Peer Review Report

Background:

• 7 CFR 205.509 requires Administrator to establish a Peer Review 

Panel to annually review NOP adherence to accreditation procedures.

• NOP contracted with American National standards Institute (ANSI) in 

2005 and 2014, and with National Institute of Standards and 

Technology (NIST) in 2010. 

• Foreign governments have also conducted Peer Reviews of the NOP: 

EU in 2010 & 2014; Canadian FIA in 2011 and 2013; Korea in 2014.
• NOSB made recommendations to the NOP on peer review in 2001, 

2005 and 2009.

• In 2010 OIG found that using third party organizations to conduct 

peer review did not satisfy 205.509

• NOP in 2014 asked NOSB for recommendation to establish a 

repeatable and transparent process. 

• CACS sought public comment, and provided a recommendation to 

NOP in April 2015

• 2016 NOP established Peer Review Panel and contracted with ANSI
Panel Members

• 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 Coordinate 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.
Methodology

• Panel meetings by conference call and face to face over period May-August 

2016

• Selection of Certifier files to Review

• Detailed Review of files selected 

• Detailed analysis of all NOP Documents, site evaluation reports, policies 

and procedures which are referenced and used in Accreditation process. 

• Lead Auditor prepared ISO /IEC 17011 analysis

• Preparation of Individual Reports

• Critical Review of each other’s analyses, 

• September 2016 Lead Auditor Report and all individual reports to NOP 
• The findings will be considered part of the NOP quality management 

system and corrective actions will be made as necessary and 

appropriate.

• Findings will be presented to NOSB
2016 Peer Review Panel Presentation 

for 

United States Department of Agriculture 

Agricultural Marketing Service 

National Organic Program- Peer Review

Prepared by ANSI Lead Evaluator 

USDA-AG6395S150169-2016NOSB-Rev00 
Scope:

Procedure outlined in NOP 1031 (5/12/16), Peer Review of National Organic 

Program (NOP) and instructions from 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 to the NOP Deputy Administrator 

and the National Organic Standards Board. 

USDA NOP 2016 PEER REVIEW PANEL PRESENTATION

USDA-AG6395S150169-2016NOSB-Rev00

Slide 2 
Key Findings

 NOP and its staff are in general compliance with ISO/IEC 17011 

 Opportunities for Improvement

− The accreditation body's procedures lack clarity to verify that the auditors are 

reviewing the regulatory status of ingredients and processing aids. 

− During file review an isolated instance of the NOP not following NOP 2000 for 

notification to certification body of a suspension was observed. 

− Consistent accreditation records are not being used and retained in order for 

the NOP to be in full compliance with 205.502

USDA NOP 2016 PEER REVIEW PANEL PRESENTATION

USDA-AG6395S150169-2016NOSB-Rev00

Slide 3 
Key Findings Continued

− NOP 2005-4 Witness Audit Checklist is not complete. The NOP 2005 procedure 

does not provide the control needed to approve the document for adequacy 

prior to use.

− 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

USDA NOP 2016 PEER REVIEW PANEL PRESENTATION

USDA-AG6395S150169-2016NOSB-Rev00

Slide 4 
Key Findings Continued

− ISO/IEC 17011, Clause 4.3.2 requires the Accreditation Body to document the 

relationship with related bodies and identify potential conflicts of interest. Where 

conflicts are identified, appropriate action shall be taken; however, the procedure 

does not identify the procedure to determine the appropriate action.

− 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.

USDA NOP 2016 PEER REVIEW PANEL PRESENTATION

USDA-AG6395S150169-2016NOSB-Rev00

Slide 5 
National Organic Program | Agricultural Marketing Service 

USDA Agricultural Marketing Service

National Organic Program

NOP’s Response

to Peer Review

Miles McEvoy

NOP Deputy Administrator

Fall 2016 NOSB Meeting
National Organic Program | Agricultural Marketing Service 

Peer Review Process

• American National Standards Institute 

(ANSI); panel of 4 independent auditors

• Process driven by Memo to NOSB 

(November 2014): “Peer Review of NOP 

Accreditation” 

• A vital component of NOP’s commitment 

to continuous improvement

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National Organic Program | Agricultural Marketing Service 

Context for Peer Review 

• NOP’s goal is to align with ISO/IEC 17011, a quality standard 

that applies to accreditation bodies like NOP

• NOP is a small program serving a large and growing industry

• We have strong, robust accreditation procedures

• We have a skilled pool of auditors who receive ongoing 

training – several are new to NOP

• NOP provides annual training to certifiers 

• Our tools include the regulations, checklists, guidelines, 

procedures, and the NOP Handbook 

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National Organic Program | Agricultural Marketing Service 

NOP’s Corrective Actions 

• Audit found that not all NOP documents are adequately 

controlled.

– NOP is actively improving processes that will make it more 

consistent in how the team applies its accreditation 

procedures and checklists – this will avoid inconsistencies 

– NOP is inventorying where document controls are lacking, 

and in FY 2017 will implement a process improvement 

project for document management and control 

– In the FY 2017 audit season, NOP will make sure that all 

auditors consistently use the correct version of checklists

– NOP recognizes the importance and value of records 

management – we have made significant progress, and will 

continue to improve in this area. 

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National Organic Program | Agricultural Marketing Service 

NOP’s Corrective Actions 

• NOP will update out-of-date references to quality 

standards. Example: replace ISO/IEC Guide 65 with ISO/IEC 

17065.

• As government employees, NOP staff adhere to strict 

conflict of interest and ethics laws. These rules and any 

necessary enforcement steps are detailed in USDA 

Directives, but are not included in NOP’s quality manual. 

• NOP will continue to strictly follow all federal laws related 

to conflict of interest and ethics – this is part of our oath 

when we become Federal employees and civil servants. 

• NOP will update its quality manual to explicitly document 

these existing requirements. 

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National Organic Program | Agricultural Marketing Service 

NOP’s Corrective Actions 

• In FY 2017, NOP will update its procedures to help 

auditors more clearly document how they perform 

ingredient and processing aid reviews when auditing 

certifiers 

– The review is being done – we need to document it 

better 

• Certifiers need to notify the NOP when changes occur 

that could impact compliance. NOP will provide more 

examples to certifiers of when this applies. 

– Example: Certifier adds a satellite office

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National Organic Program | Agricultural Marketing Service 

In Closing ...

• NOP appreciates the constructive feedback from ANSI.

• NOP will continue to refine its records management 

practices, improve accreditation processes, and continue to 

regularly train auditors and certifiers.

• By further strengthening accreditation procedures, NOP 

continues to support the organic community and maintain 

organic integrity for all.

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