08 May 2009

What does organic mean for Steenbergs in practicality?

What does organic mean for Steenbergs in practicality?

Basic business set-up

As a business, Steenbergs is relatively simple to manage from an organic perspective.  We are committed to importing and manufacturing organic food, and we are committed to thinking in a green way in everything we do.  We are not part-green or just a bit organic at the edges of what we do as our main business; this isn’t some cynical marketing gimmick or way of keeping the UK major multiples happy by adding a few lines of organic into the mix of a range of standardised, factory food.


So, with us, it’s a matter of remembering to squeeze in that 1% of conventional product lines at some time in the manufacturing week.  At Steenbergs, it’s a matter of finding room to keep our non-organic ingredients, rather than worrying about contaminating the precious organic in the corner with the mass of conventional ingredients in the warehouse; our non-organic ingredients are on 1 small, 6 ft long shelf in the corner of a 2500 sq ft warehouse that’s stacked 3 pallet spaces high with organic kit.


We source all our products from reputable international and European exporters of organic spices and herbs, most of whom we have been dealing with for over 3 years.  One of them, Lanka Organics in Sri Lanka is a group we have partnered with since we started importing directly from source in 2004.


Every product and every unit of raw material that comes into our warehouse is traceable with a unique code back to the original incoming product batch code.  This can be traced from incoming source batch code through to our end sales unit, or vice versa from a single jar of organic black pepper back to the incoming bag of organic black peppercorns that came into our warehouse and back to the grower at origin.


The only other thing that really matters is what happens in the middle, i.e. the processing part.  Firstly, we never mix non-organic with organic processing (and never put non-organic raw materials into organic materials and call it organic) and we have a principal of never, ever seeking a derogation to use non-organic materials in organic products and call them organic.  A derogation is an opt-out that allows you to use a non-organic ingredient where it is “impossible” to find that ingredient as organic, so long as it is less than 5% of the end product.  Personally, I think this rule is pretty dubious and is easily abused by those who don’t understand it.  In the end, like pregnancy where you’re either pregnant or you are not, so for organic it is either organic or not, and I say no to derogations completely.


For example, some people quote to me the fact that it’s okay to use non-organic in our products if the organic is less than 5% - well it isn’t and I am sure that they are just being loose with the technical details but it does give me the heebie-jeebies.  Secondly, it means that you can specify into your product something obscure and then get round the underlying principles of organic.  For example, you could specify into your product fresh Scotch Bonnet chillis or Bhut Jolakia chillis and, as these are not available as organic anywhere in the world, you can go for a derogation, but it is possible to change your product slightly and use a hot dried chilli, such as dried chilli pilli pilli from somewhere in Africa (perhaps Tanzania or Uganda), without too much problem with the end product. 


Another example could be smoked paprika.  As far as I am aware, this is not yet available in a organic format but manufacturers are always after it as they like the idea of getting natural smokiness into their products without using something ghastly like liquid smoke.  But you could use a beautiful organic paprika from Spain, then add an organically approved smoked salt (available commercially from the likes of Maldon Salt) or even smoke the end product oneself under organic rules.


Anyway, going back to what we do.  If we are packing a raw material straight into its end packaging, we basically get a container of organic chilli, for sake of argument, and check that its status has not been compromised (via broken packaging etc) and then pack the organic chilli carefully under normal good food manufacturing procedures.  All the relevant identification information is recorded and approved labels are put onto the packaging, detailing organic status, which our organic certification agency is, together with the normal food safety information.


The only wrinkle to the above is when we make our organic blends, of which we have over 300.  In this instance, we calculate the recipe ingredients using our computer-held database of recipes (all of these are based on batch sizes of 1kg so we simply work out how many kilos we want and then multiply the ingredients up).  In our own blending room, which is separated from the packing rooms, we take the picked organic raw materials, weigh them out carefully, mix them together and store them in suitable food-grade containers.  All the relevant identification information is recorded and approved labels are put onto the packaging, detailing organic status, which our organic certification agency is, together with the normal food safety information.


Since we began in October 2003, we have been audited each year by Organic Food Federation, which is registered as UK Certification 4 (Soil Association is UK Certification 5).  We are checked against our compliance with the law as embodied in EC834/2007 (previously EC2092/91; these are the EC regulation numbers) and the specific rules of the Organic Food Federation.  The Organic Food Federation itself is registered with defra and regularly reviewed by defra for its competence as an organic certifier.  The key issues for any certifier are: (i) can we prove the materials we are dealing with came in as organic (see below); (ii) are we maintaining the organic integrity of these materials; (iii) can we trace all the materials as they come in and out; (iv) are we correctly labelling and disclosing the organic status of our products? 


Import process


For Steenbergs, verification of the original organic status of our raw materials is paramount.  In this area, it’s down to proving the organic chain of custody from seed planted in India, China, Spain or wherever right to our warehouse door in Ripon, North Yorkshire.


Whether we are certified by Organic Food Federation or Soil Association is less important for the sourcding and importation part of the cycle as what actually matters is the certifier of the original farmer or farmers group.  Certification outside of the EC is usually undertaken by one of the international European agencies (the British certifiers have been particularly poor at getting themselves out there to do this type of business), so the certifiers are agencies like Control Union from the Netherlands, Ecocert from France, BCS-Oeko and Lacon from Germany, IMO from Switzerland or Indocert from India.


Importing products from the EC is simple.  We order it from businesses certified as organic within their own country and keep records of the chain of custody, i.e. batch codes on the incoming product. 


Similarly, products from a number of approved countries can also be purchased on the same basis but with a slight technical wrinkle.  As products from outside the EC require Customs Clearance and (as a food) authorisation from UK Port Health, there is an importation form that needs the official stamp and signature from the exporters organic certification agency confirming that the products being exported are organic under EC law; this form is then countersigned and stamped by the UK Port Health Authorities as it enters the UK (or technically as it enters the European Community, i.e. this is an EC rule not a British rule). 


In fact, this latter point is important: organic is nothing really to do with Britain, it is a European Community matter and is governed by EC law under EC834/2007 (it used to be EC2092/91). defra, the Organic Food Federation and the Soil Association are all effectively agents of the European Parliament and what can be regarded as organic is ultimately a matter for Europe and not Britain.


These approved countries are those that are regarded as having a certification process and certification agencies as good as any country in the European Community.  This includes countries such as Argentina, Australia, Costa Rice, India, Israel, New Zealand and Switzerland.  For the purpose of organic rules, Iceland, Liechtenstein and Norway are regarded as members of the European Community.


When we started in 2003, countries like India were not approved under the fast-track route.  In these cases, you had to go through a longer route.  It is interesting to note the countries with equivalence; you would perhaps expect Canada and the US to be approved but they are not, whereas you may not expect Argentina, Costa Rice and India to be in the approved club.  I suspect that there is a large political element in who is in and who is out of the fast-track club.


To get initial authorisations, we have had to complete some fairly onerous forms (now called an OB11) that required us to prove that, for each product, for each agricultural unit and for each processing centre, we could show that EC organic legislation had been met and that an EC-authorised certification agency has been undertaking regular inspections of the land, farming method, processing methods and export handling to ensure that the produce is organically farmed and that nothing in the post-farm process could adulterate the organic status of the farmed food.  This could take weeks of toing and froing with many finickety queries.  These import authorisations must be renewed every year through the completion of a shorter form (an OB12) that also requires sign off by the EC-authorised agency.


However, on the basis of streamlining (read penny pinching and cost-saving), this checking process as been effectively stopped and become a rubber-stamping process.


Perversely, the system is actually now more expensive than it used to be.  In the past, I filled out the forms (which were really long) but nowadays the form is much shorter and has to be completed by the exporter’s certification agency, which includes their seal and sign-off.  A renewal used to cost us £50 which we paid to defra but now costs £15 plus the cost to the external agency of €125.  Wouldn’t it have been better to charge us £75 or £100 and allowed us to continue to do the work – this would have kept the income in the UK, allowed the staff to be kept on at defra, rather than shifting the increased cost to British businesses while shifting the cash benefit to agencies based in mainland Europe.


What extra checks do we do?


The above processes are all very well, but they are really legalistic and it is key for us that our organic suppliers believe in organic and are not simply very good at form filling.  This is one of my great bugbears about legislation in all spheres – by relying on legislation, it enables businesses to turn around and say “we’ve met the requirements of the law” whereas in actual fact they are flouting the idea behind the law in all some areas that are not directly and very specifically addressed in the legislation.  In accounting, we used to talk about looking at “the substance” of transactions rather than “the form”.


We choose our organic suppliers very simply.  We look for businesses that only do organic products and have been doing organic for at least 5 years.  Wherever possible we like them to also be involved in fair trading in some format, whether Fairtrade/Max Havelaar or Ecocert Fairtrade or Traidcraft Fairtrade or some other recognised process.  We also like to meet them and look into their eyes to see whether they really believe in organic and ethical trading or whether it’s simply a money-making gimmick.


We then try and visit as many as possible places, but this is financially really difficult for a small business like ours, so we cannot do this as much as we would like.


We also get our suppliers to complete a long and detailed Self-Audit Questionnaire that covers many aspects from Good Food Manufacturing through to How Do You Treat Employees and what Manuring Process do you use.


Then when the products come in, we test them on a random basis for microbiological quality, pesticide contamination and sometimes irradiation.  Nothing is released into our production until these tests are satisfactory.  Any issues are then questioned back through the chain.  Once we had a real internal scare and thought that one of products had been irradiated but after loads of extra testing, which cost us a fortune, meetings with the farmers and their certification agency, it appears that the laboratory made a mistake or at least the result was a rogue - we retested the original and new samples as well as samples of other products from the same supplier and found no evidence. 


We then trade with them continuously as we believe that the best way is for us to build up a relationship over time and a feeling of mutual trust.  So while we are still bringing on new suppliers all the time, one of our favourite suppliers (Lanka Organics/Greenfield Tea) was our first approved organic supplier and we are still working with and doing more things all the time.