National Organic Program

1400 Independence Avenue, SW

Room 2642-South, STOP 0268

Washington, DC 20250-0268

NATIONAL ORGANIC PROGRAM RESPONSE TO 2021 PEER REVIEW

December 29, 2021

FROM: Jennifer Tucker, Ph.D.

Deputy Administrator

National Organic Program (NOP)

SUBJECT: National Organic Program Response to 2021 Peer Review

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 National 

Organic Program (NOP) Accreditation.” For its 2021 peer review, the NOP contracted with the 

ANSI National Accreditation Board (ANAB). The 2021 ANAB Peer Review Panel evaluated 

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

an international quality standard for accreditation bodies

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

policies and procedures, and ISO/IEC 17011, and shared positive feedback about several areas of 

program operations.

Opportunities for Improvement

Below is NOP’s summary of ANAB’s one recommended area for improvement.

1. Impartiality Risk Analysis. NOP can improve its existing draft risk analysis matrix, 

which documents potential threats to the impartiality of the program, by finalizing the 

document. This includes identifying any additional potential threats to impartiality, and 

explaining the classification of different types of threats, including residual levels of risk 

after mitigation.

NOP Response

NOP agrees with the importance of actively monitoring and managing potential risks to 

impartiality in its accreditation program, compliance and enforcement activities, and other 

program activities. Since the 2020 Peer Review was completed, NOP has focused on developing 

a process to better document the program’s risk mitigation strategies for safeguarding 

impartiality. In response to the opportunity for improvement, the NOP is implementing the 

following actions:

1. Risk Analysis. NOP has completed its draft Risk Mitigation Table documenting the ways 

in which the program mitigates and controls potential threats to the program’s 

impartiality. NOP included additional areas of potential risk in the table, and an 
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explanation of how the program manages the potential harm from potential threats. As a 

part of the new safeguarding impartiality process, NOP has requested the National 

Organic Standards Board (NOSB) review and comment on NOP’s risk mitigation 

strategies in place during the Spring 2022 NOSB public meeting. Additionally, this 

review by the NOSB satisfies the ISO-based requirement for stakeholder input and 

provides additional insight in how the NOP can continuously improve its own processes. 

Next Steps

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

seriously and will continue to evolve our process controls and planning in response to ANAB’s 

comments and feedback. By focusing on quality and risk-aware processes, the NOP continues to 

support the organic community and maintain organic integrity for all.