Product Certification Accreditation

2017 Peer Evaluation Panel

Executive Summary

For

United States Department of Agriculture

Agricultural Marketing Service

National Organic Program

1400 Independence Avenue, SW Room 2642 (Stop 0268)

Washington, DC 20250 USA

Dates of Review Panel:

April 20 – June 30, 2017

Prepared by:

American National Standards Institute

1899 L Street, 11th Floor

Washington, DC 20036

Document: Executive Summary

Document: Executive Summary USDA-AG-6395-S-16-0208-2017-ES-ANSI-REV6

CONFIDENTIAL
 

 

 

 

 

2017 Peer Review Panel 

Executive Summary 

National Organic Program 

CONTENTS 

I. GENERAL INFORMATION ..................................................................4 

II. INTRODUCTION .................................................................................5 

III. PURPOSE OF PEER REVIEW PANEL ....................................................5 

IV. EXECUTIVE SUMMARY.. ....................................................................6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2017 Peer Review Panel 

Executive Summary 

National Organic Program 

I. GENERAL INFORMATION 

Name of Reviewed Body United States Department of Agriculture 

Agricultural Marketing Service (AMS) 

National Organic Program 

Address 1400 Independence Avenue SW 

Room 2642 (Stop 0268) 

Washington, DC 20250 

Telephone 202-720-3252 

Type of Review Remote Peer Review Panel Evaluation 

Review Dates April 20 to June 30, 2017 

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 

Peer Review Panel 

Marlene Moore - Lead Evaluator, ISO/IEC 17011 PAC evaluator, past lead 

evaluator, NOP program, and ANSI/ANAB lead assessor for ISO/IEC 17065, 17025, 

17043 

Jean Richardson - Professor Emerita, University of Vermont, independent organic 

inspector, and Law Clerkship, Member NOSB (term expires: Jan 2017) 

Susan Ranck, IOIA-qualified organic inspector, Institute of Food Technologists 

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 

Report Prepared by: Marlene Moore 

Susan Ranck 

Jean Richardson 

Submitted to ANSI: August 9, 2017 (NOP review completed August 31) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2017 Peer Review Panel 

Executive Summary 

National Organic Program 

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; and 

• accrediting, auditing, and training third-party organic certifying agents. 

Program and Scope of Accreditation 

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

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

convened this panel, effective April 20, 2017, to fulfill the expectation of this requirement. The 

peer review panel is tasked to: 

• evaluate the NOP’s policies, processes, and procedures for conformance to NOP 

regulations and ISO/IEC 17011:2004; 

• review implementation of certification body accreditation processes through select file 

review; and 

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

National Organic Standards Board. 

The panel is reporting its findings in writing to the NOP Deputy Administrator and the National 

Organic Standards Board. The findings shall be considered part of the NOP management system. 

III. PURPOSE OF PEER REVIEW PANEL 

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 purpose 

of ensuring that an authoritative body oversees conformity assessment bodies. 

Peers evaluate accreditation bodies to reduce trade barriers and demonstrate the competence of 

accreditation body operations. Accreditation reduces risks for businesses and their customers by 

assuring that accredited Conformity Assessment Bodies (CABs) are competent to carry out the 

work they undertake within their scope of accreditation. The peer panel evaluation provides 

confidence in the operation of the accreditation process and acceptance of the conformity 

assessment outcome in the market place. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2017 Peer Review Panel 

Executive Summary 

National Organic Program 

IV. EXECUTIVE SUMMARY 

The Peer Review Panel Evaluation Report details the NOP’s compliance with ISO/IEC 

17011:2004 and the review of NOP’s accreditation procedures and decisions. The report is 

presented separately from this Executive Summary. 

The Peer Review Panel members find that NOP and its staff are in general compliance with 

ISO/IEC 17011 and NOP policies and procedures. Opportunities for Improvement have been 

identified and are detailed in the ensuing Peer Review Panel Evaluation Report and in ANSI’s 

Conformity Assessment portal, ANSICA. The Opportunities for Improvement (OFIs) for 2016 

were reviewed and are implemented for most of the items identified. 

The Opportunities for Improvement (OFIs) for 2017 include: 

• 2017-USDA NOP-01-O-MOOM-(17011)5.5: The records do not indicate that the 

corrective action procedure is implemented. 

Evidence: The form, NOP 1020-2, is no longer an active document. This document 

includes all the required elements of the procedure. The OFIs from the 2016 ANSI 

review are not listed. A few of the OFIs were submitted with a response but it is 

unclear if all were part of the planning. The Internal Audit from 2016 had seven 

findings and the corrective actions do not appear tracked as NOP 1020 states. 

• 2017-USDA NOP-02-O-MOOM-(17011)5.6: The 2016 OFIs are not listed on form 

1020-2 as required by the procedure, NOP 1020. The status of implementation of the 

actions taken and a review of the effectiveness are not recorded as defined by the 

procedure. 

Evidence: The Preventive Action system indicates Opportunities for Improvement 

are handled as defined in NOP 1020. The form NOP 1020-2 is no longer an active 

document. The Operating Plan document was cited as the replacement. The Operating 

Plan does not include the specific details cited in this clause (5.6). The plan does not 

include a record of the actions taken and the effectiveness of the actions. 

• 2017-USDA NOP-04-O-RANS-(17011)7.2.3: The accreditation body did not 

complete the review section of the application. 

Evidence: There is an area of the application itself to indicate USDA review. This 

section was not completed for any of the files reviewed. The application review is 

documented on the NOP 2005 Checklist. 

• 2017-USDA NOP-05-O-RANS-(17011)7.5.6: The accreditation body did not 

provide evidence for determination of the number or geographic location(s) for 

audit(s) _of satellite offices associated with a certification body. (As an example of 

previous evidence provided, NOP 2000 section 6.3, Section 8 was referred to by the 

NOP staff during the closing meeting.) 

Evidence: There was no documented sampling procedure provided for instances of 

multiple offices (satellites of the certifier) working under the accreditation of one 

CAB. None of the files selected for review had satellite offices. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2017 Peer Review Panel 

Executive Summary 

National Organic Program 

• 2017-USDA NOP-06-O-RANS-(17011)7.9.4: The accreditation body certificate 

does not meet requirements for: c) all premises from which one or more key activities 

are performed and which are covered by the accreditation; e) the effective date of 

granting of accreditation and, as applicable, the expiry date; g) a statement of 

conformity and a reference to the standard(s) or other normative document(s), 

including issue or revision used for assessment of the CAB. 

Evidence: The full address of the certification body does not appear on the 

certificates. The certificate listed a date earlier than the decision. Accreditation body 

is using the statement 'as amended' to indicate current version of the 7 CFR 205. This 

does not meet the standard requirement of the date of issuance of the standard. 

• 2017-USDA NOP-08-O-RANS-(17011)7.14.1: The accreditation body did not 

consistently ensure records were sufficient to exhibit accreditation activities were 

completed as required. 

Evidence: Isolated instances of incorrect or incomplete records were observed 

(Proposed Corrective Action not dated or signed; LPS 109 not signed by applicant; 

inconsistency in completion of NOP 2005 indicating activities completed via check 

mark (some auditors check boxes; others do not.). 

Some files contain application versions other than those cited in NOP 2000. NOP 

2000 Section 4.1 requires that forms, TM-10CG Application for Accreditation and 

LPS-109 Application for Service, be submitted for both initial and renewal 

applications. 

• 2017-USDA NOP-09-O-MOOM-(17011)5.2.2: Certifiers' corrective action 

submittal does not ensure that the implementation is completed in a timely manner. 

Evidence: The evidence received for corrective action implementation is insufficient 

to ensure the non-conformance can be closed at the next visit. The number of nonconformities that are not cleared at subsequent visits for the files reviewed 

demonstrated the need for more frequent assessments or more timely submittals. 

• 2017-USDA NOP-10-O-MOOM-(17011)7.11.3: The AB performed surveillance onsite assessments that exceeded two years. 

Evidence: The procedure, NOP2000 Table 1, indicates surveillance is performed 

within 24 - 36 months of the renewal assessment. ISO/IEC 17011 recommends a 

surveillance within one year of accreditation and for two years between assessments. 

The NOP lacks resources to perform on-site assessments to meet this 

recommendation. More frequent on-site visits will ensure the clearing of corrective 

actions. 

END EXECUTIVE SUMMARY.