National Organic Standards Board

Certification, Accreditation and Compliance Committee

Proposed Recommendation

Inspector Qualifications

September 14, 2011

Background

On June 23, 2011, the Deputy Administrator of the National Organic Program (NOP) 

issued a memorandum to the chair of the National Organic Standards Board (NOSB) 

requesting a proposal outlining the criteria that inspectors should be required to meet 

prior to conducting inspections of organic production and handling operations. The 

Certification, Accreditation and Compliance Committee (CACC) has reviewed this 

request and, in consultation with representatives from the organic community, 

developed this proposal. We believe that it would be appropriate, and in the best 

interest of the organic community, for the NOP to issue guidance to Accredited 

Certification Agencies (ACAs) on this subject and respectfully submit our 

recommendations below. 

Relevant Regulatory Text

The NOP regulations require that certifiers use employees and contractors with 

sufficient expertise in organic production. The following passages represent all of the 

rule language directly addressing or related to inspector qualifications:

205.501 General requirements for accreditation.

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

must:

(1) Have sufficient expertise in organic production or handling techniques to fully 

comply with and implement the terms and conditions of the organic certification 

program established under the Act and the regulations in this part;

(2) Demonstrate the ability to fully comply with the requirements for accreditation 

set forth in this subpart; ...

(4) Use a sufficient number of adequately trained personnel, including inspectors 

and certification review personnel, to comply with and implement the organic 

certification program established under the Act and the regulations in subpart E 

of this part;

(5) Ensure that its responsibly connected persons, employees, and contractors 

with inspection, analysis, and decision-making responsibilities have sufficient 

expertise in organic production or handling techniques to successfully perform 

the duties assigned.
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(6) Conduct an annual performance evaluation of all persons who...perform onsite inspections...

§ 205.504 Evidence of expertise and ability.

A private or governmental entity seeking accreditation as a certifying agent must submit 

the following documents and information to demonstrate its expertise in organic 

production or handling techniques...:

(a) Personnel.

(1) A copy of the applicant‟s policies and procedures for training, evaluating, and 

supervising personnel;

(2) The name and position description of all personnel to be used in the 

certification operation, including ... certification inspectors, ...;

(3) A description of the qualifications, including experience, training, and 

education in agriculture, organic production, and organic handling, for:

(i) Each inspector to be used by the applicant and...

(4) A description of any training that the applicant has provided or intends to 

provide to personnel to ensure that they comply with and implement the 

requirements of the Act and the regulations in this part.

Discussion

Organic inspectors perform a critical function in the ongoing fulfillment the Organic 

Foods Production Act and the NOP regulations. What professional and technical skills, 

knowledge and training are necessary to conduct effective inspections? There are 

currently no specific qualification criteria or standards for what constitutes the “sufficient 

expertise” called for by the section 205.501(a)(1) of the regulations. This discussion 

seeks to clarify issues related to defining standard inspector qualifications for all ACAs, 

and offers a proposal for baseline levels of: 

a) pre-requisite experience, training and knowledge, 

b) continuing education and training, and 

c) performance oversight and assessment . 

Because there are a number of different scenarios under which ACAs employ 

inspectors-including full time employees, part time employees, regular contractors, 

one-off contractors, etc- we must consider a system that allows for a wide variety of 

ACA- inspector relationships while ensuring that the inspectors are doing their part to 

uphold the high levels of integrity expected by the organic community. 
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In the absence of specific regulatory requirements for the qualifications of organic 

inspectors, ACAs have instituted a wide range of requirements and criteria in their hiring 

process, training, and performance monitoring. While the CACC is aware of the 

requirements of a few ACAs in particular, the actual extent and range of these specific 

requirements among the 100 worldwide NOP approved ACAs is not fully known. 

The International Organic Inspectors Association (IOIA), formed in 1991, offers an 

organic inspector training program which is broadly recognized among ACAs. The IOIA 

training is currently the only training of which we are aware that is targeted at organic 

inspectors. Most ACAs include IOIA training certificate among their baseline inspector 

qualification criteria. Some ACAs require additional training beyond the IOIA certificate. 

These commonly include apprentice inspections and/or annual inspector trainings. 

Some ACAs, especially those located outside the United States, do not require IOIA 

training. 

The CACC believes that targeted training, such as that provided by IOIA, should be 

strongly encouraged. We suggest that the NOP consider entering in to a Memorandum 

of Understanding or other recognition agreement or subcontract with IOIA so that IOIA 

can be formally recognized and authorized by the NOP. This could allow IOIA to create 

a formal inspector approval for inspectors who have successfully passed their training 

course and participate in continuing education. While IOIA currently offers an 

“accredited inspector” status, it is the understanding of the CACC that this designation is 

not particularly meaningful to ACAs during their hiring process, and that relatively few 

qualified inspectors seek “accreditation”. We believe that having a pool of inspectors 

which are formally approved by IOIA under the auspices of the NOP would be extremely 

beneficial to the entire organic community. 

It is essential that during the accreditation process, ACAs are verified as hiring only 

competent, trained inspectors. Anecdotal evidence suggests that while the qualifications 

of certification personnel are evaluated during current NOP audits, those of contract or 

part-time inspectors are not often reviewed. The CACC is particularly concerned about 

situations where an ACA may rely on only one inspector, or a small handful of 

inspectors, to perform all of the inspections for an ACA. In particular, it is essential that 

the ACA has sufficient criteria for assigning different types of operations to that 

inspector. 

At minimum, all ACA‟s should be required to attend annual NOP trainings and those 

trainings must include clear direction as to inspector qualification and continuing 

education. We find arguments that such trainings are cost prohibitive unconvincing. 

The NOP has been offering these trainings in many locations in the US and abroad for 

many years and has been clear of their intention to continue to do so. Those ACAs who 

need to adjust fees or adjust budgets accordingly need to do so. This is essential in 
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assuring their clients—and thereby the general public—that they are operating on a 

level playing field in the national and international arena. This is critical to prevent 

responsible ACAs from falling victim to certifier shopping based on costs which have 

been subsidized by systematic use of under qualified inspectors who charge less for 

their services. The training of ACAs is essential to ensuring that they have the 

opportunity to make judgments about the qualifications of the inspectors they use. 

We recognize that there is not absolutely uniform need for training, experience or 

education for inspector qualifications across all types of inspections. Distinctions are 

needed according to the types of operations that are being inspected. These can be 

defined in different layers and to different degrees. The first and broadest categorization 

is by scope: Crops, Handling, or Livestock. Wild crop harvesting, the fourth scope under 

the NOP, should be considered a subtype of crop production, as it is of minor 

prevalence, and an experienced organic crops auditor can effectively perform these 

inspections after a focused briefing on specific issues and standards related to wild crop 

harvesting practices. 

Within those three major lenses of the scope of production there are then a range of 

specialties and levels of complexity. Because of the significant diversity of crops and 

operation types, we cannot reasonably set the same requirements for inspectors of all 

the possible different crops, processes, products, animals and livestock rearing 

methods. While a good inspector should be capable of inspecting any operation under 

the general scope to which they are qualified, some types of production are particularly 

complicated and may require additional training. Dairy is one sub-category of livestock 

that arguably calls for a separate qualifications category. Dairy operations often involve 

unique practices and standards from other livestock production that require special 

training and experience for the inspector. 

An additional challenge posed in appropriately assigning inspectors to operations is 

balancing the need for familiarity with the production system and ensuring a lack of 

conflict of interest. Operations being inspected rightfully expect that the inspector 

understand the fundamentals of the product being produced or handled. For example, 

an otherwise qualified inspector who is also growing strawberries or has grown 

strawberries might likely be a qualified inspector to inspect another strawberry farm. 

However, the strawberry farm being inspected may object to an inspector who currently 

or previously worked for a business that is in direct market competition. We recognize 

that this may be less of an issue for ACAs where inspectors are full time employees. 

While familiarity of the inspector with the type of operation being inspected is necessary, 

what is more critical is the type of general auditing skills that are not easily taught. To a 

large extent, a typical organic inspector is a “general practitioner”. Many of the general 

auditing skills are applicable across the entire range of organic inspections. Expertise in 
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one of the three general areas makes it easier for an inspector to increase their scope 

to include additional types of inspections. We believe that a successful crop inspector 

can be more quickly trained to also do handling inspections than someone who has no 

inspection experience. Therefore, we believe that the specific-scope qualification 

criteria should be more flexible for an experienced inspector who is extending the scope 

of their existing qualifications. 

We believe that ongoing continuing education is essential for organic inspectors. Like 

many other professions, we believe that organic inspectors should stay up to date on 

the emerging issues in the field through attending conferences, advanced trainings, or 

other educational events where either specific or general knowledge can be acquired. 

While most, if not all, ACAs do not currently require this of their inspectors, we assert 

that they can, and indeed should. 

We recognize that we must be careful to implement requirements that are fair to all 

ACAs, regardless of size, but also seek to provide a meaningful baseline for hiring 

inspectors to assure to the greatest degree possible consistency the organic production 

marketplace an the consumer marketplace. At this time, we suggest that standardized 

inspector qualifications requirements should remain somewhat broadly defined. The 

organic inspector profession is not large or deep enough presently to accommodate 

many narrowly define scopes of qualifications. There is a need for definitions and 

requirements for baseline qualifications that will meet the needs of having capable 

knowledgeable inspectors but that are practical and achievable by inspectors and the 

ACAs. 

Beyond the required NOP annual performance evaluation for all inspectors, it is 

unknown to what extent ACAs monitor inspector performance, provide constructive 

feedback, and require corrective action when correctable performance issues are 

detected. Some ACAs provide an evaluation of every inspection report. Some ACAs 

may require periodic witness audits of their inspectors, however this is currently 

unusual, perhaps due to limited administrative and over-sight resources within the 

ACAs. We believe that more rigorous oversight of the inspectors by ACAs would 

provide value to the organic community. Organic inspectors, especially those that work 

on contract for a number of ACAs, would likely welcome more feedback about their 

performance. 

It is essential that ACAs are capable of ensuring that only qualified inspectors perform 

their inspections and assert that annual NOP training is essential for ACAs just as 

annual inspection training is for inspectors. While some ACAs use complex database 

systems to match inspector qualifications with the operation type, this can also be 

accomplished using simpler methods not requiring computerized systems. However it is 

done, we believe that each ACA must be able to justify why the specific inspector has 
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been assigned to a particular operation and why they are qualified to perform the 

inspection. 

Proposed Guidance

Baseline Qualification Criteria for Organic Inspectors

A. As fundamental initial “organic inspector” criteria:

1. Baseline pre-requisite knowledge and expertise for initial „organic inspector‟ 

status.

a. Minimum two years of combined work experience, education, and training 

in organic production, applicable to the scope of inspections to be initially 

performed: crops, handling, or livestock. 

b. Must include at least two of the three different criteria: experience with the 

scope of operations to be inspected, education relevant to the scope of 

operations to be inspected, or specific training within the scope of 

operations to be inspected.

c. Training equivalent to the Independent Organic Inspectors Association 

(IOIA) basic training, i.e. four days of concentrated training culminating in 

a qualifying exam. 

d. Apprenticeship consisting of a minimum of three shadow inspections, 

accompanied by an experienced organic inspector and followed by 

witness inspections where the apprentice is observed and deemed 

competent by the experienced inspector or certifying agent.

e. Must have a good evaluations and recommendations by an experienced 

organic inspector or certifying agent assessing the inspector 

understanding of inspection protocols and applicable organic standards.

f. Once an individual has established themselves as a competent organic 

inspector in any one of the three general areas, addition of a new scope 

does not require an additional two years of focused experience and 

training in that area. General organic inspecting skills are applicable to all 

areas and can therefore greatly assist the inspector in expanding their 

scope, while seeking whatever specific additional knowledge is required to 

sufficiently understand the new area.

B. As continuing organic inspector criteria: 

1. Continuing Education

a. Annual training by Accredited Certifiers Association (ACA) to update on 

specific procedures of the ACA as well as National Organic Program 

(NOP) standards updates and guidelines. 

b. Minimum 8 hours annual continuing education related to the type of 

inspection work performed. Each hour of curriculum time (e.g. class time, 
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coursework, field study, testing), equals one hour of continuing education 

hours. Trainings conducted by ACAs and closed to the general inspection 

community do not apply toward continuing education hours given their 

tendency to focus on certifier procedures, rather than broad knowledge 

such as agronomic and food industry practices, and general auditing skills. 

c. In-depth training on the topic of recordkeeping and/or accounting must be 

included as part of continuing education, and IOIA is encouraged to 

develop a training to fulfill this need. 

d. Continuing education credits include webinars, seminars, workshops, and 

colleges and university extension programs related to the type of 

inspection work performed or new scope of inspection interest.

C. ACA accreditation criteria to ensure adequate monitoring and oversight of inspector 

qualifications:

1. Annual attendance of NOP trainings.

2. Documented inspector qualification monitoring program that readily provides 

verification that all inspectors employed or contracted in the service of the 

ACAs are qualified according to these criteria. 

3. Provide programmatic and consistent annual training to inspectors regarding 

processes, policies and procedures specific to the ACA. Training materials 

used must be available for review during accreditation audits and included in 

annual ACA updates to the NOP. 

4. Provide all inspectors with performance assessment and oversight 

accordingly:

a. Witness audits by ACA to be conducted at a minimum every 300 

inspections or 3 years, whichever is less. Results must be 

documented. Witness audits may be conducted by certification 

management, senior inspectors or senior reviewers. 

b. Evaluation of every inspection provided to the inspector. 

c. Annual performance evaluation provided to the inspector. 

d. All serious or persistent performance issues that arise during any of 

the above assessments must be documented by the ACA, and must 

include documented corrective action and improvement measures as 

deemed necessary by the ACA. 

Committee Vote

Motion: John Foster Second: Barry Flamm

Yes: 6 No: 0 Abstain: 0 Absent: 0 Recuse: 0