"Co-packing" is where a producer hires another business to produce a prepared or processed food product for him or her.
Our present product standards do not explicitly address co-packing. We permitted it to date because (a) a prepared/processed food producer can buy regular wholesale ingredients for their product(s), (b) a producer can hire employees to produce his or her prepared food products, (c) therefore, a producer can hire a co-packer to produce a prepared food product and in accordance with our present prepared/processed food standards, buy wholesale ingredients for their product, and not personally produce any of the product or do any of the work.
Because of differences of opinion, both within the committee in and in comments we have received, we are presenting two versions for public comment. As a result of comments received, we may select one of the two to forward to the board as our recommendation, or we may send them both to the board. As a result of comments from customer and producer members, the wording may change.
Our present product standards do not explicitly address co-packing. We permitted it to date because (a) a prepared/processed food producer can buy regular wholesale ingredients for their product(s), (b) a producer can hire employees to produce his or her prepared food products, (c) therefore, a producer can hire a co-packer to produce a prepared food product and in accordance with our present prepared/processed food standards, buy wholesale ingredients for their product, and not personally produce any of the product or do any of the work.
Because of differences of opinion, both within the committee in and in comments we have received, we are presenting two versions for public comment. As a result of comments received, we may select one of the two to forward to the board as our recommendation, or we may send them both to the board. As a result of comments from customer and producer members, the wording may change.
Version 1.0 takes care of a primary concern of the board about our first proposal submitted to them after public comment last year, which was to require that the contract with the co-packer specify the use of local production for meat or poultry or eggs if those were ingredients and that the contract be inspected to ensure that this was there. It requires that at least one ingredient in the product must be either grown by the producer or sourced from an Oklahoma source.
Version 1.1 is a response to committee, member, and board comments about the need to require either some work or production from the producer for a product to be legitimate in our system. Since using a co-packer does not use the producer's labor to make the product, Version 1.1 takes the process a step further and requires that one or more of the "primary definitive ingredients" of the product be produced by the producer hiring the co-packer. So a producer could hire a co-packer to make strawberry jam, as long as he or she provided the strawberries. They could not buy strawberries from the regular wholesale system, or from another local producer, and then hire a co-packer to make the jam.
While a regular prepared/processed food producer could produce a food item for sale that includes nothing that was actually grown by the producer, the producer and his/her family and/or employees are "producing" their work as an essential "ingredient" of the finished product. This proposal would close our system to those with simply a good idea, a tasty recipe, and capital to hire a local co-packer and buy ingredients.
The argument against that is that even a product produced by a co-packer that includes no local ingredients does strengthen the local food system, since co-packers are an essential aspect of a local food system and it would be better for our members to e.g. buy a "small Oklahoma brand" ketchup than to go to the supermarket and buy a national brand produced in California or somewhere else.
Some of the producers however feel very strongly that a producer should either be providing the work or some of the ingredients for it to qualify for sale through us, since our hypothetical locally co-packed/ingredients sourced wholesale product could get into supermarkets and have a market there.
The argument against that is that even a product produced by a co-packer that includes no local ingredients does strengthen the local food system, since co-packers are an essential aspect of a local food system and it would be better for our members to e.g. buy a "small Oklahoma brand" ketchup than to go to the supermarket and buy a national brand produced in California or somewhere else.
Some of the producers however feel very strongly that a producer should either be providing the work or some of the ingredients for it to qualify for sale through us, since our hypothetical locally co-packed/ingredients sourced wholesale product could get into supermarkets and have a market there.
This does not impact in any way prepared or processed food producers who do their own labor, or hire employees to help make their products.
I am at this time not sure if this would negatively impact any of our existing producers. I expect that to come out during public comment period.
So as you can see, there is, a kind of a fundamental "existential" issue for the coop that must be addressed here that should not/cannot be resolved by the Standards Committee by itself.
This public comment period will run until Wednesday, February 9.
Those who subscribe to the public discussion group can comment by sending email to okfoodret@yahoogroups.com or post at http://groups.yahoo.com/group/okfoodret/ . Those who subscribe to okproducers@yahoogroups.com can send email to okproducers@yahoogroups.com . Comments may be sent privately to me at bwaldrop@cox.net and they will be forwarded to the committee and included in our report to the board, which will be in the minutes for the meeting. We expect to send this to the board and that it will be voted on at the meeting on February 13th. If people want to speak to the board about this, they can do so at that time. Do not send email to members@oklahomafood.coop or producers@oklahomafood.coop as it will be automatically deleted by the system since only those with the password can post to those listservs.
Thanks for your assistance in this aspect of the governance of the coop.
Bob Waldrop, chair, Standards Committee
Co-packed Products, version 1.0
1. In order to sell a prepared or processed food product, where the
production is carried out by a co-packer, a coop member must apply for
and be approved as a Food Producer Using a Co-packer, using the
application published at the coop's website. No producer may use a
co-packer to prepare foods for sale through the Oklahoma Food
Cooperative without applying for and being approved as a Food Producer
Using a Co-packer.
2. Existing producers of prepared foods using co-packers are
grandfathered in as Food Producers Using a Co-packer, but they must
complete the application form and send it to the Compliance Committee,
and their co-packed products must meet these standards. Any co-packed
products that they sell, that do not meet these standards, must be
brought into compliance within six months or removed from their list of
products sold through the cooperative.
a. If a producer rents a facility to make a prepared food product, and
the labor is done by the producer, his or her household, and/or
employees, this is not considered co-packing under these standards.
3. Definitions. For the purposes of this co-packing standard, these
are the definitions of prepared and processed foods.
a. A co-packed product is a product that is produced by a business
separate from the producer, his or her household, and/or employees,
based on a contract or agreement with a coop producer. For the purposes
of this standard, cured meats, sausages, luncheon meats and other
charcuterie, offered by producers, prepared by a processor that is licensed by the USDA or the state of Oklahoma, on
behalf of a coop food producer, are not considered to be "co-packed".
This copacking standard is not intended to cover any primary food
products like raw meat, raw whole vegetables, unmilled grain, etc.
Grain may be cleaned, and meat may be cut and packaged, by third parties
and not be considered co-packing.
b. A Prepared Food Product is any food that has been prepared in a
manner which changes the food from its original state, but which does
not require a Processing Authority Letter from an agency that
issues processing authority letters.
c. A Processed Food Product is a prepared food that requires a
Processing Authority Letter issued by an agency that issues processing
authority letters to be legal for sale,
4. All co-packed prepared and processed food products, as defined
herein, sold through the Oklahoma Food Cooperative must comply with all
applicable laws and
government regulations, and the producer warrants to the Coop that the
prepared and/or processed products to be sold by the producer comply
with the relevant laws and regulations.
5. Ingredients. The requirements for ingredients of prepared and
processed food products in the existing standards of the Oklahoma Food
Cooperative apply to all co-packed products. Any meat or eggs must be
sourced from non-CAFO Oklahoma sources, and at least one ingredient in the
recipe must be sourced from Oklahoma sources or raised
by the producer himself/herself. If the product contains meat or eggs, the
contract with the co-packed must specify the use of non-CAFO Oklahoma
production, and the coop's inspector must verify that the contract contains
a clause to that effect. Proprietary information about recipes may be
blacked out in the copy of the contract that is inspection.
6. The co-packer must be located in the state of Oklahoma.
7. Producers using a co-packer must include the name and location of
their co-packer in the description of their products, and identify which
ingredient(s) are sourced from Oklahoma or raised by the producer
himself/herself, for example:
Strawberry jam. Ingredients: sugar, strawberries, pectin. Co-packed by
the Desirable Foods Company, Bug Tussle, Oklahoma, using Oklahoma
strawberries.
Or,
Zucchini-Cheese-Hamburger Casserole. Ingredients: zucchini, cheese,
noodles, hamburger, basil, herbs. Made with hamburger and zucchini from
my farm. Co-packed by the Desirable Foods Company, Bug Tussle, Oklahoma.
6. All applications for co-packed products must include a copy of the
contract(s) with the co-packer. However, any proprietary information
included in such contracts may be inked out to avoid disclosure of such
proprietary information.
+++++++++++++++++++++++=
Co-packed Products, Version 1.1
1. In order to sell a prepared or processed food product, where the
production is carried out by a co-packer, a coop member must apply for
and be approved as a Food Producer Using a Co-packer, using the
application published at the coop's website. No producer may use a
co-packer to prepare foods for sale through the Oklahoma Food
Cooperative without applying for and being approved as a Food Producer
Using a Co-packer.
2. Existing producers of prepared foods using co-packers are
grandfathered in as Food Producers Using a Co-packer, but they must
complete the application form and send it to the Compliance Committee,
and their co-packed products must meet these standards. Any co-packed
products that they sell, that do not meet these standards, must be
brought into compliance within 1 year or removed from their list of
products sold through the cooperative.
a. If a producer rents a facility to make a prepared food product, and
the labor is done by the producer, his or her household, and/or
employees, this is not considered co-packing under these standards.
3. Definitions. For the purposes of this co-packing standard, these
are the definitions shall be used.
a. A co-packed product is a product that is produced by a business
separate from the producer, his or her household, and/or employees,
based on a contract or agreement with a coop producer. For the purposes
of this standard, cured or dried meats, jerkeys, sausages, luncheon meats
and other
charcuterie, offered by producers, prepared by
a processor that is licensed by the USDA or the state of Oklahoma, on
behalf of a coop food producer, are not considered to be "co-packed".
This copacking standard is not intended to cover any primary food
products like raw meat, raw whole vegetables, unmilled grain, etc.
Grain may be cleaned, and meat may be cut and packaged, by third parties
and not be considered co-packing.
b. A Prepared Food Product is any food that has been prepared in a
manner which changes the food from its original state, but which does
not require a Processing Authority Letter from an agency that
issues processing authority letters.
c. A Processed Food Product is a prepared food that requires a
Processing Authority Letter issued by an agency that issues processing
authority letters to be legal for sale.
d. Primary definitive ingredient. A primary definitive ingredient is an
ingredient that gives a food product its nature or character as a food
product. A product may have more than one primary definitive ingredient.
Examples:
+ The primary definitive ingredient of a jam or jelly is the fruit or
vegetable that provides its identity. For strawberry jam, the primary
definitive ingredient is strawberries. For apple-peach jam, the primary
definitive ingredients are apples and peaces.
+ The primary definitive ingredient of a hamburger casserole is the
hamburger. The primary definitive ingredients of a hamburger-cheese
casserole are the hamburger and the cheese. The primary definitive
ingredients of a hamburger-zucchini-cheese casseroles are the hamburger,
cheese, and zucchini.
4. All co-packed prepared and processed food products, as defined
herein, sold through the Oklahoma Food Cooperative must comply with all
applicable laws and
government regulations, and the producer warrants to the Coop that the
prepared and/or processed products to be sold by the producer comply
with the relevant laws and regulations.
5. Ingredients. The requirements for ingredients of prepared and
processed food products in the existing standards of the Oklahoma Food
Cooperative apply to all co-packed products, except as provided below.
(a) Any meat or eggs must be sourced from non-CAFO Oklahoma sources, and
(b) at least one of the primary definitive ingredients must be raised by
the producer himself/herself.
(c) If the product contains meat or eggs, the contract with the co-packed
must specify the use of non-CAFO Oklahoma production, and the coop's
inspector must verify that the contract contains a clause to that effect.
The contract must specify the use of the producer's production of the
identified primary definitive ingredient(s) and forbid substituting
additional amounts of said definitive ingredient not grown by the producer.
Proprietary information about recipes may be blacked out in the copy of the
contract that is inspected
6. The co-packer must be located in the state of Oklahoma.
7. Producers using a co-packer must include the name and location of
their co-packer in the description of their products, and identify which
ingredient(s) are sourced from Oklahoma or raised by the producer
himself/herself, for example:
Strawberry jam. Ingredients: sugar, strawberries, pectin. Co-packed by
the Desirable Foods Company, Bug Tussle, Oklahoma, using strawberries raised
on my farm.
Or,
Zucchini-Cheese-Hamburger Casserole. Ingredients: zucchini, cheese,
noodles, hamburger, basil, herbs. Made with zucchini from
my farm and hamburger from Oklahoma sources. Co-packed by the Desirable
Foods Company, Bug Tussle, Oklahoma.
6. All applications for co-packed products must include a copy of the
contract(s) with the co-packer. However, any proprietary information
included in such contracts may be inked out to avoid disclosure of such
proprietary information.
Co-packed Products, version 1.0
1. In order to sell a prepared or processed food product, where the
production is carried out by a co-packer, a coop member must apply for
and be approved as a Food Producer Using a Co-packer, using the
application published at the coop's website. No producer may use a
co-packer to prepare foods for sale through the Oklahoma Food
Cooperative without applying for and being approved as a Food Producer
Using a Co-packer.
2. Existing producers of prepared foods using co-packers are
grandfathered in as Food Producers Using a Co-packer, but they must
complete the application form and send it to the Compliance Committee,
and their co-packed products must meet these standards. Any co-packed
products that they sell, that do not meet these standards, must be
brought into compliance within six months or removed from their list of
products sold through the cooperative.
a. If a producer rents a facility to make a prepared food product, and
the labor is done by the producer, his or her household, and/or
employees, this is not considered co-packing under these standards.
3. Definitions. For the purposes of this co-packing standard, these
are the definitions of prepared and processed foods.
a. A co-packed product is a product that is produced by a business
separate from the producer, his or her household, and/or employees,
based on a contract or agreement with a coop producer. For the purposes
of this standard, cured meats, sausages, luncheon meats and other
charcuterie, offered by producers, prepared by a processor that is licensed by the USDA or the state of Oklahoma, on
behalf of a coop food producer, are not considered to be "co-packed".
This copacking standard is not intended to cover any primary food
products like raw meat, raw whole vegetables, unmilled grain, etc.
Grain may be cleaned, and meat may be cut and packaged, by third parties
and not be considered co-packing.
b. A Prepared Food Product is any food that has been prepared in a
manner which changes the food from its original state, but which does
not require a Processing Authority Letter from an agency that
issues processing authority letters.
c. A Processed Food Product is a prepared food that requires a
Processing Authority Letter issued by an agency that issues processing
authority letters to be legal for sale,
4. All co-packed prepared and processed food products, as defined
herein, sold through the Oklahoma Food Cooperative must comply with all
applicable laws and
government regulations, and the producer warrants to the Coop that the
prepared and/or processed products to be sold by the producer comply
with the relevant laws and regulations.
5. Ingredients. The requirements for ingredients of prepared and
processed food products in the existing standards of the Oklahoma Food
Cooperative apply to all co-packed products. Any meat or eggs must be
sourced from non-CAFO Oklahoma sources, and at least one ingredient in the
recipe must be sourced from Oklahoma sources or raised
by the producer himself/herself. If the product contains meat or eggs, the
contract with the co-packed must specify the use of non-CAFO Oklahoma
production, and the coop's inspector must verify that the contract contains
a clause to that effect. Proprietary information about recipes may be
blacked out in the copy of the contract that is inspection.
6. The co-packer must be located in the state of Oklahoma.
7. Producers using a co-packer must include the name and location of
their co-packer in the description of their products, and identify which
ingredient(s) are sourced from Oklahoma or raised by the producer
himself/herself, for example:
Strawberry jam. Ingredients: sugar, strawberries, pectin. Co-packed by
the Desirable Foods Company, Bug Tussle, Oklahoma, using Oklahoma
strawberries.
Or,
Zucchini-Cheese-Hamburger Casserole. Ingredients: zucchini, cheese,
noodles, hamburger, basil, herbs. Made with hamburger and zucchini from
my farm. Co-packed by the Desirable Foods Company, Bug Tussle, Oklahoma.
6. All applications for co-packed products must include a copy of the
contract(s) with the co-packer. However, any proprietary information
included in such contracts may be inked out to avoid disclosure of such
proprietary information.
+++++++++++++++++++++++=
Co-packed Products, Version 1.1
1. In order to sell a prepared or processed food product, where the
production is carried out by a co-packer, a coop member must apply for
and be approved as a Food Producer Using a Co-packer, using the
application published at the coop's website. No producer may use a
co-packer to prepare foods for sale through the Oklahoma Food
Cooperative without applying for and being approved as a Food Producer
Using a Co-packer.
2. Existing producers of prepared foods using co-packers are
grandfathered in as Food Producers Using a Co-packer, but they must
complete the application form and send it to the Compliance Committee,
and their co-packed products must meet these standards. Any co-packed
products that they sell, that do not meet these standards, must be
brought into compliance within 1 year or removed from their list of
products sold through the cooperative.
a. If a producer rents a facility to make a prepared food product, and
the labor is done by the producer, his or her household, and/or
employees, this is not considered co-packing under these standards.
3. Definitions. For the purposes of this co-packing standard, these
are the definitions shall be used.
a. A co-packed product is a product that is produced by a business
separate from the producer, his or her household, and/or employees,
based on a contract or agreement with a coop producer. For the purposes
of this standard, cured or dried meats, jerkeys, sausages, luncheon meats
and other
charcuterie, offered by producers, prepared by
a processor that is licensed by the USDA or the state of Oklahoma, on
behalf of a coop food producer, are not considered to be "co-packed".
This copacking standard is not intended to cover any primary food
products like raw meat, raw whole vegetables, unmilled grain, etc.
Grain may be cleaned, and meat may be cut and packaged, by third parties
and not be considered co-packing.
b. A Prepared Food Product is any food that has been prepared in a
manner which changes the food from its original state, but which does
not require a Processing Authority Letter from an agency that
issues processing authority letters.
c. A Processed Food Product is a prepared food that requires a
Processing Authority Letter issued by an agency that issues processing
authority letters to be legal for sale.
d. Primary definitive ingredient. A primary definitive ingredient is an
ingredient that gives a food product its nature or character as a food
product. A product may have more than one primary definitive ingredient.
Examples:
+ The primary definitive ingredient of a jam or jelly is the fruit or
vegetable that provides its identity. For strawberry jam, the primary
definitive ingredient is strawberries. For apple-peach jam, the primary
definitive ingredients are apples and peaces.
+ The primary definitive ingredient of a hamburger casserole is the
hamburger. The primary definitive ingredients of a hamburger-cheese
casserole are the hamburger and the cheese. The primary definitive
ingredients of a hamburger-zucchini-cheese casseroles are the hamburger,
cheese, and zucchini.
4. All co-packed prepared and processed food products, as defined
herein, sold through the Oklahoma Food Cooperative must comply with all
applicable laws and
government regulations, and the producer warrants to the Coop that the
prepared and/or processed products to be sold by the producer comply
with the relevant laws and regulations.
5. Ingredients. The requirements for ingredients of prepared and
processed food products in the existing standards of the Oklahoma Food
Cooperative apply to all co-packed products, except as provided below.
(a) Any meat or eggs must be sourced from non-CAFO Oklahoma sources, and
(b) at least one of the primary definitive ingredients must be raised by
the producer himself/herself.
(c) If the product contains meat or eggs, the contract with the co-packed
must specify the use of non-CAFO Oklahoma production, and the coop's
inspector must verify that the contract contains a clause to that effect.
The contract must specify the use of the producer's production of the
identified primary definitive ingredient(s) and forbid substituting
additional amounts of said definitive ingredient not grown by the producer.
Proprietary information about recipes may be blacked out in the copy of the
contract that is inspected
6. The co-packer must be located in the state of Oklahoma.
7. Producers using a co-packer must include the name and location of
their co-packer in the description of their products, and identify which
ingredient(s) are sourced from Oklahoma or raised by the producer
himself/herself, for example:
Strawberry jam. Ingredients: sugar, strawberries, pectin. Co-packed by
the Desirable Foods Company, Bug Tussle, Oklahoma, using strawberries raised
on my farm.
Or,
Zucchini-Cheese-Hamburger Casserole. Ingredients: zucchini, cheese,
noodles, hamburger, basil, herbs. Made with zucchini from
my farm and hamburger from Oklahoma sources. Co-packed by the Desirable
Foods Company, Bug Tussle, Oklahoma.
6. All applications for co-packed products must include a copy of the
contract(s) with the co-packer. However, any proprietary information
included in such contracts may be inked out to avoid disclosure of such
proprietary information.
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