1400 Independence Avenue, SW.

 Room 2646-S, STOP 0268

Washington, DC 20250-0201

NATIONAL ORGANIC PROGRAM RESPONSE TO PEER REVIEW

March 6, 2017

FROM: Miles McEvoy

Deputy Administrator

National Organic Program (NOP)

SUBJECT: National Organic Program Corrective Actions

Background

The peer review process is a vital component of the 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.” In 2016, the U.S. Department of Agriculture (USDA) National Organic Program 

(NOP) contracted with the American National Standards Institute (ANSI) to conduct a peer 

review of the NOP. 

The Peer Review Panel evaluated NOP’s compliance with ISO/IEC 17011 and reviewed the

NOP’s accreditation procedures and decisions. The Peer Review Panel found that NOP and its 

staff are in general compliance with ISO/IEC 17011 and the NOP’s own policies and procedures.

NOP Corrective Actions

The Peer Review Panel identified opportunities for improvement. The NOP is implementing the 

following corrective actions to make improvements to the program:

 NOP is improving control of its documents.

o NOP recognizes the importance and value of records management. NOP is 

actively improving processes that will make it more consistent in how the team 

applies its accreditation procedures and checklists in order to avoid 

inconsistencies. We have made significant progress and will continue to improve.

(Oversight of records management is now a defined responsibility assigned to the 

NOP’s Chief of Staff; effective March 1, 2017.)

o NOP is inventorying where document controls are lacking, and in 2017 will 

implement a process improvement project for document management and control.

(Assigned to Office of the Deputy Administrator; due by September 30, 2017.) 

o In the 2017 audit season, NOP will ensure that all auditors consistently use the 

correct version of checklists. (Assigned to the Accreditation and International 

Activities Division; auditor training was conducted on January 12, 2017.) 

 NOP will revise out-of-date references to quality standards. Example: replace ISO/IEC 

Guide 65 with ISO/IEC 17065. (Assigned to each NOP Division for review and editing 

of their document collection; due by March 31, 2017.)
INFORMATIONAL MEMORANDUM FOR THE SECRETARY 

Page 2

 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; NOP 

will add references to these USDA rules in its quality manual. 

o 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. 

o NOP will revise its quality manual to explicitly document these existing 

requirements. (Assigned to Office of the Deputy Administrator; due by September 

30, 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, but NOP needs to document it better. (Assigned to the Accreditation and 

International Activities Division; an updated Material Review Checklist for auditors was

developed January 2, 2017 and shared during auditor training on January 12, 2017.)

 Certifiers need to notify the NOP when changes occur that could impact compliance, so 

the NOP will provide more examples to certifiers of when this applies. Example: Certifier 

adds a satellite office. (Assigned to the Accreditation and International Activities 

Division; the annual report checklist is being revised to clarify the compliance 

information (as reflected in the certifier’s Terms of Accreditation) that certifiers need to 

submit; due by April 30, 2017.)

Next Steps

The NOP appreciates the constructive feedback from ANSI. Throughout 2017, the 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.