United States Department of Agriculture 1400 Independence Avenue SW. NOP 2027

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

National Organic Program Washington, DC 20250 Page 1 of 3

NOP 2027 Personnel Performance Evaluations Rev04 Authorized Distribution: Public 

 

Instruction

Personnel Performance Evaluations

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 personnel performance evaluations. This instruction is directed at certifying 

agents, who must satisfy additional USDA requirements as part of their accreditation (see § 

205.501(a)). Certifying agents that employ contracted personnel to perform certification duties 

are also affected by this instruction. 

2. Background 

Section 205.501(a)(6) of the USDA organic regulations requires that certifying agents conduct 

annual performance evaluations of all persons who conduct inspections, certification review, or 

implement measures to correct any deficiencies in certification services. This instruction 

establishes the minimum requirements for conducting certification personnel performance 

evaluations. 

On January 19th, 2023, USDA published the Strengthening Organic Enforcement final rule (88 

FR 3548), which defines certification review and provides additional clarification about 

personnel training and qualifications.

3. Policy and Procedure

A certifying agent must conduct annual personnel performance evaluations and implement 

measures to correct any deficiencies in certification services (see § 205.501(a)(6)). 

3.1 Personnel

Certifying agents must conduct annual performance evaluations of personnel and contract staff 

that perform any of the following roles: 

a. Conduct inspections; 

b. Conduct certification reviews; or 

c. Implement measures to correct any deficiencies in certification services.

3.2 Evaluation Criteria

Certifying agents conducting performance reviews should use the following kinds of evaluation 

criteria: 

a. Performance criteria

i. Knowledge, Skills, and Abilities 
United States Department of Agriculture 1400 Independence Avenue SW. NOP 2027

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

National Organic Program Washington, DC 20250 Page 2 of 3

NOP 2027 Personnel Performance Evaluations Rev04 Authorized Distribution: Public 

Defined competency system that assesses technical and interpersonal 

competencies, including whether personnel have sufficient expertise in organic 

production or handling techniques, the ability to work competently and 

effectively with clients and colleagues, and knowledge of the USDA organic 

regulations applicable to perform the duties assigned. The regulations provide 

additional clarification about personnel training and qualifications (see § 

205.501(a)(4)-(5)). 

ii. Responsibilities 

Personnel engage in timely planning, preparation, and follow-up of certification 

activities. This may include time management, deliverable review quality, and 

completeness of work. 

b. Witness inspection (Inspectors only)

Witness inspections involve evaluating inspectors while they are conducting 

inspections and are considered the most effective method to assess inspector 

performance. Each inspector must be subject to a regular field evaluation at least once 

every three years, or more frequently if warranted, pursuant to § 205.501(a)(6)(i). 

Inspectors with less than three years of inspection experience must undergo a witness 

inspection annually. The witness inspection system should be developed using best 

practices, such as a risk-based approach (i.e., inspector experience, annual number of 

inspections, work product assessment, etc.) or another approach sufficient to 

determine inspector competency. Certifying agents must maintain documented 

policies, procedures, and records for witness inspections, pursuant to 

§ 205.501(a)(6)(ii). All inspectors still require an annual performance evaluation, 

regardless of when their most recent witness inspection occurred. 

i. Witness inspections should be conducted at the certifying agent’s expense.

ii. Certifiers may use the witness inspection of another accredited certifier. If a 

certifier chooses to do this, it must review the evaluation to ensure a complete and 

thorough evaluation is conducted. It is each certifier’s responsibility to ensure that 

its inspectors, both staff and contractors, comply with the USDA organic 

regulations. 

c. Supervisor or Peer Review 

A process for delivering performance feedback that includes both written and verbal 

feedback with personnel at least annually. This review should include both 

observations on past performance during the previous period and a performance plan 

to guide development and improvement in the upcoming period. 

Each year certifying agents must confirm that all personnel, including contracted staff and 

inspectors that were field evaluated by other entities, meet performance criteria that they have 

established. If personnel have not met the performance criteria, then the certifying agent must 

implement measures to correct any deficiencies in certification services.

4. References 
United States Department of Agriculture 1400 Independence Avenue SW. NOP 2027

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

National Organic Program Washington, DC 20250 Page 3 of 3

NOP 2027 Personnel Performance Evaluations Rev04 Authorized Distribution: Public

USDA Organic Regulations (7 CFR Part 205)

205.2 Terms defined.

Certification activity. Any business conducted by a certifying agent, or by a person acting on 

behalf of a certifying agent, including but not limited to: certification management; 

administration; application review; inspection planning; inspections; sampling; inspection 

report review; material review; label review; records retention; compliance review; 

investigating complaints and taking adverse actions; certification decisions; and issuing 

transaction certificates.

Certification review. The act of reviewing and evaluating a certified operation or applicant 

for certification and determining compliance or ability to comply with the USDA organic 

regulations. This does not include performing an inspection.

§ 205.501 General requirements for accreditation.

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

...

(6) Conduct an annual performance evaluation of all persons who conduct inspections, 

certification review, or implement measures to correct any deficiencies in certification 

services.

(i) Witness inspections—certifying agents must ensure that each inspector is 

evaluated while performing an inspection at least once every three years, or more 

frequently if warranted. Inspectors with less than three years of inspection experience 

must undergo a witness inspection annually. Witness inspections must be performed 

by certifying agent personnel who are qualified to evaluate inspectors. 

(ii) Certifying agents must maintain documented policies, procedures, and records for 

annual performance evaluations and witness inspections.