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2022 ANAB Peer Review Report

For 

Agricultural Marketing Services (AMS)

National Organic Program (NOP)

Dates of Review Panel:

August 29 to September 9, 2022 

Prepared by

ANSI NATIONAL ACCREDITATION BOARD 

1899 L Street, 11th Floor

Washington, DC 20036

Document: 2022-USDA-PeerReviewPanel-01-1-PeerReviewTeam
ANAB 2022 Peer Review Report

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Table of Contents

I. GENERAL INFORMATION ............................................................................3

II. SCOPE.........................................................................................................4

III. INTRODUCTION ..........................................................................................4

IV. RESULTS OF PEER REVIEW PANEL EVALUATION..........................................5

Previous OFIs....................................................................................................................... 6

2022 Opportunities for Improvement........................................................................ 6

2022 Comments................................................................................................................. 6

2022 Strengths.................................................................................................................... 7

V. CONCLUSION..............................................................................................8
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I. GENERAL INFORMATION

Accreditation Body

Name of Reviewed Body United States Department of Agriculture

Agricultural Marketing Services (AMS)

National Organic Program

Address 1400 Independence Avenue S.W.

Room 2648 South Building

Washington, DC 20250

Telephone (202) 720-3252

Review by: 

Type of Review Peer Review Panel Evaluation

Peer Review Dates August 29 and 30; September 1, 7, 8 and 9, 2022

Review Standard(s) US 7 CFR Part 205, National Organic Program 

ISO/IEC 17011:2017 Conformity Assessment – General 

requirements for accreditation bodies accrediting 

conformity assessment bodies

Peer Review Team

Lead Reviewer: Mario Llerenas

Technical Reviewer: Susan Ranck

Technical Reviewer: Jean Richardson

ANSI Staff:

 Nikki Jackson, Senior Director

Erica Hinton, Accreditation Manager

Report Prepared by: Mario Llerenas

Jean Richardson

 Susan Ranck

Submitted on: December 12, 2022
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II. SCOPE

The NOP is establishing a peer review panel to satisfy adherence to internal and regulatory

requirements. ANSI National Accreditation Body (ANAB) convened this panel on August 12, 2022.

The peer review panel is tasked to:

• Evaluate NOP polices, processes, and procedures for conformance to NOP regulations 7 CFR 

Part 205 and ISO/IEC 17011;

• Review implementation of certification body accreditation processes through select file review;

and

• Report the peer review panel findings in writing to the NOP Deputy Administrator and the 

National Organic Standards Board.

The panel is reporting their findings in writing to the NOP Deputy Administrator and the National Organic 

Standards Board. The findings will be considered part of the NOP quality management system.

III. INTRODUCTION

The National Organic Program (NOP) is part of the Agricultural Marketing Service (AMS), U.S. 

Department of Agriculture (USDA), and is the organization responsible for activities relating to the 

development, implementation, and administration of the Organic Foods Production Act of 1990 (OFPA) 

as well as the USDA organic regulations. Key functions of the NOP include:

• Developing, reviewing, implementing, and interpreting the organic standards 

• Enforcing organic production, handling, and labeling standards

• Accrediting, auditing, and training third‐party organic certifying agents

Panel Members

Susan Ranck – Risk Assessment Evaluator; ANAB Technical Expert Assessor in Food

Jean Richardson - Professor Emerita, University of Vermont, Environmental Law and 

Environmental Studies; Independent organic inspector; IOIA qualified; NOSB 2012-2017

qualified; ISO/IEC trained

Mario Llerenas – ISO/IEC 17011 Expert (Qualified Peer Assessor); Risk Assessment 

Evaluator; ANAB Food Safety Lead Assessor

ANAB Staff – Nikki Jackson, Senior Director, Product Certification Accreditation Program. 

Contract/Project Manager

Document Review - The review panel conducted a Document Review and completed a working 

document before the remote evaluation. The working document, including the tentative schedule of 

the personnel to interview during the remote assessment, was created on August 24, 2022 and sent

to USDA NOP. The Peer Review team used the working document to take notes during the remote

assessment, and the findings are included in this report.
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Assessment Plan

The remote assessment plan was issued on August 15, 2022; this version was approved and signed by

the Quality Manager of USDA NOP. The assessment plan approved by USDA NOP is uploaded in

ANSICA, the ANAB database.

The assessment plan shows a separate Peer Review for the QMS and the Technical assessments.

The Technical Peer Review was conducted on August 29 to September 1st, 2022; the QMS Peer Review 

was conducted on September 7th to 9th, 2022.

Opening / Closing Meetings

In accordance with the assessment plan, the opening technical meeting was conducted on Tuesday, 

August 30, 2022 at 9:00 am with five NOP senior staff and the technical members of the ANAB Peer 

Review team in attendance. At the end of the opening meeting, the NOP Deputy Administrator, Jennifer 

Tucker, explained the key changes in the organizational structure of the NOP, the accreditation process, 

and its relationship with other governmental departments.

The closing meeting for the technical remote Peer Review was conducted on Thursday, September 1, 

2022 at 3:30 pm with three NOP persons and two technical assessors of the Peer Review team in 

attendance. The results of the remote assessment were discussed during the technical closing meeting: 

The QMS opening meeting was conducted on Wednesday, September 7, 2022 at 9:00 am with the NOP 

quality manager and the lead member of the ANAB Peer Review team in attendance.

The final closing meeting for the 2022 remote Peer Review was conducted on Friday, September 9, 2022

at 3:30 pm with three persons from NOP staff, including the NOP deputy administrator, Jennifer Tucker,

and two persons of the Peer Review team in attendance (Susan Ranck and Mario Llerenas). The results 

of the remote assessment were discussed during the final closing meeting. 

Zero opportunities for improvement (OFI) and three comments with observations for NOP to consider in 

its management system were identified during this remote Peer Review.

Additional Comments

The management system of USDA NOP is very well documented, implemented, and functions in 

accordance with ISO/IEC 17011:2017 and US 7 CFR Part 205, National Organic Program requirements.

The Peer Review team was very impressed by the improvements in the organization, resources, and 

accreditation process since the last Peer Review in 2021. Significant improvements have been 

implemented since the last Peer Review in both the QMS and the Accreditation Process.

NOP personnel demonstrated sound knowledge in both management system and technical requirements.

The NOP program management also demonstrated commitment to continuous improvement.

IV. RESULTS OF PEER REVIEW PANEL EVALUATION

METHODOLOGY

The Peer Review team verified the compliance of USDA NOP to 7 CFR Part 205 and ISO/IEC 

17011:2017 based on the sampling of documents, interviews, and records; the Peer Review team

selected four accreditation files and associated NOP qualified assessors and staff in order to verify 

the accreditation process and competency. The conclusions of the Peer Review team are based on 

objective evidence collected and observed during the assessment and are contained in this report 

as compiled by the lead and technical evaluators.
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Previous OFIs 

The OFI cited from 2021 was documented and reviewed by the Peer Review team during the 2022 

remote assessment to verify the effectiveness of the actions implemented by NOP. The outcome of 

this review is presented below:

2021 Opportunity for 

Improvement 

2022 Verification of the effectiveness

2021-USDA NOP-01-OLLEM-(17011) 4.4.6

NOP has the opportunity to 

improve its risk analysis matrix

developed to document potential 

threats to the impartiality of the 

NOP’s operations and activities. 

The NOP 1009 Risk Mitigation Table was finalized and sent 

to the NOSB – CACS Subcommittee for review and approval

in the NOP letter dated November 18, 2021.

https://www.ams.usda.gov/sites/default/files/media/CACSRis

kMitigationProp.pdf

Following Public Comment, CACS and then the full NOSB 

voted to accept the proposal on the NOP’s Risk Mitigation 

Table but with some modifications as described in their 

Proposal. It will be provided to NOP as a Recommendation, 

and NOP will update and finalize the table accordingly. 

CLOSED

2022 Opportunities for Improvement

During this remote assessment, the Peer Review team did not identify any finding/opportunity for 

improvement. 

2022 Comments

During this remote assessment, the Peer Review team identified three observations classified as 

Comments. These comments originated from the Peer Review team and can be considered by 

NOP as examples of good practices in the accreditation process.

COMMENT # 1

NOP 1000 Quality Manual: section I Scope and section 2 Normative references showing 4 

links to the website. These 4 Links are no longer working. NOP was able to find the information 

on the website; however, it would be convenient to update these links during the next revision 

of the Quality Manual.

NOP 1010 NOP Quality Management System: section 4.5 Final clearance, Approval and 

Publication paragraph 5 requires the Quality Manager to send an email to the entire NOP 

announcing the addition and availability of the document.

Section 4.6 Obsolete Documents requires the Quality Manager to add an “Archived” watermark 

to the document.

The activities above (for communication and watermark on obsolete documents) are not 

always followed by NOP.

COMMENT # 2

NOP’s current policy is to keep the records indefinitely. NOP is working on a new document 

which lists all types of records with the retention and final disposition for each. Document: NOP 
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Records File Plan and Disposition Schedule. The document is in draft form and in process of 

being updated and approved. ANAB recommends that USDA NOP finalize this new document.

COMMENT # 3

NOP has strengthened the entire organization over the last two years by increasing its staff 

and integrating work across all Divisions, thus ensuring that all key positions have strong depth 

to enable them to handle the current workload. There were isolated instances where a lack of 

depth in personnel was evident. Specifically, the position of Appeals Management is staffed 

with one person with no additional persons observed to be cross-trained. As the NOP grows, 

the need to have more than one person able to fulfill the requirements of this position will 

become necessary.

2022 Strengths

The Peer Review team identified positive processes and activities during the 2022 remote

assessment. The following are the strengths identified by the team:

NOP PROCESS COMMENTS

Quality Management 

System The NOP Quality Management System is documented in 

accordance with the ISO/IEC 17065 and 7 CFR Part 205. 

NOP demonstrated that the system is well documented and 

implemented.

In January 2022, the NOP announced they had trademarked the 

organic seal to provide additional authorities for oversight. 

NOP objectives and 

goals NOP develops goals and objectives annually which informs the 

program’s projects and strategic planning. 

During this peer review, NOP demonstrated success in reaching its 

goals and objectives, and exceeded some expectations set for 2021 

and 2022. 

Team work approach NOP has created a competent and effective management team. 

During this peer review, ANAB collected evidence that the NOP 

team works from its foundation of clearly defined purpose and goals.

All NOP personnel interviewed demonstrated understanding and 

commitment to NOP business goals. 

Assessment NOP is in the process of developing cross-platform reports to 

increase efficiencies in oversight capabilities, and in managing audit 

scheduling for certifiers and satellite offices.

During the Peer Review, NOP demonstrated continuous 

improvement in all aspects of the assessment from increased staff 

hires, tracking work, scheduling audits, and to identifying fraud and 

compliance with NOP regulations.

Competency NOP continues to develop new course offerings within the Organic 

Integrity Learning Center. 

The number of people taking the Learning Center modules also 

continues to increase, including modules designed to increase the 

knowledge and skills of organic inspectors. 
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Team Work NOP hired Materials Specialists in both the Accreditation and 

Compliance & Enforcement Divisions.

NOP has implemented cross-divisional discussions about materials 

which support increased consistency in materials compliance and 

risk identification.

In addition, the NOP materials specialists are working with the ACA 

who has an active materials group now in place so that all certifiers 

can more easily receive notice of potential issues and any changes 

to the approved materials lists.

Number of Staff The NOP has continued to hire staff in all Divisions to meet the 

expanding number of certified producers worldwide.

NOP Responsive to 

Public Comment The Origin of Livestock Final Rule was published and the Proposed 

Rule on Organic Livestock and Poultry Standards is out for public 

comment. 

These rules have been developed through a public process and the 

NOP has effectively moved these through rulemaking.

The NOP has also responded to staffing concerns raised by 

certifiers by establishing the Human Capital project.

V. CONCLUSION

This report completes the work of the 2022 ANAB Peer Review for the USDA NOP accreditation body.

The review covers the NOP’s compliance with ISO/IEC 17011:2017 as well as a review of NOP’s 

accreditation procedures, decisions, and conformance with 7 CFR Part 205.

The Peer Review Panel members conclude that USDA NOP and staff continue to operate in conformance 

with ISO/IEC 17011:2017, 7 CFR Part 205 and NOP’s own policies and procedures. No findings and three 

observations classified as comments were identified during this remote assessment. 

NOP management consistently demonstrated their commitment to improvement to the Peer Review team. 

The Peer Review team would like to express appreciation to USDA NOP personnel for their cooperation 

and commitment during the Peer Review assessment.

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