United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-3

Agricultural Marketing Service Room 2648-South Building Effective Date: May 15, 2013

National Organic Program Washington, DC 20250 Page 1 of 4

NOP 2005-3 Certification File Review Checklist Grower Groups Supplement Rev03 05 15 13 Authorized Distribution: Public

National Organic Program 

Certification File Review Checklist – Supplement for Grower Groups 

Instructions: This Checklist is used in conjunction with Tables 1 - 3 of NOP 2005. The Checklist is used only to record the 

overall evaluation of Grower Group files where a full file review was conducted. 

Use the certification file number as recorded in Table 1, NOP 2005 to identify the certification file(s). If a requirement is 

not applicable, include relevant information in the "Remarks" for that section.

This Checklist is not used to record the overall evaluation of full file reviews for types of operations other than grower 

groups. Instead, the Certification File Review Checklist, NOP 2005-2, must be used.

References:

Policy Memo 11-10 Grower Group Certification

NOSB Recommendation: Criteria for Certification of Grower Groups, October 20, 2002

NOSB Recommendation: Certifying Operations with Multiple Production Units, Sites, and Facilities under the National Organic 

Program, November 19, 2008

Organic System Plan (OSP) §205.401 (a) and §205.406 (a)

Does the OSP include: Yes No Certification File 

Number(s)

A description of practices and procedures to be performed and 

maintained, including the frequency with which they will be performed? 

§§205.200; 205.202 - 205.207; 205.236 – 205.240; and 205.270 – 205.272

A list of each substance to be used as a production input, indicating its 

composition, source, location(s) where it will be used, and 

documentation of commercial availability, as applicable?

A description of the monitoring practices and procedures to be 

performed and maintained, including the frequency with which they will 

be performed, to verify that the plan is effectively implemented?

A description of the recordkeeping system implemented to comply 

with the requirements established in §205.103?

Does the OSP include a description of the management practices and 

physical barriers established to prevent commingling of organic and 

nonorganic products on a split operation and to prevent contact of 

organic production and products with prohibited substances?

Additional information deemed necessary by the certifying agent to 

evaluate compliance with the regulations? 
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-3

Agricultural Marketing Service Room 2648-South Building Effective Date: May 15, 2013

National Organic Program Washington, DC 20250 Page 2 of 4

NOP 2005-3 Certification File Review Checklist Grower Groups Supplement Rev03 05 15 13 Authorized Distribution: Public

Issues Specific to NOSB Recommendation, November 2008

ACA Policies and Procedures and Producer Group Operation (PGO) 

prerequisites:

Yes No Certification File 

Number(s)

Did the ACA verify and does the PGO meet the prerequisites for a PGO 

as defined in section III.B?

a. PGO is organized as a person 

b. Certification owned by the Group 

c. PGO seek certification with qualified ACA 

d. PGO practices uniform, consistent process, same inputs 

e. Members only market through PGO, unless individually 

certified 

f. PGO utilizing centralized processing, distribution, marketing 

facilities and systems 

g. PGO record-keeping protocols are consistent 

Did the ACA approve the designation of specific members or subunits as 

belonging to a single production unit according to the criteria defined in 

section III.C? 

a. Shared training regime 

b. Operate together under same section of PGO OSP 

c. Share common input supply 

d. Share common ICS personnel 

e. Use single post-harvest processing system 

f. Located within geographic proximity 

g. Produce unique products or varieties 

h. Share the same harvest schedule 

Does the ACA have policies and procedures for determining how many 

of the sub-units within a production unit must receive an annual 

inspection by the ACA’s inspector as required by section III.D.1(Risk 

Factors and See Annual Sampling Percentage Rate below)?

Do the ACA’s policies and procedures include determining which subunits present the greatest risks of non-compliance?

Criteria and guidance for Annual Sampling Percentage Rate 

(Based on NOSB Recommendation 2008, section III.D.1)
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-3

Agricultural Marketing Service Room 2648-South Building Effective Date: May 15, 2013

National Organic Program Washington, DC 20250 Page 3 of 4

NOP 2005-3 Certification File Review Checklist Grower Groups Supplement Rev03 05 15 13 Authorized Distribution: Public

Once the annual sampling percentage rate is determined by the ACA, the highest risk sub-units are identified and 

inspected. Of the remaining samples to be inspected annually, at least 25% of these the sub-units should be 

selected at random. This helps to prevent the complacency that might be inadvertently encouraged by a certifier 

focusing only on higher-risk members of the multi-site operation.

Example 1: 100 sub-units. Sample rate determined by the ACA: 10%. 3 sub-units are identified by ACA as "high 

risk" and inspected. Of the remaining 97 sub-units, 7 more will need to be inspected to reach the 10% rate. At 

least 2 of those (25%) should be selected for inspection at random. 

Example 2: 100 sub-units. Sample rate determined by the ACA: 30%. 10 sub-units identified as "high risk" and 

inspected. Of the remaining 90 sub-units, 20 more will need to be inspected to reach the 30% rate. At least 5 of 

those (25%) should be selected for inspection at random.

It is the responsibility of the ACA to instruct the inspectors on which high-risk sub-units must be inspected and 

the number of lower-risk sub-units that should be sampled based on their determination of the group’s over-all 

risk. The ACA will ensure that this protocol is transparent.

Assessment of units to be inspected by the ACA’s inspector

A. Annual Sampling Percentage Rate established by ACA:

B. Total number of sub-units in the PGO:

C. A multiplied by (x) B = (number of sub-units to be inspected by ACA):

D. Number of sub-units identified as high risk by ACA and must be inspected:

E. C subtract (-) D = (number of remaining sub-units):

F. E multiplied by (x) 25% = (minimum number of sub-units to be selected at random):

Yes No

Certification File 

Number(s)

In reviewing the file and “C” above were there a sufficient number of 

sub-units inspected?

Was the required number of high risk sub-units inspected? (“D” above)

Were a minimum of 25% sub-units randomly selected? (“F” above)

Were the remaining sub-units inspected based on the criteria in section 

III.D.1?

Was there a mandatory inspection of new entrants to the production unit?

Did the ACA properly identify members within the production unit that 

processed or consolidated product from more than one member and have 

them inspected annually in accordance with section III.C?

Remarks:

XXX

Issues Specific to NOSB Recommendation, October 2002

Requirements:

Yes No

Certification File 

Number(s)

PGO has established and implemented an internal control system (ICS) 

in accordance with Recommendation #1?
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-3

Agricultural Marketing Service Room 2648-South Building Effective Date: May 15, 2013

National Organic Program Washington, DC 20250 Page 4 of 4

NOP 2005-3 Certification File Review Checklist Grower Groups Supplement Rev03 05 15 13 Authorized Distribution: Public

Was all information required to be provided to the inspector prior to the 

inspection provided in accordance with §205.501(a)(18) and 

Recommendation #2.A?

Was the method for determining how many growers to be inspected 

documented in the file?

Does the inspection report include information on the Internal Control 

System (ICS) and Organic Control Points; including steps taken by the 

ICS to enforce compliance with the standards as described in 

Recommendation #2.B; and information on the applicable areas of the 19 

areas that should be included as described in Recommendation #2.C?

Remarks:

XXX

Overall Determination Statement: 

Include a statement based on an overall determination on whether the operation meets the following as applicable: the crop 

production standards (§§205.200 through 205.206); the handling production standards (§§205.270 through 205.272); the 

NOSB Recommendation: Criteria for Certification of Grower Groups, October 20, 2002; and applicable guidance 

documents of the NOP Handbook. 

Include a statement on whether the initial review, inspection, and final decisions were in compliance with the requirements.

XXX