sweetsorghum. Sorgo stalks are crushed to releasethe juice, which is cleansed of impurities andconcentrated by cooking in open pans. Theresult is a clear, amber-colored, mild flavoredsyrup. Unlike molasses, which is a by-productof sugar manufacturing, sorghum syrupretains all of its natural sugars and nutrients.

How is it used?

Sorghum is a versatile sweetener. It isoften used as table syrup—poured directlyover pancakes, biscuits, or bread. Sorghumsyrup is also a nutritious cooking ingredient.Usually, 2/3 cup of sorghum substitutes for acup of sugar; it can be substituted cup forcup in recipes that call for molasses, honey,corn syrup, or maple syrup, such as desserts,

breads, and sauces. For further informationabout sorghum syrup—what it is, where tobuy it and how to use it—contact the NSSPA,National Sweet Sorghum Producers andProcessors Association (see SorghumResources).

Regional adaptation

Sorghum syrup is a tradition in the lowerMidwest and the Southeast, where Kentuckyand Tennessee remain the leading states inproduction. In recent decades, however, theenterprise has expanded northward, withcommercial production reaching intoWisconsin and Minnesota.

Farm production basics

Sweet sorghum plants resemble corn.Both are tropical grasses and resemble eachother when immature. Differences appear atflowering. Whereas the male (tassel) andfemale (silks) flower parts grow on differentparts of the corn plant, they are combined onthe sorghum plant. The resulting seed in a

SECTION II, ENTERPRISE 1

Sorghum Syrupby George Kuepper

Sorghum Syrup: The Basics

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sorghum plant is produced in a panicle atthe top of the stalk, as opposed to the side-borne ears of corn.

Sorghum and corn are also cultured simi-larly. In fact, field operations up until harvestare almost identical. Harvesting sorghum forsyrup, however, is quite different. All theharvestable juice is in the stalks and the optionsfor harvest are usually dictated by the levelof mechanization employed by the farmer.

The level of harvest mechanization varieswith the size and capitalization of each farm.On very small, traditional operations, workershand-strip leaves from the standing canesusing wooden slats or sticks. (Crushing ormilling green leaves along with the stemsmay impart off-flavors to the syrup.)

After stripping, farmers hand-cut andremove the seed heads. (Unless they can becollected as livestock fodder, leaves and seedheads are typically left in the field or otherwisediscarded before the stalks are milled. Sweet

sorghum is often harvested when seed headsreach the soft-dough stage, which is generallytoo immature for grain to be dry-stored.)

Intermediate scale operations often relyon archaic row-binders that cut and bundleun-stripped sorghum cane. Bundles are leftin the field for several days to allow leaves todry and speed the desirable transformationof sucrose into simpler sugars that do notreadily crystallize. Seed heads must still betopped before milling. A cutter-bar or rotarymower offset-mounted on a front-loadertractor bucket can lop off seed heads justahead of the row binder. Alternatively,bundles can be topped individually in thefield or when stacked on a wagon usingpowered hedge trimmers or a chainsaw. Thedifficulty with this approach is the ever-dwindling number of working row-binders—technological marvels that are no longerbeing manufactured in the United States.

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usually choose one of two options.The first entails the use of amodified forage chopper to harvestthe un-stripped cane.Modifications usually includeremoving some chopper blades toensure that stem joints are longer.The cut sorgo will be then passedover screens and blowers at themill to remove the leaves prior tomilling. A second approachinvolves farm-engineered single-pass equipment that cuts and millsin the field. Since green leaves arecrushed using this method, additional atten-tion to processing is required to ensure goodquality syrup. In both instances, cane isusually topped ahead of cutting using eithera bucket-mounted mower, like intermediate-scale farmers use, or some other alternative.

Farm-scale processing basics

Sorghum syrup continues to be madeprimarily on-farm. Even larger processors growmost, or all, of the crop they process. And assuggested by the different levels of harvest

mechanization, scales of commercial processingrange from very small to quite large.

Milling—the crushing of sorgo stalks toexpress juice—is the primary step in process-ing. Small- and intermediate-scale farms typi-cally use refurbished sorghum and sugarcanemills that were manufactured in the earlyand middle decades of the 20th century.

The majority of on-farm mills featurethree rollers (see figure at left). These arearranged either horizontally or vertically.

Most vertical mills are small andwere designed to be powered bydraft animals. Most producers,however, have adapted them forsmall engine or tractor drive. (Whilethe number of small mills is alsodwindling, the machinery is lesscomplex than row-binders and easierto refurbish and maintain.)

After crushing, sorghum juice isstrained to remove large contami-nants. It may be cooked immediately,but settling for a short time iscommon and encouraged. Settlinghelps clarify the juice and results in a 11

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higher quality syrup.

It is often desirable to hold andsettle juice for several hours—evenovernight—in order to ensureenough for an efficient round ofcooking. Holding juice prior tocooking can be done in two ways.It can be either refrigerated, or pre-heated and stored at 190°–205° Funtil cooking. Either methodallows for effective settling andpermits the addition of alpha-amylase enzymes that assist inbreaking starches down into sugars.This prevents the problem of syrupgelling in the container. Pre-heating typicallyrequires steam, and therefore, an on-siteboiler. (Once one makes the leap to installinga boiler, it dictates how cooking will be done.)

Converting juice to syrup is fundamen-tally a process of evaporation. Water is “boiledoff” to thicken the juice. It takes from 6 to 12gallons of juice to make one gallon of finishedsyrup. The better quality syrups are made onrelatively shallow pans with a large surfacefor rapid evaporation. The less time that juiceor syrup is exposed to heat, the lighter andmore attractive the product color will be.

While all manner of cooking vessels canbe used, the most common style of sorghumcooker is the continuous-flow evaporator.Also common are batch pans and a uniqueform of continuous flow evaporator called a“Stubbs” pan. Small operations will typicallyuse only one type of pan. Larger, morecomplex operations may use a mix of pantypes. For example, a semi-syrup might beprepared in a Stubbs pan, then transferred toa continuous flow pan for finishing.

Bottling is often done immediately after

cooking, while the syrup remains hot. This iscommonly done to ensure a sterile productand to achieve a natural vacuum seal on thecontainer. However, since microorganismscannot grow on properly prepared syrup,hot packing is not necessary.

When sorghum syrup is stored for a longperiod of time, it can crystallize in the sameway that honey does. Crystallization occurswhen there is a high concentration of sucrosesugar in the final product. Processors some-times add invertase enzymes to prevent crys-tallization. The enzyme converts sucrose toglucose and fructose sugars. It is added tofinished syrup prior to bottling; it worksslowly in the container over a period ofseveral weeks.

For more detailed descriptions of sweetsorghum production and processing, seeSweet Sorghum Culture and Syrup Production

by Mask, Production of Sweet Sorghum for

Syrup in Kentucky by Bitzer, Processing Sweet

Sorghum for Syrup by Bitzer and Fox, Sweet

Sorghum Production and Processing byKuepper, and the DVD Sweet Sorghum Syrup

Production (see Sorghum Resources).12

Mule-powered sorghum press

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Cultural requirements

Crop rotations and fertility. There is apersistent myth among old time producersthat good quality syrup can only be madefrom cane grown on poor soil. It is true thatsyrup quality will suffer when there areexcess nitrates in the soil. Under organicmanagement, this suggests care in severalareas of fertility management.

For example, excess soil nitrates caneasily accumulate following plowdown ofpure legume stands. If forages or cover cropsprecede a sorghum planting, they shouldcontain no more than 50% legumes.Otherwise, sweet sorghum can be grownsuccessfully following most crops. It is alsorisky to apply fresh manure prior to plantingthe crop. Manure often contains excessnitrates. If used, it is best applied to someother crop in the rotation.

Sweet sorghum also has a reputation forbeing “hard on soil.” Two factors contributeto this. First of all, sorghum is ratherdrought-tolerant. This characteristic is partlydue to the crop’s ability to forage and extractmore moisture from the root zone than mostagronomic crops. This can leave subsequentcrops thirsty under dryland conditions.Second, sorghum residue has a high carbon-to-nitrogen ratio. It can lock up soil nitrogensomewhat longer than other plant matterafter it is tilled into the soil. That said, mostother farm crops can be planted aftersorghum without particular problems.

Seed selection & sourcing. At this time, itis challenging to find organic seed of anysweet sorghum varieties. Seed may be avail-able from farmer cooperatives and local seed

suppliers, but the selection of varieties isusually limited. Growers in the South andMidwest commonly buy untreated seed fromMAFES Foundation Seed Stocks; many saveseed for subsequent seasons.

Heritage varieties are becoming easier tofind as there are a growing number ofheirloom seed companies. Some excellentsources include Sand Hill PreservationCenter, Baker Creek Heirloom Seeds, andNative Seeds/SEARCH (see SorghumResources for seed sources).

There are currently no genetically-engi-neered sweet sorghum varieties. It isunlikely that seed companies will invest intheir development soon, unless interest insweet sorghum-based ethanol balloons.

It is not common practice to coat sweetsorghum seed with fungicides or otherprohibited materials. There is one exception,however. Some sorghum seed—especially formodern varieties like “Topper 76-6,” “Dale,”and “Theis”—may be treated with ConcepIII—a chemical protectant for use with herbi-cides containing S-metolachlor. Seed treatedwith Concep III or similar protectants areusually special ordered and treated seed iseasy to identify and avoid.

Weed management. Weed control insweet sorghum is similar to that used incorn, only a bit more challenging. Sorghumis smaller-seeded and slower to emerge thancorn. Therefore, it is a bit slower to develop aweed-suppressive canopy. Once a canopy isestablished, though, sweet sorghum growstall and does an excellent job out-competingmid- and late-season weeds.

Cultivation options are similar to corn,though they may be timed a bit later due tosorghum’s slower emergence. Blind cultiva- 13

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tion with a rotary hoe, spike tooth, or flex-tine weeder can be tried, though caution iswarranted. Because sorghum is small-seeded, blind cultivation can take a highertoll than it does on corn. An excellent guideto cultivation tools and their use is Steel in

the Field by Greg Bowman (see SorghumResources).

Delaying planting to give sorghum acompetitive edge on weeds is generally asound strategy. However, it may increasesusceptibility to disease and may not be agood idea for many heirloom varieties.

Innovative growers began experimentingwith transplanting in the 1980s, using thesame equipment used for tobacco. Thisstrategy gives the crop a head start and is agreat boon to weed management. Details areoutlined in the University of Kentucky DVDSweet Sorghum Syrup Production (seeSorghum Resources).

Pest and disease management. Mostsorghum diseases and insect pests aremanageable using resistant varieties andgood organic cultural practices. Heirloomvarieties, however, may not show the samelevel of resistance and tolerance. Insecticidesand fungicides are rarely used in convention-al production, and allowed products wouldprobably not be efficacious or economical fororganic production either.

As with corn, delayed planting is one ofthe tools that can be used for weed manage-ment. However, late planting also increasessusceptibility to diseases.

Another consideration in disease manage-ment is the presence of johnsongrass—aperennial relative of sweet sorghum that is analternate host for diseases. Conventional

growers are advised to clear johnsongrassfrom adjacent fields and borders. This is noteasily done even with conventional herbicides.Organic growers may, however, keep john-songrass mowed on a schedule that reducesthe development and spread of disease spores.

Organic Processing Issues

Juice extraction (Milling)

Conventional practices used in millingsorghum cane are acceptable under organicmanagement and there are few organiccontrol points. Food-grade grease must beused to lubricate open gears and bearings.While these materials are synthetic, they donot need to be on the National List. They arenot food or processing ingredients. They aremanufactured as “food-grade” mainly as asafety measure in the event of accidentalcontamination. In practice, every effort mustbe made to ensure that lubricants do notcontact the cane or the juice. Food-gradelubricants are widely available (see SorghumResources).

Cleaning is usually done with a waterspray. If synthetic cleaning and disinfectingagents are used, they should be followedwith a water spray to remove any residue.Chlorine products are commonly employed.As a general rule, certifiers allow moststandard cleaning agents if residues areeffectively removed via clean water rinsing.This will be true at a number of organiccontrol points in sorghum making. Whensynthetic cleaners or other agents not on theNational List are used in contact surfaces, an“intervening event” such as a clean waterrinse must be used to remove any contami-nating residues before organic crops can beprocessed.14

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issue, the use of draft animals to power thesorghum mill should be mentioned. Stateregulations may or may not permit usinghorses, mules, or oxen for milling, due tocontamination hazards from dung, dust,dander, etc. While using draft animals maybe an excellent agri-tourism marketing tool,be certain to thoroughly understand therestrictions and requirements involved.

Juice handling/storage

In practice, sorghum producers use awide variety of containers to hold juice priorto cooking. Stainless steel is certainly thestandard, but galvanized livestock tanks,plastic tubs, and wooden barrels are allacceptable. Similarly, stainless steel, plasticPVC, and FDA approved food grade waterhoses or flexible tubing may be used totransfer juice. As with cleaning the mill,various agents, such as chlorine bleach, maybe used to aid in cleaning and disinfectingstorage and transfer equipment as long as aclear water rinse follows.

The care taken for cleaning mills andjuice handling equipment may appearsomewhat lax. However, cooking tempera-tures in sorghum making typically exceed230° F. Such high temperatures eliminatemost, if not all, microbial hazards that ariseduring the milling and juice handling stages.

Cooking

Evaporating sorghum juice to makesyrup is a basic process with only a feworganic control points of concern. Essentiallythose are the use of amylase enzymes andprocedures, and the choice of materials forcleaning the evaporator pan.

Amylase enzymes. Sometimes, sorghum

syrup may “gel” after bottling. Gellingresults when the juice contains too muchstarch. Many producers control gelling byadding amylase enzymes. Amylase convertsstarch granules to simple sugars anddextrans. Amylase can be added to the juiceat various stages, depending on how juice ishandled and the cooking system that is used.

Enzyme use is an organic control pointbecause genetically-engineered and non-GEforms of amylase are both on the market andboth are widely used. It is important that theorganic processor obtain a non-GE enzyme.At present, it appears that most processorsbuy enzymes through the NSSPPA, whichprovides both GE and non-GE forms. Becertain to request non-GE amylase!

Lastly, it helps to know that the starchproblem can also be addressed by othermeans, either eliminating the need forenzymes or reducing them to a fallbackmeasure. Some sorghum varieties, forexample, are less starchy. Timely harvest canalso make a difference; over-mature canestend to yield more starch. Settling the juicefor one to three hours is perhaps the mostuseful practice for reducing starch levels.

Cleaning the evaporator pan. Aftercooking is completed, about one inch ofwater should be left in the evaporator panovernight. An alkaline detergent is oftenadded to remove mineral deposits. Thefollowing morning, an acid cleaner is used toremove salt precipitates. Use non-metallicscrubbers to prevent leaving metal fragmentswhere they might end up in the final product.Thoroughly rinsing the pan with clear waterafter the acid cleaning is standard practice andprovides the “intervening event” preventingfood contact with a prohibited substance. 15

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However, for the extra careful, there are anumber of acid-based cleaners that meet therequirements of the National OrganicProgram. These are commonly used in thedairy industry to clean milk lines and equip-ment, circumstances where interveningwater rinsing is not allowed. The OrganicMaterials Review Institute (OMRI) may listseveral allowed acid-based cleaners (seeSorghum Resources).

Be certain to dispose of used cleaningsolutions in a proper fashion. If they are notdirected into a sewer or septic system, it isadvisable to capture and dispose of themproperly in a covered pit, away from surfacewaters and tree roots.

Syrup handling and bottling

In many cases, syrup is bottled shortlyafter cooking, after cooling down to about130—140° F. There are several advantages toquick bottling while the syrup remains fairlyhot. Among them is the rapid flow of thesyrup, which speeds the bottling process.Packing a hot product also provides anatural vacuum seal and reduces the hazardof microbial contamination.

Traditionally, sorghum was packed forsale in four-pound metal cans. These arerarely seen anymore. Glass jars and plasticsyrup bottles have largely supplanted cans.Recently, however, a number of concerns havebeen raised about plastic containers. Twochemicals, bisphenol A (BPA) and phthalates,contained in many grades of plastic, havebeen highlighted. They may be of concernwhen sorghum is hot-packed, as high temper-atures tend to leach them from the plastic.Generally speaking, the safest plastics forfood packaging appear to be the mostcommon—those made from HDPE #1 and #2.

Fortunately, the most popular plastic bottlethat producers use at present is made fromHDPE #2 plastic (see Sorghum Resources.)

Invertase enzymes. Like honey, sorghummay crystallize (go to sugar) in storage. Thisis most often a problem when syrup is storedover winter. Crystallization results when thereis an imbalance among the three main sugarsin sorghum—sucrose, fructose and glucose.Typically, the culprit is excess sucrose, thoughtoo much glucose can also cause “sugaring.”Producers can add invertase to convert sucroseto fructose and glucose. This is done mostcommonly to finished syrup just prior tobottling, though invertase can also be addedto semi-syrup, if making and holding semi-syrup as part of the process. The issue withinvertase is the same as that discussed underamylase: care must be taken to ensure that theenzyme is not genetically engineered.

As with gelling, crystallization can alsobe reduced through management practices.Certain varieties, such as “Keller,” have areputation for crystallizing, and can beavoided. Cutting canes several days prior tomilling, and allowing them to lie on theground or in a stack at the mill, encouragesthe natural conversion of sucrose.

Labeling

The federal Food and Drug Administration(FDA) sets the basic requirements for foodproduct labeling. There are often state-basedprograms available through departments ofagriculture that can assist in complying withfederal requirements for weights andmeasures and other factors. State depart-ments of agriculture may also have addition-al labeling programs that can help distin-guish products. The Oklahoma Departmentof Agriculture, Food, and Forestry, for16

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Oklahoma that allows in-state farms andother businesses to promote and label theirproducts accordingly.

Another labelingprogram of interest isprovided by the NationalSweet Sorghum Producersand Processors Association(NSSPPA). Concern aboutthe abundance of“blended“ and imitation”sorghum“ labeled as pureprompted the NSSPPA to develop a logo thatassures the consumer of a pure, unadulteratedproduct (see Sorghum Resources).

National Organic Program (NOP)

labeling requirements. Sweet sorghum syrupproducts that have been produced andprocessed organically must be properlylabeled when marketed as organic. There arefour levels of labeling:

1. A product may be labeled as “100%Organic” if it contains only 100% organicagricultural ingredients. Sweet sorghumsyrup might be labeled “100% Organic” ifNO enzymes, other processing aids, or othernon-organic ingredients are added. TheUSDA’s organic seal may be used onproducts labeled “100% Organic.”

2. A product may be labeled “Organic” ifit contains a minimum of 95% organic agri-cultural ingredients. The remaining 5% ofingredients may include only those allowedon the National List. For example, sorghumthat has been made using non-GE enzymescan be labeled as “Organic.” The USDA’sorganic seal may also be used on productslabeled Organic.

3. A product may be labeled “Made WithOrganic Sorghum” if it contains a minimumof 70% organic ingredients. The remaining30% of ingredients may not be produced orprocessed using sewage sludge, irradiation,or genetic engineering. A syrup blend ofsorghum and conventional sugarcane syrupmight qualify for this label; a blend usingconventional corn syrup likely would not, asmost (if not all) conventional corn syrupcomes from genetically engineered corn. TheUSDA’s organic seal may NOT be used onproducts labeled “Made With Organic.”

4. Products that contain less than 70%organic ingredients may identify them on theingredients panel. For example, a loaf of breadmay list its ingredients as “whole wheat flour,oat flour, wheat berries, organic sorghumsyrup, rolled oats, butter, sea salt, yeast.”

Additional specific requirements for organiclabeling are addressed in Subpart D of theNational Organic Standard §§205.300–311.

Additional regulatory issues

All food products manufactured for thepublic must be prepared in an approvedlicensed facility. In most states, licensing isoverseen by the state health department.Additional approval and licensing by thestate agriculture department might also berequired for some enterprises in some states.

If a farm falls within the limits of a city,there may be additional zoning requirementsto meet. City and/or county regulations mayalso apply to the construction of new facili-ties if those are needed. If a steam boiler is tobe used, state certification will also be neces-sary; such certification may also require thatspecial boiler insurance be purchased.

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General information for sweet sorghumproduction and processing

National Sweet Sorghum Producers andProcessors Association (NSSPPA)c/o Morris Bitzer2049 Rebel RoadLexington, KY 40503Tel: 859.806.3358Fax: [email protected]/nssppa/

Sweet Sorghum Syrup Production (DVD),dept.ca.uky.edu/agc/distrib/record_details.asp?ID=200

University of Kentucky educational DVD

gives a 13-minute overview of sorghum

production and processing.

Sweet Sorghum Culture and Syrup Production

by Paul Mask and William C. Morris.Alabama Cooperative Extension Systempublication ANR-625. November 1991.www.aces.edu/pubs/docs/A/ANR-0625/

Production of Sweet Sorghum for Syrup in

Kentucky by Morris Bitzer. University ofKentucky Cooperative Extension Servicepublication AGR-122. November 1994.www.ca.uky.edu/agc/pubs/agr/agr122/agr122.pdf

Processing Sweet Sorghum for Syrup

by Morris Bitzer and Joe D. Fox.University of Kentucky CooperativeExtension Service publication AGR 123.May 2000. www.ca.uky.edu/agc/pubs/agr/agr123/AGR123.pdf

Sweet Sorghum Production and Processing

by George Kuepper. Kerr Center for Sustainable Agriculturewww.kerrcenter.com/publications/sorghum/sorghum.html

Sorghum seed sources

Baker Creek Heirloom Seeds2278 Baker Creek RoadMansfield, MO 65704Tel: 417.924.8917rareseeds.com

Hubert Farms10685 E. 1700 N.Ferdinand, IN [email protected]

Source of “Sugar Drip” sorghum seed

MAFES Foundation Seed StocksBox 9811Mississippi State, MS 39762-9811Tel: 662.325.2390Fax: 662.325.8118msucares.com/crops/sorghum/descriptions.html

Native Seeds/SEARCH526 N. Fourth AvenueTucson, AZ 85705Tel: 520.622.5561www.nativeseeds.org

Sand Hill Preservation Center1878 230th StreetCalamus, IA 52729563.246.2299www.sandhillpreservation.com

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Source of seed for various sorghum varieties

Organic

National Organic Program (NOP) Barbara Robinson (Acting Director),Deputy Administrator

USDA-AMS-TMPRoom 4008-South Building1400 Independence Avenue, SWWashington, DC 20250-0020Tel: 202.720.3252Fax: [email protected]/nop

Organic Materials Review Institute (OMRI)Box 11558Eugene OR 97440Tel: 541.343.7600Fax: [email protected]

Steel In the Field: A Farmer’s Guide to Weed

Management Tools by Greg Bowman.SARE Handbook Series #2. 2001.www.sare.org/publications/weeds.htm

Labeling

Made in Oklahomawww.madeinoklahoma.net/

U.S. Food and Drug Administration, FoodLabeling and Nutritionwww.cfsan.fda.gov/label.html

HDPE #2 Plastic Sorghum JugsGuenther Sorghum Supply4363 Muddy Pond Rd.Monterey, TN 38574Tel/Fax: [email protected]

Enzymes

National Sweet Sorghum Producers andProcessors Association (NSSPPA)c/o Morris Bitzer2049 Rebel Road, Lexington, KY 40503Tel: 859.806.3358Fax: [email protected]/nssppa/

Be certain to specify non-GMO/non-GE

enzymes; NSSPPA supplies both!

Food-grade lubricants

ThomasNetwww.thomasnet.com/products/grease-food-grade-35701408-1.html

Directory of suppliers of food-grade

lubricants.

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What is a salad mix?

Salad mix can be made up of any combi-nation of lettuces, leafy greens, herbs, andflowers, but usually is a mix of several typesof young leaf lettuces. Salad mixes areextremely popular, relatively easy to grow,and produce marketable crops quickly,making them an attractive value-added optionfor the small grower.

Production basics

Growing salad mix is largely the same asgrowing leaf lettuce. The seedbed is preparedand the lettuces and other greens are seededdirectly. Usually, but not always, the differenttypes and varieties are sown separately, withthe idea that they will be proportionatelyblended later on to create the final product.Depending on the types and varieties ofgreens planted, harvest usually occurs within30 days since the greens are harvested young,about four to six inches tall. The main difficultywith salad mix production is staggering plantingdates so that a steady supply is availablethroughout the season.

The lettuces and other ingredients in saladmix are usually not in the field long enough tobe susceptible to many pests or diseases. Aphidsand thrips are possible insect pests. Damping-off is the main fungal disease affecting younggreens. Weed control is very important as

young lettuces cannot out-compete weeds.

Farm-scale processing basics

The greens are harvested, depending onscale, either by hand, using a small-scaleharvester, or by using a large-scale harvester.Proper post-harvest handling is crucial forproduct quality. The greens need to be cooledimmediately after harvest, usually by immers-ing them in near-freezing cold water. Greensmust be carefully washed and sorted. Dirty,gritty, or low quality greens are unacceptableto almost all customers.

Greens may be washed several times.When greens are completely washed, dried,and graded, they are packed and returned to avery high humidity, near-freezing environ-ment. Usually each type of lettuce and othergreens are grown and harvested separatelyand then mixed after they have been washedand dried. However, because salad mix hasbecome so popular, many seed companiesoffer mixes designed to mature together, andwith different colors and flavors. The mix canbe packaged for sale after washing and drying.

More information on harvesting, washing,spinning equipment and methods, and packagingcan be found in the ATTRA publication Specialty

Lettuce and Greens (see Salad Mix Resources).

SECTION II, ENTERPRISE 2

Packaged Fresh SaladGreens (Salad Mix)by Holly Born

Salad Mix: The Basics

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Salad mix and other leafy greens arealmost always eaten raw. Since they are oftenharvested by hand, hand sorted, and handmixed and packaged, there are many pointsin the process where they can be touchedand contaminated. Even products at finalretail may be touched many times beforethey are eaten. Thus salad mix productionand marketing poses many challenges tofood safety.

While this guide focuses on post-harvesthandling and packaging of salad mix, it isimportant to note that food safety andquality begins with choice of production siteand can be affected at every step in theproduction and marketing chain. Attentionto all food safety practices is especiallyimportant for a product such as salad mixthat is eaten raw. Production sites must notbe vulnerable to potential contaminationfrom manure or prohibited chemicals inrunoff water from neighboring sites. Everyeffort should be made to exclude animalsfrom production and handling areas, andworkers must practice proper hand washing.

Since salad mix is washed and cooled,water must be tested for contamination withpathogenic organisms such as E. coli, andreuse of wash water should be avoided toreduce cross contamination. Local healthdepartments will advise on the types ofwater tests that are needed, and often test forbacteria and nitrates. The health departmentcan also make referrals to licensed testinglaboratories in the area. All equipment thathas contact with the product must be cleanedand sanitized. Transportation vehiclesshould be inspected to be sure they are cleanand sanitary. See the Salad Mix Resourcessection for sources of comprehensive food

safety guidelines for growers and handlersof leafy greens.

Organic Production Issues

Cultural requirements

Organic growing of salad mixes followsthe same general steps outlined above.However, there are some special considerationsfor organic production. Organically grownseed is required for organic production, butnon-organically grown untreated seed maybe used if the type and variety needed is notcommercially available as organic. Varietiesused may not be genetically engineered.

If manure is applied within 120 days ofharvest, it must be composted according tothe requirements of the National OrganicStandard §205.203(c)(2). Specifically, animalmanure and accompanying feedstocks mustgo through a process in which: 21

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• The initial C:N ratio of the feedstocksis between 25:1 and 40:1; and

• A temperature between 131 - 170 °Fis maintained for three days if an in-vessel orstatic aerated pile system is used; or

• A temperature between 131 - 170 °Fis maintained for 15 days if a windrowcomposting system is used. During thatperiod, the materials must be turned aminimum of five times.

Raw manure may be used if the intervalbetween application and incorporation, andharvest, is 120 days or more. However, thismay still be risky. A recent study analyzedorganic and conventional vegetables grownin Minnesota for bacteriological contamina-tion. While it found no significant differencesin bacteria levels between vegetables fromconventional and certified organic growers,it did find that growers who used manure orcompost aged less than twelve months hadvegetables with coliform bacteria levelsnineteen times higher, on average, than thosewho used a longer aging process. [1]

Since food safety for leafy greens is soimportant, it may be wise to forego use ofmanures entirely and rely on alternativemeans of soil fertility such as formulatedorganic fertilizers or green manures—cropsplowed down to improve the soil.

As mentioned earlier, salad mix greenshave few pests, mainly thrips and aphids.Organic growers often use insecticidal soapto control these pests. Ideally, soap formula-tions should be mixed with softened ordistilled water as minerals—especiallycalcium—in hard water reduce the spray’seffectiveness. [2] There are few good organical-ly acceptable products for controlling fungaldiseases, but some of the biofungicides are

effective. Baking soda may be useful, too.ATTRA is a good source for information onthese topics (see Salad Mix Resources).

All inputs must be allowed for organiccrop production and approved for the useintended, i.e. fertility, insecticide, diseasecontrol, etc. The Organic Materials ReviewInstitute (OMRI) is an excellent guide toallowed materials (see Salad Mix Resources).For additional guidance, see ATTRA’s Organic

Materials Compliance in Salad Mix Resources.

Organic Handling Issues

Cleaning and sanitizing equipment

Cleaning equipment involves use ofdetergents to remove visible dirt and mostmicroorganisms, while sanitation refers toelimination of the remaining microorganismswhile ensuring that the organic product is notcontaminated by the cleansers and sanitizers.

The chlorine based sanitizers (bleach,sodium hypochlorite, and others), peraceticacid, hydrogen peroxide, phosphoric acid,and ozone are among the sanitizers on theNational List of Allowed and ProhibitedSubstances (see Part I, General Resources)that can be used. Peracetic acid is effectiveand more environmentally friendly thanchlorine products, but more expensive.Ozone is most expensive but poses no risksto workers handling chemicals and leaves noresidues to affect the environment.

Often, use of chemicals not on theNational List, such as quaternary ammonium,iodine, and synthetic surfactants, may beallowed if followed by an “interveningevent,” such as a clear water rinse or the22

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The most straightforward approach is touse cleaners and sanitizers that are on theNational List. Again, check with the certifierand check the OMRI guidance materials forhelp in determining which cleaners and sani-tizers to use.

Post-harvest handling

Wash water will need to be tested forcontaminants. Most certifiers will request awater test unless the water is from a moni-tored source that complies with the SafeDrinking Water Act. Most municipal watersources meet these standards. Sanitizers areusually used in wash water and must be onthe National List as allowed for food contactsurfaces if synthetic. Some commonly usedsanitizers include chlorine based sanitizersas described above, hydrogen peroxide, andperacetic acid/peroxyacetic acid. The certifi-er will expect a plan to test the waterdischarged and document the results ofthose tests.

An excellent, comprehensive guide topost-harvest handling for organic crops isPostharvest Handling for Organic Crops (seeSalad Mix Resources). It is highly recommendedfor all organic growers, but especially thosegrowing products that are consumed raw.

Marketing

Labeling

Most salad mix will be comprised of onlycertified organic lettuces and other leafygreens and can be labeled “100% Organic.”However, it is possible to formulate productsthat might have less organic content andrequire different labeling.

For example, products containing at least95% certified organic ingredients can belabeled “Organic.” In such cases, the remain-ing 5% of ingredients may include only thoseallowed on the National List. A product maybe labeled “Made With Organic” if itcontains a minimum of 70% organic ingredi-ents. The remaining 30% of ingredients maynot be produced or processed using geneti-cally engineered organisms, sewage sludge,or irradiation.

§205.606 of the National OrganicStandard is a list of nonorganic agriculturalproducts that may be used in “Organic”products if organic equivalents are notcommercially available. The grower wouldbe expected to document a search for organicsources of these ingredients. Some organicsources §205.606 ingredients can be found ata special website maintained by theAccredited Certifiers Association and at theOrganic Trade Association’s Organic PagesOnline (see Salad Mix Resources).

Regulatory

Federal regulation

Unless total annual organic sales are lessthan $5,000, an operation must become certi-fied by an accredited certifying agent to repre- 23

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sent its salad mix as “Organic.” To locate acertifier, visit the National Organic Program’swebsite (see Salad Mix Resources). For moreinformation on the organic certificationprocess and for other useful salad mixresources, visit the ATTRA website.

A question that arises with salad mixproduction and sales concerns the boundarybetween post-harvest management of avegetable crop and processing. The distinctionis important. If the activities associated withpreparing salad mix for market are deemedprocessing (handling), the grower is requiredto submit an organic handling system plan aswell as the organic production system plan,which is not only time-consuming, butrequires additional certification fees.

Generally speaking, harvesting, cooling,and washing are recognized as post-harvestactivities. If the grower then sells the productin bulk or allows customers to self-bag at themarket, it might not be viewed as processing.This, however, is not a hard-and-fast rule. Itwill be necessary to talk with the certifier todetermine where he or she draws the line.

State regulation

Regulations can vary from state to state.Most will consider salad mix a processedproduct and require licensing or permits ifthe mix is processed beyond simpletrimming, for example by chopping orshredding, and/or if the product is sold aswashed, “ready-to-eat.” Many states willconsider it an unprocessed product as longas it is labeled with the instructions to washthe product before eating. Additionally,growers may be held liable for customerproblems if customers eat the salad mixunwashed. Although as detailed abovegrowers will certainly be thoroughly

washing the salad mix, they may want toprotect themselves by making sure thatproduct labels and all printed materialsspecify that customers must wash theproduct before eating.

Liability insurance

Growers will probably want to carrysome food product liability insurance. In fact,many farmers’ markets and most retailersrequire proof of such insurance. Insurancecompanies may be able to work with foodproduct liability insurers, or direct growers tosources of such insurance. Many smallproducers have obtained food product liabilityinsurance at very affordable rates throughtheir local Farmers Union or Farm Bureau.

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Production and post-harvest

Kuepper, George, Janet Bachmann, andRaeven Thomas. 2002. Specialty Lettuce &Greens: Organic Production. CT117. ATTRA,Fayetteville, AR. attra.ncat.org/attra-pub/lettuce.html

Other ATTRA publications on organicvegetable production. Available free ofcharge. Call 800.346.9140, or visitwww.attra.ncat.org/organic.html#vegetable.Publications include:

■ Resource Guide to Organic andSustainable Vegetable Production

■ Scheduling Vegetable Plantings forContinuous Harvest

■ Organic Market Farm DocumentationForms

■ Season Extension Techniques forMarket Gardeners

■ Organic Crop Production Overview

■ NCAT's Organic Crops Workbook – AGuide to Sustainable and AllowedPractices

■ Suppliers of Seed for CertifiedOrganic Production

■ Postharvest Handling of Fruits andVegetables

■ Use of Baking Soda as a Fungicide

■ Thrips Management Alternatives inthe Field

Suslow, Trevor. No date. PostharvestHandling for Organic Crops. OrganicVegetable Production in California Series.University of California Publication No. 7254.anrcatalog.ucdavis.edu/pdf/7254.pdf

Organic

National Organic Program (NOP) Barbara Robinson (Acting Director),Deputy AdministratorUSDA-AMS-TMPRoom 4008-South Building1400 Independence Avenue, SWWashington, DC 20250-0020Tel: 202.720.3252Fax: [email protected]/nop

Organic Materials Review Institute (OMRI)Box 11558Eugene OR 97440Tel: 541.343.7600Fax: [email protected]

Baier, Ann, and Lance Gegner. 2008. OrganicMaterials Compliance. IP313. ATTRA,Fayetteville, AR. 8 p.www.attra.ncat.org/attra-pub/PDF/organicmaterials.pdf

Food Safety

Gorny, James R. (Editor-In-Chief). 2006.Commodity Specific Food Safety Guidelines for

the Lettuce and Leafy Greens Supply Chain.

Produce Industry Groups: InternationalFresh-cut Produce Association, Produce

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Packaged Fresh Salad Greens (Salad Mix) Resources

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Marketing Association, United Fresh Fruitand Vegetable Association, and WesternGrowers.www.cfsan.fda.gov/~dms/lettsup.html

Commodity Specific Food Safety Guidelinesfor the Production and Harvest of Lettuceand Leafy Greens, the guidelines for theLeafy Green Product Marketing Agreementmember program, are available at www.caleafygreens.ca.gov/members/resources.asp

Small-Scale Harvesting Equipment

Johnny’s Selected Seeds955 Benton Ave., Winslow, ME 04901-2601Tel: 877.564-6697Fax: [email protected]

Organic Ingredients

Organic sources for agricultural ingredientslisted on NOP § 205.606. A website sponsored by the theAccredited Certifiers Association (ACA). www.606organic.com

Organic Pages Online. Organic Trade AssociationP.O. Box 547Greenfield, MA 01302 www.theorganicpages.com

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What are jams, jellies, and spreads?

Fruit growers can extend the season byoffering their customers products such asjams and jellies. These products are relativelysimple to produce and have very good shelflife. Jellies and jams are low-risk foods froma food safety perspective because of theirhigh sugar and high acid content. As long asthey are protected from air, jams and jellieswith adequate soluble solids and acid can bepreserved with minor heat treatment.However, molds can still grow in them, sothey must be sealed to prevent mold, as wellas moisture loss and oxidation.

These products will collectively bereferred to as “spreads” unless the specifictype is meant. “Jelly” is strictly defined inthe United States as, “that semisolid foodmade from not less than 45 parts by weightof fruit juice ingredient to each 55 parts byweight of sugar.” A jam is similar to a jellyexcept that the crushed or pulped fruit ingre-dient is used rather than the juice. The fruitis cooked until it is concentrated to about68% solids. At least 45 parts of fruit arerequired for each 55 parts of sugar.[3]“Preserves” are like jam but with largerchunks of fruit; “conserves” are a mix of

fruits and sometimes other ingredients.

Sugared jam and jelly sales have beendeclining overall. However, the market fororganic, all-fruit, and low-sugar spreads isgrowing. All of these are attractive to buyersof organic food who prefer to avoid the highlevels of refined sugar in jams and jellies.[4]These low-sugar spreads are often sweetenedwith cane juice, agave, or most commonlywith fruit juice concentrate. Buyers of thesetypes of spreads tend to prefer a very highpercentage of fruit and a natural fruit tasteand texture.

Crop production basics

It is beyond the scope of this publicationto cover production of the many types offruits (and even vegetables and herbs) thatcan be used to make spreads. However, fruitcan be grouped by how much pectin itcontains, and this in turn determines process-ing needs. Fruits containing enough naturalpectin to form a gel include crab apples, tartapples, sour blackberries, sour boysenberries,most plums, cranberries, lemons, and wildgrapes (Eastern Concord variety).

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SECTION II, ENTERPRISE 3

Jams, Jellies, andSpreadsby Holly Born

Jams, Jellies, and Spreads:The Basics

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Fruits that will usually require additionalpectin are sweet cherries, quince, ripe black-berries, sour cherries, grapefruit, grape juice,grapes, melons, and oranges. Fruits alwaysrequiring added pectin are peaches, pears,figs, apricots, elderberries, strawberries,raspberries, grapes (Western Concordvariety), guava, and pomegranates.

In practice, pectin is almost always addedin order to obtain a consistent product.

Farm-scale processing basics

Fruit spreads are made from a variety offruits, singly or mixed, with varying levels ofripeness. Pears, peaches, apricots, strawberries,and raspberries gel best if picked slightlyunderripe. Plums and cherries are best ifpicked when just ripe. Harvested fruit isinspected for quality, using color, ripeness,and taste as guides. Fruit that passes inspec-tion is cleaned, crushed, and pasteurized.

Next, pre-measured amounts of fruitand/or juice, sugar, and pectin are blendedin a cooking kettle and cooked until thedesired thickness and taste are achieved. For

fruit to gel, pectin, acid, sugar, and water are

needed. “Low-” and “reduced-sugar”

versions of jams and jellies require that the

sugar content be at least 25% less than that in

the regular product. The type of pectin may

need to be changed to one that works with

less sugar. Often gelatin is added. Fruit

spreads are sweetened with fruit juices only

and are cooked longer to reduce the fruit to a

thick, jam-like consistency.

Pectin is usually blended with sugar and

added to heated water or fruit juice. Pectins

are classed as rapid-set and slow-set, or by

the pounds of jelly that one pound of pure

pectin will produce. Rapid-set pectin gels at

higher temperatures than the slow-set type,

and is usually used for jams and preserves to

keep the fruit from rising to the top before it

is set. Slow-set is used for jelly. The low-

methoxy pectins differ from normal pectin in

that they form gels at low sugar concentra-

tions, or in the absence of sugar and over a

wide range of acidity (or pH) values.

The mixture is usually reworked—

cooked and cooled—about three times. If28

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Preserves are almost always packaged inglass, although bulk packaging in food-contact-grade plastic is also done. In general,packaging materials that are approved forfood contact are appropriate for use inorganic processing. The packaging itself islikely to be one of the main costs involved inproduction.

Heat processing does not harm theproduct quality and gives a better seal as wellas killing any mold that may be present on thetop surface of the fruit mixture. (A minimumtemperature of 185° F is needed to kill moldspores. This is easily achieved with a hotwater bath since water boils at 212° F.)

Clean jars are filled with the fruit spreadmixture and metal lids are placed on the jars.The jars are then heated in boiling waterbath canners for 6-10 minutes before beingcooled. Sealing the jars with paraffin wax isnot recommended. If the seal is incomplete,mold can grow in the jelly.

Organic Production Issues

Fruit must be certified organic in orderfor the product to be certified as organic.Fruit from operations under the $5,000exemption from certification cannot be used.See Jams, Jellies Resources for sources ofinformation on growing organic fruits.

Organic Processing Issues

Product Composition

Only products containing 100% certifiedorganic ingredients may be labeled “100%Organic.” Products containing at least 95%certified organic ingredients with the other5% of ingredients produced without the useof excluded methods (genetic engineering,sewage sludge, or ionizing radiation) may belabeled “Organic.”

The National Organic Standard, §205.606,provides a list of non-organic agriculturalproducts that may be used in “Organic”products if organic equivalents are notcommercially available. If any of these non-organic ingredients are used, the search fororganic sources must be documented.

Some sources of organic products listed on§205.606 can be found at www.606organic.com.Another good source of all types of organicingredients is the Organic Trade Association’sOrganic Pages Online at www.theorganic-pages.com.

Products with at least 70% certifiedorganic ingredients may be labeled “Madewith Organic” and specify up to three ingre-dients or ingredient categories. The remain-ing 30% of ingredients may not be grownusing sewage sludge as a fertilizer, may notinclude genetically-engineered (excluded)ingredients, and may not be irradiated. See“Labeling” for more information on howproduct composition affects labeling.

Pectin

High-methoxy pectin is a natural ingredientand should be organically sourced. However,it is also on the National List under 29

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§205.606, indicating that nonorganic pectinmay be used if no organic form is commer-cially available. Low-methoxy pectins, usedin making reduced or sugar free products,are synthetic, but are on the National Listunder §205.605. Therefore, you can use them(low-methoxy pectins) in products labeled"Organic" or "Made with Organic" ingredients.

Citric acid

Citric acid is on §205.605 as a non-synthetic, nonagricultural ingredient.However, it must be produced by microbialfermentation of carbohydrate substances andnot be derived from microorganisms thathave been genetically modified.

Gelatin

Gelatin, if used, must be organic. If non-organic gelatin is used, it may only be usedin “Made with Organic” products, and mustbe produced without genetically engineeredinputs or processes.

Technical assistance in jam and jellymaking is usually available through univer-sity food science departments and otherprograms to offer assistance to food productentrepreneurs. This expertise may be neededto adapt conventional recipes to organic, asorganic ingredients often have slightly differ-ent chemical properties that may change thefinal product if not accounted for. Forexample, organic sugar usually contains atiny bit more calcium than conventionalsugar. This can change how pectin behaves.

Cleaning and sanitizing equipment

Cleaning involves use of detergents toremove visible dirt and most microorganisms,while sanitizing refers to elimination of theremaining microorganisms. Both processes

must be accomplished without contaminat-ing the organic products with eithercleansers or sanitizers. Sanitizers on theNational List that can be used include thechlorine based sanitizers (bleach, sodiumhypochlorite, and others), peracetic acid,hydrogen peroxide, phosphoric acid, andozone. Peracetic acid is effective and moreenvironmentally friendly than chlorineproducts, but it is more expensive. Ozone ismost expensive but poses no risks toworkers handling chemicals and leaves noresidues to affect the environment.

Often, chemicals not on the National List,such as quaternary ammonium, iodine, andother synthetic surfactants, are allowed iffollowed by an “intervening event,” such aspassage of time or a clear water rinse, thatensure the organic products do not contactprohibited materials. The processor will beexpected to demonstrate that the interveningevent is sufficient to preclude contamination,

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CERSand regularly monitor for residues.Monitoring may include pH testing, orammonium test strips if using quaternaryammonia products. Testing must demonstratethat no residues remain. However, the bestapproach is always to use cleaners and sanitiz-ers that are on the National List. Be certain toconsult the certifier. OMRI (Organic MaterialsReview Institute) guidance materials are defi-nitely recommended for help in determiningwhich cleaners and sanitizers to use.

Labeling

Labels need to include the common nameof the product (for example, “RaspberryJam”) and list all ingredients in descendingorder of predominance. The processor andthe date of packaging/batch code needs tobe identified so that in case of product recall,only affected batches can be recalled insteadof the whole product line.

National Organic Program (NOP)

labeling requirements. If labeling as “100%Organic” or “Organic,” the organic ingredi-ents must be identified in the ingredientstatement and the statement “Certified by[Certifying Agent]” must appear on the labelunder the name of the processor. Theseproducts may display the USDA Organic seal.(See Part I, Organic Labeling for definitions.)

For products labeled “Made withOrganic Ingredients,” organic ingredientsmust be identified in the ingredient state-ment and the total organic percentage can bedisplayed on the principal display panel. Thestatement “Certified by [Certifying Agent]”must appear on the label under the name ofthe processor. Products with less than 70%organic ingredients can only identify theorganic content in the ingredient statement,and total organic percentage can be displayed

on the information panel only. These productsmay not display the USDA seal.

Regulatory

Farm-scale processing. In general, theprocessor will need to be licensed or permit-ted as a food handler. Usually this requiressuccessfully completing courses in safe foodhandling as required by the state healthdepartment. The state health department willbe able to direct interested parties toapproved courses.

Where will processing take place? Insome states, home-based kitchens may processsome types of food for sale. For example, inTennessee, a “Domestic Kitchen” is a homebased kitchen that meets the established require-ments herein in order to process non-potentiallyhazardous foods for sale to the general public.

“Non-potentially hazardous foods” are jam,jellies, candy and baked goods that do not meetthe definition of potentially hazardous foods.[5] Most states require that commercial foodprocessing be done in a state-licensed commer-cial kitchen such as those used by restaurants,bakeries, churches and other places of worship,community centers, fairgrounds, etc. Generally,any location that prepares food for service tothe public may be an option.

Processors will probably want to carrysome food product liability insurance, and infact many farmers’ markets and most retail-ers require proof of such insurance.Insurance companies may be able to workwith food product liability insurers or directprocessors to sources of such insurance.Many small producers have obtained foodproduct liability insurance at very affordablerates through their local Farmers Union orFarm Bureau.

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General information on organic fruitproduction

ATTRA publications. Available free ofcharge. Call 800.346.9140, or visitwww.attra.ncat.org/horticultural.html#FruitsFruit publications include:

■ Tree Fruits: Organic ProductionOverview

■ Grapes: Organic Production Organicand Low-Spray Peach Production

■ Organic Pear Production

■ Low-Spray and Organic PlumProduction

■ Strawberries: Organic Production

■ Blueberries: Organic Production

■ Organic Culture of Bramble Fruits

Also see NCAT’s Organic Crops Workbook: A

Guide to Sustainable and Allowed Practices atattra.ncat.org/new_pubs/attra-pub/PDF/cropsworkbook.pdf

General information on fruit processing

Smith, Durward. 2006. Fruit Jellies–FoodProcessing for Entrepreneurs Series.University of Nebraska CooperativeExtension Service Publication No. G1604.www.ianrpubs.unl.edu/epublic/pages/publicationD.jsp?publicationId=418

An in-depth technical discussion of jelly and

jam making

Oregon State University Jam and Jellywebsites:oregonstate.edu/dept/foodsci/foodweb/jelly.htm

Links to publications from Cooperative

Extension

National Center for Home Food Processing:www.uga.edu/nchfp/how/can7_jam_jelly.html

Information on many different types of

spreads with a large number of recipes

Selected Jams, Jellies, and SpreadsResources from Organic Processingmagazine:

Organic Processing magazine is published quar-

terly by The Target Group, Inc. To subscribe,

visit: www.organicprocessing.com

Crofter’s Gets Conventional Processors Outof a Jam—and Into the Nichewww.organicprocessing.com/opspring05/opspring05enterprise.htm

Seeing Eye to Eye: A Guide to Finding thePerfect Co-packerwww.organicprocessing.com/opfall05/opfall05coverstory.htm

Organic Pest Management Operations andRequirementswww.organicprocessing.com/opfall04/opod04manufacturing.htm

Segregating an Organic Facility: It’s Not asHard as You Thinkwww.organicprocessing.com/opfall05/opfall05processing.htm

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Jams, Jellies, and Spreads Resources

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CERSHow to Clean an Organic Facilitywww.organicprocessing.com/opfall03/opod03manufacturing.htm

Organic

National Organic Program (NOP) Barbara Robinson (Acting Director), DeputyAdministratorUSDA-AMS-TMPRoom 4008-South Building1400 Independence Avenue, SWWashington, DC 20250-0020Tel: 202.720.3252Fax: [email protected]/nop

Organic Materials Review Institute (OMRI)Box 11558Eugene OR 97440Tel: 541.343.7600Fax: [email protected]

ATTRA publications. Available free ofcharge. Call 800.346.9140, or visitOrganic Certification and Regulations:www.attra.ncat.org/organic.html#overview Publications include:

■ National Organic Program ComplianceChecklist for Handlers

■ Organic Certification Process

■ Preparing for an Organic Inspection:Steps and Checklists

■ Organic Materials Compliance

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What are table eggs?

Table eggs or shell eggs are eggs in theform most familiar to consumers—fresh andin-the-shell. Though commercial table eggsmay come from a variety of birds, and manyof the procedures are the same, this discussionwill focus on chickens. It also focuses onrelatively small operations, particularly thosewith direct-to-consumer sales or sales tolocal restaurants and retailers.

Farm production basics

Acquiring chicks. Farmers typicallypurchase day-old chicks from hatcheries ordistributors that work with hatcheries.Shipping is usually done via USPS or UPS.Sometimes chicks may also be purchasedfrom local farmers co-ops and farm suppliers.It is wise to order only pullets (female birdsless than one year old), unless the produceralso wants to raise males for slaughter.Depending on the cost of feed, it may bemore economical to buy started pullets,which are birds old enough to lay eggs(about 20-22 weeks).

Brooding. It takes up to eight weeks forchicks to “feather out” and they are especiallydelicate and vulnerable for the first three.Chicks must be raised in brooder boxesequipped with lamps for heating and which

provide protection from drafts, predators,and excessive handling. Non-slipperybedding is required to prevent “spraddlelegs.” Growers recommend rice hulls, woodshavings, ground corn cobs, and similarmedia. Close confinement is desirable forwarmth, though at two weeks or so, the needfor space will increase as the birds begin togrow rapidly.

Appropriate food, clean water, and gritmust be available from the outset. Pullet feedshould contain 18% protein for the first eightweeks, and be reduced to 16% from then upuntil laying.

Layer housing. Even free-range poultryrequires some form of housing to providenesting sites for laying and roosting, toprovide protection from the elements andpredators, and to ensure the comfort neces-sary for productive laying.

A minimum of one-and-a-half to threesquare feet of floor, per hen, is recommended.There should be one nest box for every fourto five hens, located two feet above the floorlitter. Allow six to eight inches per bird forroosting space, with the poles spaced 12–14inches apart and 18-36 inches above the floorlitter. [6,7] 34

SECTION II, ENTERPRISE 4

Table Eggsby Anne Fanatico and George Kuepper

Table Eggs: The Basics

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CERSLayer management and nutrition. Once

laying begins, pullets should be switched toa laying ration that contains 16 - 18% proteinwith 3.5% calcium. Floor litter should bethree to six inches deep, low dust, and keptreasonably dry. Wet litter should always beremoved.

Day length can be managed to stimulatelaying. At 18 weeks, pullets should be placedon 14 hours of daylight. When half of thebirds have begun laying, it should beadjusted to 16 hours. [8]

The laying cycle for a chicken flock isusually 12 months. Production peaks ataround six to eight weeks, then slowlydeclines. In commercial production, hens areeither destroyed or processed at 70 weeks, orthey are forced to molt. Molting is a naturalprocess in which birds renew their feathersand replenish their bones and reproductivesystems. During molting, egg laying declinesfurther or ceases entirely. Following forcedmolting, the hens can resume production andare often kept up to 105 weeks of age.

Egg collection. Eggs should be collectedtwice a day, more often if weather is extremelyhot or cold. Immediately discard any crackedor misshapen ones. Promptly cool eggs to 45°F. (Eggs held at room temperature rapidlylose grade.) Store them with the small enddown. [9]

On-farm processing basics

Ideally, eggs are processed the day afterthey are laid. The USDA requires processingwithin 30 days of lay. In programs thatassure high quality, eggs are processedwithin seven days of lay.

Cleaning. Discard eggs that are verydirty. If eggs are washed (wet cleaned), the

wash water should be about 20° F warmerthan the eggs. This encourages the contentsto swell and push dirt out of the pores.Water of equivalent or lower temperaturescan draw contaminants into the eggs; muchhigher temperatures can lead to cracking.Water exposure should be as brief as possibleto reduce the possibility of contamination.Mild cleaning agents are sometimes used inwet cleaning. Eggs should be dried as soonas possible.

It is unusual, but wet cleaning is prohib-ited by state regulation for some markets.Specifically, Minnesota regulations prohibitthe sale of wet-cleaned eggs to stores andrestaurants. [10] Immersion washing is espe-cially frowned upon and may be specificallyprohibited. Dry cleaning using a brush,sandpaper, or a loofah sponge has fewerissues than wet cleaning, and is recommend-ed for small producers.

Preventing dirty eggs through bettermanagement of the hens and their nesting 35

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space will greatly reduce the need forcleaning the eggs. (See Plamondon’s “EggQuality/Egg Washing” webpage in TableEgg Resources.)

Candling. Candling is a means for assess-ing the interior quality of eggs. The namehearkens back to the days when an egg washeld up in front of a candle to reveal theinside. Today, a high-intensity light is used.Interior quality is determined by the size ofthe air cell (the empty space between thewhite and shell at the large end of the egg,smaller in high-quality eggs), the proportionand density of the white, and whether or notthe yolk is firm and free of defects. [11]Candling will also reveal cracking; crackedeggs should not be sold. Farm-scale equip-ment for candling can be homemade or isavailable through farm supply outlets suchas NASCO (see Table Egg Resources).

Grading. The primary USDA egg gradesare AA, A, and B. Grades are based on bothexterior and interior quality. For specifics onegg grading, see the USDA-AMS PoultryPrograms website(www.ams.usda.gov/poultry/). Grading alsoinvolves sorting eggs into weight classes orsizes (peewee, small, medium, large, extralarge, and jumbo). The USDA Egg Grading

Manual details what an egg of a specific classneeds to weigh. Many producers do notgrade but mark their eggs as mixed, unclas-sified, or ungraded. Farm-scale equipmentfor grading is available through farm supplyoutlets such as NASCO (see Table EggResources).

Packaging. Eggs may be carton-packedaccording to size or as unsized. Standardpackaging for direct sale is by the dozen,half-dozen, or dozen-and-a-half. Cartons aretypically made of pulp paper, styrofoam, or

clear plastic.

Labeling. Eggs packed under federalregulations require the pack date to bedisplayed on the carton. It is a three-digitJulian date that represents the consecutiveday of the year. The carton is also dated withthe “Sell-by” or expiration date, whichdepends on the state requirements. Eggswith a federal grade must be sold within 30days from day of pack. [12]

Organic Issues

Organic production issues

Obtaining chicks. For any poultry to beconsidered organic, it must be managed assuch beginning no later than the second dayof life. Therefore, the standard practice ofbuying day-old chicks from conventionalhatcheries presents no problem. However,organic growers do not have the option ofusing starter pullets, unless they came from acertified organic grower.

Whether the organic farmer seeks a nichemarket for colored eggs, or chooses toproduce standard white eggs, the issue ofbreed selection is important. The NationalOrganic Standard stipulates that breedsshould be chosen for disease resistance andsuitability to site and operation. However,high-yielding genetics are typically used inboth conventional and organic poultryproduction, with consequences. High-yieldingbirds can lay over 300 eggs per year but mayalso develop osteoporosis or brittle bones.

There is increasing interest in usingheritage breeds for organic production.Fortunately, selection for egg production has36

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CERSbeen common with heritage breeds in recentdecades, and good utility strains exist. Forfurther information, read ATTRA’s Poultry

Genetics for Pastured Production (see Table EggResources).

As technology advances, genetically-engineered and cloned birds may becomeavailable. These are prohibited in organicproduction.

Brooding. The National OrganicStandard §205.239(a)(1) requires outdooraccess for all organic livestock. This does notapply to brooding chicks. Confinementbrooding is a proper and good example oftemporary confinement as allowed under§205.239(b).

While many conventional growersprovide chicks with a medicated starterration while brooding, this is not allowed inorganic systems. Organic managementrequires 100% organic feed. Chick starterfeeds, as well as all feeds provided at laterstages of life, must be certified organic.

Layer housing. Housing should protectbirds from the elements, maintain a comfort-able temperature, provide ventilation andclean bedding, and allow birds to exerciseand conduct natural behaviors. Cages are notpermitted.

In addition, the birds must have access tothe outdoors for exercise areas, fresh air, andsunlight, and must be able to scratch anddustbathe. According to §205.239(b) of theNational Organic Standard, livestock may betemporarily confined due to inclementweather, requirements of the stage ofproduction (e.g. brooding), conditions underwhich the health, safety, or well-being of theanimal could be jeopardized, or risk to soil

or water quality. Many certifiers allowconfinement during cold weather. However,some breeds are quite hardy and willventure outdoors if allowed.

Wire and all-slat flooring is generally notpermitted; some solid flooring with littershould be maintained so birds can scratch.If birds are likely to eat their litter, it must beorganic to comply with the requirement for100% organic feed.

Litter treatments, such as sodium bisul-fate and hydrated lime, are common inconventional production to lower pH, reducemicrobial growth, and control ammoniaproduction. These are synthetic materialsthat are not allowed in organic production. Iflitter treatments are used, they must beeither non-synthetic or be made fromsynthetics allowed for that purpose on theNational List. (Hydrated lime is on theNational List, but is restricted to use as atopical treatment for external pests.)

Where used, treated lumber must notcontact the birds, eggs, feed, or soil theytraverse. For guidance on alternatives, readATTRA’s Organic Alternatives to Treated

Lumber (see Table Egg Resources).

In practice, the requirement for outdooraccess has resulted in a wide array ofhousing options and a fair bit of confusionover how much space and time outdoorsthat birds should have. At least one certifierhas approved a system wherein outdooraccess is limited to enclosed porches. At theother extreme are some pasture basedsystems where birds not only go outside, buthave abundant forage.

The National Organic Standard does notspecify indoor or outdoor stocking densities,

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but many organic certifiers look for a lowerstocking rate than the industry average of 0.7square feet per bird; most look for at least 1.5square feet per bird.

There is no limit on the number of birdsthat may be raised in one house; nor is therea requirement for the number of bird exits or“popholes” that should be provided.Furthermore, how much outdoor access abird should have during its lifetime is notspecified under the Standard.

Layer management and nutrition. Feedmust be 100% organic, whether producedon-farm or purchased. It may contain onlythose synthetic additives and supplementsfound on the National List. No animal drugs,antibiotics, or slaughter byproducts areallowed in organic feed. Feed rations mustprovide the levels of nutrients appropriate tothe type of bird, breed, and age/stage ofdevelopment. Any pasture or free-rangeareas must have been free of synthetic chem-icals for three years.

Synthetic amino acids are prohibited inorganic production, with the exception ofsynthetic methionine, which will be allowed

until October 1, 2010. Providing adequatemethionine in poultry diets can be challeng-ing when birds do not supplement their dietwith free-range foods like insects and earth-worms. Supplementing with methionine-richsoybean or sunflower meals result in dietsexcessive in overall protein. This stresses thebirds and leads to more nitrogen excretion inmanure and urine.

Generally, certifiers do not permit forcedmolting because it is very stressful to thebirds. Organic producers, especially smallproducers, may let the flock molt naturally,though it is common to destroy/process theflock at about 70 weeks. Natural molting isnot as efficient as forced molting, but itmaintains the birds’ welfare and extendstheir productive life. Ideally, layers should beallowed to molt naturally and kept for atleast two to three years.

Disease and pest management. Diseaseprevention in organic systems starts withclean birds. Make certain to get birds frombreeding flocks approved by the USDANational Poultry Improvement Program,which certifies that flocks are free of certaindiseases.

Proactive health management is veryimportant in organic production. Thisincludes proper nutrition, and adequatehousing, space, and ventilation to reducestress and support immunity. Good sanita-tion is vital. Sanitation between flocks isparticularly important. An “all-in, all-out”management (completely harvesting a flockbefore starting a new one) is advised. Thisreduces pathogens, many of which dieduring the “downtime.” Downtime shouldlast two to four weeks for good control.

Thorough cleaning is an important first38

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CERSstep towards effective sanitation and disin-fection of a poultry house. Organic mattermust be removed in order for a disinfectantto work. Approved sanitizers and disinfec-tants include chlorine materials, iodine,hydrogen peroxide, peracetic acid, phos-phoric acid, organic acids, and alcohol,though alcohol is not particularly effective.Propane-fueled heat tools may also be usedfor disinfection.

In addition, water lines need regularcare. They can be flushed with organic acids,such as citric acid or vinegar, to loosendebris, and then sanitized with iodine orhydrogen peroxide, between flocks. Chlorineis also used for water-line sanitation whenbirds are in the house.

Vaccines are allowed in organic produc-tion. Poultry vaccines are commonly used toprevent Marek’s disease, Newcastle disease,infectious bronchitis, and coccidiosis.

Good biosecurity should be practiced,including limiting visitor access to the birdarea. Footbaths with approved disinfectants,such as iodine, as well as disposable bootiesor dedicated footwear, can be used at theentrance to houses. Since wild birds, particu-larly waterfowl, can carry diseases that harmdomestic poultry, it is important to excludethem from free-range areas. Outdoor feedersshould not attract wild birds. Self-feedersthat dispense feed on demand are advisable(see Table Egg Resources).

Some producers have biosecurityconcerns with outdoor access and argue thatvaccines need time to create immunity;however, long periods are not required.Immunity generally develops a week or soafter the first boost. The last round ofvaccines (usually 16-18 weeks) is intended to

protect the flock during lay and outdooraccess is not likely to interfere. For furtherinformation, see Table Egg Resources.

Probiotics are often used in organicpoultry production to replace prohibitedantibiotic growth promoters (AGP). Probioticsare beneficial microbes, which are fed to birdsto establish beneficial gut microflora, therebyreducing colonization by pathogenic organ-isms, such as Salmonella and E. coli, by“competitive exclusion.”

Other natural products include prebiotics,which are non-digestible food ingredientsthat benefit the host by selectively stimulat-ing the growth of bacterial species present inthe gut. An example is lactose, which is usedby beneficial lactic acid bacteria in the gut.

External parasites such as mites can bemanaged by allowing birds to dustbathe.Many producers add diatomaceous earth tothe dustbaths to increase their effectiveness.If mite treatment is needed, pyrethrum is anallowed natural product. For roost mites,which inhabit roosts, cracks, and crevices inthe house, a natural oil, such as linseed oil,can be used.

Rotating yards, range, and pasture is thekey to reducing internal parasites. TheNational Organic Standard prohibitsstandard synthetic parasiticides, thoughnonsynthetic materials and additions to theNational List might be made. Conventionalanticoccidial medications are not allowed forcontrol of the protozoan parasite coccidiosis,which is usually controlled through manage-ment or vaccines. Read ATTRA’s Poultry

Parasite Management for Natural and Organic

Production: Coccidiosis (see Table EggResources).

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For rodent, fly, and other pest control, amultilevel approach is used, beginning withprevention and sanitation. Secondly, mechan-ical and physical controls such as traps andfans are used. Thirdly, natural and/orallowed synthetic pesticides can be used.

Physical alterations. Physical alterationsare allowed only if essential for animalwelfare and done in a manner that mini-mizes pain. Beak trimming (to reduce featherpecking) is controversial. Feather pecking isan indicator of stress in the perpetrator andthe victim and might better be addressedthrough management or lower bird popula-tions. Beak trimming is only permitted ifsuch methods fail.

Manure management. The NationalOrganic Standard requires managing wastein ways that do not pollute or contaminateorganic products, and that optimize nutrientrecycling. Burning may not be used as ameans of disposal. Ideally, organic poultrymanure will be returned to organic croplandand pasture. Read ATTRA’s Manures forOrganic Crop Production (see Table EggResources).

Organic processing issues

Wet cleaning. If detergents or other addi-tives are used for wet cleaning, they musteither be nonsynthetic or among the allowedsynthetics on the National List at §205.603 ofthe National Organic Standard. Allowedsynthetics include chlorine, hydrogenperoxide, ozone, and peracetic acid. Theseserve mostly as sanitizers rather than aswashing agents. At the time of this writing,the Organic Materials Review Institute(OMRI) lists one brand name product as anallowed egg wash (see OMRI in Table EggResources).

Be conscious of where wash water goes.Ongoing and excessive use of detergent canbe harmful to septic systems. Vinegar isnonsynthetic and effective at removingbacteria and stains if mixed 1:3 with water.Vinegar contains acetic acid, which helps tokill microbes.

Labeling

The federal Food and Drug Administration(FDA) sets the basic requirements for foodproduct labeling. There are often state-basedprograms available through departments ofagriculture that can assist in complying withfederal requirements for weights andmeasures and other areas of compliance.State departments of agriculture may alsohave additional labeling programs that canhelp distinguish products. The OklahomaDepartment of Agriculture, Food, andForestry, for example, has a program titledMade In Oklahoma that allows in-state farmsand other businesses to promote and labeltheir products accordingly.

National Organic Program (NOP)

labeling requirements. When dealing with40

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1. A product may be labeled as “100%Organic” if it contains only 100% organicagricultural ingredients. Table eggs cancertainly be labeled “100% Organic” if theywere not washed, or were washed usingwater without any cleaners or sanitizers. TheUSDA’s organic seal may be used onproducts labeled “100% Organic.”

2. A product may be labeled “Organic” ifit contains a minimum of 95% organic agri-cultural ingredients. Certifiers may requirethat whole eggs washed or sanitized usingany agent other than pure water be labeled“Organic.” The USDA’s organic seal mayalso be used on products labeled “Organic.”

Additional specific requirements fororganic labeling are addressed in Subpart D ofthe National Organic Standard §§205.300–311.

Additional regulatory issues

The Egg Products Inspection Act waspassed in 1970 to ensure egg products aresafe for human consumption. In 1972, quar-terly on-site inspections of all shell eggprocessors became required. A producer witha flock of less than 3,000 hens is exempt fromcomplying with the Act, although states havetheir own egg laws and regulation is on astate-by-state basis.

All food products manufactured for thepublic must be prepared in an approvedlicensed facility. In most states, licensing isoverseen by the state health department.Additional approval and licensing by thestate department of agriculture might also berequired for some enterprises in some states.

If the farm falls within the limits of a city,there may be additional zoning requirementsto meet. City and/or county regulations mayalso apply to the construction of new facilitiesif those are needed.

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General information

ATTRA publications. Available free-of-charge. Call: 800-.346-.9140, or visitwww.attra.ncat.org/livestock.html#Poultry

Poultry publications include:

■ Alternative Poultry ProductionSystems and Outdoor Access

■ Growing Your Range Poultry Business:An Entrepreneur's Toolbox

■ Label Rouge: Pasture-Based PoultryProduction in France

■ Pastured Poultry: An HPI Case StudyBooklet

■ Poultry House Management forAlternative Production

■ Poultry: Equipment for AlternativeProduction

■ Poultry Genetics for PasturedProduction

■ Range Poultry Housing

Sustainable Poultrywww.sustainablepoultry.ncat.org

Standards, grading, and equipment

USDA-AMS Poultry ProgramsSTOP 0259, Room 3944-South1400 Independence Avenue, SWWashington, DC 20250-0259Tel: 202.720.2356Fax: 202-690-2930www.ams.usda.gov/poultry

NASCO901 Janesville Ave.P.O. Box 901Fort Atkinson, WI 53538-0901Tel: 800.558.9595www.enasco.com/top/313/

Egg washing

Egg Quality/Egg Washing. No date. RobertPlamondon’s Poultry Pages.www.plamondon.com/faq_eggwashing.html

Biosecurity

USDA Biosecurity for the Birdswww.aphis.usda.gov/vs/birdbiosecurity/

Fanatico, Anne. 2006. Avian Influenza inFree-range and Organic Flocks. ATTRA.September. attra.ncat.org/avian.html

Organic

National Organic Program (NOP)Barbara Robinson (Acting Director), DeputyAdministratorUSDA-AMS-TMPRoom 4008-South Building1400 Independence Avenue, SWWashington, DC 20250-0020Tel: 202.720.3252Fax: [email protected]/nop

Organic Materials Review Institute (OMRI)Box 11558Eugene OR 97440Tel: 541.343.7600Fax: [email protected] 42

Table Egg Resources

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Behar, Harriet. 2007. Organic PoultryProduction: Eggs. FS 702. Midwest Organic& Sustainable Education Service (MOSES),Spring Valley, WI.www.mosesorganic.org/attachments/productioninfo/fsegg.html

Anon. 1999. Small-Scale Egg Production(Organic and Nonorganic). PennsylvaniaState Cooperative Extension, UniversityPark, PA.agalternatives.aers.psu.edu/Publications/small_scale_egg.pdf

Kuepper, George. 2004. NCAT’s OrganicLivestock Workbook: A Guide to Sustainableand Allowed Practices. ATTRA. February.attra.ncat.org/new_pubs/attra-pub/PDF/livestockworkbook.pdf

Treated lumber alternatives

Gegner, Lance. 2002. Organic Alternativesto Treated Lumber. ATTRA. July.attra.ncat.org/new_pubs/attra-pub/lumber.html

Pest, parasite, and disease managementFanatico, Anne. 2006. Poultry ParasiteManagement for Natural and OrganicProduction: Coccidiosis. ATTRA.attra.ncat.org/attra-pub/coccidiosis.html

Self-feeders

www.solwayfeeders.com

Waste management

Kuepper, George. 2003. Manures forOrganic Crop Production. ATTRA. March.attra.ncat.org/attra-pub/manures.html

Processing

Beyer, R. Scott. 1998. Packing Eggs on theFarm for Direct Sales. Kansas StateUniversity Cooperative Extension. January.www.oznet.ksu.edu/library/lvstk2/mf2307.pdf

Sok, Kody M. and Sheila E. Scheideler. 2007.Egg Cleaning Procedures for the BackyardFlock. University of Nebraska-LincolnExtension, Lincoln, NE. June.www.ianrpubs.unl.edu/epublic/live/g1724/build/g1724.pdf

General Legal/Regulatory

Hamilton, Neil. 1999. The Legal Guide forDirect Farm Marketing. Drake UniversityAgricultural Law Center, Des Moines, IA.235 p.

Speier, Jess Anna, and Jill E. Krueger. 2006.Understanding Farmer’s Market Rules.Farmers’ Legal Action Group, Inc. (FLAG),St. Paul, MN.www.flaginc.org/topics/pubs/arts/FarmersMarket.pdf

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1. Mukherjee, Avik, Dorinda Speh, ElizabethDyck, and Francisco Diez-Gonzalez. 2004.Preharvest Evaluation of Coliforms,Escherichia coli, Salmonella, and Escherichiacoli O157:H7 in Organic and ConventionalProduce Grown by Minnesota Farmers.Journal of Food Protection 67(5):894–900.

2. Kuepper, George, Janet Bachmann, andRaeven Thomas. 2002. Specialty Lettuce &Greens: Organic Production. ATTRAPublication #CT117. attra.ncat.org/attra-pub/lettuce.html

3. Smith, Durward. 2006. Fruit Jellies--FoodProcessing for Entrepreneurs Series.University of Nebraska CooperativeExtension Service Publication No. G1604.www.ianrpubs.unl.edu/epublic/pages/publicationD.jsp?publicationId=418

4. Trevison, Catherine. 2005. Organic JamHas Scent of Success. The Oregonian.October 20.

5. Center for Profitable Agriculture Info#138: Rules and Regulations for Establishingand Operating “Domestic Kitchen Facilities”in Tennessee,. January 2007.cpa.utk.edu/pdffiles/cpa138.pdf

6. Thornberry, Fred D. 1997. The SmallLaying Flock. PS5.250. Texas AgriculturalExtension Service, College Station, TX. 4 p.

7. Clauer, Philip J. No date. ManagementRequirements for Laying Flocks. Small FlockFactsheet No. 3. Virginia CooperativeExtension, Blacksburg, VA. 2 p.

8. Thornberry, Fred D. 1997. The SmallLaying Flock. PS5.250. Texas AgriculturalExtension Service, College Station, TX. 4 p.

9. Shady Lane Poultry Farm andPoultryman’s Supply Co. No date. SmallScale Table Egg Quality and Processing.sustainablepoultry.ncat.org/downloads/tableegg.ppt

10. Anon. 2007. Sale of Shell Eggs toGrocery Stores and Restaurants. MinnesotaDepartment of Agriculture.www.mda.state.mn.us/food/safety/eggsafety.htm

11. Anon. No date. Eggs. Food Dictionary,Epicurious website.www.epicurious.com/tools/fooddictionary/entry?id=2400

12. USDAD FSIS. 2007a. Focus on ShellEggs.www.fsis.usda.gov/Fact_Sheets/Focus_On_Shell_Eggs/index.asp

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Endnotes

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George KuepperKerr Center for Sustainable Agriculture

P.O. Box 588Poteau, OK 74953

[email protected]

Kerr Center for Sustainable AgricultureP.O. Box 588, Poteau, OK 74953

Phone: 918.647.9123 • Fax: [email protected]

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