Natural Foods Merchandiser

Retailer Role As Organic Gatekeeper Undiminished By New Regulations

As the organic community and U.S. Department of Agriculture wrestled with the substance of national organic standards, retailer certification for methods of handling organic foods was one of many contentious issues. Retailers may have been relieved to learn that the USDA's final standards, issued in March 2001 with an implementation deadline of October 2002, do not include that requirement for the time being.

Yet retailers remain responsible, both legally under the USDA's rule and as partners in the supply chain from seed to table, for treating organic products according to very specific guidelines. The Organic Trade Association calls it Good Organic Retailing Practices, and the GORP acronym is now commonly used to refer to the actions and systems retailers must follow to maintain the integrity of organic production.

"It's really the last step in maintaining the integrity of the organic product," says Dave Gagnon, director of operations for the Organic Trade Association, based in Greenfield, Mass. "Retailers don't have to be certified at this time, but they still have to comply with the new rule and with basic procedures to maintain that integrity."

But violations of those basic procedures are rampant—usually due to ignorance rather than deliberate fraud or malice—and come October of next year, scrutiny of retailer practices and fines for noncompliance are likely to increase. Retailers who mislabel conventional produce as organic, for example, or have the two types of produce in contact with each other, or who incorrectly label prepared foods, will be subject to fines up to $10,000.

Enforcement is expected to be primarily in the form of the USDA's response to direct complaints—there won't be "organic police" in undercover garb going from store to store. But many believe that the heightened visibility of organics because of the USDA's new rule will also bring more inquiry by pro-organic consumer advocates, journalists and even anti-organic forces into the retailer aspect of the organic marketplace.

"There will be more and more articles questioning this break in the [certification] link," says Goldie Caughlan, nutrition education manager for the seven-store, Seattle-based Puget Consumer's Co-op chain and a consumer representative to the National Organic Standards Board. "As that happens, more and more consumers will be asking questions and will take their questions to the managers.

"Keeping first and foremost the consumer in mind, the consumer has every reason to expect that if they're purchasing organic, it is what it says it is," Caughlan adds. "Absent official certification, that's precisely why retailers need to take extraordinary precautions to make every attempt to act as though they are subject to certification."

(The states of Texas, Maryland, Vermont, Washington and California currently do have retail standards, with some requiring certification. Retailers in these states should be in close communication with state agencies to understand how state requirements will be integrated with the USDA regulations.)

Walking The Organic Line
Two principles lie at the heart of good organic retailing. First, the organic movement was built on the public's right to know how any food is grown and processed. To that end, retailers must track incoming product to make sure it is what it says it is, and they must be able to communicate that to the consumer. This includes accuracy in signage and marketing materials, as well as the ability to easily track and name the producer and the specific certifying agency of organic products.

The second principle is that organic product must be protected from contamination throughout the supply chain, including the retail level, to guarantee to consumers that they are getting what they pay for and expect. This means careful monitoring of both the front and back end of the store.

If this sounds easy enough, consider that the Organic Trade Association has developed a unique handbook and training program for good organic retailing practices that clocks in at close to 300 pages. "[It covers] receiving practices, storage practices, display practices, food preparation," says Phil Margolis, vice president of OTA's board of directors and CEO and founder of Neshaminy Valley, an Ivyland, Pa.-based natural foods distributor. "Our goal with the GORP project is to identify all those different control points which are areas of your operation where organic integrity can be compromised."

While OTA's GORP manual and training provide a comprehensive, turnkey approach complete with checklists and questionnaires, some retailers develop their own systems and programs to monitor organic handling practices based on long experience and depth of knowledge. Seattle's PCC chain is one of those, Caughlan says, and the company is acutely aware of the need to target problem areas and pay close attention to the details.

"I believe if we were certified organic, there would be something almost like a HACCP program [HACCP stands for Hazard Analysis at Critical Control Points, a model designed to ensure food safety]," Caughlan says. "If retailers would think of voluntary organic certification like a HACCP approach, they would go through the whole system and see where the holes are. Maybe it's in the back room where we're stacking stuff, or where we're storing, putting things into boxes and repacking that would break the chain. I also think of stocking bulk as something people have to be very cautious of."

In fact, while problems of commingling and incorrect labeling seem most obvious to observers in the produce section, precise organic handling systems must also be in place in the bulk department, in the deli and prepared foods area, in the meat department and in packaged groceries. For example, organic meat should never be stored beneath conventional meat, just as organic produce should never be displayed beneath conventional produce—run-off from above will contaminate the organic product. Even in-store pest control methods must take contamination of organic foods into account.

Even the most exacting and well-thought-out system for good organic retailing, however, is only as good as the employees who work within that system. And the ongoing difficulties of staff training, education and turnover affect good organic retailing as much as any other factor.

Rolling Downhill: Training And Educating Staff
The task of finding qualified employees, let alone those who are engaged and committed to organic integrity, remains a challenge for most retailers. Staff members often have their hands full fulfilling everyday demands. Developing and implementing appropriate systems for organic handling and keeping employees up to date with the changes in organic regulations and consumer expectations is even more daunting.

"Things have been changing rapidly over the past few years, even in the last year, and I feel the education we give our employees about organic is now outdated, of the 'don't panic it's organic' variety," says Sarah Miles, marketing director for the New Leaf chain of markets, based in Santa Cruz, Calif. "Now that we've come out of limbo and have a federal rule to work with, it's time to overhaul our employee education about what organic is so that they can better respond to consumer questions and requests."

If attitudes "roll downhill," then management, of course, plays a key role by showing their own commitment to good organic retailing and letting employees know that it matters. "As with all aspects of this business, the turnover in staff means there's a constant need to be sure your staff is out there and aware, that [good organic retailing] is very serious and not just a marketing strategy," PCC's Caughlan says. "At Safeway, your main challenge is to know what aisle such and such is on, but here it's a very different story."

The complexities of understanding the organic rule, as well as requirements for handling and labeling, and communicating this information to employees, cannot be underestimated. But retailers who accept the GORP mandate and wholeheartedly comply with both the concept and the day-to-day actions of maintaining organic integrity will not just save themselves from embarrassing public relations problems and legal fines; they may have a distinct marketing advantage as well.

The Organic Advantage
Those in the organic community expect to see wider availability of organic foods as a result of national organic standards. Many conventional stores can be expected to introduce or expand their offerings of organic foods. Clearly, competition will increase—but a well-defined program of good organic retailing practices can give consumers confidence in one store over another. The key to this differentiation, however, will be a store's ability to back up its claims of understanding and protecting organic.

"It's a very good marketing strategy for retailers to present themselves as good organic retailers," Caughlan says. "But it'll be hard to prove without an audit trail." In addition, it requires a hard look at how information is communicated to consumers. "With the federal definition, I feel I need to reformulate the language we use to educate employees and customers about organic to be both simpler and more objective," Miles of New Leaf says, " but it has to remain fun, feel good and be tasty too. Now that's a challenge."

Because it takes time to develop both marketing materials and GORP systems, and there is some admitted confusion about many aspects of the federal organic rule, the time to begin exploring ways to make your store exemplary in organic retailing is now. It's an important way to be ready for heightened visibility when the organic rule takes effect and to be prepared for retailer certification should that change be made in the federal rule in years to come.

Elaine Lipson ([email protected]) is a Colorado-based freelance writer and the author of The Organic Foods Sourcebook (Contemporary Books, 2001).

What Makes A Good Organic Retailer?

NFM posed this question to Sarah Miles, marketing director for the New Leaf chain of markets based in Santa Cruz, Calif. She says good organic retailing is in the details, but is also so much more—in a sense of priorities, vision and leadership.

"A good organic retailer seeks and offers an organic choice in as many categories as possible throughout the store, is responsive to customer requests for organic products, creates direct relationships with small local organic growers, and supports sustainable agriculture and organic farming in as many arenas as possible.

"A good organic retailer needs a defined set of standards for good organic retailing practices, a healthy employee education program and clear in-store materials defining and identifying organic products to consumers.

"A good organic retailer should make leading decisions regarding the products it chooses to carry in its stores. For example, conventionally grown strawberries are a major crop here in our region, the Monterey Bay area, and methyl bromide [a highly toxic pesticide used on strawberry crops] drift into neighborhoods and schools is an important local issue.

Therefore, New Leaf chooses to carry only organic strawberries. No matter what you buy from our stores, you won't be supporting the spraying of strawberry fields here where we live and work. In this way, we model to our community a way to make responsible consumer choices."

Organic Resources

Organic Trade Association
For information on OTA's GORP manual and training program, visit or call 413.774.7511. Look for OTA at booth #1569 at Natural Products Expo East or attend a GORP training session at the Renaissance Hotel on Saturday, Oct 13, or Sunday, Oct. 14, from 8 to 11 a.m. The cost, including a GORP handbook and CD, is $195 for OTA members, $395 for nonmembers. For more information, contact OTA's David Gagnon at 413.774.7511, ext. 25 or [email protected]

USDA National Organic Program
For the complete text of the USDA's final national organic rule and other information on the National Organic Program, visit or call 202.720.3252.

The Texas Department of Agriculture
The Texas Department of Agriculture requires organic certification for producers, processors, distributors and retailers of organic food and fiber within the state. For a look at how this state agency certifies and enforces retail organic standards, visit their Web site at

Natural Foods Merchandiser volume XXII/number 10/p. 50, 58, 60, 62

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