Food safety and organic control
Grow Sow Greener Ltd
Food safety and organic control
How we buy, handle, pack, label and trace seed — and what documentation we can put in your hands. Written for commercial growers, sprouters and trade buyers who have their own auditor to answer to.
Most seed suppliers say nothing about any of this. If you grow microgreens or produce sprouts for sale, your own food safety system depends on what your seed supplier can evidence, and "we buy good quality seed" is not evidence. This page sets out the controls we operate and the paperwork we can supply.
Certification and licensing
- Organic certification
- OF&G UKP1856Certifier code GB-ORG-02
- Seed marketing licence
- APHA / DEFRA 7665Packing, processing, distribution and marketing of seed
- Registered company
- 15052242England and Wales
- Food safety system
- HACCP-basedDocumented plan, reviewed annually
Organic certification covers specific products and processes rather than a whole catalogue. We hold both organic and conventional lines, so the certificate is the document that tells you what is covered. Download our OF&G organic certificate (PDF), and if you need confirmation for a specific line you are buying, ask us and we will send it.
The regulations we work to
Seed sold for sprouting is food in Great Britain, and is regulated as such. Seed sold for sowing is regulated on variety, purity, germination and labelling instead. Much of our range is bought for both, so we apply the stricter reading throughout and treat all seed sold for sprouting or microgreen growing as food.
| Area | What applies |
|---|---|
| General food law | Regulation 178/2002 — the duty not to place unsafe food on the market, and traceability one step back and one step forward |
| Food hygiene and HACCP | Regulation 852/2004 Article 5 — a permanent procedure based on HACCP principles |
| Sprouting seed traceability | Regulation 208/2013 Article 3 — a specified data set per batch, updated daily and retrievable on demand |
| Microbiological criteria | Regulation 2073/2005 — the criteria our supplier certificates are tested against |
| Allergen and consumer information | Regulation 1169/2011 — allergen declaration and prepacked food labelling |
| Food contact materials | Regulation 1935/2004 and Regulation 10/2011 — declarations of compliance held for our packaging |
| Seed marketing | Seed Marketing Regulations 2011 — licensing, lot identification, labelling and record keeping |
| Organic | Regulations 834/2007 and 889/2008 as they apply in Great Britain, and the OF&G processing standard |
Worth knowing if you produce sprouts for sale
Producing sprouts is not the same as packing seed. A business that germinates seed for sale needs establishment approval from its local authority under Regulation 210/2013, following at least one on-site visit — approval, not just registration. It must also sample for Salmonella and the named STEC serogroups at least monthly under Regulation 2073/2005, and keep traceability records under Regulation 208/2013 that reach back to the seed lot.
That last obligation is the one we can help with directly. We can supply the seed-side documentation your traceability records need.
How we handle seed
We buy whole, dry, untreated seed in bulk, and repack it by hand and by filling machine into retail and trade quantities from 10g to 25kg. We do not clean, grade, treat, heat, wash or germinate seed. That matters for one specific reason, and we would rather say it plainly than dress it up:
There is no kill step. Nothing we do reduces a microbiological hazard already present in the seed, and the person eating sprouts will not cook them either. So our controls sit where they can actually work — in which seed we will accept in the first place, in the conditions we hold and pack it under, and in what the label and the records say. Any seed supplier claiming their packing process makes seed safe is describing something that does not exist.
- Supplier approvalWe buy only from approved suppliers operating documented food safety systems. Untreated seed is specified on the purchase order and confirmed on the supplier's paperwork. Organic orders state organic on the order itself.
- Intake and goods-in checkDocumentation is checked before anything is unloaded. Lot numbers are cross-checked three ways — sacks, packing list and invoice — and weights and varieties are verified against the packing list. Every sack is inspected for splits, damp, pest damage and tampering. No lot number is issued until every check passes.
- Bulk storageSealed containers, raised clear of floor and wall, dry ambient conditions. Organic and conventional stock is separately identified, closed and labelled at all times.
- Run planningOrganic runs are the first operation after a clean. Conventional lines run last. Allergenic species run last in the day and never before a non-allergenic species.
- Equipment set-upHopper, nozzle and machine internals stripped, vacuumed and wiped. Bench, scoops and scales sanitised. Where detergent is used, a final potable water rinse before production starts. Plant is inspected before use.
- Labelling and lot codingLabels are drawn from an approved specification for that product. A lot code is assigned and recorded, linking the pack back to the supplier lot it came from.
- Weighing, filling and sealingScales checked against a known test weight at the start of every packing day and calibrated annually against certified weights. Excess air removed and the pouch heat sealed to a set temperature and dwell.
- Pack checksFirst pack, last pack and one in every 25 checked against the label specification, check-weighed on the calibrated scale, and checked for seal integrity. A failure stops the run and everything back to the last good check is quarantined.
- Storage and despatchSealed, labelled packs held in dry ambient storage. Orders picked to the lot code, with the traceability data carried on the despatch record.
- Record close-outRecords completed and signed, lot numbers cross-checked, and filed. Records are retained for five years.
Where control is critical
Our HACCP plan identifies two critical control points. Two, not twenty — because in a dry seed repacking operation there are only two steps where control is genuinely essential and measurable, and padding the list with things that are really housekeeping helps nobody.
| Control point | What it controls, and the standard |
|---|---|
| Accepting a lot at intake | The last point at which a contaminated, treated or unverifiable lot can be stopped. Our standard is that no lot is released into sprouting or microgreen use without a supplier certificate of analysis for that specific lot, covering Salmonella and the STEC serogroups O157, O26, O111, O103, O145 and O104:H4, from an accredited laboratory. Lot numbers must correspond exactly across sacks, packing list and invoice. Seed must be untreated. Organic lots need a supplier certificate valid on the date of supply and listing the goods. Anything short of that is quarantined or rejected. |
| Applying the label and lot code | The label is the only thing telling you what the product is, whether it carries an allergen, whether it is organic and which lot it came from — and a labelling error cannot be caught further down the line. Every pack must carry the correct species and variety, net quantity, durability date, storage conditions, our details, the lot code, allergen information where it applies, and the organic certifier code and origin statement on organic lines. Checked at the start of the run, at the end, and one in every 25. |
Everything underneath
Most of the day-to-day work sits in the prerequisite programmes rather than the control points. These run continuously and each one is documented, scheduled and recorded.
| Programme | What it covers |
|---|---|
| Cleaning and sanitation | Defined permitted materials and methods, scheduled before every run, after every run, daily, on every changeover, weekly and annually. Cleaning is recorded and its effectiveness verified, not just scheduled. Compressed air is not used on benches or product contact surfaces — it moves seed dust rather than removing it. |
| Allergen management | Allergenic species are packed last, followed by a full wet changeover clean and a recorded visual verification. Allergen status of every line in the range is documented and reflected on the label. |
| Pest control | Housekeeping first. Screened entry points, doors closed, spillage cleaned. Weekly internal inspection and a quarterly minimum visit by a BPCA certified contractor who is told the site is organic. No aerosol or fumigation methods are used. |
| Supplier approval | Organic certificates valid at the date of supply and listing the goods, non-GMO declarations renewed annually, the supplier's own food safety documentation, lot-level certificates of analysis and phytosanitary certificates where they apply. Suppliers reviewed annually. |
| Packaging | Compostable, resealable, plastic-free pouches. Food grade, unused, stored off the floor. Declarations of compliance held from the packaging supplier. |
| Calibration | A repacking business is a weighing business. Scales checked daily against a test weight and calibrated annually to external standards. |
| Waste and hygiene | Waste segregated, labelled, sealed and logged. Personal hygiene standards, controlled access to the packing area, no glass in the packing area. |
| Training | Anyone whose work can affect food safety or organic integrity is trained before working unsupervised, refreshed annually, and the training recorded. |
Organic integrity
Organic control is not run as a separate system alongside food safety. Loss of organic integrity is treated as a hazard in the same plan, with its own control points, so nothing falls between the two.
- Segregation. Organic operations are separated by place or time from conventional ones. Simultaneous organic and conventional packing on the same line is never done.
- Sequencing and cleaning. Organic runs first after a clean, with the effectiveness of that clean checked and recorded before the run starts.
- Verification at intake. Supplier organic status is checked against the accompanying documents, and the result of that check is written into the records — not merely ticked off on a delivery note.
- Mass balance. Inputs reconciled against outputs on a defined cycle, with a tolerance and a documented investigation when it is exceeded, plus a full physical stocktake at least annually.
- Labelling. Certifier code and origin statement on every organic pack. Artwork approved by our certifier before printing.
- Doubt. If there is any suspicion about the organic status of a product, it is separated and identified, organic reference is withdrawn, and our certifier is informed immediately. The trigger is suspicion, not proof.
Traceability
Every pack carries a lot code that links it to the supplier lot it was filled from. That gives a trace in both directions.
| Direction | What it reaches |
|---|---|
| Backwards | Pack → our lot code → supplier lot → the supplier's consignment paperwork, organic certificate, certificate of analysis, phytosanitary certificate and import documentation |
| Forwards | Lot → packing record → quantities and pack sizes produced → despatch record → your order |
Our procedure sets a four-hour target for a complete two-way trace and requires the exercise to be carried out at least once a year, recorded, with any gap treated as a corrective action. Records are retained for five years — longer than the three years the organic and seed marketing rules each require on their own, because keeping one retention rule is easier to run than three.
What travels with a trade order
For lines sold for sprouting, Regulation 208/2013 Article 3 requires a specified data set to be kept and passed on. We supply all of it, including the field most often missed — the taxonomic name of the plant, not just the common name.
- Accurate description, including the taxonomic name of the plant
- Volume or quantity supplied
- Name and address of the operator the seed was dispatched from
- Name and address of the consignor or owner, where different
- Name and address of the operator it is dispatched to
- Name and address of the consignee or owner, where different
- Reference identifying the lot or batch
- Date of dispatch
Allergens
Mustard, white mustard and red mustard carry mustard, a regulated allergen. Wheatgrass is wheat and carries cereals containing gluten. These are packed on shared equipment, which is managed by run sequencing and a full changeover clean rather than by a blanket precautionary label. Allergen status is declared on the pack and we will confirm the position for any line in writing.
Mung bean is Vigna radiata. It is not soya, and we do not label it as such.
Documentation and traceability support for commercial growers
If you produce microgreens or sprouts for sale, you carry your own food safety obligations — a documented HACCP-based system, traceability to seed lot, and for sprout producers, establishment approval and a monthly sampling regime. Most growers we supply are excellent at growing and find the paperwork the hardest part of the business.
We already hold and maintain the seed-side records that sit at the top of your traceability chain. We can supply them to you, and we can help you build the rest.
Talk to us about what you need. Email trade@growsowgreener.co.uk and ask for the documentation service.
Asking us for evidence
Any of this can be evidenced. If you are auditing us as a supplier, or your own auditor has asked you to demonstrate control over your seed, tell us what you need and we will send it — certificates by lot, organic certification for the specific line, our HACCP plan on request under a confidentiality agreement, or answers to a supplier questionnaire.
Email trade@growsowgreener.co.uk.
- OF&G organic certificate — Certificate of Compliance UKP1856, certifier code GB-ORG-02
- Non-GMO statement
- This page as a PDF
Our licences and certificates page shows the same certificates in full, with what organic certification means for how we work.
Grow Sow Greener Ltd · Company number 15052242 · VAT 351346809
APHA / DEFRA seed marketing licence 7665 · Organic certification OF&G UKP1856, certifier code GB-ORG-02
trade@growsowgreener.co.uk · growsowgreener.co.uk
This page describes our own control system. It is provided for information to trade customers and is not a substitute for your own food safety management system or for advice from your local authority, certifier or the FSA.