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 Room 2646-S, STOP 0268

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NATIONAL ORGANIC PROGRAM RESPONSE TO 2017 PEER REVIEW

December 11, 2017

FROM: Ruihong Guo, Ph.D. 

Acting Deputy Administrator

National Organic Program (NOP)

SUBJECT: National Organic Program Corrective Actions:

Response to 2017 Peer Review Audit 

Background

The peer review process is a vital component of the U.S. Department of Agriculture (USDA) 

Agricultural Marketing Service National Organic Program’s (NOP) commitment to continuous 

improvement. The peer review process is described in NOP 1031 “Peer Review of the National 

Organic Program (NOP) Accreditation.” For its 2017 peer review, the NOP contracted with the 

American National Standards Institute (ANSI). The 2017 ANSI Peer Review Panel evaluated 

NOP’s compliance with NOP accreditation procedures and decisions, and with ISO/IEC 17011, a 

quality standard. 

The ANSI auditors analyzed NOP’s procedures thoroughly; their depth of review is reflected in 

the granularity and specificity of the report. As a result, the ANSI findings are very precise and 

detailed. 

Overall, the ANSI auditors found that NOP and its staff are in compliance with NOP’s own 

policies and procedures, and ISO/IEC 17011.

Opportunities for Improvement

The Peer Review Panel identified eight (8) opportunities for NOP to clarify procedures and 

improve recordkeeping:

Procedures

1. NOP corrective actions are not tracked as described in NOP 1020 (corrective action 

procedure). 

2. NOP needs to ensure timely implementation of corrective actions before the next audit 

cycle. 

3. NOP does not have a procedure for determining the number and location of certifier 

satellite office audits.

4. NOP assessments of certifiers occur every 2.5 years, not every 1-2 years as recommended 

in ISO 17011. 

Recordkeeping

5. NOP did not complete the “review” section of accreditation application documents. 

6. There were some instances of incorrect versions or incomplete records (lack of dates or 

signatures).
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7. NOP accreditation certificates do not contain the certifier’s full address and do not 

indicate the current version of 7 CFR Part 205. 

8. There was an isolated instance of a date discrepancy on an accreditation certificate.

NOP Corrective Actions

NOP continues to focus on records management and devote resources to improving processes,

updating or retiring procedures and providing training. In response to the eight (8) ANSI 

findings, the NOP is implementing the following corrective actions:

Procedures

1. Tracking Corrective Actions: The NOP corrective action procedures are addressed in 

the NOP’s quality management system, but have not been sufficiently consistent to 

ensure timely submission and closure by the next audit cycle. NOP has revised its 

procedures to track and monitor peer review corrective actions. The NOP 1020 

Corrective and Preventive Action Procedure has been retired. In the future, NOP will 

monitor corrective actions using the program’s operating plan. 

o Assigned: Office of the Deputy Administrator

o Due date: March 1, 2018 

2. Timely Implementation of Corrective Actions. NOP will use the program’s operating 

plan to ensure timely implementation of corrective action from audits. The operating plan 

will record action items resulting from internal and external audits, and management 

reviews.

o Assigned: Office of the Deputy Administrator

o Due date: March 1, 2018

3. Certifier Satellite Office Tracking. NOP is currently launching an accreditation 

management system called ACCREDIT. This tool, and additional staff, will help 

accreditation timeline management and satellite office tracking. NOP 2000 Accreditation 

Policies and Procedures generally addresses audits of certifier satellite offices. Moving 

forward, NOP will use the ACCREDIT tool to schedule and document the number and 

geographic location(s) of certifier satellite office audits throughout the five-year 

accreditation period. 

o Assigned: Accreditation and International Activities Division

o Due date: March 1, 2018

4. Assessment Timing: The current USDA organic regulations and NOP 2000 

Accreditation Policies and Procedures require that the accreditation renewal occur every 

5 years and that the mid-term evaluation occur every 2.5 years. NOP will explore options 

for more frequent assessments, but currently lacks the resources to perform onsite 

assessments every 1-2 years per ISO 17011 recommendations. We are reviewing how we 

could potentially use the Annual Report process for more frequent follow-ups. 

o Assigned: Accreditation and International Activities Division

o Due date: March 1, 2018

Recordkeeping

5. Accreditation Applications. NOP conducts robust audits of new applicants and 

accredited certifiers, and continues to refine components for processing applications for 
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accreditation as its quality system evolves. These changes will be reflected in NOP’s 

templates, forms, and procedures as they are introduced. 

o Assigned: Accreditation and International Activities Division

o Due date: July 1, 2018

6. Incomplete Records (Dates/Signatures). To verify 1) that forms were signed as 

required, and 2) that USDA completed the review section of the application forms, NOP 

revised the audit process and issued an instruction memo to auditors reminding them 

about required signatures and which forms were required depending upon the audit type. 

NOP will also review the revised process and memo during annual auditor training.

o Assigned: Accreditation and International Activities Division

o Status/due date: Auditor memo issued October 5, 2017; auditor training scheduled 

for March 6-8, 2018. 

7. Accreditation Certificate. NOP will revise the accreditation certificate template to 

reference the current USDA organic regulations and include certifier’s complete address. 

o Assigned: Accreditation and International Activities Division

o Completed: December 1, 2017

8. Accreditation Certificate Date. NOP will reaffirm its quality assurance procedures for 

certificates to ensure consistency and minimize errors.

o Assigned: Accreditation and International Activities Division

o Due date: March 1, 2018

Next Steps

The NOP values the constructive feedback from ANSI. We take continuous improvement

seriously, and will continue to evolve our records management practices, refine accreditation 

processes, and conduct regular training for auditors and certifiers. With a focus on quality 

accreditation processes, NOP continues to support the organic community and maintain organic 

integrity for all.