NCAT Agriculture Specialist
© NCAT 2005
The author (right) conducting a field inspection with Delfina Córcoles and her daughter.
Photo by Rex Dufour, NCAT.
This guide is to help organic producers and handlers understand, prepare for, and get the most from the process of organic certification to USDA National Organic Standards (see www.ams.usda.gov/nop). It discusses the purposes and benefits of the inspection for organic certification, provides a general description of the organic certification process, and outlines the role of the organic inspector. A companion ATTRA publication, Preparing for an Organic Inspection: Steps and Checklists, is written for those already familiar with the basic certification process, to help them prepare more systematically for an initial or annual inspection. It includes steps for preparing for the organic inspection and checklists of audit trail documents and required records for certification of organic crop and livestock production and handling facilities.
Organic certification provides third-party confirmation that a production or handling operation is in compliance with organic standards. Certification enables qualified producers and handlers to market agricultural products under a USDA certified organic seal. In its simplest terms, the organic seal assures the consumer of organic integrity. First, a product is grown in an organic production system that emphasizes plant and animal health, preventative management of pests, and judicious use of allowed materials. Then, the product is tracked and protected from contamination from the field to final sale, whether it is a raw agricultural commodity or a multi-ingredient processed product. The label may carry a claim of "100 percent organic," "Organic" (95% to 100%), or "Made with organic ingredients" (at least 70% organic ingredients).
As an organic inspector, I have heard from both farmers and food processors that an important benefit of organic certification is that it requires and inspires them to keep better records. Records help identify and solve problems more readily. A newly certified organic bakery described how the organic certification process immediately paid off in that business.
Dairy farmers describe how their record keeping helped them maintain healthier herds and good milk production, after their first year of organic certification.
-Ann Baier, organic inspector
The organic inspection doesn't need to be scary, stressful, or onerous. The inspection process can be useful to producers of crops or livestock, and processors or handlers of agricultural products. The organic inspection is a unique opportunity because it involves the most face-to-face contact between the producer or handler and an inspector who works for the certifier.
Organic certifiers conduct annual inspections of all their clients (certified parties) to verify, through on-site review of actual activities and the corresponding records, that the clients are in compliance with the relevant organic standards. Every USDA-accredited certification agency must make annual inspections. Most inspections are scheduled with the client in advance; however, some inspections are unannounced. This publication will help you incorporate management practices that will keep you prepared for an inspection at any moment. Benefits of the inspection process for organic certification include the following.
The steps that help you prepare for your inspection for organic certification will also help you maintain healthy farming systems and viable business practices.
The producer or handler chooses a certifier and requests an application packet. USDA accredited certification agencies (ACAs or certifiers) are listed on the NOP Web site (www.ams.usda.gov/nop/CertifyingAgents/Accredited.html). All USDA-accredited certifiers—whether private (non-profit or for-profit) or governmental—certify to the same USDA National Organic Standards. Some certifiers, however, are better recognized in the organic industry/marketplace, and some may offer certification to additional standards—such as International Foundation for Organic Agriculture (IFOAM), European Union (EU), Japanese Agricultural Standards (JAS), Conseil des appellations agroalimentaires du Québec (CAAQ), Biodynamic, GAP, Kosher, or Fair Trade—while other certification agencies may provide services such as newsletters, workshops, or educational opportunities. Consider your marketing needs—whether your approach to marketing requires verification of compliance to other standards—as well as your personal interests.
An Organic System Plan should include information about management practices such as animals' access to pasture and outdoors. The pastured layer hens at left belong to Paul and Leti Hain of Tres Pinos, California.
Photo by Ann Baier.
The producer or handler submits an application and an Organic System Plan (OSP) to the certification agency, using the certifier's forms and guidelines and attaching any requested documentation, licensing agreements, and fees. The OSP consists of written plans and relevant information concerning all aspects of your operation. Following are some examples of required information.
The certifier reviews the Organic System Plan (OSP) and accompanying documentation for completeness and assesses the applicant's capacity to operate an NOP-compliant operation. The certifier determines that the operation can meet the requirements for certification as outlined in the OSP. The certifier will then assign a qualified organic inspector to do an on-site inspection.
Organic inspectors assess the adequacy of procedures to prevent contamination.
Photo by Ann Baier.
Organic inspections come prior to initial certification, then annually thereafter. The inspection must occur when a person knowledgeable about the operation is present, and should occur where and when the crops, livestock, and/or processing or other handling can be observed. The Inspection Preparation Checklists in the ATTRA publication Preparing for an Organic Inspection: Steps and Checklists provide a detailed description of the documentation required for the three major types of operations: crops, livestock, and handling. In all three types of operations, the organic inspector conducts an on-site inspection and review of record keeping to verify that the OSP accurately reflects your operation and is in compliance with NOP standards. Records to be verified include input materials, production, harvest and sales records, as well as appropriate product packaging and labeling. The inspector assesses the risk of contamination from prohibited materials, and may take soil, tissue, or product samples as needed.
At the end of the inspection, the inspector conducts an exit interview with the inspected party to confirm the accuracy and completeness of the inspector's observations. The inspector will review any requests for additional information and any issues of potential non-compliance with respect to the National Organic Standards. The inspector provides the inspected party with a written copy of the exit interview before leaving the inspection. The inspector then provides a report to the certifier. The inspector reports his or her observations only and does not make the certification decision.
The certifier will review the report and determine whether the operation is eligible for organic certification. The final decision is then communicated in writing to the client seeking certification, along with any requirements for initial or continuing certification. The certifier may request further information or remediation, or issue a notice of noncompliance, if the operation is not in full compliance with all pertinent organic standards. Significant noncompliances may result in denial or revocation of certification and/or require correction prior to organic certification or renewal. Minor non-compliance issues are those that do not threaten the integrity of the organic products. (For example, procedures are properly carried out but inadequately documented.) The notice will cite the issues of concern and specify the time by which the operation must remedy the noncompliance and provide documentation of the remediation to the certifier.
A certificate of organic certification is issued if the operation is determined to be compliant under the NOP (and any other applicable) standards. Upon issuance of the organic certificate, the operation may begin selling its products as organic. Product labels must identify the certifier ("Certified organic by...") beneath the name and identifying information of the producer or handling company. Use of the USDA and/or the certifier's seal is optional. The certified party should review the details of labeling in NOP section 205.300-311, and ask the certifier to review any labels prior to printing. All certified operations must be inspected annually.
The "inspector" is not the same as the "certifier." It is important for the producer or handler to have clear expectations about the role of the inspector—what services he or she can and cannot provide. As noted in Step 4: Organic Inspection, the primary role of the inspector is to gather on-site information and provide an accurate report to the certifier. The inspector verifies a) whether observations of an operation's daily practices are consistent with the client's Organic System Plan (previously submitted to and approved by the certifier), b) whether the practices and inputs are in compliance with the USDA National Organic Standard, and c) whether those practices and inputs are adequately documented. The certifier then makes the certification decision based on information provided in the OSP, the inspection report, and associated documents.
The organic inspector can refer clients to sources of information about organic compliance.
Photo by Ann Baier.
The inspector can do the following:
The inspector cannot serve as your advisor or consultant. The inspector may not recommend specific products, practices, animal or plant varieties, or give advice for overcoming identified barriers to certification. The inspector must not hold a commercial interest in the business being inspected, provide paid consulting services, accept gifts, favors, or payments other than the prescribed inspection fee. Finally, the inspector does not make the certification decision. Any of the above constitutes a conflict of interest that is strictly prohibited by law, as described in NOP Section 205.501.
The certified entity can be assured that the inspector has signed both a conflict of interest and a confidentiality agreement with the certifier to protect all proprietary information of the inspected operation.
Even when you take into consideration the limitations of the inspector (as described above), the inspection can still be a useful opportunity to expand your knowledge of organic requirements, the processes necessary to meet those requirements, and associated information. As you prepare for your inspection, you might find it helpful to make notes of any questions you have, in particular about the certification process and where to go for assistance in answering further questions. To avoid potential conflicts of interest, please be aware of the limitations on the role of your inspector.
The National Organic Program (NOP)
Organic Materials Review Institute
International Federation of Organic Agriculture Movements
Biodynamic Farming and Gardening Association
International Organic Inspection Manual IFOAM and IOIA, December 2000.
Thanks to Brian Magaro and Lois Christie, organic inspectors who provided their pre-inspection letters as resources for developing this publication.
Appreciation to the following reviewers:
Organic Certification Process
By Ann Baier, NCAT Agriculture Specialist
Paul Williams, Editor
Cole Loeffler, HTML Production
This page was last updated on: August 28, 2014