NATIONAL ORGANIC STANDARDS BOARD
FINAL RECOMMENDATION
Adopted on June 4, 1994 in Santa Fe, New Mexico
STANDARDS AND PROCEDURES GOVERNING THE ACCREDITATION OF ORGANIC
CERTIFICATION ORGANIZATIONS
INTRODUCTION
This document includes the NOSB Draft Recommendations in the
following areas of accreditation of organic certification
organizations:
I. The purposes of accreditation
II. Three basic criteria, and standards based on statutory
requirements and purposes
A. Competence (Expertise)
B. Transparency (Record-keeping)
C. Independence (freedom from conflict of interest)
III. The three phases of the accreditation process, the procedures for
each and possible outcomes
A. Application
B. Field Evaluation and Audit of Agency Records
C. Peer Review and Recommended Outcome
IV. Other procedures:
A. Determination of Indemnification process and costs
B. Administrative Appeals and Complaints Process
C. Costs of Accreditation
V. Appendices:
A. Glossary. [IN PROGRESS]
B. Application
1. Basic Information
2. Memorandum of Agreement
3. Questionnaire: Policies and Procedures
4. Required Documents
C. Report and Scoring forms [IN PROGRESS]
NOTE: An additional section of the Table of Contents concerning
implementation will be developed by the Accreditation
Committee for subsusquent inclusion into the Final Board
Recommendations. This section will include, but not be
limited to:
1. Control of the use of the certifier's mark or symbol;
2. Control of the USDA shield by the certifying agency;
3. Cost of certification; and
4. Suspension or termination of accreditation
Part I. The purposes of Accreditation
The Organic Foods Production Act of 1990, or Title XXI,
Organic Certification, was enacted by Congress as part of the 1990
Farm Bill (Food Agriculture, Conservation and Trade Act) The purposes
of the OFPA are:
(1) To establish national standards governing the
marketing of certain agricultural products as organically
produced products
(2) To assure consumers that organically produced products
Meet a consistent standard; and
(3) To facilitate interstate commerce in fresh and
processed food that is organically produced.
To achieve these goals, OFPA requires the USDA to establish a
mandatory national organic certification program, and the
accreditation process is a crucial component of this national program.
Accreditation has two basic purposes:
First, accreditation will assure the public that organic
certification agents and organizations, both public and private, will
carry out certification activities consistent with OFPA and the
certification requirements of the national organic certification
program. Section 6514 of the OFPA states:
"The Secretary [of Agriculture] shall establish and
implement a program to accredit a governing state
official, and any private person, that meets the
requirements of this section as a certifying agent for
the purpose of certifying a farm or handling operation
as a certified organic farm or handling operation."
Second, the accreditation program provides a role for state
government and the private sector in the national organic
certification process. The accreditation process encourages the
utilization of existing organic certification organizations as
certifying agents and allows private certification organizations to
coexist with state certification agents on a level playing field.
To understand how the accreditation program fits into the
organic certification scheme, it is helpful to view the national
organic certification program as a whole. The national organic
certification program has four fundamental components:
1. USDA Administrative and Enforcement Authority. The Secretary of
Agriculture has ultimate authority and responsibility to administer
and enforce the national organic certification program and OFPA
statutory requirements. The Secretary has delegated this authority to
the Agricultural Marketing Service (AMS), which is a USDA agency. The
Secretary is also authorized to delegate administrative and
enforcement authority to states with a USDA-approved state organic
certification program.
2. USDA-Approved State Programs. The Secretary of Agriculture is
authorized to approve state organic certification programs that are
consistent with the requirements of the national certification
program. States with USDA-approved state certification programs may
assume administrative responsibilities under the implementation of the
national organic certification program within that state. OFPA allows
states to include additional standards and/or requirements in the
state organic certification program, if those standards and
requirements have been approved by the USDA, are
consistent with the purposes of OFPA, and do not have a discriminatory
impact in the organic marketplace. Approved state organic
certification programs are subject to the authority of the Secretary
of Agriculture.
3. The USDA Accreditation Program. OFPA requires the
Secretary of Agriculture (USDA) to implement the
national organic certification program through
accredited certifying agents. Accredited certifying
agents will be responsible for determining whether
organic producers and/or handlers are in compliance with
OFPA standards and requirements. State officials and
private organizations can apply to the USDA for
accreditation as certifying agents. The USDA will
administer the accreditation program and make all
determinations regarding approval of accreditation
applications and/or revocation of a certifying agent's
accreditation status. State and private applicants for
accreditation will be evaluated under the same basic
accreditation criteria and procedures. Once accredited,
state and private certifying agents will be functionally
equivalent.
In addition, guidelines will be established for the
accreditation of agencies conducting certification
services in foreign countries. For a product bearing the
seal of a U.S.-based certifying agency to be imported
into the United States, the agency indicated shall meet
the following requirements:
a. The agent shall be accredited to certify the
production and handling of organic products within
the United States.
b. The agent shall be able to demonstrate that
oversight of the procedures utilized to certify
the production and handling of the imported
product has been provided by a USDA-recognized
governmental or non-governmental authority.
c. The agent shall be able to demonstrate that
only those imports produced and/or handled in
compliance with the U.S. Organic Food Production
Act have been certified.
d. The agent shall be able to demonstrate the
application of U.S. OFPA inspection requirements
to the certification of a farm or handling
operation located within a foreign country.
e. The agent shall be able to demonstrate adequate
documentation of the organic integrity of the
imported product from farm through U.S. Customs
clearance.
f. Copies of all records pertinent to the
certification of each imported product shall be
maintained at the U.S. agency office.
It is recognized that some private certifying agents
have established programs to address specific
philosophies and/or regional considerations, and may
wish to include requirements for the awarding of the
certifying agent's seal that are supplemental to the
standards promulgated in the OFPA. Such requirements
shall not be in conflict with the National Organic
Standards. Supplemental requirements shall not
preclude the certification to OFPA standards of
producers and handlers who do not seek to utilize the
private agent's seal.
4. The National Organic Standards Board (NOSB). The
NOSB serves as an advisory board to the Secretary of
Agriculture. The role of the NOSB is to recommend
organic standards and provide public input to help the
Secretary shape the policies and regulations that will
govern the national organic certification program.
----------------------------------
It is important to distinguish between the process of
accreditation of certifying agents and the process of approval of
State organic certification programs. The outcome of the
accreditation process is authorization of a certifying agent, be
it a state or a private person, to certify an organic farm or
handling operation. The outcome of the approval process is
authorization of a state to (1) administer the certification
program in that state; and (2) enact additional standards.
"Approval" of a state organic certification program does not
constitute "accreditation" of the state as a certifying agent.
Consequently, a state with a USDA-approved state organic
certification program must also independently apply to the USDA
for accreditation in order to carry out certification activities.
OFPA authorizes the Secretary to appoint a Peer Review
Panel to assist the Secretary in the accreditation process. The
purpose of the Peer Review Panel is to represent and utilize the
expertise existing in the organic community. The Peer Review
Panel shall be comprised of individuals with experience in the
production and handling of organic food and familiarity with
organic certification methods and procedures.
The Peer Review Panel is a critical component of the
Accreditation Program because it utilizes the expertise of the
private sector and preserves a role for the private organic
industry in the National Organic Certification Program. Sec.
6516 (a) of the OFPA states:
Peer Review
In determining whether to approve an application for
Accreditation submitted under Section 6514 of this 1
title, the Secretary shall consider a report concerning
such applicant that shall be prepared by a peer review
panel established under subsection (b) of this section.
The NOSB interprets this statutory provision, which requires
the Secretary to consider a peer review panel report when
determining whether to approve an application for Accreditation,
to be a mandatory requirement. The NOSB recommends that the Peer
Review Panel be incorporated into the USDA Accreditation Program
as a mandatory requirement through the rule making process.
Part II: Criteria for Accreditation
The accreditation process is designed to reach judgments
regarding a certifying agent's degree of compliance with three
essential program attributes -- competence, transparency, and
independence, each of which is grounded in OFPA statutory
provisions. These attributes reflect key goals all certifying
agents should strive toward; the degree to which certifying agent
programs, policies, and activities are found to be consistent
with these goals will be among the most heavily weighted factors
taken into account by the Peer Review Panel in reaching
accreditation status recommendations.
A. Competence: (Expertise)
1. COMPETENCY OF THE CERTIFYING AGENT
The Committee reviewed the steps in the certification process
with respect to the content of each step in terms of the output
of the Certifying Agent; the input received from applicant
producers, handlers, inspectors and others, and the process 2
involved; the competencies required to perform each step of the
certification process; and indices of competence.
a. Steps in the Certification Process
The Committee identified seven (7) steps in the certification
process. These are:
(1) Promulgation of the Application for Certification and
Certification Standards;
(2) Submission of the completed Application and Affidavit,
including the Organic Plan, by a producer or handler;
(3) Initial review of the Application by the Certifying
Agent;
(4) On-site inspection of the farm or handling operation by
an inspector;
(5) Administrative review and certification determination
by the Certifying Agent;
(6) Annual recertification and reinspection and submission
of an affidavit by the producer or handler; and
(7) Procedures relating to the handling of complaints and
appeals of adverse determination by the certifying
agency.
Each of these steps requires input, process and output, with the
corresponding competencies.
(1) Promulgation of the Application for Certification and
Certification Standards:
The output of this step of the certification process includes the
Application Form and Certification Standards, the Organic Plan
requirements for each particular kind of operation seeking
certification, a fee schedule, and, by identifying the competence
areas of the certifying agent, the specific kinds of operations
for which the Certifying Agent declares expertise.
The competencies required are:
* knowledge of the Organic regulations, as evidenced by the
requirements outlined in the Application Form and Certification
Standards and the Certifying Agent's Organic Plan requirements;
* knowledge of the specific kinds of operations for which
the Certifying Agent declares expertise (e.g., for a vegetable
processing operation: Current Good Manufacturing Practice for
processing operations, low-acid food canning regulations), as
evidenced by appropriate training of inspectors and reviewers
of applications (e.g., see Title 21, Code of Federal
Regulations,Section 113.10 and Title 9, Code of Federal
Regulations, Section 260 381.310);
* knowledge of operationally specific standards, handbooks
and manuals; and
* financial competence, as evidenced by a published fee
schedule and current financial statements, such as an
independently audited annual financial statement or similar
financial report.
(2) Submission of the completed Application and Affidavit,
including the Organic Plan, by a producer or handler:
The output of this step in the certification process is a
completed Application and an Organic Plan. The competencies
required of the Certifying Agent relate to the confidentiality of
certain information submitted by the producer or handler and
generated by the Certifying Agent and to the record keeping
system and procedures of the Certifying Agent required to satisfy
the record keeping requirements of the OFPA.
(3) Initial review of the Application by the Certifying Agent:
This step in the certification process involves a general
evaluation of the Application and Organic Plan against the
organic regulations and the specific requirements and standards
for the type of operation requesting certification, and requires
sufficient expertise to make valid judgments. Many of the
competencies required in step 1, above, are required here. In
addition, the Certifying Agent must have competence in
systematically recognizing potential conflicts of interest and
avoiding actual conflicts of interest, as evidenced by specific
written policies and procedures.
The output of this step in the certification process is to
determine eligibility and provide specific instructions to an
inspector who physically performs the next step in the process.
The Certifying Agent must be knowledgeable of the organic
regulations and the specific type of operation being reviewed by
the reviewers within the Certifying Agent, in order to identify
both general and specific areas for inspection. The Certifying
Agent must have policies and procedures to maintain
confidentiality of its internally generated initial
recommendation.
The Certifying Agent must be competent in training its
Application reviewers to achieve individual competence in the
organic regulations, organic plan content, and specific standards
and good operating practices for specific types of operations.
(4) On-site inspection of the farm or handling operation by an
inspector:
The Certifying Agent must have the competence to evaluate the
credentials, ability and affiliations of inspectors, in order to
select inspectors competent to inspect the type of operation
requesting certification, without conflict of interest. The
Certifying Agent must show competence in its supervision of
inspectors, with regard to inspector performance standards,
reporting requirements and ethical behavior. Specifically, the
Certifying Agent must have a general inspection protocol and
specific criteria for assessing risks to organic integrity,
especially adherence to the Organic Handling Plan and
contamination with synthetic pesticides and other synthetic
substances, and for testing food and soil and water for residues
of pesticides and other synthetic substances as appropriate.
The competency required of the inspector, as an agent of the
Certifying Agent and thus of the Secretary, includes technical
knowledge of the type of operation in addition to knowledge of
the organic regulations.
The output of this step in the certification process is the
inspection report. The Certifying Agent, specifically the
members of its review panel, must be competent in evaluating the
inspection report as it pertains to the type of operation
requesting certification.
The Certifying Agent is responsible for maintaining as
confidential information proprietary information gathered by the
Inspector. The Certifying Agent must demonstrate satisfactory
oversight of inspectors' conduct with respect to protection of
confidential information. This is evidenced by a signed
affidavit.
(5) Administrative review and certification determination by the
Certifying Agent:
This step in the certification process consists of reviewing the
Application, the Initial Recommendation and the Inspection
Report, and deciding whether the operation will be certified or
not. The competencies required for this process are the same as
those required for step 3 and step 4. The output of this step is
the certification decision. The record keeping and
confidentiality competencies of step 2 are again essential here.
The final reviewers should have competence in determining
compliance with organic standards and regulations and in
interpreting inspectors' reports.
A written procedure with objective decision criteria is an
indicator of competency in this step. This can also be verified
at the time of field evaluation.
(6) Annual recertification and reinspection and submission of an
affidavit by the producer or handler:
The OFPA requires annual inspection and recertification of
organic producers and handlers. The Organic Plan will require
evaluation of progress toward certain goals agreed upon by the
Certifying Agent and the producer or handler. Record keeping
competency of the Certifying Agent is essential, as evidenced by
the ability to locate prior years' Organic Plans for the producer
or handler requesting recertification. A system for "automatic"
follow-up that will assure pesticide testing of soil or food when
justified by the prior history of an operation is an index of
record keeping competency.
(7) Procedures relating to the handling of complaints and
appeals of adverse determination by the certifying agency:
The Certifying Agent must have formal procedures that protect the
rights of petitioners, to enable producers, handlers, inspectors,
and others to submit complaints or to appeal decisions of the
Certifying Agent. The Certifying Agent must have competency in
enforcing its decisions and adjudicating appeals of its
decisions.
The output of the appeal process is a "decision review report."
The Certifying Agent must have access to competent legal counsel,
to minimize its legal exposure and thus risks to the integrity of
the organic program.
An index of competency is the availability of records documenting
the results of the appeals process.
2. QUALIFICATIONS OF INSPECTORS
Certifying agents must employ or contract inspectors who
have thorough knowledge of, and/or can demonstrate expertise in
the following:
(1) General principles of organic food production, for
crops, livestock or processing/handling.
(2) All applicable organic food production regulations,
including audit and labeling requirements. (Federal, State)
(3) Applicable inspections procedures, forms, and policies.
(4) Specific production, handling, or processing and pest
control methods (both organic and conventional), for product to
be inspected, i.e.:
Livestock (species)
Processing (type)
Crops (type)
Handling.
(5) Risk assessment for potential contamination and
appropriate steps to be taken when contamination is suspected.
(6) Adequate written and oral communication skills.
Required expertise may be acquired by work experience in
agriculture (crops/livestock), food processing, or audit-
inspection (as applicable), formal education, specific training
courses, or past organic inspection experience &/or training.
"Sufficiency" of expertise as regards "qualified inspectors" must
be determined in relation to the types of operations an inspector
is assigned to inspect. (A processing inspector, familiar only
with fruit and vegetable processing, may for example, need to
seek additional training, reading, or other exposure to
familiarize her/himself with another particular type of food
processing.)
It is the responsibility of an Accredited Certification
organization to determine that an inspector has both the general
and specific expertise required to adequately observe and report
compliance with and deviations from organic production and
handling methods in the operations to which s/he is assigned. It
is the responsibility of the inspector to note the need for
additional information or expertise if deemed necessary in the
course of an inspection, and to decline an assignment for which
s/he lacks necessary expertise, or where sufficient
information/protocols are not provided by the certification
agency.
REFER TO: [TABLE A.1. Competence]
Click to view Table A1
Additional requirements:
7. Accredited Certification organizations must have on file
affidavits from all inspectors assuring compliance with statutory
requirements regarding confidentiality and conflict of interest.
3. CONTROL OF THE USE OF THE CERTIFIER'S MARK OR SYMBOL
4. CONTROL OF THE USDA SHIELD BY THE CERTIFYING AGENCY
5. COST OF CERTIFICATION
NOTE: An additional section concerning above sections 3, 4,and
5 will be developed by the Accreditation Committee for
subsequent inclusion into the Final Board Recommendations.
B. Transparency: Record-keeping
The basis of transparency is documentation, maintenance of
records, publication of basic certification information and
appropriate access to information by the public, and to records
by the Secretary, and the certified party as specified below:
1. PRODUCER/HANDLER RECORDS 432
Record-keeping required of producers and handlers that must be
available to the Secretary, certification agent, and State
official:
Information which must be outlined and documented, as
appropriate, by the producer or handler and reviewed by the
certifier, includes:
(1) All substances applied to the growing and stored
crop, growing medium, growing area, storage area, irrigation or
post-harvest wash, or seed, while owned by the producer or
handler, with dates, rates, and method of application, and name
of applicator. [OFPA Sec. 2112 (d)]
(2) All substances administered and fed to animals, all
medication and drugs, with dates and dosages; and all substances
applied in any area where animals, milk or animal products are
kept, with dates, rates, and method of application, and name of
applicator, while animals are owned by this certified producer or
handler.
(3) All substances applied to food, or applied in any
area or container where food is handled while under the ownership
of the certified entity who handles the food, with dates, rates,
and method of application, and name of applicator. [OFPA Sec.
2112 (d)]
(4) All substances used in the handling of food or
applied in any area or container where food is handled or stored,
while under the ownership of the certified entity who handles the
food, with dates, rates, and method of application, and name of
applicator. [OFPA Sec 2112 (d)]
(5) Proof of certification of all products handled and
all organic ingredients used for each product labelled as organic
or "with organic ingredients." (refer to NOSB PHL Committee
Labeling Draft.)
Click to View NOSB PHL Labeling Draft
(6) Sufficient records of all inputs, products handled,
and date, source, lot number, and quantity; and all sales
(whether bulk, raw or processed) with date, source lot number,
quantity and recipient/transferee, to enable an auditing or
inspecting certifier or investigator to reconstruct a "chain of
custody" for all transactions during the period of time in which
the certified entity holds title to the product, whether or not
the product is physically in the possession of the certificant.
On at least an annual basis, certifying agencies or their
inspectors must conduct at least one random product commodity
tracking that demonstrates the steps of production or
manufacturing prior to the shipment of that product from the
premises of that farm or manufacturer.
2. CERTIFIER RECORDS
a. Records required to be kept by certifier, to be submitted to
USDA/AMS as part of the Accreditation Application and upon
request available to the public [FOIA]:
Because verification of information about practices is
crucial to consumer confidence in the organic label,
accountability of certifiers is essential. The basic premise that
"organic" means "basic information about this food is
obtainable," extends logically to verification of the organic
claim. Thus, "certified organic" must mean "basic information
about this certification claim is obtainable."
For this reason USDA will maintain updated records of each
Accredited Certifier's policies and procedures, and will compile
a list on quarterly basis of all Accredited Certifiers and
certified parties, which can be made available to the public by
request. The availability of the list should be published in the
Federal Register and food trade periodicals.
(1) Organization address, phone #, hours
(2) List of certified parties
(a) Producers, handlers, processors
(i) Past and present
(ii) Current status of each
(3) Decision documentation procedures
(4) Decision making structure
(5) Decision maker identities and affiliations
(6) Certification review process
(a) Certification standards and procedures
(b) Review body identities and affiliations
(7) Inspector selection criteria covering both the
competence of inspectors and their assignment.
(8) Organizational Structure (Articles of Incorporation,
By-laws, and organizational chart.)
(9) Organizational affiliations
(a) Major funding sources
(b) Major shareholders
(10) Established standard procedures for document
request response
(a) Fees for information requested
(expenses, i.e., fax, photocopy, staff time)
(b) Reasonable turnaround time for "standard" requests
for information.
(11) Established standard procedures for sampling and
laboratory analyses that pertain to certification.[Sec.
2107 (a) (9)] 520
b. Public Access to Production and Handling Information
One basis premise of transparency is that basic information
about organic food and how it was produced and processed is
available to the public. That is, accountability in terms of
records and public scrutiny is implicit in the use of the term
"organic." At the same time, confidential business information
of producers and handlers must be protected, while consumer
access to information for health related issues must be ensured.
All purchasing and sales records, relating to ingredients,
substances applied, or recipes and other proprietary production
information are considered to be confidential business-related
information, which must be available to the certifier, but also
must be protected from public disclosure under confidentiality
provisions of OFPA. [Sec 2116 (g)]
Any other information contained in records which is not
required to be disclosed, including financial and business
related information, shall be removed before disclosure.
[Sec.2116 (g)]. 538
NOTE: An additional section concerning public access will be
developed by the Accreditation Committee for subsequent inclusion
into the Final Board Recommendations.
c. Records required to be kept by certifier and available upon
request to the Secretary or his representative:
The critical determinants of transparency are clear
articulation of the policies and procedures governing
certification decision-making, as well as open accessibility and
clear documentation of the evidentiary basis upon which a
particular certification decision is based. Transparency is
achieved by having and following clear written standards,
procedures and policies; good record-keeping; explaining the
roles and responsibilities of officers, staff, inspectors and
decision-making bodies; responsiveness to legitimate inquiries
and complaints; maintaining an open, accessible, and responsive
appeals process; and, by full disclosure and timely resolution of
potential conflicts of interest.
Disclosure of the fiscal foundation for a certifying agent's
activities is also essential to achieve transparency. Certifying
agents should, on an ongoing basis in an annual report or other
accessible means, document all sources of funds and revenue, the
level and purpose of all expenditures, and the relationship
between fee structure, income, other sources of revenue,
expenditures, and services rendered.
Verification of certification claims through ongoing
independent review is the basis of National Accreditation.
Certifiers work must be replicable, documented, and accessible to
review, following consistently administered policies and
procedures. Field evaluators, under confidentiality agreements,
designated by the Secretary, shall have access [Sec. 2116 (c)(2)]
upon request to any and all records concerning the certifying
agent's activities under this chapter, including:
(1) Certificant files, including application, organic
plan, inspection forms and questionnaires, decision
documentation.
(2)Personnel and policy manuals, organizational chart.
(3) Full documentation of all appeals, complaints, and
trademark or seal violations.
(4) Fiscal accounting: breakdowns of income and expenditures.
(5) Inspector, staff and decision maker contracts,
including confidentiality agreements and disclosure of
affiliations relative to potential conflict of interest. [Sec.
2116 (c)(2);(d); Sec. 2107 (a) (9)]
(6) Laboratory analyses, which must be reported to
Secretary if shows any violative residue. 586
(7) Business records relating to conflict of interest 587
provisions of the National Standards.
d. Records required to be routinely available upon request to
certificant at reasonable cost for processing of request:
(1) Inspector contract, as above.
(2) Inspection report.
(3) Names and affiliations of all decision makers.
(4) Results of laboratory analyses.
3. Maintenance, access and transference of records as
required under OFPA:
a. Producers and handlers are required to keep records of all
substances as required above, for five years.
[Sec. 2112 (d)] 600
b. Certifiers are required to keep records as above for ten
years. [Sec. 2116 (c)(1)]
c. Any certifying agent shall allow access by the Secretary or
his representative, or the governing State official, to any and
all records concerning the certifying agents activities under
this title. [Sec. 2116 (c) (2)]
d. If any certifying agent is dissolved, suspended or loses
Accreditation, all certification records or copies of records
concerning certifier activities Accredited under this title shall
be transferred to the Secretary immediately upon request, and
made available to the governing State official. Confidentiality
of records must be maintained by certifiers even following a
dissolution, suspension, or de-accreditation of the certifier.
[Sec.2116 (c) (3)]
C. Independence: (freedom from conflict of interest)
Definition: The term "conflict of interest" is defined as
the use by an individual of his or her position for personal
advantage or to the detriment of the integrity of the Organic
Program. Personal advantage includes interest in another
organization by the individual or a member of his or her
immediate family (household), or receipt or acceptance of
economic or non-economic favors, gifts or benefits of more than
nominal value accruing to the individual or his or her designee,
other than as part of his or her bona fide compensation."
Owners, officers, staff, committee members, board members,
employees and contractors of Certifying Agents who have a
financial interest in a farm or handling operation certified by
the Certifying Agent, or who otherwise stand to gain financially
from a certification decision, except for receipt of agreed upon
fees for service or for use of a trademark or seal, must be
isolated from those certification decisions in which they have an
interest. Certifying Agents act as agents of the Secretary under
the Organic Program, so an individual employed by a Certifying
Agent represents the Secretary in certification activities.
Recommendation: The Committee recommends to the Secretary
that a Certifying Agent must have written policies and procedures
regarding:
1. the application handling process;
2. disclosure of inspector financial interests and
affiliations;
3. the appeal of inspection results;
4. the certification decision making process;
5. disclosure of financial interests and affiliations 643
of members of the decision making body, including 644
conditions of disqualification from decision making;and
6. the appeal of certification decisions 647
Furthermore, the Committee recommends that the Accreditation
Authority itself must have a responsive and accessible complaint,
appeal and investigation process.
Part III: Procedures for Accreditation (and Outcomes)
The Accreditation Process has three phases:
A. Application;
B. Field Audit and Evaluation; and
C. Peer Review and Recommendation to Secretary.
A. APPLICATION (Phase I)
1. Submission of Application 657
To be eligible for review within the first round of
accreditation, certifying organizations must submit applications
for accreditation within 90 days of the publication of this
notice. Certification organizations who submit an application
for accreditation within this time frame will be evaluated in the
first round of Accreditation and may continue to provide
certification services.
Certifying agents will be asked in the application form to
request accreditation in specific program categories:
i. Organic Production: crops, livestock and related on-farm 667
processing.
ii. Organic Food Processing and Handling.
iii. International Trade. (Certifiers who certify operations
outside the USA who wish approval from the Secretary for
import equivalency to US standards.)
To initiate the accreditation process, a certifying agent
shall submit to the Secretary of Agriculture or his designee, an
application, along with all required memoranda, documentation,
and the applicable fee. Appendix B contains the Application
Form, Memorandum of Agreement, and a description of required
documentation.
The completed application form and accompanying documentation should
be sent to:
National Organic Standards Program
USDA/AMS/TMD
P.O. Box 96456
Washington, D.C. 20090-6456
Phone inquiries regarding the status of applications should be
directed to: Michael Hankin (202) 205-7806.
In the first round, applications will be reviewed in the
order in which they are received. Existing certifying
organizations shall be given priority in the processing of
applications and field evaluation. Organizations which have not
been certifying prior to the beginning date of the application
period should not begin doing so until they have completed Phase
I of the Accreditation Process.
Until completion of the first round of accreditation reviews
in response to all properly completed applications received from
currently active certifying organizations, certifying
organizations may continue certification activities, or initiate
new categories of certification services.
2. Review of Application:
The AMS/NOP Staff shall review applications for completeness
and any obvious deficiencies or problems in a certifying agent's
policies, programs, procedures, fiscal arrangements, or in regard
to conflict of interest. If AMS/NOP staff makes a preliminary
determination that the certifier's application indicates that the
certifier meets the statutory requirements and the basic criteria
of independence, transparency and competence as outlined in this
regulation, they shall recommend to the Peer Review Panel that
the "Accreditation Applied For" status be granted.
If AMS/NOP staff determines that the certifier's application
does not meet the requirements of the OFPA, or if there is a need
for further information or clarification of policies and
procedures, the applicant will be notified accordingly.
Notification:
Within 60 days of receipt of an application, the AMS Staff
shall respond to the applicant regarding whether the application
has been found to be complete or deficient. Notification shall
explain any deficiencies in the application and its supporting
documentation, and explain options for overcoming deficiencies.
New organizations wishing to begin certifying, and those who have
been notified of an unsatisfactorily completed application, and
have not responded within 60 days of notice, may not provide
certification services, and must reapply for Accreditation.
Within 60 days of receipt of any additional information
submitted to complete an application deemed incomplete, the
Accreditation Staff shall inform the applicant of any remaining
deficiencies, or acceptance of the application as complete. If
the applicant does not respond within 60 days to notice of an
incomplete application, they will have to wait for the next
annual cycle of application and shall not be allowed to continue
or begin certification activities. If the response still does not
fulfill the requirements of the application, resubmission may
continue, but Phase I must be complete within 12 months of the
opening date for applications in that annual cycle, or further
certification activity will be prohibited.
Close and thorough review of fully completed applications is
intended to optimize certifier's successful field evaluation, to
focus field evaluation on most salient areas of certifiers'
operations, and to increase efficiency and effectiveness of time
spent in field evaluation visits. To this end, the Committee
recommends that AMS utilize the existing expertise in Organic
Certification Program Evaluation to provide in-service training
to AMS/NOP staff who will be reviewing applications.
To facilitate commerce during the first annual cycle of
Accreditation, The National Organic Production Program will
publish a list of certifiers who have satisfactorily applied for
Accreditation, and are in the "pipeline" for field evaluation and
peer review. This list will be published six months following the
opening of the application process, and subsequently every six
months.
Following the determination of "Application Accepted"
status, the Peer Review Panel must be consulted on recommended
assignment of the field evaluators and priority scheduling of
visits. Upon completion of Phase I, and in preparation for the
review process carried out in Phase II, AMS/NOP Staff shall
provide applicants an explanation of the basic steps in the
process and an estimated time-line for completion of various
stages in the review and decision-making process.
At this point, for the first round of Accreditation
application, AMS shall publish a list of all certifiers who have
their applications complete and who are ready for field
evaluation.
B. FIELD EVALUATION AND AUDIT OF AGENCY RECORDS (PHASE II)
1. Nature and Purpose of Field Evaluation
The purpose of the field evaluation-audit phase of
Accreditation is to verify that each certifying organization is
in fact functioning in a manner consistent with the requirements
of the OFPA, the Accreditation Program and the policies and
procedures outlined in their applications. Basic functions such
as record keeping, assignment and activities of inspectors, and
the content and uses of the organic plan and audit control will
be checked to assure that certification decisions rest upon an
acceptable technical foundation. Policies on decision making,
conflict of interest protection and confidentiality will be
reviewed in the context of actual cases, to determine that they
are effectively being followed.
2. Design/ Assignment/ Approval of Evaluation Team
The overall design of the field evaluation will follow the
procedures outlined below. Some emphasis on certain program or
policy areas may be indicated by the review of the Application,
and these will be considered in the assignment and balance of
particular evaluator expertise. Questions of procedure or
application of policies that remain from the Application review
shall be indicated to the assigned evaluators. The size and
composition of evaluation review teams will vary depending on the
scale and scope of a certifying organization's activities. The
proposed composition of Evaluation Teams shall be submitted
routinely for comment to the Peer Review Panel, as well as to the
certifying agent to be visited. AMS shall take into account the
suggestions of the Peer Review Panel, and any concerns raised by
certifying agents regarding the ability of an individual review
team member to carry out an impartial review. The USDA should
seek in its selection to create the most qualified, appropriate
and unbiased team possible. Final responsibility for approving
Evaluation Teams shall rest with AMS, with a process for appeal.
All certifiers have the right to impose confidentiality
conditions on any member of the site visit team, except insofar
as OFPA requires USDA access to records.
An international organic standards organization that is
recognized by the Secretary for purposes of accreditation of
certifying agents may perform on-site evaluations in the United
States. Any on-site evaluation performed by such entity may, at
the discretion of the Secretary, constitute compliance with the
on-site evaluation requirement appearing in the Secretary's
domestic accreditation program provided that: (1) All written
reports or documents produced or resulting from the on-site
evaluation by such organization shall be provided to the
Secretary; and (2) Such documents and reports become part of the
permanent record of the certifying agent held by the Secretary.
The site visit will routinely be scheduled at the
certification agent's headquarters, and possibly at certain other
field locations. In cases where a certifying organization
carries out its activities through multiple chapters in several
locations, AMS/NOP, in consultation with the Peer Review Panel,
shall decide how many additional field locations, if any, will be
visited and evaluated in order to gain an accurate appraisal of
the certifying agent's programs and policies followed across all
locations or chapters. The key factor governing whether
locations in addition to headquarters will need to be visited,
and possibly accredited separately, is the locus of final
decision making, permanent record storage, oversight and audit
control. If chapters are completely autonomous in making and
reviewing the final certification decisions, and are issuing
certifications, they should require separate field visits.
3. Content of Site Visit
a. Formal meeting to introduce evaluators and
staff, and to review procedures to be followed.
b. Random sample of certification files pulled for
review, with case-file review form to be completed.
c. Review of written policies and procedures, with
questions for staff relative to actual implementation of these.
Do staff functions appear to be well defined, understood, and
carried out effectively?
d. Review of decision making process, composition of
review panels.
e. Review of complaints and appeals cases, at
discretion of evaluation team.
f. Review of residue testing procedures and
findings.
g. Review of certifier's production audit systems,
if applicable. If certifier does not maintain a transaction-audit
system of certified product, what methods do they use to insure
that such systems are practiced effectively by their
certificants?
h. Review of inspector qualifications and assignments.
i. Optional field visits of certificants: (NOSB
shall develop further recommendations).
j. Interviews by phone of parties relevant to
certification decisions when warranted.
k. Completion of Evaluation Scoring Form,
including all areas listed above, as well as compliance with OFPA
re: conflict of interest, confidentiality, use of seal,
reasonable fees, appeals and complaints and
investigation/enforcement.
l. Exit Interview: A summary of the Team's finding shall be presented
verbally to the Certification Director at the conclusion of the Team's
visit.
4. Access to Records
In carrying out field evaluations, individuals acting on
behalf of the Accreditation Program shall be granted the full
rights of access to information accorded the Secretary in the
statute. Evaluators who are contracted by the USDA for this
purpose shall sign non-disclosure agreements assuring protection
of confidential information.
Inability or unwillingness to provide requested documentation,
records, statements of policy, resumes of staff or
members of governing bodies, or financial disclosure forms shall
be grounds for denial or suspension of accreditation.
The certifying agent shall be prepared, upon request, to
provide copies of selected documents and records to Evaluation
Team members, although most basic documents shall already have
been provided as part of the application. Such requests may
include basic procedures and policy manuals, a limited number of
case file records, resumes of personnel, and fiscal records, and
any other supporting material which may aid in the evaluation.
5. Evaluation Report
The Evaluation Team's field visit(s) shall be summarized in
a written report completed, under all but exceptional
circumstances, within 30 calendar days of the visit. An outline
of the Team's findings shall have been presented verbally at the
conclusion of the Site Visit (Exit Interview, step l. above.)
The report must be signed by all members of the review team, any
of which are free to add personal observations or additions to
the report, which may include objections or differing views
relative to certain conclusions or sections of the report. A
copy of the field evaluation report, as submitted to AMS, shall
be provided to the certifying agent, who shall have 14 days to
clarify or correct factual matters addressed in the report, or
provide further clarification or documentation of program
elements identified in the report as a possible basis for a
decision to deny accreditation.
6. Role of Peer Evaluators
A peer evaluator will be selected from each certification
group being accredited that wishes to exchange volunteer time for
this purpose with other certification groups. Selection must be
based on the qualifications outlined in Sec. A2. (below) and who
is most familiar with the day to day operations of certification,
and qualified to assist in the assessment of other certification
program's management. These individuals will comprise an
evaluator pool from which the selection of members for each
review team can be made to create a balance of expertise and
experience which reflects the size and type of program being
evaluated. In the case of very small programs it may be
determined that only one evaluator is required for the field
visit. In composing each review team from the pool of qualified
peer evaluators, AMS shall strive to create a balance of
expertise in keeping with the size and complexity of the
certifying operation. State certification programs shall have
their evaluations include a peer-certifier from another state
program, as private certifiers shall have their evaluation team
include another private certifier. All those in the pool will be
required to attend a Training and Orientation session before
doing any site visits. Evaluators may be compensated for travel
and per diem expenses to attend a training session.
7. Qualifications of Evaluators
Evaluators, both USDA personnel and peer evaluators,
assigned to do field audits of Certification Organizations
seeking Accreditation under the O.F.P.A. should:
1) Have complete familiarity with policies and procedures of
Organic Certification program management: application, inspection
and decision making, and required record-keeping. Shall have
received orientation in risk assessment in relation to
certification program management.
2) Have: a) demonstrable expertise in agricultural cropping
and livestock systems predominately certified by the certifier to
which they are assigned, or
b) demonstrable expertise in food technology and
inspection, or
c) have demonstrable experience in quality systems
management, audit-inspection, or pesticide-food safety
enforcement.
3) Be familiar with all requirements of the O.F.P.A., and
ensuing U.S.D.A. regulations.
4) Have demonstrated both written and oral communication skills.
5) Submit three letters of recommendation verifying
expertise and relevant experience.
6) Submit notarized affidavits ensuring compliance with all
Federal requirements regarding confidentiality and conflict of
interest, for each assigned evaluation.
Preference will be given to those with past experience as
certification inspectors.
C. PEER REVIEW AND RECOMMENDED OUTCOME (PHASE III)
1. Background commentary
Under the Organic Foods Production Act of 1990, any person
or State government can apply to be an agent of the Department of
Agriculture for the purpose of certifying a farm or handling
operation in accordance with the Act. Only food products
produced on a USDA certified farm and handled by a USDA certified
organic handling operation can sell or label their food products
"organically produced" or "organic." Organic handling operations
are defined as operations that receive or otherwise acquire
organic agricultural products, and process, package, or store
such products. Under the USDA's National Organic Production
Program, consumers of food labeled "organic" are guaranteed by
the USDA they are purchasing food products raised and handled
according to the standards set forth in the Act.
Because the USDA Accredited Organic Certifying Agents are
the critical element in legitimizing the organic label claim, to
be an accredited certifying agent, an application must be made to
the USDA, and verified through on-site field evaluation. both
the application and the field assessment then go to a Peer Review
Panel appointed to assist the secretary in evaluating the
performance of certifiers.
The specification of a Peer Review Panel in the Act, the
history of the US organic movement, and the use of quality
management systems models (which certification programs resemble
and which are required for international trade) argue for a
community or stakeholder role in assuring consumers that organic
farmers and handlers are meeting the quality standards indicated
by the "organic" label.
2. Functions, Responsibilities, and Operation of the
Stakeholder-Peer Review Panel may include:
a). advise (oversight) of screening of applications,
b). recommendations for site evaluators and evaluations,
c). reviews the Field Evaluation Report, Application Screening
Report, and other documentation. (Might include complaint or
appeals information, other evaluation reports, references.)
d). completes Scoring Document
e). recommends to Secretary as to approval (with time frame for
re-evaluation, renewal shorter or longer) or denial,
f). oversee fairness of process,
g). make recommendations to NOSB and USDA on how to improve or
adjust the program.
This panel will conduct routine operational/ administrative
activities by conference calls and by mail. In person meetings to
make recommendations will be scheduled to coincide with
accreditation cycles. The locations of these meetings will be
determined by the panel. Panel members, exclusive of the USDA
member, shall serve without compensation. Travel costs will be
reimbursed.
3. Qualifications, Composition and Size of the Peer Review Panel
The Secretary shall establish a Peer Review Panel that
provides impartiality and representation of all sectors of the
organic community. Individuals to be considered must have a
history of participation and experience in a certification
program/process. Key qualifying components of this experience
include serving on a certification committee, advisor to a
certification board or program, or as a certification inspector,
as well as having expertise in organic farming and handling.
The nine Peer Review Panel members should represent five
key sectors of the organic community, as follows:
1. certified organic farmer - 3
2. certified organic handler/processor - 2 total (1 each)
3. organic certification agents - 2 total (1 each from a
state and a private agent)
4. a consumer/public interest group representative - 2
5. USDA representative - 1
6. NOSB representative (ex-officio) - 1.
Each of the four geographical regions (as defined under the
USDA-Sustainable Agriculture Research and Education program)
should have at least two voting members on the Panel.
All Peer Review Panel member must have required experience
and should be trained on all aspects of the USA/NOPP Organic
Accreditation Program.
Conclusion: A Peer Review Panel with member representation
from the entire organic community, working in conjunction with
the Secretary of Agriculture embodies a democratic quality
management system consistent with certification review practices
used historically in the United States. It will further the
ongoing involvement of grassroots organizations and consumers in
a productive, efficient and effective partnership with USDA.
Such a quality system for organic certifying agent
accreditation offers consumers, regulators, and trading partners
the assurance that "organic" food will consistently meet US
national "organic" standards.
Note: In keeping with international guidelines for standard
setting organizations, no individual acting as a Peer Evaluator
or member of an Accreditation Field Evaluation Team shall also
participate on the Review Panel. Members of the Review Panel may
be asked to assist in the Application Screening/Review process,
prior to Field Evaluation. Essentially, evaluation must be an
independent and discrete function.
PART IV. OTHER PROCEDURES
A. Determination of Indemnification process and costs
"Indemnification" means that the private certifiers must
extend their General Liability Insurance to add a clause naming
the Secretary of the U.S.D.A. as an "additional insured." Typical
cost for this estimated at 2-5% of premium cost. (Indemnification
is not a "surety bond" procedure.)
B. Administrative Appeals and Complaints Process
A fair and effective appeals system is essential to the
success and integrity of the "National Organic Production
Program" and to the accreditation process. Independence and
objectivity being of prime importance, the NOSB makes the
following recommendations to the Secretary:
1. Any person adversely affected by a National Organic Production
Program action or decision must be given the opportunity to
appeal that determination. The Secretary must, in all cases, have
final decision making authority in the administrative review
process.
2. In the interest of fairness, the National Organic
Accreditation Program appeals must be conducted by independent
hearing officers who are not responsible for the implementation
and administration of the National Organic Production Program.
Because AMS is responsible for this program, the use of hearing
officers who or employed or under the authority or control of
AMS, presents a problem of conflict of interest. To protect the
integrity of the appeals process, and to ensure fairness of these
determinations, this board recommends that an independent USDA
Appeals Division be utilized or established to conduct the
appeals review process, and to make final appeals decisions. This
board further recommends that the National Organic Production
Program appeals be administered by the National Appeals Division
that is being proposed in the current USDA reorganization plan as
called for in HR 3171, Sec.4. This recommendation is not meant to
imply the establishment of a separate USDA Appeals Division
solely for organics, but to strongly recommend the necessity for
an independent review process and for organics to be included in
the new USDA independent appeal division.
3. To ensure an "expedited" appeals process [OFPA, Sec 6520 (a)]
and because food products are seasonal and some are highly
perishable, organic farmers, handlers, processors and certifiers
must be given the opportunity to correct any adverse decision by
the National Organic Accreditation Program so that they can carry
out their business activities and avoid undue economic losses due
to the inability to market their products.
4. It is essential that all persons adversely affected by the
National Organic Accreditation Program be notified, in a timely
manner, that they have appeal rights. Therefore, the NOSB
recommends mandatory procedures be established that shall require
all National Organic Accreditation Program decisions to be made
in writing, including written explanation of the basis for the
decision and a timely written notice of appeal rights and procedures.
5. To ensure that this appeals system is end-user friendly and
that knowledge of appeals rights are readily available and simple
to understand, the NOSB recommends that at the accreditation and
certification application stages that appeals informational
brochures be mandatorily provided to such persons. This
informational brochure must include in easy to understand
language the following: Their appeals rights, procedures, time
lines for due process and all key phone numbers, personnel and
addresses necessary to "expedite" these rights, if and when
necessary.
6. Furthermore it is the intent of the NOSB to be systematically
apprised of the appeals process functioning, on a quarterly
basis. This information should include: number of appeals, and
outcome, kinds of appeals, and any problems arising from this
process that may need new or revised recommendations to USDA for
ensuring this independent and expedited appeals process.
C. Costs of Accreditation
Recognizing that there will be substantial start-up costs to
implement the USDA Accreditation Program; that revenues from
certification fees will be substantially higher after handlers
not now certified have applied; and that costs of the first year
of accreditation will exceed successive years; and, because the
OFPA is a consumer protection law and is intended as well to
support and encourage environmentally sound agricultural
practices and because additional costs to organic producers will
be perceived as disincentives; the Board sees the use of
appropriated funds as justified, and therefore recommends that
the first round of accreditation be paid for through a direct
appropriation of federal funds. Furthermore, the Board
recommends that (1) fees charged to certifiers not exceed the
ongoing costs of administering Accreditation after the first
round and that fees collected be used exclusively for that
purpose; and (2) the ongoing program administration costs above
the cost of Accreditation be paid for through direct appropriated
funds.
D. Suspension or termination of accreditation
NOTE: An additional section concerning this subject will be
developed by the Accreditation Committee for subsequent inclusion
into the Final Board Recommendations.
Part V. APPENDICES
Contents:
A. Glossary
B. Application
Part 1. Basic Information
Part 2. Memorandum of Agreement
Part 3. Questionnaire: Policies and Procedures
Part 4. Required Documents
C. Other forms
Application screening report
Notification
Field evaluation report
Peer review board scoring document and memo
Indemnification of Secretary (Bond)
APPENDIX A
GLOSSARY (to be developed)
APPENDIX B
APPLICATION FOR ACCREDITATION
Submitted to:
The United States Department of Agriculture
for the USDA Organic Certification Accreditation Program
Please fill out all sections and answer all questions.
Before answering questions in this application, please study
carefully the content of the Federal Register Notice: " Standards
and Procedures Governing Accreditation of Organic Certification
Organizations."
This application contains four sections:
1. Basic Information
2. Memorandum of Agreement (Statement of Intent)
3. Questionnaire (Program policies and Procedures)
4. Checklist of Required Documentation
Please send the completed application and all accompanying
materials to:
National Organic Standards Program
USDA/AMS/TMD
Room 2510 - S
P.O. Box 96456
Washington, D.C. 20090-6456
Phone inquiries regarding the status of applications should be
30 acrdtbfr.894
directed to: Michael Hankin (202) 205-7806.
Application for Accreditation
Part 1. Basic Information
1. Name of Organization; contact person for inquiries regarding
this application; phone/fax numbers; headquarters address
2. Organization Type: state or private.
2.A. Describe your legal status. Do you have chapters/field
offices -- what do they do, what policies and procedures do they
follow, and how do services offered differ across chapters/offices
and headquarters?
2.B. Please describe the relationship of your governing body
to the body which makes certification decisions.
3. How long have you offered organic certification services?
Please describe briefly the history of your organization or
program.
4. Please list the name, title, address, and phone/fax of your
organizations chief staff officer, chairperson or head of your
board or governing body, and the individual responsible for
fiscal management.
(Attachment)
5. PLEASE CHECK THE CATEGORIES OF CERTIFICATION FOR WHICH YOU ARE
APPLYING FOR ACCREDITATION, and list the current number of
certificate holders and/or licensees and estimated annual sales of
certified product:
Number Volume
of certificants
_____Crops and/or livestock
_____Processing and handling
_____Foreign certifications
of certificants who import to US
6. If conducting certifications of the production and/or handling
of organic products imported into the United States, please
complete the following sections (a.-e.) below:
a. List the foreign countries within which you presently conduct
certification services, and indicate those from which products are
imported into the U.S.
b. List those countries other than the United States to which
products bearing the seal of your agency are exported.
c. Explain cases where the application of agency policies,
procedures, and standards differ from those applied within the
United States.
d. Describe the measures controlling the issuance of certificates
to producers and/or handlers in foreign countries that ate
implemented by your agency. Please cite how these measures differ
from those employed to ensure the integrity of products produced
and/or handled within the U.S.
e. List the records pertaining to the certification of producers
and/or handlers located in foreign countries that are accessible
and on file at the U.S. agency office.
7. Geographic area(s) of current certification activity (states
and other countries.)
8. Areas of certification competence (specific types of producers
and or handlers for which you have specific standards and inspector
expertise.)
Part 2. MEMORANDUM OF AGREEMENT
NAME OF CERTIFYING AGENT ___________________________________
The following signatories, being duly authorized to represent
the above referenced organic certification agency, hereby confirm,
according to the best of their knowledge, full and ongoing
compliance with requirements of the Organic Food Production Act,
1990, National Organic Production Standards, and Standards and
Procedures Governing the Accreditation of Organic Certification and
the accuracy of information provided in this Accreditation
Application. Further, said signatories hereby assume full
responsibility for submitting or providing access to the
Secretary, or his designee, to supporting documentation as may be
required. [ 2116(d), (e) & (i): "Agreement;" "Private certifying
agent agreement;" &"Administrator"]
Further it is agreed that the private entity signatories shall
hold the Secretary harmless for any failure on the part of said
agent to carry out the provisions of the OFPA 1990.
Signed:
Date:
(Name, title)
Notary Public
Name:
Number:
Date:
Place:
Part 3. QUESTIONNAIRE
Description of Program Policies and Procedures
Please answer all questions in the space provided, summarizing
information, policies, and procedures described in more detail in 4
your attachments.
VERY IMPORTANT -- After your summary response to each question,
please provide clear and explicit directions regarding where the full
explanation/documentation is located in the various attachments.
ORGANIC PRODUCTION STANDARDS
The purpose of this section is to provide information needed
to evaluate the basic equivalency of your procedures with the OFPA
provisions governing the content and use of organic plans.
l. Do you require a three-year history of management without
prohibited substances for all farms certified? yes__ no__
2. Do you have provisions and policies to insure that organic
integrity is maintained in "mixed" (organic/conventional)
operations? yes__ no__
3. Do you require annual on-site inspection? yes__ no__
4. Do you have a published list of approved/prohibited inputs?
yes__ no__
5. Do you have standards for:
organic farm and handling plans yes__ no__
soil fertility management yes__ no__
manure management yes__ no__
seeds and transplants yes__ no__
wild crops yes__ no__
livestock yes__ no__
6. Do you have standards for organic food processing and handling?
yes__ no__
7. Will your standards, fiscal policies or practices prohibit your
organization from recognizing certifications by other organizations
accredited under the OFPA? yes__ no__
POLICIES AND PROCEDURES
Seal or Trademark
1. Please describe your trademark or seal, and the policies
governing its use.
2. What are the financial consequences, if any, and policies
governing use of your seal or trademark? (By "consequences", we
mean any obligation to exchange funds, or incur a financial
obligation of any sort).
Staff
1. Describe your policy regarding inspector qualifications, train-
ing, and assignments. What do you ask inspectors to do? How are
they paid? Who selects and assigns them to specific cases?
2. Describe your policies to guard against conflict of interest
among inspectors, staff, officers, committee members and clients.
3. Does your organization perform consulting or advisory services?
Are these agricultural, marketing or legal services?
If so, do you have written procedures with respect to the
separation of certifying functions and consulting functions? How do
you insulate the certifying function?
By procedure ______
By organizational function______
Confidentiality and Access to Records
1. Describe the policies and procedures you have used, or will use
to assure confidentially of records on individual clients.
2. Describe how you handle requests for information on a client
from another certifying organization, from a member of the public,
from a prospective buyer.
Finances
Explain how your program is financed, with references to an
attachment which provides an accounting for your last fiscal year.
(i.e., audited annual report, financial statement, IRS report,
State govt audit)
Appeals and Complaints
1. Describe your appeals processes and policies.
Policy Changes
1. Describe the process you use, and who makes decisions relative
to changes in:
* Standards
* Program management
* Decision-making authority
* Job descriptions
* Fiscal matters
* Actions recognized by applicant as essential to attain
accreditation
Part 4. Additional Documentation Required
1. Criteria for certification (Standards) (What you send to a
potential client who seeks information on the services you offer.)*
2. Minimum information required from producers or processors
regarding growing or handling practices (Application/Organic Plan
Questionnaire) and methods for verifying that information.
3. Procedures for inspection, including frequency instructions
given to inspectors, and what Inspection Report must cover.*
4. Qualifications of and training requirements for all inspectors.*
5. List of key staff. officers, shareholders, committees, approved
inspectors and persons with decision making authority, for chapters
as well as main office.*
6. Program and personnel policy manual, including decision making
procedures.
7. Articles of incorporation or state law/charter.
8. Organizational chart.
9. Latest annual report or its equivalent.
10. Procedures for soil and tissue sampling and analysis.
11. List of currently certified clients.*
*Changes or updates in * items must be revised and reported
annually to USDA.
APPENDIX C
OTHER FORMS (to be designed)