United States Department of Agriculture 1400 Independence Avenue SW. NOP 2025

Agricultural Marketing Service Room 2648-South Building Effective Date: March 20, 2024

National Organic Program Washington, DC 20250 Page 1 of 2

NOP 2025 Internal Program Review Rev01 Authorized Distribution: Public

Instruction

Internal Program Review

1. Purpose and Scope

This instruction clarifies and standardizes procedures to be followed by certifying agents 

accredited by the U.S. Department of Agriculture (USDA) National Organic Program (NOP)

when conducting internal program reviews. This instruction is directed at certifying agents, who 

must satisfy additional USDA requirements as part of their accreditation. (See § 205.501(a)(21).)

2. Background

Section 205.501(a)(7) of the USDA organic regulations requires that certifying agents conduct

an annual program review of their certification activities. The internal program review, also 

referred to as an internal audit, evaluates a certifying agent’s certification system and procedures 

for the purposes of continuous improvement, by identifying issues prior to external audits as well 

as areas of strength and those needing improvement. This instruction establishes the minimum 

requirements for conducting internal program reviews.

3. Policy and Procedure

A certifying agent must conduct an annual program review of its certification activities. (See §

205.501(a)(7).) The results of the program review, as well as any adjustments made in response 

to the review, must be reported to the NOP annually. (See § 205.510(a)(4).)

3.1 Program Reviewer

The internal program review must be conducted by one or more of the following:

a. Certifying agent’s staff

b. Outside auditor

c. Consultant

Qualified program reviewers must have the expertise to conduct such reviews, including 

knowledge of certification, auditing, and the USDA organic regulations as directed by § 

205.501(a)(4). Internal program reviews are conducted by personnel different from those who 

performed the certification activity being audited.

3.2 Summary of Findings

The annual internal program review of all certification activities ensures adherence to the

regulations. The review must be conducted in a planned and systematic manner and the results 

must be documented in a report, which must:
United States Department of Agriculture 1400 Independence Avenue SW. NOP 2025

Agricultural Marketing Service Room 2648-South Building Effective Date: March 20, 2024

National Organic Program Washington, DC 20250 Page 2 of 2

NOP 2025 Internal Program Review Rev01 Authorized Distribution: Public

a. Identify the dates on which the review was conducted;

b. Identify any findings;

c. Identify how any proposed corrective actions will be addressed in a timely and 

appropriate manner; and

d. Assess prior findings and implemented corrective actions of prior program reviews.

Personnel responsible for certification activities must be informed of the findings. Certifying 

agents must annually report to the NOP the program review results and any adjustments made in 

response thereto. Certifying agents must also maintain records of the internal program review.

4. References

USDA Organic Regulations (7 CFR Part 205)

§ 205.501 General requirements for accreditation.

(a) A private or governmental entity accredited as a certifying agent under this subpart must:

...

(4) Continuously use a sufficient number of qualified and adequately trained personnel, 

including inspectors and certification review personnel, to comply with and implement 

the USDA organic standards.

...

(7) Have an annual program review of its certification activities conducted by the 

certifying agent’s staff, an outside auditor, or a consultant who has expertise to conduct 

such reviews and implement measures to correct any noncompliances with the Act and 

the regulations in this part that are identified in the evaluation;

§ 205.510 Annual report, recordkeeping, and renewal of accreditation.

(a) Annual report and fees. An accredited certifying agent must submit annually to the 

Administrator, on or before the anniversary date of the issuance of the notification of 

accreditation...

(4) The results of the most recent...annual program review and a description of 

adjustments to the certifying agent’s operation and procedures implemented or to be 

implemented in response to the...program review.

Original Issue Date: August 2, 2013