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2021 ANAB Peer Review Report

For 

Agricultural Marketing Services (AMS)

National Organic Program (NOP) 

Dates of Review Panel:

October 5 - 7, 2021 

Prepared by

ANSI NATIONAL ACCREDITATION BOARD 

1899 L Street, 11th Floor

Washington, DC 20036

Document: 2021-USDA-PeerReviewPanel-1-0-PeerReviewTeam
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I. TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................... 2

I. GENERAL INFORMATION................................................................................................... 3

II. SCOPE ............................................................................................................................... 4

III. INTRODUCTION ................................................................................................................ 4

IV. RESULTS OF PEER REVIEW PANEL EVALUATION................................................................. 5

 Previous OFIs..................................................................................................................... 5

 2021 Opportunities for Improvement................................................................................ 7

 2021 Strengths.................................................................................................................................8

V. CONCLUSION ..................................................................................................................... 9
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I. GENERAL INFORMATION

Accreditation Body

Name of Reviewed Body United States Department of Agriculture

Agricultural Marketing Services (AMS)

National Organic Program

Address 1400 Independence Avenue S.W.

Room 2648 South Building

Washington, DC 20250

Telephone 202-720-3252

Review by: 

Type of Review Peer Review Panel Evaluation

On-site Peer Review Dates October 5 to 7, 2021

Review Standard(s)

US 7 CFR Part 205, National Organic Program 

 ISO/IEC 17011:2017 Conformity Assessment – General 

requirements for accreditation bodies accrediting conformity 

assessment bodies

Peer Review Team

Lead Reviewer: Mario Llerenas

Technical Reviewer: Susan Ranck

Technical Reviewer: Jean Richardson

ANSI Staff: Reinaldo Figueiredo, ANAB Senior Program Director

 Nikki Jackson, ANAB Accreditation Director

Elizabeth Okutuga, ANAB, Accreditation Manager

 Ron Hicks, Food technical expert

Report Prepared by:

 Mario Llerenas

Jean Richardson

 Susan Ranck

Submitted on: November 24, 2021
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II. SCOPE

The NOP is establishing a peer review panel to satisfy adherence to internal and regulatory

requirements. ANSI National Accreditation Body (ANAB) convened this panel on August 18, 2021.

The peer review panel is tasked to:

• Evaluate NOP polices processes and procedures for conformance to NOP regulations 7 CFR 

Part 205 and ISO/IEC 17011;

• 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 their findings in writing to the NOP Deputy Administrator and the National Organic 

Standards Board. The findings will be considered part of the NOP quality management system.

III. 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 of 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

Panel Members

Susan Ranck – Risk Assessment Evaluator; ANAB Technical Expert Assessor in Food 

Jean Richardson - Professor Emerita, University of Vermont, Environmental Law and 

Environmental Studies; Independent organic inspector, IOIA qualified; NOSB 2012-2017; 

ISO/IEC trained.

Mario Llerenas – ISO/IEC 17011 Expert (Qualified Peer Assessor); Risk Assessment 

Evaluator; ANAB Food Safety Lead Assessor

ANAB Staff - Reinaldo Balbino Figueiredo, Senior Program Director, ANAB staff,

ISO/IEC 17011 evaluator. Contract/Project Manager.

ANAB Staff – Nikki Jackson, Director, Product Certification Accreditation Program

ANAB Staff – Ron Hicks, Food Expert

Document Review - The review panel conducted a Document Review and completed a working 

document before the remote evaluation. The working document including the tentative schedule of 

the personnel to interview during the remote assessment was created on October 3, 2021 and sent to 

USDA NOP. The Peer Review team used the working document to take notes during the remote

assessment, and the findings are included in this report.

Assessment Plan

The remote assessment plan was issued on September 10, 2021; this version was approved and signed 

by the Quality Manager of USDA NOP. The assessment plan approved by USDA NOP is uploaded in

ANSICA, the ANAB database.

Opening / Closing Meetings

In accordance with the assessment plan, an opening meeting was conducted on Tuesday, the 5th of 

October 2021 at 8:30 am with six NOP senior staff and the members of the ANAB Peer Review team in 

attendance. At the end of the opening meeting, the NOP Deputy Administrator, Jennifer Tucker, 
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explained the key changes in the organizational structure of the NOP, the accreditation process, and its 

relationship with other governmental departments. 

The closing meeting for the remote assessment was conducted on Thursday, 7th of October 2021 at 4:00

pm with the same six NOP persons and the three assessors of the Peer Review team in attendance. The 

results of the remote assessment were discussed during the closing meeting: One opportunity for 

improvement (OFI) was documented and two comments with observations for NOP to consider in its 

management system were identified during this remote Peer Review. 

Additional Comments

The management system of USDA NOP is very well implemented and functions in accordance with 

ISO/IEC 17011:2017 and US 7 CFR Part 205, National Organic Program requirements with the exception 

of one Opportunity for Improvement (OFI) identified.

The Peer Review team was very impressed by the improvements in the organization, resources, and 

accreditation process since the last Peer Review in 2020. Significant improvements have been 

implemented since the last Peer Review in both the QMS and the Accreditation Process.

The NOP personnel demonstrated sound knowledge in both management system and technical 

requirements. 

The NOP program management also demonstrated commitment to continuous improvement. 

IV. RESULTS OF PEER REVIEW PANEL EVALUATION

1. METHODOLOGY - The Peer Review team verified the compliance of USDA NOP to 7 CFR 205 

Part 205 and ISO/IEC 17011:2017 based on the sampling of documents, interviews, and records; 

the Peer Review team selected 5 accreditation files and NOP qualified assessors in order to verify 

the accreditation process and competency. The conclusions of the Peer Review team are based on 

objective evidence collected and observed during the assessment and are contained in this report 

as compiled by the lead and technical evaluators.

2. PREVIOUS OFIs - The three OFIs open from 2019 and two OFIs cited from 2020 were 

documented and reviewed by the Peer Review team during the 2021 remote assessment to verify 

the effectiveness of the actions implemented by NOP. The outcome of this review is presented 

below:

2020 Opportunity for Improvement 2021 Verification of the effectiveness

2020-USDA NOP-01-O-LLEM-(17011) 

4.4 (2019 OFI)

The NOP ́s revised Quality Manual NOP 1000 

is in the process of being finalized and states 

in the section 4.4 “The NOP identifies, 

evaluates, mitigates and documents potential 

risks to impartiality including conflicts of 

interest arising from its relationship and the 

relationships of its personnel on an ongoing 

basis. The NOP records identified perceived 

risks to the impartiality of the NOP’s 

operations and accreditation activities, in NOP 

1009 Risk Mitigation Table” 

The draft of the NOP 1009 Risk Mitigation 

Table was reviewed. 

NOP should finalize the new version of the 

Quality Manual as well as the Risk Mitigation 

Table.

The Quality Manual NOP 1000 was finalized 

on January 4, 2021 under revision 05.

The structure of the manual is in accordance 

with the requirements of the ISO/IEC 

17011:2017 standard.

The NOP Quality Manual is well documented 

and complies with the requirements. This part 

of the 2020 OFI has been closed.

CLOSED

Note: The NOP 1009 Risk Mitigation Table 

was not finalized at the time of the 2021 Peer 

Review and one OFI was identified (see 

below 2021 opportunities for improvements).
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2020-USDA NOP-02-O-LLEM-(17011) 

5.6 (2019 OFI)

During the revision of the Quality Manual and the 

QMS documentation, NOP is archiving and 

combining some documents in order to have a 

more efficient QMS documentation. One of the 

documents to be archived is NOP 1002 Duties, 

Responsibilities and Authorities. 

NOP should finalize the revision and release of 

the new QMS documents, verifying that the 

duties, responsibilities and authorities are

consistent with positions in the Organizational 

Chart.

NOP 1002 document was archived.

The duties, responsibilities and authorities for

NOP employees are documented in Position 

Descriptions. 

Sampling of staff and technical personal were 

reviewed and compliant with the 

requirements.

CLOSED

2020-USDA NOP-03-O-LLEM-(17011) 

9.3 (2019 OFI)

The control of documents was improved and 

now documents are in PDF files.

The new version of the NOP 1010 includes the 

Control of Records and External documents; 

however, this section is not yet finalized. 

NOP should finalize the NOP 1010 new version 

and complete the release process.

NOP 1010 NOP Quality Management 

System: Document Development, Review, 

and Distribution Process was finalized on 

November 26, 2020 under the revision 03.

Section 4.8 Control of Records and External 

Documents was reviewed and complies with 

the requirements.

CLOSED

2020-USDA NOP-05-O-RANS-

(17011)7.6 (2020 OFI)

The accreditation body does not have a

documented policy/procedure for the timely

completion of assessments. 

File reviews and discussion with the 

management staff indicate there is no formal 

policy for the completion of assessment 

activities. This lack of definition makes it difficult 

for the organization to determine adequate 

resources to meet assigned deliverables.

A timeline of assessment activities was

established including individual steps 

throughout the process. The total time frame 

from audit through accreditation decision is 

five months. Assignment of a KPI based 

upon this timeline is under consideration.

CLOSED

2020-USDA NOP-06-O-RANS-

(17011)7.11.2

The organization does not have a defined 

process for completion of certifier satellite offices 

as part of the accreditation cycle.

There is no formal policy for satellite office visits 

as part of the accreditation cycle. A tracking 

document was presented as a historical 

illustration but was not currently in use.

Satellite office audit scheduling has been 

incorporated into the five-year accreditation 

cycle through the utilization of a pilot project 

the NOP is conducting in 2022. The NOP will 

be piloting its risk-based approach for certifier 

oversight, including satellite offices. . 

CLOSED

3. 2021 Opportunities for Improvement. During this remote assessment, the Peer Review team 

identified one opportunity for improvement. The following is the 2021 opportunity for improvement 

(OFI) documented by the review panel:

Requirement Opportunity for 

Improvement

Evidence 
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ISO/IEC 17011:2017

4.4.6 The accreditation body 

shall have a process to identify, 

analyze, evaluate, treat, monitor 

and document on an ongoing 

basis the risks to impartiality 

arising from its activities 

including any conflicts arising 

from its relationships or from the 

relationships of its personnel. 

The process shall include 

identification of and consultation 

with appropriate interested 

parties as described in 4.4.5 to 

advise on matters affecting 

impartiality including openness 

and public perception.

2021-USDA NOP-01-OLLEM-(17011) 4.4.6

NOP has the opportunity to 

improve its risk analysis 

matrix developed to 

document potential threats to 

the impartiality of the NOP’s 

operations and activities.

The draft of NOP 1009 Risk 

Mitigation Table was reviewed, and 

the methodology complies with the 

expectations of ISO/IEC 17011.

However, the following 

observations on the document 

should be considered by NOP to 

improve the process: 

1) Finalize NOP 1009 document; 2) 

document the methodology 

including the criteria for impact, 

likelihood, and residual risk levels; 

and 3) include other sources of 

potential threats to Impartiality, 

such as: 

+ Commercial

+ Finances

+ Related Bodies

+ Training

+ Marketing

4. 2021 Comments. During this remote assessment, the Peer Review team identified two 

observations classified as Comments. These comments originated from the technical Peer 

Review team and can be considered by NOP as examples of good practices in the accreditation 

process.

COMMENT # 1

As part of the response to the pandemic, certification bodies implemented various approaches 

to complete inspection requirements, while ensuring the safety of both their inspectors and the 

sites to be inspected. These methods included remote inspections, offsite document review, 

and alternative onsite inspections. The NOP maintains the requirement that certifiers conduct 

an annual inspection and allows the certifier to determine the best method. This process would 

be improved if the certifier conducted a risk-based assessment of the operation prior to 

determining if remote inspection activities are appropriate.

COMMENT # 2

As part of the NOP internal pandemic response, the program transitioned to positions with the 

option for remote work. Over the past year the NOP has hired and onboarded new staff in a 

remote setting and no longer requires that all NOP positions are based in the DC area. The 

review of recent hires indicates this transition has positively impacted the applicant pool in 

terms of both number of applicants and the qualifications of said applicants. It is the current 

intent of the NOP to continue this allowance of remote work positions. 

2021 Strengths. The Peer Review team identified positive processes and activities during the 

2021 remote assessment. The following are the strengths identified by the team:

NOP PROCESS COMMENTS

Quality Management 

System totally in 

accordance with 17011 

requirements.

NOP has finalized the documents related to the Quality Management 

System and demonstrated that the system is well documented and 

implemented.
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The documentation complies with the requirements of the International 

Standard for accreditation bodies, ISO/IEC 17011:2017. 

Software application for 

managing the complaints 

process 

NOP developed a software application for handling complaints. The 

application considers many possibilities for tracking complaints, allowing 

for an in-depth analysis of sources, types, impact, etc. 

Due to the effectiveness of the application, NOP is now addressing 

complaints in a timely manner.

NOP objectives and goals 

go beyond expectations NOP develops goals and objectives annually which informs the 

program’s projects and strategic planning. . 

During this peer review, NOP demonstrated compliance with its goals 

and objectives, and exceeded some expectations set for 2021.

Team work approach NOP has created a competent and effective executive team. During this 

peer review, ANAB collected evidence that the NOP team works from 

the foundation of its clearly defined purpose and goals.

All NOP personnel interviewed demonstrated understanding and 

commitment to NOP business goals. 

Organic Integrity 

Learning Center 

NOP has continued to expand the Organic Integrity Learning Center and 

increased the number of attendees world-wide. The increased 

participation has strengthened the technical training of inspectors and 

certifiers with demonstrated improvement in the consistency of 

certification. 

Personnel and crossdivisional collaboration NOP hired 21 key personnel in the last 12 months. These hires were

balanced among all divisions so additional experts are now available in 

both the Standards Division and the Compliance and Enforcement

Division to support and strengthen the work of the Accreditation Division. 

There is a documented system in place to facilitate the sharing of 

expertise, thereby supporting cross-divisional collaboration. 

Stronger control systems 

and standardization NOP has effectively strengthened its database and control systems 

through the standardization of systems resulting in improved 

communications, both within the NOP and externally through reports 

available to public stakeholders. This improvement has resulted in

greater consistency, increased efficiencies, and transparency in publicfacing program materials.

Strengthen Organic 

Standards NOP strengthened the Standards Division by hiring additional Materials 

Specialists and moving forward with several rules. NOP is drafting final

rules for Strengthening Organic Enforcement (SOE) and Origin of 

Livestock (OOL), and the proposed rule for Organic Poultry and 

Livestock Standards (OLPS). NOP actively engages the National 

Organic Standards Board, stakeholders, and partners in this process. 

These actions will strengthen consistency in organic certification. 

Robust Enforcement NOP continues to expand its safeguarding of organic integrity through 

the increased use of risk-based oversight approaches, surveillance, and 
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enforcement actions world-wide. All of which will increase the integrity 

and consistency in the organic marketplace.

V. CONCLUSION

This report completes the work of the 2021 ANAB Peer Review for the USDA NOP accreditation body.

The review covers the NOP’s compliance with ISO/IEC 17011:2017 as well as a review of NOP’s 

accreditation procedures, decisions, and conformance with 

7 CFR Part 205. 

The Peer Review Panel members conclude that USDA NOP and staff continue to operate in conformance 

with ISO/IEC 17011:2017, 7 CFR Part 205 and with NOP’s own policies and procedures. One OFI and two 

comments were identified during this remote assessment. 

NOP management consistently demonstrated their commitment to improvement to the Peer Review team. 

The Peer Review team would like to express appreciation to USDA NOP personnel for their cooperation 

and commitment during the Peer Review assessment.

--------------------------------------------- END OF REPORT ----------------------------------------------