MENDOCINO
RENEGADE

Processor Standards

Processor Certification

In addition to MENDOCINO RENEGADE Basic Requirements and Procedures, MENDOCINO RENEGADE will certify processed food only from ingredients that are:

a) certified organically grown, raised or produced, and
b) in their processing have not been treated with synthetically or artificially derived preservatives, colorings, flavorings, irradiation or any other artificial or synthetic additive.

Processor operations must be inspected at least once with inspection occurring while the organic product is being run in order to be eligible for Certified Organic status. MENDOCINO RENEGADE inspects certified processors at least annually. The Review Committee may require more frequent inspection.

Definitions

According to the California Organic Foods Act of 1990, "Processed" means cooking, baking, heating, drying, mixing, grinding, crushing, pressing, churning, separating, extracting juices or other materials, peeling, fermenting, eviscerating, preserving, dehydrating, freezing or manufacturing which materially alters the flavor, keeping quality or any other property of a food. It does not include refrigeration, or any other treatment which merely retards or accelerates the natural processes of ripening or decomposition. It also does not mean husking or water-rinsing of a food that is considered part of post harvest handling.

"Processors" include operations that assemble purchased or farmed ingredients and market processed products.

A "co-processor" or "co-packer" does not, at any time, own the ingredients or the finished product and only performs custom processing or packaging for the processor. When used in the standards, the word co-processor includes both co-processors and co-packers.

Responsibilities of Co-Processors

A co-processor may be certified but is not eligible to use the MENDOCINO RENEGADE name or seal on any but the MENDOCINO RENEGADE certified processor's certified product. Both the processor and the co-processor must meet MENDOCINO RENEGADE standards, but it is the processor who is ultimately responsible for the co-processor's compliance. The co-processor must give MENDOCINO RENEGADE access to plant, facilities and all pertinent audit documents at any reasonable time, without prior notice, whenever such access is requested. The co- processor is not obligated to pay an assessment. The processor is responsible for all fees. A co-processor may choose to be certified independently of the processor, and is subject to all the rights and responsibilities of a certified processor. Co-processors certified independently of processors are responsible for all fees.

Raw Materials

MENDOCINO RENEGADE Certified Ingredients. The ingredients of a MENDOCINO RENEGADE certified processed product must be organically grown and certified according to MENDOCINO RENEGADE standards. Copies of MENDOCINO RENEGADE grower certificates for raw materials must be placed on file at the time of purchase as part of the manufacturer's audit.

Non-Mendocino Renegade Certified Ingredients. Certificates from other certifying organizations will be accepted if one of two conditions are met:
1) a committee comprised of the Review Committee (or alternate in the event of conflict of interest), and MENDOCINO RENEGADE staff agree to recognize the certifier as compatible; or
2) a review of full documentation by MENDOCINO RENEGADE indicates the ingredient was gown in accordance with MENDOCINO RENEGADE standards.

Livestock Products

Meat and dairy products must be produced in accordance with MENDOCINO RENEGADE Livestock Standards. Organic meat cannot come in contact with non- organic meat.

Water

Water is a non-certifiable organic ingredient. All water used in processing, either as an ingredient or as a processing aid, must be noted in the manufacturer's audit. Water used in processing must meet the Safe Drinking Water Act. For products where water is in contact with foods or where water is listed as an ingredient, MENDOCINO RENEGADE must have an analysis of potential contaminants as required by the Safe Drinking Water Act.

Non-Organic Ingredients

The Federal Organic Foods Production Act and the California Organic Foods Act as amended by A.B. 1713, allow non-organic ingredients in processed food labeled as organic provided those ingredients do not exceed 5% by weight of the total product, excluding salt and water. MENDOCINO RENEGADE allows the following items from a nonorganic source in certified organic processed food from non-GMO sources:
1) Natural organic acids. Includes acetic, ascorbic, citric, malic and tartaric acids.
2) Plant-derived gums. Includes carob bean, acacia, locust bean and xanthum gums.
3) Leavenings and anti-caking agents. Includes calcium carbonate (limestone), calcium phosphate, magnesium carbonate (dolomite), sodium carbonate and bicarbonate (baking soda).
4) Enzymes.
5) Pectin.
6) Mineral Salts. Includes sea salt, sodium, calcium, magnesium and potassium chlorides; potassium iodide; calcium, iron and magnesium sulfates. May exceed 5% by weight.
7) Seaweed and seaweed extracts. Includes agar, alginates, carageenen, kombu, nori.
8) Yeast.

Ingredients may be added to or deleted from this list by review and recommendation of the Review Committee.

Residue Testing

All ingredients in an organic product may be tested for residues as required by the Review Committee or MENDOCINO RENEGADE sampling protocol. The Review Committee may also require residue tests for processing aids, fumigants and additives. Residue test results must fall within the guidelines of no pesticide residue in excess of 5% of EPA allowable levels.

Manufacturing Facility

In order to be certified, the processor must demonstrate compliance with all applicable State and Federal food processing standards. If appropriate, a current permit from the County Health Department or equivalent agency must be on file. In addition to meeting all State and Federal food manufacturing standards, the processor of organic foods must submit a complete description of the processing method. This description should detail how all ingredients are handled, processed, and ultimately packaged. It should detail each machine, its ability to be thoroughly cleaned, the introduction of all ingredients, including water, into the product, packaging procedures and cleanup procedures.

The manufacturer needs to demonstrate that once packaged, the product has not been contaminated by any step in the process. Manufacturers must be aware of possible contamination by various forms of packaging. For example, no packaging film that acts as a preservative is allowed. Periodic residue testing of the entire product after packaging may be required.

Transportation and Storage

All reasonable precautions must be made to avoid contamination from, or confusion with, a non-organic substance in the transportation and storage of raw ingredients, intermediate and finished products. When contamination occurs, the product may no longer by labeled organic. No prohibited materials can be used for insect and rodent management in stored organic products. Prohibited materials must not be used in vessels that contain organic ingredients or finished products.

Cleaning and Pest Control

All reasonable precautions must be made to avoid contamination of organically grown or approved non-organic products by such synthetically formulated compounds for cleaning storage areas and pest control.

Sanitation

MENDOCINO RENEGADE recognizes that the Federal Food and Drug Administration and the State Health and Safety Code requires sanitation procedures for food processors. MENDOCINO RENEGADE Certified Food Processors are expected to follow Good

Manufacturing Practices (GMPs) for their processed products. The processor must take adequate steps to eliminate sanitizer residues.

Pest Control

The California Organic Foods Act prohibits the use of synthetic pesticides in organic food production. Fumigants, fogs and other pesticides cannot be applied to processing, storage and transportation facilities when certified organic ingredients or products are present.

Record Keeping

Minimum Requirements. In accordance with the California Organic Foods Act of 1990, MENDOCINO RENEGADE requires that processors maintain a complete audit trail. The processor must maintain these records for a minimum of three years from the date on which the food is sold. Processors must make this information available to MENDOCINO RENEGADE and its authorized agents upon request. This includes, but is not limited to receipts, invoices, and written or computer stored records of organic ingredients, intermediate and finished processed products. Specifically, the law requires: a) The names, addresses and, if applicable, the organic registration numbers of all suppliers of organic food. b) Invoices for each shipment from the supplier of food must state that the food may be sold as organic.
c) If the food is MENDOCINO RENEGADE certified, the processor must have current MENDOCINO RENEGADE certificates on file.
If the food is not MENDOCINO RENEGADE certified, the processor must have on file separate written documentation from a certification organization that the food is certified. d) All substances applied to the food or used in its processing, all substances applied to the food while in the control of the processor, and all substances applied in or around any area where the food is kept, including the quantity of substances applied and the date of each application. All substances shall be identified by brand name, if any, and by source. e) The name, address and, if applicable, the organic registration numbers of all handlers, processors, or retailers to whom the food is sold or otherwise transferred, the quantity transferred and the date of the transaction.

Audit Control

Processors must maintain a complete audit trail for all organically processed food. In single ingredient foods, a batch numbering system may be adequate. In multi-ingredient foods, the audit system must include both organic and non-organic ingredients. Manufacturers must periodically demonstrate that sales of organically processed products match the purchase of organic products purchased. The audit trail should be complete enough to immediately trace any product suspected of contamination from point of origin to the processor's customer.