2016 Peer Review Executive Summary USDA-AG6395S150169-2016-EXS-ANSI-REV00

Product Certification Accreditation

2016 Peer Review Executive Summary

United States Department of Agriculture 

Agricultural Marketing Service National

Organic Program

1400 Independence Avenue, NW 

Room 2646 South Building 

Washington DC 20250 USA

Dates of the Peer Review: 

May 16 – August 5, 2016

Prepared by

American National Standards Institute

1899 L Street, 11th Floor

Washington, DC 20036

CONFIDENTIAL

This report contains confidential information and shall not be reproduced and/or distributed without the written 

consent of the American National Standards Institute, unless it is in its entirety.

Document: Executive Summary

USDA-AG6395S150169-2016-EXS-ANSI-REV00
2016 Peer Review Executive Summary USDA-AG6395S150169-2016-EXS-ANSI-REV00

Contents

I. GENERAL INFORMATION ON THE PEER REVIEW...................... 2

II. INTRODUCTION .................................................................................. 3

III. PURPOSE OF THE PEER REVIEW ................................................. 3

IV. SUMMARY ......................................................................................... 4

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2016 Peer Review Executive Summary USDA-AG6395S150169-2016-EXS-ANSI-REV00

I. GENERAL INFORMATION ON THE PEER REVIEW

Accreditation Body

Name of the Accreditation Body United States Department of Agriculture

Agricultural Marketing Service (AMS), 

National Organic Program (NOP)

Address 1400 Independence Avenue SW

Room 2646-South Building

Washington DC 20250

Peer Review

Type of Process Remote Assessment Peer Review

Dates May 16 – August 5, 2016

Peer Review Standard(s) ISO/IEC 17011:2004 Conformity Assessment – General requirements 

for accreditation bodies accrediting conformity assessment bodies,

US 7 CFR Part 205, National Organic Program

Evaluation Team

Robert (Bob) Miller PE – ANSI/ANAB Lead Assessor, ISO/IEC 17011, 17020, 17025 and 

17065.

Jean Richardson Ph.D., Professor Emerita, University of Vermont, Environmental Law and 

Environmental Studies; Independent Organic Inspector; NOSB (2012-2017) - Chair 2014-

2015 and NOSB Certification and Accreditation Subcommittee 2012- 2017.

James Riddle, Organic Independents LLP; Founding President, International Organic 

Inspectors Association; ISO training; Former board member, International Organic 

Accreditation Service; and Former chair, National Organic Standards Board.

Susan Ranck, IOIA trained organic inspector, IFT Certified Food Scientist, ANSI technical 

assessor. 

Elizabeth Okutuga, Program Coordinator, ANSI staff, ISO/IEC 17011 process knowledge 

and project coordinator.

Reinaldo Balbino Figueiredo, Senior Program Director, ANSI staff, ISO/IEC 17011 

evaluator. Contract/Project Manager.

Document Review Report

Prepared by ANSI Assessment Team

Revised and Resubmitted: September 13, 2016
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2016 Peer Review Executive Summary USDA-AG6395S150169-2016-EXS-ANSI-REV00

II. INTRODUCTION

The National Organic Program (NOP) is part of the Agricultural Marketing Service (AMS), U.S. 

Department of Agriculture (USDA), and is the organization responsible for activities relating to the 

development, implementation, and administration in accordance with the Organic Foods Production 

Act of 1990 (OFPA) and the USDA organic regulations. Key functions of the NOP include:

• Developing, reviewing, implementing and interpreting the organic standards 

• Enforcing organic production, handling, and labeling standards

• Accrediting, auditing, and training third‐party organic certifying agents

Program and Scopes of Accreditation

The NOP established a peer review panel to satisfy internal requirements regarding adherence to 

internal and regulatory requirements. American National Standards Institute (ANSI) has convened 

this panel effective May 16, 2016 to fulfill the expectation of this requirement.

This Peer Review was conducted pursuant to 7 CFR 205.509, Peer Review Panel, of the USDA 

Organic Regulations. This Peer Review follows a procedure outlined in NOP 1031 (5/12/16), Peer 

Review of National Organic Program (NOP) and as modified by letter of Miles McEvoy dated 

5/19/2016.

The panel was tasked with the following

• evaluate the NOP’s polices processes and procedures for conformance to NOP regulations 

and ISO/IEC 17011,

• review implementation of certification body accreditation processes through selected file 

review of five files, and 

• reporting the peer review panel findings in writing to the NOP Deputy Administrator and the 

National Organic Standards Board. 

III. PURPOSE OF THE PEER REVIEW

Accreditation is the independent evaluation of conformity assessment bodies against recognized 

standards to ensure their impartiality and competence. Through the application of national and 

international standards, government, purchasers and consumers can have confidence in the 

certifications provided. Accreditation bodies are established in many countries with the primary 

purpose of ensuring that conformity assessment bodies are subject to oversight by an authoritative 

body.

Accreditation bodies are evaluated by peers in order to reduce trade barriers and demonstrate the 

competence of the accreditation body operations. Accreditation reduces risk for business and its 

customers by assuring that accredited Conformity Assessment Bodies (CABs) are competent to 

carry out the work they undertake within their scope of accreditation. The purpose of the peer 
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2016 Peer Review Executive Summary USDA-AG6395S150169-2016-EXS-ANSI-REV00

evaluation is to provide confidence in the operation of the accreditation process thus providing 

acceptance in the market place of the conformity assessment outcome.

IV. SUMMARY 

The report covers NOP’s compliance with ISO/IEC 17011 and review of NOP’s accreditation 

procedures and decisions, The Review Panel members find that NOP and its staff are in general 

compliance with ISO/IEC 17011 and NOP’s own policies and procedures. Opportunities for 

Improvement have been identified and are recorded in the individual reports and also in ANSI’s 

Conformity Assessment portal, ANSICA. The opportunities for improvement include:

• The accreditation body's procedures lack clarity to ensure that the auditors are reviewing 

the regulatory status of ingredients and processing aids.

• The NOP did not follow NOP 2000 for notification to certification body of a suspension.

• Consistent accreditation records are not being used and retained in order for the NOP to 

be in full compliance with 205.502.

• NOP 2005-4 Witness Audit Checklist is not complete. The NOP 2000 procedure does not 

provide the control needed to approve the document for adequacy prior to use.

• Some NOP regulations allow NOP to be involved with CAB functions such as suspension, 

revocation and appeal; these regulations do not comply with ISO/IEC 17011 clause 4.3.6 

A.

• The accreditation body does not ensure there is immediate notification to the NOP for 

potential changes by certified bodies that may affect compliance.

• The accreditation body is required to ensure a balanced representation of interested 

parties with no single party predominating. Balanced representation of interested parties is 

not described for Accreditation Committee, NOP 2012 clause 2 qualifications. 

• ISO/IEC 17011, Clause 5.3 requires all documents to be controlled. Not all documents are 

adequately controlled.

• NOP indicates it has procedures for identification, collection, indexing, accessing, filing, 

storage, maintenance and disposal of its records, but specific procedures are not 

identified.

• ISO/IEC Guide 65 has been superseded by ISO/IEC 17065; however, some documents 

and procedures still refer to Guide 65.