National Organic Standards Board

Compliance Accreditation and Certification Subcommittee Proposal 

Training and Oversight of Inspector and Certification Review Personnel 

August 17, 2018

I. INTRODUCTION & BACKGROUND

In Spring 2018, the CACS brought forward a proposal entitled Inspector Qualifications and Training which 

recommended the establishment of mandatory qualifications, ideal levels of experience or background, and 

compulsory continuing education. The goal of this proposal was to further strengthen the skills and abilities 

of the inspector pool and bolster the certification system on the whole. The proposal passed with broad 

support of the Board and organic stakeholders, both of whom clearly expressed interest in being involved in 

the establishment of such qualifications, as well as expanding the scope to include certification review 

staff. 

As the Program moves forward with the Board’s recommendation, it has requested specific areas of 

training that could be incorporated into the USDA’s Learning Management System (LMS), an online 

platform for remote learning. This proposal summarizes public comments regarding improvement of 

inspection skills, identifies specific areas that could be included in the LMS, and provides further 

approaches for strengthening inspector and review staff. 

II. RELEVANT AREAS OF THE STATUTE, RULE and RELATED DOCUMENTS

205.501(a) 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;

(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.

(6) Conduct an annual performance evaluation of all persons who review applications for certification, 

perform on-site inspections, review certification documents, evaluate qualifications for certification, 

make recommendations concerning certification, or make certification decisions and implement 

measures to correct any deficiencies in certification services;

NOP Memo to Accredited Certifying Agents: Criteria and Qualifications for Organic Inspectors, April 2012

NOP 2027, Instruction: Personnel Performance Evaluations, March, 2017

CACS Proposal: Personnel Performance Evaluations of Inspectors, April 2017

Accredited Certifiers Association Guidance on Organic Inspector Qualifications, February 2018

NOSB Oct 2018 proposals and discussion documents pg. 43 of 204
CACS Discussion Document: Import Oversight, February 2018

CACS Proposal: Inspector Qualifications and Training, May 2018 

III. DISCUSSION 

Many commenters noted the essential and critical work on-site inspectors and office certification review 

staff perform, especially in the complicated area of import oversight. There are specific skills needed to 

address the challenges of tracking diverse organic products through both domestic and international supply

chains as the products move through numerous physical handlers as well as brokers and others who do not 

take physical possession of the products. International, U.S. federal, state and local regulations contribute 

to the risk to organic integrity through phytosanitary and other requirements. NOP accreditation auditors 

should have the skills, background and expertise needed as described in the NOP 2500 Auditor Criteria, to 

provide certification oversight and to continually improve their knowledge along with inspectors and 

certification personnel.

Based upon public comment regarding the Import Oversight discussion document, as well as the Inspector 

Qualifications and Training Proposal passed at the Spring 2018 meeting, the NOSB received practical 

solutions for improvement to our pool of inspectors and certification review staff. Some of these comments 

follow under the relevant topic area:

Accounting Skills

• Improve skills and background for performing in/out mass balance audits, and include a clear 

description in the inspector report on what was reviewed and discovered on-site

• Improve performance of rigorous trace backs from received product through the entire chain to 

original source

• Increase command of basic accounting skills and understanding of tracking of financial records 

through a variety of accounting systems

• Inform clients that the organic inspection could include more detailed review of financial records, 

including bank statements, deposits, etc.

Technical and Interpersonal Skills

• Increase awareness and skill in reviewing organic certificates and other documentation to identify 

areas of weakness where fraud could occur

• Improve communication, including interview and listening skills

• Improve skills in how to diffuse negative situations

Organic System Plan

• Add a specific section where the operator provides a sample audit in their OSP, with sample 

documents and how they interact with each other, to aid the on-site inspector when they are 

tracking a sale with this “roadmap”

Inspector Training and Oversight

• Trainings should be rigorous and include testing

• Continuing education should be required

• Mandatory minimum qualifications

• Some commenters proposed a system of licensing or accrediting inspectors, however there was no 

consensus around this idea

NOSB Oct 2018 proposals and discussion documents pg. 44 of 204
• Specialized trainings by type of operation

• Inspectors should be categorized by scope and skills to aid certifiers in choosing qualified inspectors 

for each entity 

• Improve and expand inspector mentoring for beginning inspectors, peer mentoring for experienced 

inspectors

• Encourage team inspections

• Create more robust systems for client and reviewer/inspector feedback to identify areas of 

weakness and strength

• Increased understanding of import protocols and requirements

In order to meet these challenges, the NOSB recommends a variety of approaches:

1. The current system of training inspectors on the organic regulations through the International 

Organic Inspectors Association (IOIA), the Accredited Certifiers Association (ACA), and individual 

certifiers should be improved and become more standardized. This would improve professionalism

and confidence in our system. Accreditation of training programs through a third party such as ISO 

should be a long-term goal. A cost/benefit analysis of this accreditation should be completed. The 

NOP could fund a task force to develop a baseline curriculum and attendee testing protocols, using 

templates from other sectors of the food industry.

2. The USDA should provide organic inspectors and certification review personnel access to the 

Learning Management System. The following areas, available through LMS, would be most 

appropriate to the organic industry: investigative skills, auditing, organic regulations, and other 

items as needed.

3. The USDA could facilitate the development of a practical and comprehensive 

apprenticeship/mentor/peer mentor program, to enhance the skills of all levels of organic 

inspectors and review staff. This could include one-on-one in-person mentorships, long distance 

communication and learning through conference calls or webinars, and on-line courses with 

testing.

4. A standardized system of tracking inspector skills, background and knowledge should be developed, 

to aid certifiers in choosing appropriate inspectors for specific jobs. This could also encourage 

inspectors to improve their resumes with continued education, such as taking an accounting course

at a local technical college. This would then be added to their list of skills. This information should 

be publicly available.

5. A standardized system of inspector and reviewer feedback should be developed for use by organic 

certification agencies, to provide consistency and confidence in how inspectors are chosen 

between various certifiers.

6. This process of inspector oversight and training subject areas should be continually improved and 

updated by the NOSB and NOP, to address issues as they arise.

V Subcommittee vote

Motion to adopt this proposal as guidance to the NOP: “Inspector and Certification Review Personnel 

Training and Oversight”.

Motion by: Harriet Behar

Seconded by: Rick Greenwood

Yes: 8 No: 0 Abstain: 0 Absent: 0 Recuse: 0 

Approved by Scott Rice, Subcommittee Chair to transmit to NOSB, August 17, 2018

NOSB Oct 2018 proposals and discussion documents pg. 45 of 204