Making Sense of Rules Governing Chlorine Contact in Postharvest Handling of Organic Produce

Abstract

Compliance with National Organic Program (NOP) standards for postharvest chlo-rination has become a battle zone between packers on the one hand and certifiers and third-party auditors on the other. Wholesale and foodservice buyers of organic produce, both whole and minimally processed, have not taken a strong or consistent position regarding compliance with NOP restrictions on chlorine dose. A good deal of confusion has developed over varying perspectives regarding the interpretation of comments embodied in the National Organic Substances List regarding the absolute dose limits, monitoring, and measurement of chlorine residual compounds in organic postharvest handling and minimal processing (fresh-cut produce) operations. The focus of the debate revolves around whether to measure chlorine concentrations • at the point of contact with the edible product • immediately downstream from each point of treatment • at the point of final effluent discharge or recapture for circulation and reuse The only clear point of agreement among packers, shippers, minimal proces-sors, certifying agents, and audit inspectors is that measurement at the point of injec-tion or treatment is not crucial for compliance, although some buyers specify an upper limit of total chlorine in order to minimize concerns about the development of chlorinated disinfection by-products due to their negative health and environmental impacts. The current NOP standard specifies a maximum of 4 ppm of chlorine residu-als downstream. Rancorous argument has often led to inconsistent application of the NOP rule. Though not documented, auditors may apply different criteria for different operations.