National Organic Standards Board

Compliance, Accreditation and Certification Subcommittee Proposal

Inspector Qualifications and Training

February 26, 2018

I. INTRODUCTION

Since passage of federal organic standards over twenty years ago, the organic sector has seen rapid 

growth to nearly $50 billion in sales in the U.S. Such growth has driven expansion in organic production 

around the globe, and in turn, the growth of increasingly complex organic supply chains. With wellpublicized incidents of proven fraudulent imports in the last year, and recognition such fraud impacts all 

players in the trade, the need for qualified inspectors experienced in a broad range of operations diverse

in scope and scale has never been greater.

Inspectors play an essential role in organic certification, often serving as the sole public face of a 

certification agency (certifier) to the certified operation. Inspectors are the eyes and ears of the certifier, 

responsible for verifying and documenting organic control points. They play a crucial role in protecting 

the integrity of the organic supply chain.

USDA organic regulations require that certification staff, including inspectors, have sufficient expertise in 

organic production and handling techniques (7CFR 205.501(a)). This proposal seeks to highlight the 

criteria for qualifications and training necessary to be an effective and competent inspector. The 

Subcommittee acknowledges this discussion can just as easily relate to certification reviewers—and 

certifiers at large—as it does to inspectors. The criteria outlined below should be considered essential 

for all individuals and certifiers; however, for the purpose of this document we are focused on the 

inspector.

The Subcommittee recognizes the extensive body of work that has already been created in an effort to 

build the foundation for a skilled pool of organic inspectors. We do not intend for this to substitute for 

that work but to further build on this foundation, with particular focus on complex organic supply 

chains.

Many resources regarding inspector training and qualification exist and there are general agreements 

among certifiers on the minimum qualifications they outline. Nevertheless, USDA organic regulations do 

not include mandatory requirements for inspector qualifications or training. The Subcommittee 

proposes that the establishment of mandatory qualifications, ideal levels of experience or background, 

and compulsory continuing education tied to the scope and scale of operations to which inspectors 

would be assigned, would strengthen the certification system.

II. BACKGROUND

The initial and continuing training of inspectors and the establishment of minimum and ideal

qualifications is not a new topic. Since 1991, the International Organic Inspectors Association (IOIA) has 

promoted and provided inspector training to provide a basis for consistency and integrity in 

certification. Certifiers and independent training organizations provide training for staff and contract 

inspectors, addressing changes and updates to the regulations to provide a basis for consistency and 

integrity in certification. Certifiers provide specific training to ensure that the contract inspectors they 

work with are familiar with the forms, procedures, and processes of their agencies. Training resources 

include the International Organic Inspectors Association (IOIA), the American National Standards 

Institute (ANSI), the International Organization for Standardization (ISO), the Accredited Certifiers 

Association (ACA), state agency-sponsored investigative trainings, and others.
Inspectors may be independent contractors working for one or more certifiers, or they may be directly 

employed by a certifier. Most certifiers have policies stating minimum qualifications for contracted and 

staff inspectors and may be responsible for the initial training of an inspector. However, independent 

contractors are responsible for establishing their own knowledge base, maintaining their knowledge,

and keeping their expertise current through continuing education. Such diverse backgrounds and 

training schemes make for an inconsistent baseline of knowledge and practice, exposing the certification 

system to potential weaknesses.

In an April 2012 memo to certifiers, the NOP recognized the vital role inspectors play in ensuring organic 

integrity. The memo reminded certifiers of the importance of a rigorous hiring and selection process 

when considering inspection personnel. The NOP noted plans to release draft guidance covering the 

qualifications necessary for inspectors and reviewers, however, guidance was not published.

In 2011, NOP entered into a contract with IOIA to further describe baseline qualifications and continuing 

education of inspectors. In using this work, in early 2018 the ACA developed a best practices document 

for organic inspector qualifications. Both have provided valuable insight into the development of this 

discussion document.

III. RELEVANT AREAS OF THE 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
IOIA Criteria for Inspectors and Reviewers working for NOP Accredited Certifying Agencies, November 

2011 (See Appendix 1) 

IV. DISCUSSION

Inspector qualifications can be broken down into several distinct areas:

1. Knowledge

Inspector knowledge includes proficiency in inspection & auditing techniques; strong 

understanding and knowledge of the USDA organic regulations; understanding of organic 

certification and inspection processes; and familiarity with the documents and procedures of 

the certifier whom they represent. It is essential this knowledge base be in the scope and scale 

of production in which the inspector is working.

2. Skills

Essential skills include keen observation; clear communication in spoken and written form as 

well as an ability to articulate regulations and requests for information; a high level of 

organization; and strong investigative skills. As much as an inspector must be able to 

communicate and observe, they must also know how to read a situation and interviewee, to 

listen and to allow an operator the space to convey answers to questions and the knowledge 

they hold of their operation.

Other skills and abilities vital to the inspector’s role are a code of honest and ethical work 

practice; diplomacy; impartiality; and an overall professional approach to their work.

3. Experience

An inspector must have experience inspecting the specific scope of operations to which they are 

assigned. For example, while an inspector may have experience with and deep knowledge of 

poultry operations, they may have little experience in other production under the livestock 

scope such as dairy, beef, or goats, production systems with unique aspects.

Similarly, an inspector may have experience evaluating small flocks of birds or several cows on a 

diversified farm. But they may not have had the experience of evaluating large-scale production 

systems with multiple barns or larger herds. Thus, they should not be assigned or accept work 

evaluating these operations until they have gained the capability and training to do so.

Mentorships, though often challenging for independent inspectors to arrange, can provide a 

pathway for gaining experience.

Such experience also applies to handling operations. An inspector may have experience verifying 

small production lines, value-added on-farm processing, or basic multi-ingredient products. 

However, applicable skills and experience are necessary for tracing back complex supply chains 

across multiple handlers and geographical trade boundaries and navigating the varying 

standards and protocols these supply chains entail.

4. Training (Initial and Continuing)

Training can come in a variety of ways and often ties directly to experience gained working in 

other roles in the organic sector. Though valuable, related experience does not supplant the 

need for intensive, inspection-specific training. Additionally, training does not end once initial 

proficiencies are reached and deemed sufficient. As in any profession, investment in continuing 

education is crucial to keeping current with evolving regulations, technologies, and trade.
Prior to taking the lead on inspections, an inspector must know the scope of operation; be 

educated in the tenets of auditing; be deeply familiar with the relevant regulations; and have 

familiarity with the certifier’s procedures and forms. Only when these minimum qualifications 

have been met should an inspector begin in-field training and evaluation.

As noted above, a variety of resources exist to provide initial training in organic inspection, and 

the Subcommittee encourages referencing these for greater detail in establishing minimum 

baselines. Additionally, certifiers provide training of their own, often coupling in-house training 

with independent training, and then following with shadowed or mentored inspections with 

seasoned staff. However, as noted above, there is a lack of mentorship opportunities for the

independent inspector seeking to gain direct experience in the field.

Continuing education can take the form of advanced in-person training or webinars to increase 

competency in areas such as complex trace back and mass balance audits, and updates to 

regulations that require additional evaluation methods. No matter the method, continuing 

education must be a part of maintaining and improving professional competence in the field.

5. Evaluation

Evaluation is essential to both the beginning inspector and the inspector with many seasons and

varieties of operations under their belt. For the beginning inspector, evaluation should be

incorporated in initial training so that productive feedback may be offered, positive practices

reinforced, and areas for improvement identified. Especially helpful is coordinating inspections

with seasoned inspectors with experience in the scope and scale inspected so that a new

inspector may shadow, partner, and then lead on inspections while training. This provides

opportunity for feedback and support as the inspector becomes comfortable and competent in

their role.

An earlier proposal, Personnel Performance Evaluations of Inspectors, was discussed at the

Spring 2017 NOSB meeting and addressed criteria for the field evaluation of existing inspectors.

V. RECOMMENDATIONS

The Subcommittee recommends the National Organic Program develop minimum qualifications and 

training, and continuing education guidelines to ensure a professional and competent inspector pool to 

meet the demands of ever-evolving and complex organic supply chains. These should include 

considerations of the criteria included above in the Discussion area of the document. The Subcommittee 

encourages the program to use existing resources in this area.

VI. REQUEST FOR PUBLIC COMMENT

The NOSB is requesting public comment from the community on the following questions:

• Are the criteria and qualifications laid out in the ACA Best Practices for Inspector Qualifications

sufficient to establish a baseline for inspector competency? What changes do you suggest?

• What other resources are available to train new and seasoned inspectors?

• Should there be a licensing system for inspectors by scope and/or scale in recognition of their

specific skills? How do you think such a system should work?

• While this document focuses on inspectors, what other roles should the CACS consider (e.g.,

initial and final reviewers as well as other certifier personnel)?
• What models from other industries that facilitate high quality personnel through training and

oversight could the organic industry emulate?

Subcommittee vote

Motion to approve this discussion document on inspector qualifications

Motion by: Harriet Behar

Seconded by: Ashley Swaffar

Yes: 7 No: 0 Abstain: 0 Recuse: 0 Absent: 0 

Approved by Scott Rice, CACS Chair, to transmit to NOSB February 26, 2018
IOIA Draft 3 TASK 1 Page 1 of 37

Task 1

Criteria for Inspectors and Reviewers working for 

NOP Accredited Certifying Agencies

Revision November 6, 2011

Appendix 1
IOIA Draft 3 TASK 1 Page 2 of 37

Table of Contents

1. Overview 3 

2. Inspectors

2.1 Inspector Responsibilities (Key Activities) 3 

2.2 Recommended Requirements 6 

2.2.1 Knowledge 6

2.2.2 Skills (areas of expertise) 6 

2.2.3 Abilities (capacity, talent) 8 

2.2.4 Personal Attributes 9 

2.2.5 Work Experience 10

2.2.6 Training 11

2.2.7 Inspection Experience 11 

2.3 Recommended Performance Evaluation Standards 12

2.4 Recommended Professional Development Activities 17

3. Reviewers

3.1 Reviewer Responsibilities (Key Activities) 18

3.2 Recommended Requirements 20

3.2.1 Knowledge 20

3.2.2 Skills 21

3.2.3 Abilities 22

3.2.4 Personal Attributes 22

3.2.5 Work Experience 23

3.2.6 Training 24

3.2.7 Reviewer Experience 25

3.3 Recommended Performance Evaluation Standards 25

3.4 Recommended Professional Development Activities 29

4. Definition of terms 30

5. References 33

6. Appendices 34

7. Endnotes 35
IOIA Draft 3 TASK 1 Page 3 of 37

1. Overview

These proposed ACA Inspector and Reviewer Criteria reflect the maturing of the organic sector 

domestically and worldwide. The professions of organic inspector and reviewer are barely thirty 

years old. While recognizing the variation in ACAs (private, state) and of work arrangements 

(contractual, full time, part-time), these proposals address the need for consistency 

inherent in a regulatory environment, while recognizing the tremendous diversity 

throughout - and fundamental to - the organic sector. 

In this document, ACA Inspector and Reviewer Criteria are considered within the four scopes of 

the National Organic Program (NOP) Regulations, i.e., crop production, wild crop harvesting, 

livestock production and handling. 

Section 2 describes the responsibilities of organic inspectors. Specific knowledge, skills, 

abilities and personal attributes for organic inspectors are discussed. Specific work place 

experience, training and inspection experience are also recommended. Based on these criteria, 

Performance Evaluation Standards are then set forth. Finally, examples of Professional 

Development Activities are listed.

Section 3, similarly, describes criteria for Initial Reviewers and Final Reviewers, followed by 

specific knowledge, skills, abilities, personal attributes, work place experience, training and 

review experience. Section 3 concludes with Performance Evaluation Criteria and Professional 

Development Activities for reviewers.

Section 4 defines specific terms for the reader.

Section 5 is based on the Organic Food Production Act of 1990, the NOP Regulations, 

numerous published guidance and policy documents, as well on the work of non-profit 

organizations with considerable expertise in the field. 

Appendix, Section 6 suggests guidelines for preparation, inspection and reporting time for 

various inspections. 

2. Inspectors

2.1 Inspector Responsibilities (Key Activities)

Organic inspections are an evidence-based and standards-based verification of the accuracy of 

the Organic System Plan to verify whether or not the Organic System Plan is implemented and 

to determine whether production/handling operations and inputs used are in compliance with 

NOP Regulations.1

 

Scopes of inspections are crops, wild crop harvesting operations, livestock operations or 

handling (processing) operations. Throughout the inspection, the inspector is gathering 

information by interviewing personnel, observing production/handling practices, and verifying 

records. Each step of the way, information is assessed against the applicable standards and 

issues of concern are identified.

Inspections can be broken down into the following tasks: 
IOIA Draft 3 TASK 1 Page 4 of 37

1. Review file and assignment from Accredited Certifying Agent (ACA); prepare an

inspection plan and make arrangements with operator, taking care to schedule the

inspection at a time in the production cycle when organic operations can be

observed2

;

2. Conduct an opening interview with the operator and relevant personnel (includes

verifying scope of inspection, operator understanding of ACA forms, etc.)3

3. Verify accuracy of OSP and all other information supplied by operator, with particular

attention to areas where organic integrity is at risk (i.e., buffers, inputs). Verify

production/handling capacity of the operation (yield estimates) and conduct on-site

inspection of in/out balance and traceability4

;

4. Verifying label and packaging;

5. Clarify issues of concern which were identified in the pre-inspection review;

6. Assess corrective actions taken to address minor non-compliances for certified

operators5

;

7. Identify and summarize areas of potential non-compliance6;

8. Identify and communicate additional information to be submitted by operator7;

9. Gather samples, provide inspected party with a receipt and maintain chain of custody8;

10. Conduct and document an exit interview with the operator according to NOP

Regulations and ACA procedures9

;

11. Communicate the findings to the ACA according to ACA procedures10.

In addition, the following tasks are to be carried out by the inspector:

For organic crop producers:

Evaluate soil management, assess adjoining land use, assess buffer zones; review land history, 

assessing production capacity of the land, evaluate seeds and planting stock used, examine 

crop rotation practices, assess pest control practices, assess harvest, labeling and shipping

procedures. 

For organic wild crop harvest producers:

Evaluate designated harvest areas, sustainable harvest practices, and procedures that ensure 

an adequate audit trail.

For organic livestock producers: 

Inspectors evaluate soil management, adjoining land use, buffers, land history, production 

capacity of the land, seeds and planting stock used, health care practices, origin of livestock, 

livestock living conditions, conditions for temporary confinement of livestock, and pasture 

management practices. 

For organic handlers:

Evaluate receiving, processing, pest control, storage, labeling and shipping, as well as practices 

to prevent commingling and contact with prohibited substances.

For split11 operations (operations that handle both organic and non-organic): 

NOP 205.100, NOP 201(a)(5) and NOP 205.400(c) specifically describe that on split operations, 

‘the inspector must inspect non-certified production and handling areas, structures and offices to 

assess: 

1) the potential for commingling;

2) steps taken to prevent commingling and contact with prohibited substances and

3) if any non-organic or contaminated products are being sold as organic.
IOIA Draft 3 TASK 1 Page 5 of 37

Most inspections are regular annual inspections, either of first-time operators or of certified 

operators12 going through the annual renewal process. In the organic inspection system, annual 

inspections are full inspections, which cover every aspect of the production/handling operation 

regulated by the organic standard. At the request of the ACA, an inspector may also conduct a 

follow-up inspection, which has a more limited scope. These typically focus on previously 

identified non-compliances and issues of concern, or a change in the operation (i.e. addition of 

new acreage or production line). Finally, inspectors may conduct unannounced inspections, on 

operations selected by the ACA based on particularly high risk levels, complaints, or other 

parameters established by the ACA, including random selection and fulfillment of ACA 

accreditation requirements13. 

Because organic certification is not only about end products, organic inspection involves 

understanding and assessing entire production systems and processes14, which can be very 

complex and time-consuming. Some examples of simple to highly complex operations are in 

Appendix 1, with estimated inspection times indicated for each example. It is recommended 

that beginning inspectors not be assigned highly complex inspections until inspection 

experience is gained and a certain proficiency is mastered. 

Most inspectors work individually. Teams may be assigned for particularly adverse compliance 

situations where additional witnesses may be desirable. 
IOIA Draft 3 TASK 1 Page 6 of 37

2.2 Recommended Requirements 

Recommended requirements for inspectors depend on the complexity and scope of the 

operations being inspected (crop, wild crop, livestock and handling). 

2.2.1 Knowledge

There are six bodies of knowledge and facts required of organic inspectors.

a. Regardless of the type of inspection (crop, wild crop, livestock, handling), a good

understanding of inspection (auditing) techniques and protocols is required15.

b. Inspectors must have a demonstrated understanding of organic certification and

inspection processes16, knowing their role and limitations within them.

c. Specific to the inspection category, a demonstrated understanding of the applicable

organic regulations (CFR Title 7 Part 205 NOP and OFPA) are required. This does not

just mean knowing what the regulations say and where to find it, but most importantly,

how to apply the regulations to practical situations. The inspector must be able to explain

applicable standards and certification procedures to the operator.

d. A good understanding of production/handling processes is a critical requirement. Having

a good knowledge of current practices in the operators’ conventional counterpart is a

necessary tool for organic inspectors, enabling effective identification of risks to organic

integrity in the organic production/handling process.

e. Inspectors should be proficient – and current – in their understanding of the specific

procedures, documentary requirements and forms of the ACA17 for whom they work.

ACAs each have their own ways of gathering organic product recipes, input profiles, or

finished product labels.

f. Organic inspectors should be aware of other rules and regulations applicable to the

inspection category, notable food safety requirements18. Although such regulations are

technically beyond the scope of organic inspections, if the organic inspector observes

obvious violations of them, they are typically addressed in an addendum to the

inspection report, for the ACA’s attention.

2.2.2 Skills (areas of expertise)

Nine key skills (areas of expertise) are needed to conduct organic inspections and enable the 

organic inspector to fulfill inspection assignments effectively and efficiently. 

a. Observation skills: When conducting evidence-based inspections, a significant part of

the on-site time is spent in the field or on the production floor, understanding the ‘big

picture’ of a production system and observing the details which support (or contradict)

the Organic System Plan.

b. Communication:

1. Interviewing is a technique inspectors use to gather information so appropriate

interviewing techniques are required. Some good interview techniques are 19
IOIA Draft 3 TASK 1 Page 7 of 37

asking open ended questions, asking the same question a different way and 

paraphrasing.

2. Documenting/writing20: This includes correct grammar and spelling; accurate

writing that is clear, concise, and easily understood by the operator and reviewer;

facts vs. opinion; reference supporting documentation; citation of appropriate

NOP regulations; and explanation of issues of concern.

3. Active listening: Active listening is a structured way of listening and responding.

The elements of active listening are comprehending, retaining, and responding.

The listener asks questions and paraphrases back to the speaker to clarify

understanding. Listening carefully to operator responses reduces redundancy

during the inspection, improves accuracy, and shows respect.

c. Intermediate Math skills: Inspectors need to be able to convert easily from one unit of

measure to another, calculate yields, calculate annual feed requirements in livestock

operations, use formulas to verify in/out balances, and use percentages to validate

recipes and production reports etc.

d. Organization skills and time management21: managing preparation time, travel time,

on-site time (e.g., multiple sites) and reporting time efficiently; respect ACA deadlines;

use travel resources efficiently. Inspectors need to plan well, be prepared22, and be onsite at a time when organic operations can be verified23. The inspections must be

conducted with the authorized operator representative is present, moving smoothly from

one area of operations to another.

e. Information management and basic computer skills24 are required skills for inspectors,

both in the office and on-site. Specific risks and conditions to certification are flagged in

the preparation before inspection; these areas must be properly investigated,

observations noted in an orderly way, and conclusions communicated to the ACA.

Evidence of potential non-compliances must be substantiated, documented, tracked and

accurately reported. Working documents need to be appropriately kept secure, archived

and/or destroyed25. Demonstrated proficiency in word processing, use of spreadsheets

and data base management is required.

f. Investigative skills 26are required for all inspections, and especially those where the

inspector finds inconsistencies during the on-site inspection (i.e., if prohibited substance

use is suspected), when conducting complaint related inspections and in cases of

suspected fraud.

g. Sampling procedures: Correct sampling methods, appropriate handling of samples

(packing, labeling, shipping) and proper chain of custody impact the validity of test

results. These activities must be done according to the ACA’s contracted laboratory

procedures.

h. Skills specific to inspection scope: Additionally, numerous skills specific to the scope

of the inspection are required. The following table gives several examples for each

scope but this list is by no means exhaustive.
IOIA Draft 3 TASK 1 Page 8 of 37

Inspection scope Examples of skills specific to inspection scope

Crop - able to recognize weed species and assess impact

- able to assess soil structure and fertility, by consulting soil test results, observing 

crop performance and observing signs of compaction, good tilth etc.

- able to assess possible sources of contamination and recognize signs of pesticide 

injury to crops or other vegetation27

- able to use GPS to validate field sizes and boundaries

-able to assess crop rotations and management of pasture as a crop

- able to evaluate farm inputs

-able to evaluate manure and compost management

Wild crop - able to assess sustainability of harvesting practices

- able to read maps

- able to recognize possible source of contamination and signs of damage to wild 

crops or other vegetation

- able to determine damage to harvested crop and dependent species (plant 

and/or animal) by harvesting or over-harvesting 28

Livestock - able to calculate dry matter intake for ruminant animals

- able to assess native and tame pasture production

- able to assess overall condition of herd/flock (animal behavior, physical 

appearance

- able to asses adequate nutrition and evidence of malnutrition or parasites 

etc.)29

- able to evaluate synthetics used

- able to assess the general animal husbandry practices used for species on 

operation

- able to assess input for farms with livestock

- able to assess feed handling procedures to avoid contamination on split 

operations

Handling - able to compare proposed recipes, actual production and finished product labels

- able to verify compliance of organic ingredients, non-organic ingredients, food 

additives and processing aids

- able to assess compliance of facility pest management protocols

- able to assess equipment for commingling or contamination potential

- able to assess label compliance

- able to identify and report major and obvious food safety concerns 30

2.2.3 Abilities (capacity, talent)

Beyond knowledge and specific skills, it is recommended that organic inspectors develop 

certain abilities to facilitate their work: 

a. attention to detail without losing sight of the whole

b. able to differentiate between inspection and advice31

c. discernment32: differentiate between evidence and opinions33 judgment to interpret and 

adapt general guidelines to specific situations

d. analytical 

e. accuracy34

f. consistency

g. awareness of trends and developments in conventional and organic aspects of 

agriculture or food science
IOIA Draft 3 TASK 1 Page 9 of 37

h. self-assessment: can recognize own opportunities for improvement, can accept 

constructive criticism

2.2.4 Personal Attributes

Inspectors should possess personal attributes35 to enable them to perform inspections in 

accordance with principles of auditing. An inspector should be:

a. Honest and ethical. Integrity of the certification system rests on the integrity of its

players, including inspectors and reviewers. In quality systems, inspectors must be free 

of conflicts of interest with the operations for which they inspect. Conflicts of interest are 

declared annually36 and inspectors should defer any inspection assigned to them by an 

ACA with which they have a conflict of interest. Confidentiality37 is also important. 

Information learned about operations must be kept confidential in order to gain trust of 

operators and not be used by inspectors for personal gain. Inspectors also have a 

responsibility to report suspected fraud.

b. Impartial and non-discriminatory: Inspectors should be fair and objective38 during 

inspections and when reporting their observations to ACAs. Inspectors should be openminded to the types of people and management strategies they encounter. They need to 

treat all operators with respect and without bias. An inspector should also be aware of 

the cultural environment in which he/she is working.39

c. Professional in their conduct. Inspectors must be fit and in good mental health. As most 

inspectors work alone, they need to be self-reliant and able to function autonomously 

and decisively. During the inspection, the inspector represents an ACA and must follow 

ACA policies and procedures. They must follow all governmental laws that apply to their 

status, whether employees or contractors (ex. valid drivers license, liability insurance, 

reporting income, etc.) They should be punctual for appointments as well as meeting 

ACA deadlines. Inspectors should wear appropriate attire, pay attention to bio-security 

requirements, and have an awareness of personal safety. They should turn down work if 

too busy or if proposed assignment is beyond their realm of competence. Inspectors 

must be willing to travel and economical in their use of travel allowances.

d. Curious and tenacious. Asking questions is an important method used by inspectors to 

gather information. They must be curious about the systems they are observing in order 

to ask appropriate questions. They also must be systematic and continue asking 

questions until they have a good understanding that compliance is met.

e. Perceptive and versatile. Inspectors must be perceptive to quickly grasp an 

understanding of the variety of operations they encounter. They should have the 

flexibility to adjust to different situations and people.

f. Diplomatic. Inspectors must strive to maintain a pleasant and non-confrontational 

atmosphere throughout the inspection even while asking difficult questions. The 

inspection can be an exhausting process for the operator because it covers many areas 

of his/her operation in a relatively short period of time and patience of the operator may 

wear thin.
IOIA Draft 3 TASK 1 Page 10 of 37

g. Support goals of organic farming and handling. This last personal attribute is important 

as the attitude of the inspector toward his/her work is evident to the operator during an 

inspection. A lack of support can undermine the authority needed by an inspector.

2.2.5 Work Experience

Organic inspectors should have a minimum of one year work place experience in the 

category40 in which they will be inspecting. Examples of possible work place experience are 

given below:

Inspection category Examples of work place experience

Crop Growing up on a farm and actively participating in the daily and 

seasonal tasks

Operate own farming operation

Employment on farming operation

Farm manager

Educator at community college

Wild crop Experience as harvester of wild crops

Work in a field of natural resource management

Livestock Growing up on a livestock farm and actively participating in the daily 

and seasonal tasks 

Operate own livestock farming operation

Employment on livestock operation

Livestock farm manager

Herdsman

Veterinarian or veterinary assistant

Extensive 4-H or FFA experience

Trainer at community college

Handling Production worker in food processing facility

Management or shift foreman

Employment in food retail and/or preparation

Research and development in food processing
IOIA Draft 3 TASK 1 Page 11 of 37

2.2.6 Training

It is recommended that five kinds of training be required before beginning supervised inspection 

work:

1. Education in the category

2. General auditor training

3. Standards training

4. Specific organic inspection training

5. Training to ACA procedures and paperwork

Initially, this training will be intense and over an extended period of time. As inspection 

experience is gained, training will take the form of refresher courses or specialty modules. This 

is summarized in the table below; in the table, ‘category’ refers to crop, wild crop, livestock or 

handling:

Recommended 

training 

requirements

Inspector41 Licensed Inspector Master Inspector 

Sector 

education

College degree in agriculture 

or food science or related field, 

or relevant work place 

experience

Training in related discipline

10 hrs/yr

Training in related 

discipline

7 hrs/yr

Auditor training ISO auditing overview 

(1-2 hrs)

Relevant training from 

private training providers 

15 hrs/yr

(suggested, not required)

Lead auditor training

40 hrs (suggested, not 

required)

Standards 

training

Basic standards training

Crop (6 hrs)

Livestock (6 hrs)

Wild crop (4 hrs)

Handling (8 hrs)

Annual update to standards 

and national list

1-2 hrs per category per 

year, depending on changes 

which have been adopted

Annual update to standards 

and national list

1-2 hrs per category per 

year, depending on 

changes which have been 

adopted

Organic 

inspection 

training

Basic organic inspection 

training in appropriate 

category(level 100)

4.5 days/category42

Field Training with mentor (3 

supervised inspections and 7 

supervised inspection 

reports)43

Intermediate organic 

inspection modules related 

to appropriate category 

(level 200)

10 hrs/yr

Advanced organic 

inspection modules related 

to appropriate category 

(level 300)

3-5 hrs/year

ACA 

procedures and 

paperwork 

training

Training to ACA procedures Annual update to ACA 

procedures

Annual update to ACA 

procedures

2.2.7 Inspection Experience

Only in exceptional circumstances can a perfect combination of knowledge, skills, abilities, 

personal attributes, prior work experience and training be sufficient to autonomously conduct 

organic inspections. Some ACAs ensure that new inspectors are mentored by experienced 

inspectors. Inspections are conducted by the apprentice under supervision of the mentor; exit 
IOIA Draft 3 TASK 1 Page 12 of 37

interview documents and reports are written by the apprentice but approved and co-signed by 

mentor. 

Furthermore, it is recommended that beginning inspectors should only be assigned simple 

inspections, Licensed inspectors can be assigned simple and intermediate inspections, and only 

Master inspectors should be assigned inspections at all levels of complexity. ACAs might 

occasionally need to assign a lower level inspector, but these deviations should be rare. ACAs 

should have a systemic way to document the level of inspector and the corresponding level of 

complexity of the operations they have been assigned. In this way, operators will work with 

inspectors sufficiently trained for their type of operation, inspections will be efficient, and organic 

compliance issues will be systematically addressed.

Finally, only Master inspectors would have the qualifications to mentor apprentices.

Inspector Licensed Inspector44 Master Inspector

Inspection 

Experience

Field training (three 

supervised inspections and 

7 additional inspection 

reports reviewed by a 

supervisor/mentor) per 

category 

Have demonstrated 

proficiency in simple 

inspections in appropriate 

category, 10 unsupervised 

inspections per category

Have demonstrated 

proficiency in simple and 

medium inspections in 

appropriate category over a 

period of 2 years or 30 

inspections per category

Can mentor apprentices.

Notes:

● Category refers to crop, wild crop, livestock or handling

● In cases where a single inspection takes several days, length of experience can be expressed as 

time rather that in number of inspections, where 1 inspection = 0.5 days on-site inspection

2.3 Recommended Performance Evaluation Standards

Annual performance evaluations contribute to the continuous improvement of inspectors as well 

as being a requirement pursuant to the NOP Final Rule, 205.501(a)(6) and 205.510(a)(4).

Observation during inspection by a representative from the ACA would be periodic but not 

necessarily annual. Observation during inspection may also include an inspection witnessed by 

a peer (another inspector). 

Area of competence to be 

evaluated

Evaluation criteria Evaluation method

2.1 Responsibilities Review file and assignment from 

ACA; prepare an inspection plan 

and make arrangements with 

operator, taking care to schedule 

the inspection at a time in the 

production cycle when organic 

operations can be observed

Inspection well-prepared 

(audit plan, checklist for use 

during inspection)

Inspection appropriately 

scheduled

Feedback from 

operators

Observation during 

inspection

Interview inspector

Conduct an opening interview with 

the operator and relevant 

personnel

Opening interview covers 

essential elements (scope,

audit plan, safety/bio-security, 

confidentiality, verifying 

accuracy of information 

provided by operator etc.)

Observation during 

inspection
IOIA Draft 3 TASK 1 Page 13 of 37

Area of competence to be 

evaluated

Evaluation criteria Evaluation method

Verify accuracy of OSP and all 

other information, with particular 

attention to areas where organic 

integrity is at risk (buffers, inputs, 

split operations)

Organic Control Points 

systematically verified.

Materials appropriately 

reviewed.

Observation during 

inspection

Review of inspection 

report

Verify production/handling capacity 

(yield estimates); conduct on-site 

inspection of in/out balance and 

traceability

Record keeping system 

assessed.

Random trace back 

conducted.

In/out balance completed.

Review of inspection 

reports

Observation during 

inspection

Verifying label and packaging Labels and packaging 

verified.

Review of inspection 

reports

Observation during 

inspection

Clarify issues of concern which 

were identified in the preinspection review.

Issues of concern which 

were identified in the preinspection review are 

clarified.

Review of 

inspection reports

Observation during 

inspection

Assess corrective actions taken to 

address minor non-compliances for 

certified operators.

Previous conditions reviewed 

and verified.

Review of inspection 

reports

Observation during 

inspection

Identify and summarize areas of 

potential non-compliance

Potential areas of noncompliance identified and 

summarized.

Review of inspection 

reports

Observation during 

inspection

Identify and communicate 

additional information to be 

submitted by operator.

Missing information 

identified and 

communicated.

Review of inspection 

reports

Observation during 

inspection

Gather samples, provide receipt, 

maintain chain of custody, and 

according to ACA procedures

Samples gathered as per 

ACA and contracted 

laboratory procedures.

Review of inspection 

reports

Observation during 

inspection

Conduct and document an exit 

interview with the operator 

according to ACA procedures

Exit interview conducted, 

covering all essential 

elements.

Review of inspection 

reports

Observation during 

inspection

Communicate the findings to the 

ACA according to ACA procedures.

Report filed punctually.

Report well-written, clear, 

concise and needing no 

further information from 

inspector. 

Review of inspection 

reports

2.2.1 Knowledge Auditing techniques protocols Auditing protocols followed. Review of training 

record, course content 

and result

Observation during 

inspection

Organic certification and 

inspection processes

Certification and inspection 

procedures understood and 

followed.

Observation during 

inspection.

NOP regulations Organic requirements 

understood; could clearly 

Review of training 

record, course content 
IOIA Draft 3 TASK 1 Page 14 of 37

Area of competence to be 

evaluated

Evaluation criteria Evaluation method

explain to operator. and result

Review of inspection 

reports

Observation during 

inspection

Organic (and conventional) 

production and handling processes

Understands system being 

inspected; using terminology 

specific to system being 

inspected; thorough 

assessment of Organic 

Control Points.

Review of training 

record, course content 

and result

Observation during 

inspection

ACA procedures Uses ACA forms correctly.

Follows ACA procedures.

Review of training 

record, course content 

and result

Review of inspection 

reports

Feedback from 

reviewers

Related laws and regulations. Asks questions and makes 

observations during 

inspection pertaining to 

related laws and regulations.

Accurately reports findings.

Review of training 

record, course content 

and result Observation 

during inspection

Review of inspection 

report

2.2.2

Skills

Observation Attention to detail

Relevance of questions

Observation during 

inspection

Communication: 

Interviewing

Documenting/writing

Listening

Use of open-ended 

questions, paraphrasing

Correct grammar, spelling

Accurate, clear, concise 

Active listening

Observation during 

inspection

Review of inspection 

reports

Evaluation Analyzes data, draws 

conclusions based on 

evidence, identifies and 

assesses OCPs

Observation during 

inspection

Review of inspection 

reports

Math Verification of rations, DMI, 

recipes etc.

Verification of in/out balances

Logical analysis of results

Review of training 

record, course content 

and result

Review of inspection 

reports

Organizational skills and 

time management

Plans well

Punctual

In control of agenda

Efficient

Observation during 

inspection

Review of time began 

and time ended 

inspection

Submission of 

inspection report

Information management Well organized

Prepared - and uses -

checklists

Demonstrate appropriate 

computer skills

Observation during 

inspection

Review of inspection 

report

Investigative skills Asks good questions. Observation during 
IOIA Draft 3 TASK 1 Page 15 of 37

Area of competence to be 

evaluated

Evaluation criteria Evaluation method

Is inquisitive. 

Documents findings.

Evidence based approach.

inspection

Review of inspection 

report

Sampling procedures Samples gathered as per 

ACA and contracted 

laboratory procedures.

Maintains sample integrity 

and chain of custody.

Review of training 

record, course content 

and result

Skills specific to inspection scope 

(see examples in table 2.2.2.i)

Demonstrates competence 

specific to inspection scope

Observation during 

inspection

Review of reports

Feedback from 

operators

2.2.3

Abilities

Attention to detail Satisfactory performance: 

reviewers do not need to get 

further information from the 

inspector, inspection 

paperwork is clear and 

complete as submitted

Observation during 

inspection

Review of reports

Feedback from 

reviewers

Able to differentiate between 

inspection and advice

Does not provide advice to 

the operation; does not 

assist operators to

overcome barriers to 

certification

Observation during 

inspection

Discernment Demonstrates good sense of 

judgment; shows ability to 

interpret and adapt general 

guidelines to specific 

situations

Observation during 

inspection

Review of reports

Analytical Demonstrate logical approachObservations during 

inspection (specifically 

traceability tests)

Accuracy Absence of error Review of reports

Feedback from 

operators

Consistency Methodical approach Review of reports

Feedback from 

reviewers

Awareness of trends and

developments in conventional and 

organic – aspects of agriculture or 

food science

Appears to be up to date and 

knowledgeable

Review of training 

records

Capacity for self-assessment Open to constructive criticism

Pro-active in seeking 

additional training 

opportunities

Annual performance 

review

2.2.4 Integrity, confidentiality, freedom 

from conflict of interest, ethical, 

Satisfactory performance 

Declarations kept current 

Feedback from 

operators
IOIA Draft 3 TASK 1 Page 16 of 37

Area of competence to be 

evaluated

Evaluation criteria Evaluation method

Personal attributes open-mindedness, diplomacy, 

observant, perceptive, versatile, 

tenacity, decisiveness, selfreliance, punctuality; does not 

provide advice for inspected 

operations; professional in their 

conduct at all times; confidential;

be fit and in good mental health; 

economical in their use of travel 

allowances; cultural sensitivity, 

willing to travel

(confidentiality, C of I) Observation during 

inspection

Review of complaints 

filed naming the 

inspector

Review of annual 

documentation
IOIA Draft 3 TASK 1 Page 17 of 37

2.4 Recommended Professional Development Activities

There are a wide range of professional development activities in which organic inspectors 

should participate. They should be documented and included in their résumé, supported by 

course certificates and content lists whenever possible. This is a partial list of possible 

professional development activities:

● Conferences

● Workshops

● Community college and university courses

● eOrganic webinars

● ATTRA

● On-farm demonstrations

● Subscriptions to trade magazines

● Independent study/reading

● Networking45 (professional associations, listserves, etc.)

● Peer review: the IOIA 2010 survey refers to these as ‘witness audit with peers’. This 

concept rates highly as an additional element for inspector accreditation (licensing). 

● Performance review from certifiers: Per NOP regulation and accreditation 

requirements, ACAs must conduct an annual performance review of their inspection 

staff/contractors. At a minimum, reports, training records, feedback from operators, 

and complaints naming the inspector must be reviewed. Additionally, it is 

recommended that periodically (not every year) a qualified ACA representative 

accompany the inspector on an inspection and assess their performance, then meets 

with the inspector to give verbal and written feedback and discuss opportunities for 

improvement.

● Private coaching

● IOIA 200 level courses and 300 level courses46 (IOIA Training Institute) (advanced 

and specialty modules)

● IOIA training modules with tests47

Content lists for training activities are presented in Task 2.
IOIA Draft 3 TASK 1 Page 18 of 37

3 Reviewers

3.1 Reviewer Responsibilities (Key Activities)

There are two levels of review in the organic certification system: initial review48 (pre-inspection) 

and final review/certification decision (post-inspection)49. Initial review may be done by the same 

person as inspection, but the final certification decision, including identification of 

noncompliances, must not be made by the same person who did the initial review or 

inspection50. Depending on ACA procedures, the final reviewer makes the certification 

determination or the certification determination can be made by a different person, or even by a 

committee. 

Initial Review

The initial reviewers’ primary role is to verify, through thorough document review, whether or not 

the Organic System Plan (OSP) as submitted by the operator is complete and accurate51, has 

the potential to be in compliance with NOP Regulations and ACA requirements52, and is 

scheduled for on-site inspection53. Additional information from the operator may be requested.

The initial reviewer must verify that an operator who previously applied through another ACA 

and received a notification of non-compliance or a denial has addressed those issues54. 

Initial reviewers may review applications and/or continuation of certification documentation for 

all four scopes (crop, wild crop harvesting, livestock, or handling). 

Depending on the size and staffing of the ACA, initial reviewers may be generalists or may 

specialize in one production/handling sector or another. Initial reviewers may also consider 

requests for temporary variances, labels and market information, as well as important changes 

to the OSP which a certified operator may report between annual inspection dates. Initial 

reviewers may also evaluate inputs, although some ACAs may have specialized staff for this55. 

Initial reviewers may prepare files for inspection and even do the inspection assignations, 

although these tasks may be performed by other administrative staff.

Final review

The final reviewers’ primary role is to verify, through study of the OSP, exit interview document, 

inspection report and results of analyses for substances conducted, whether the operators’ 

production/handling system should be certified, and whether any requirements for the correction 

of minor non-compliances must be made56. Final reviewers may need additional information or 

clarification from the inspector regarding their inspection report57. 

Final reviewers communicate findings to operators, along with copies of inspection reports and 

any test results58. Final reviewers must verify compliance of labels. Final reviewers also review 

corrective action, rebuttal, appeal and mediation documentation submitted by the operator59. 

They may recommend or require a follow-up or unannounced inspection60.

Final reviewers who make the certification decision monitor deadlines for non-compliance 

correction and denial, rebuttal, revocation or suspension of certification. Final reviewers may 

mentor reviewers and often provide inspector and inspection report evaluations to the ACA. In 

the overall structure of quality management systems, complaint management is often assigned 

to final reviewers or others in the certification decision team/department.

Initial and final review tasks can be summarized as follows:
IOIA Draft 3 TASK 1 Page 19 of 37

Initial Review

1. Answer questions about certification, standards and materials, timeliness61.

2. Review OSP and supporting documentation for completeness and potential 

compliance62: 

● in the case of growers, this includes, but is not limited to, review of land 

history, contamination risks, crop rotation, fertility management, seed and 

planting stock use, pest, disease and weed management, input materials63, 

equipment, labeling64, and types of records for compliance to NOP;

● in the case of wild crop harvesters this includes but is not limited to, review of 

land history, contamination risks, sustainability, equipment, labeling65, and 

types of records for compliance to NOP;

● in the case of livestock operations, this includes but is not limited to, review of 

livestock living conditions, origins of livestock, feed composition and feed 

sources, pasture management, veterinary practices, and types of records for 

compliance to NOP; 

● in the case of handlers, this includes, but is not limited to, review of labels, 

product formulations, ingredient suppliers, facility pest management, 

sanitation materials, food additives, and types of record keeping for 

compliance to NOP.

3. If the operation was previously certified by another ACA, previous non-compliance 

issues need to be verified for resolution66.

4. Communicate with operator for additional information as needed67.

5. Prepare file for inspection, including special instructions if necessary (number of 

products to trace, number of input/output balances to conduct, for example) and 

previous report if applicable68. 

6. Assign inspector, matching competency, availability, absence of conflict of interest 

etc.69

7. Inform operator of which inspector has been assigned and manage changes to 

assignment, if needed.

8. Monitor deadlines for continuation of certification70: ensure operators update OSPs 

on time and ensure inspections are scheduled in a timely fashion etc.

9. Review temporary variance requests.

10. Review reported changes to OSP.

11. Process requests for approval of inputs.71

Final review

1. Review OSP and supporting documentation, exit interview documentation, inspection 

reports and the results of any analyses for substances conducted. 

2. Communicate with inspector for further clarification if needed.

3. Communicate with operator for additional information, if needed.

4. Provide copy of inspection report to operator72.

5. Provide copy of laboratory results (if applicable) to operator73.

6a. Grant certification including requirements for the correction74 of identified minor noncompliances within a specified period of time75 and a consistent manner;

or

6b. Issue notification of non-compliance (or even notification of denial, in accordance 

with the requirements of the NOP regulations),76 including the evidence and date by 

which the operator must rebut or correct each non-compliance. 

7. Review rebuttals and responses to non-compliances and determine if compliant.

8. Monitor deadlines for corrective actions, follow-up inspections etc; communicating 

with operators when there are missed deadlines.
IOIA Draft 3 TASK 1 Page 20 of 37

9. Require follow-up inspections if necessary.

10. Issue certification certificates.

11. Communicate decision (including any requirements for the correction of minor noncompliances) back to inspector77. 

12. Notify the NOP in cases of certification denial, and notices of noncompliance,

proposed suspension or revocation78.

13. Verify compliance of finished product labels. 

14. Contribute to performance review of inspectors in conjunction with human resources 

personnel. 

15. Contribute to performance review of initial reviewers in conjunction with human 

resources personnel. 

Peripheral responsibilities for reviewers 

● provide information to potential and actual organic operators

● ensuring maintenance of quality system and of the ACAs accreditation79

● contribute to ACA policy development

● participate in educational programming of ACA

● represent ACA at trade shows, conferences, industry events

● contribute to optimizing the certification services

● contribute to continuous improvement of inspection services

● mentor and train initial reviewers (and inspectors)

3.2 Recommended Requirements

3.2.1 Knowledge

Not unlike the position of organic inspectors, there are five bodies of knowledge and facts 

required of initial and final reviewers:

a. Regardless of the certification category (crop, wild crop, livestock, handling), a good 

understanding of accreditation80, certification and quality systems is required81. 

b. Specific to the certification category, a good understanding of the NOP Regulations

(CFR Title 7 Part 205 NOP and OFPA) is also required82. This does not just mean 

knowing what the standard says and where to find it, but most importantly, how to apply 

the standard to practical situations. The reviewer must also be able to explain applicable 

standards (and certification procedures) to the operator, when questions arise.. 

c. Very specific to the file under review, a good understanding of organic 

production/handling processes is a critical requirement. Having a good knowledge of 

current practices in the operators’ conventional counterpart is also an excellent tool for 

reviewers, enabling effective identification of risks to organic integrity in the organic 

production/handling process. Understanding the specific terms and jargon specific to the 

field under review is essential. 

d. Reviewers must be proficient – and current – in their understanding of the specific 

procedures, documentary requirements and forms of the ACA83 which employs 

them or of every ACA which they contract to84. ACAs each have their own document 

control system, their own specific procedures for reviewing OSPs and supporting 
IOIA Draft 3 TASK 1 Page 21 of 37

documentation, and prescribed ways of gathering organic product recipes, input profiles, 

or finished product labels. They have different ways of documenting changes to operator 

documents - and these processes change from time to time. Some ACAs have a data 

base for recording decisions, interpretations and precedents, which reviewers need to 

know how to use, input into and keep current. They need to know when they have the 

authority to make a determination and when they need to consult with other members of 

staff.

e. It is recommended that organic reviewers be aware of other rules and regulations 

applicable to the inspection category, such as food safety requirements85. Although 

such regulations are technically beyond the scope of organic inspections, when the 

organic inspector observes and reports obvious violations of them, reviewers need to 

know what is the appropriate action to take.

3.2.2 Skills

The recommended skills for initial and final reviewers are as follows:

a. Computer skills/information management

b. Organizational; project management

c. Writing: correct grammar and spelling; concise and easy to understand by the targeted 

reader

d. Good verbal communication

e. Time management, meeting deadlines, following up on deadlines imposed on operators

f. Meticulous: systematic about documenting and archiving conversations, emails, 

decisions etc.

g. Intermediate Math skills: needed to verify feed rations and recipe formulations, etc.
IOIA Draft 3 TASK 1 Page 22 of 37

3.2.3 Abilities

The recommended abilities for initial and final reviewers are as follows:

a. Ability to work under pressure

b. Ability to interface with operators, inspectors and other ACA staff

c. Attention to detail86

d. Thorough, meticulous

e. Analytical87

f. Accurate

g. Consistency: making the same determination and decision in similar circumstances

h. Reaches decisions in a timely manner based on logical reasoning and analysis

i. Self-assessment: can recognize own opportunities for improvement, can accept 

constructive criticism

3.2.4 Personal Attributes

Initial and final reviewers should possess personal attributes88 enabling them to handle a wide 

variety of situations in accordance with the requirements of an accredited quality system. A 

reviewer should be: 

a. Honest and ethical. Integrity of the certification system rests on the integrity of its 

players, including inspectors and reviewers. In quality systems, reviewers must be free 

of conflicts of interest with the operations they review. Conflicts of interest are declared 

annually89 and reviewers must not review any operation’s files with which they have a 

conflict of interest. Confidentiality90 is also important. Information learned about 

operations must be kept confidential in order to gain trust of operators and not be used 

by reviewers for personal gain. Reviewers also have a responsibility to act on and 

investigate suspected fraud.

b. Impartial and non-discriminatory91. Reviewers should be fair and objective, and review 

operator files consistently. They need to treat all operators with respect and without bias. 

c. Professional in their conduct. Reviewers represent ACAs and must follow ACA policies 

and procedures, including meeting deadlines. 

d. Diplomatic and tactful. Reviewers have a variety of contact with operators throughout the 

certification process, from answering certification questions, notification of initial review, 

additional information needed, decision making and identification of non-compliances 

and follow-up. This can be a trying process for operators, as their livelihood may depend 

on organic certification. Reviewers need to maintain a calm atmosphere in the office. 

e. Decisiveness. Both initial and final reviewers make decisions about additional 

information needed from the operator, whether inputs are approved, and whether 

previous non-compliances have been corrected. Final reviewers also make a decision 

regarding whether an operation is certified including identification of non-compliances. 

Consistency is needed as well as the ability to make those hard decisions.

f. Support goals of organic farming and handling. This last personal attribute is important 

as the attitude of the reviewer toward his/her work is evident to the operator. A lack of 

support can undermine the authority needed by the ACA.
IOIA Draft 3 TASK 1 Page 23 of 37

3.2.5 Work Experience

The recommended work experience required of reviewers varies from one ACA to another. 

Generally, ACAs require final reviewers to have demonstrated their competence as initial 

reviewers or as inspectors prior to moving into final review positions. As examples, the following 

table suggests some of the relevant work experiences possible for the two review levels:

Review level Initial reviewer (pre-inspection) Final reviewer (postinspection)

Relevant work experiences 

possible

One or more years in professional 

office environment and/or quality 

assurance

One or more years in 

professional office environment 

and/or quality assurance

Volunteering or interning on an 

organic farm

Auditing/regulatory compliance 

experience

1-2 years in the 

production/handling sector92

1-2 years in the 

production/handling sector93

1-2 years experience as an 

organic inspector

1-2 years experience as an 

organic inspector

Demonstrated competence as 

an initial reviewer 
IOIA Draft 3 TASK 1 Page 24 of 37

3.2.6 Training

As with inspectors, the training required of reviewers falls into several different fields, notably:

● Sector (crop, wild crop, livestock, handling)

● Regulatory/quality system

● Organic inspection

● NOP Regulations

● Accreditation requirements

● ACA procedures, forms, data management

Recommended 

training 

requirements

Level of review

Initial (pre-inspection) Final (post-inspection) 

Sector education Bachelors degree or higher in 

agriculture, food technology or 

related field, or equivalent work 

experience 94

Training in related discipline

10 hrs/yr

Regulatory, Quality 

systems

Basic quality system auditing or 

organic inspector training95

Basic quality system auditing or organic 

inspector training

Standards training Basic NOP Regulations training

Crop (and wild crop) 6 hrs

Livestock 6 hrs

Wild crop (included in crop)

Handling 6 hrs

Annual update to NOP Regulations and 

National List

1-2 hrs per category per year, depending on 

changes

Accreditation 

requirements

Training to NOP Accreditation and 

ISO 65

Update every 2 years

ACA procedures and 

paperwork training

Training to ACA procedures96 Annual update to ACA procedures
IOIA Draft 3 TASK 1 Page 25 of 37

3.2.7 Reviewer Experience

● Entry level reviewers are not expected to have review experience; initially they are under 

supervision of experienced reviewer.97

● Initial review work or organic inspection is often - but not always – a prerequisite for final 

review work 

3.3 Recommended Performance Evaluation Standards

Annual performance evaluations are required98. It is recommended that performance evaluation 

be conducted by peers (other review personnel) in conjunction with human resources staff. The 

following table suggests standards which such reviews can address. 

Area of competence to evaluate Evaluation criteria Evaluation method

3.1

Responsibilities: 

Initial reviewer

Answer questions about 

certification, standards and 

materials, timelines

Knowledgeable about 

standards, allowed 

substances, 

certification process

Review customer 

satisfaction

Review application and supporting 

documentation for completeness 

and potential compliance (refer to 

narrative for detailed examples for 

each scope). 

Incomplete applications 

and potentially noncompliant 

practices/materials are 

correctly flagged.

Sample files.

If the operation was previously 

certified by another ACA, previous 

non-compliance (NC) issues need 

to be verified for resolution.

NCs from an operator’s 

previous ACA are 

consistently verified for 

resolution.

Examine files of 

operators previously 

certified by another 

ACA.

Communicate with operator for 

additional information as needed.

Operators are 

contacted for more 

information as needed.

Sample files.

Prepare file for inspection, including 

special instructions if necessary 

and previous report if applicable.

Files are correctly 

prepared for inspector.

Inspector satisfaction. 

Sample files.

Assign inspector, matching 

competency, availability, absence 

of conflict of interest. 

Assignments are 

correctly made.

Sample files.

Inform operator of which inspector 

has been assigned99 and manage 

changes to assignment if needed.

Changes in 

assignments are made 

according to ACA 

procedure.

Examine assignment 

records.

Monitor deadlines for continuation 

of certification, ensure operators 

update OSP on time and ensure 

inspections are scheduled in a 

timely fashion. 

Deadlines are 

respected.

Analyze performance. 

Review temporary variance 

requests

Temporary variance

requests are processed 

according to ACA

procedure.

Review records of 

temporary variances.

Review reported changes to OSPs Changes to OSPs are 

reviewed and processed 

according to ACA 

procedure.

Sample files.
IOIA Draft 3 TASK 1 Page 26 of 37

Area of competence to evaluate Evaluation criteria Evaluation method

Process requests for approval of 

inputs 

Input approval requests 

are processed according 

to ACA procedure.

Sample files.

3.1 Responsibilities: 

Final reviewer

Review OSP and supporting 

documentation, exit interview 

documentation, and inspection 

reports and results of analyses for 

substances conducted

Files are thoroughly 

reviewed. Review is 

documented.

Sample files.

Communicate with inspector for 

further clarification if needed

Communications with 

inspectors are made 

when needed and 

documented.

Sample files.

Communicate with operator for 

additional information if needed.

Provide copy of inspection report to 

operator

Reports are provided to 

operator.

Sample files.

Provide copy of laboratory results (if 

applicable) to operator

Lab results are provided 

to operator.

Sample files.

Grant certification including 

requirements for correction of 

identified minor non-compliances 

within a specified time and in a 

consistent manner

OR

Issue notification of non-compliance 

(or denial) including evidence and 

date by which operator must rebut or 

correct each non-compliance.

Decisions are made 

based on evidence, in a 

consistent manner and 

documented.

Sample files.

Review rebuttals and responses to 

non-compliances and determine if 

compliance is met.

Rebuttals and responses 

are reviewed and 

assessed; conclusions 

are documented.

Sample files.

Monitor deadlines for corrective 

actions, follow-up inspections etc; 

communicating with operators when 

there are missed deadlines

Deadlines are 

respected.

Analyze performance. 

Require follow-up inspections if 

necessary

Follow-up inspections 

are required when 

appropriate.

Sample files.

Issue certification certificates Accurate certificates are 

issued.

Sample files.

Communicate decision (including any 

requirements for the correction of 

minor non-compliances) back to 

inspector.

Inspectors are notified of 

review outcomes.

Sample files.

Notify the NOP in cases of 

certification denial and notices of 

proposed suspension or revocation

NOP is notified of 

certification denials, and 

of proposed 

suspensions and 

revocations.

Review files (internal 

audit).

Verify compliance of finished product 

labels. 

Labels are reviewed 

using checklist; review 

documented.

Sample files.

Contribute to performance review of 

inspectors in conjunction with Human 

Inspector performance 

evaluated using HR 

Review files (internal 

audit).
IOIA Draft 3 TASK 1 Page 27 of 37

Area of competence to evaluate Evaluation criteria Evaluation method

resources personnel checklist.

Contribute to performance review of 

initial reviewers in conjunction with 

human resources personnel.

Initial reviewer 

performance evaluated 

using HR checklist.

Review files (internal 

audit).

Peripheral responsibilities100

3.2.1

Knowledge

Accreditation, certification and quality 

systems 

Review of training 

record

NOP Regulations Demonstrates 

understanding of NOP 

regulations 

Review of training 

record; observation at 

work

Organic production/handling 

processes

Understands system 

being inspected; using 

jargon specific to system 

being inspected.

Review of training 

record

ACA procedures and policies Uses ACA forms 

correctly.

Follows ACA 

procedures.

Review of training 

record

Review of operator files

Other applicable regulations Review of training 

record

3.2.2

Skills

Computer skills/ Information 

management

Uses programs 

competently and 

efficiently.

Performance review.

Organizational; project management Is well organized. Performance review.

Writing: correct grammar and 

spelling; concise and easy to 

understand by the targeted reader

Writes concisely and 

uses language correctly.

Review of files.

Good verbal communication Makes her/himself easily 

understood.

Observation in 

workplace.

Time management, deadlines, 

following up on deadlines imposed on 

operators

Manages deadlines 

effectively.

Performance review.

Meticulous: systematic about 

documenting and archiving all 

conversations, emails, decisions etc

Keeps proper records of 

all communications etc.

Review of files.

Math: needed to verify feed rations 

and formulations

Correctly asses rations, 

recipes.

Review of files.

3.2.3

Abilities

Ability to work under pressure Stays calm and 

focused meets 

deadlines

Employee interview

Review staff turnover

Ability to interface with operators, 

inspectors and other ACA staff

Courteous, people 

skills

Analysis of complaints 

naming reviewer.

Attention to detail Works with attention to 

detail. 

Review of files.

Thorough, meticulous Works meticulously

Analytical Bases decisions on 

facts 

Review of files.

Accurate Does not make 

mistakes.

Review of files.
IOIA Draft 3 TASK 1 Page 28 of 37

Area of competence to evaluate Evaluation criteria Evaluation method

Consistent Handles similar 

situations the same 

way.

Review of files.

Reaches decisions in a timely 

manner based on logical 

reasoning and analysis

Evidence based 

decisions

Review of files

Self assessment Accepts constructive 

criticism

Recognizes 

opportunities for 

improvement

Interview, annual 

performance review

3.2.4

Personal attributes

Tact, diplomacy; Impartiality and 

objectivity; Supporting goals of 

organic farming and handling; 

Professionalism: in presentation 

ACA values; Integrity: honesty, 

fairness and lack of bias; 

Confidentiality; free of conflict of 

interest disclosure report; 

Decisiveness: reaches decisions in 

a timely manner based on logical 

reasoning and analysis

Satisfactory 

performance 

Declarations kept 

current (confidentiality, 

C of I)

Feedback from 

operators

Review of complaints 

filed naming the 

reviewer

Review of annual 

documentation

Observation at work
IOIA Draft 3 TASK 1 Page 29 of 37

3.4 Recommended Professional Development Activities

Initial and final reviewers should participate in a wide range of professional development 

activities. They should be documented and included in their résumé, supported by course 

certificates and content lists whenever possible. This is a partial list of possible professional 

development activities:

● Conferences

● Workshops

● ACA training programs

● NOP ACA Training Programs

● University and community college courses

● eOrganic webinars

● On-farm demonstrations

● Subscriptions to trade magazines

● Independent study/reading

● Networking101 (professional associations, relevant listserve groups, etc.)

● Peer review

● Interface of review teams with inspector teams 

● Performance review from certifiers (see previous section)

● Private coaching

● IOIA webinars, seminars and training activities

● ATTRA documents

Content lists for training activities are presented in Task 2.
IOIA Draft 3 TASK 1 Page 30 of 37

4 Definition of Terms

Term Definition Source

Ability capacity, power, cleverness, talent, mental power Oxford American 

Dictionary 1999

ACA Accredited certifying agents

Area of operation The types of operation: crops, livestock, wild crop 

harvesting or handling or any combination thereof that 

a certifying agent may be accredited to certify under 

this part.

NOP 205.2

Audit Systematic, independent and documented process for 

obtaining audit evidence and evaluating it objectively 

to determine the extent to which the audit criteria are 

fulfilled. 

ISO 19011, 3

Audit in/out balance Examination of production records, inventory reports, 

receiving (purchase) reports and sales summaries for 

the purpose of verifying whether or not sales of 

organic product reconcile with production and 

receiving (purchases).

Audit trail Documentation that is sufficient to determine the 

source, transfer of ownership, and transportation of 

any agricultural product labeled as ‘100% organic’, 

the organic ingredients of any agricultural product 

labeled as ‘organic’ or ‘made with organic(specified 

ingredients) or the organic ingredients of any

agricultural product containing less than 70% organic 

ingredients identified as organic in an ingredient 

statement.

NOP 205.2

Certification (or 

certified)

A determination made by a certifying agent that a 

production or handling operation is in compliance with 

the Act and the regulations in this part, which is 

documented by a certificate of organic operation.

NOP 205.2

Certified operation A crop or livestock production, wild crop harvesting or 

handling operation, or portion of such operation that 

is certified by an accredited certifying agency as 

utilizing a system of organic production or handling s 

described by the Act and the regulations in this part.

NOP 205.2

Certifying agent Any entity accredited by the Secretary as a certifying 

agent for the purpose of certifying a production or 

handling operation as a certified production or 

handling operation.

NOP 205.2

Competence Demonstrated personal attributes and demonstrated 

ability to apply knowledge and skills.

ISO 19011

Competent authority The official government agency having jurisdiction. Codex Alimentarius 

2.2

Credentials Evidence of a person’s achievements or 

trustworthiness, usually in the form of certificates, 

references, etc.

Oxford American 

Dictionary, 1999

Immediate family The spouse, minor children, or blood relatives who 

reside in the immediate household of a certifying 

agent or an employee, inspector contractor, or other 

personnel of the certifying agent. For the purpose of 

this part, the interest of a spouse, minor child, or 

blood relative who is a resident of the immediate 

NOP 205.2
IOIA Draft 3 TASK 1 Page 31 of 37

household of a certifying agent or an employee, 

inspector contractor, or other personnel of the 

certifying agent shall be considered to be an interest 

of the certifying agent or an employee, inspector 

contractor, or other personnel of the certifying agent. 

Inspection The examination of food or systems for control of 

food, raw materials, processing and distribution, 

including in-process and finished product testing, in 

order to verify that they conform to requirements. For 

organic food, inspection includes the examination of 

the production and processing systems. 

Codex Alimentarius 

2.2

Inspector Any person retained or used by the certifying agent to 

conduct inspections of certification operators or 

certified production or handling operations.

NOP 205.2

Investigation A systematic gathering of facts and evidence to 

support or refute an allegation.

NOP Online 

Training: 

Investigating 

Complaints: What 

ACAs Should Know, 

Compliance & 

Enforcement 

Branch, June 2009

Knowledge Specific information; facts or intelligence about 

something

Oxford American 

Dictionary 1999

Material evaluation 

program

An organic certification or other program, independent 

from the crop producer or input manufacturer, with the 

expertise to verify compliance of inputs used in 

organic production and handling with NOP 

regulations. The expertise and approval of material 

evaluation programs will be a component of the NOP 

accreditation program. Approved material evaluation 

programs include NOP accredited certifying agents 

and the Organic Materials Review Institute (OMRI). 

ACAs and OMRI are audited regularly to evaluate 

their compliance with the NOP regulations and this 

policy.

NOP Handbook PM 

11-4

Official accreditation The procedure by which a government agency having 

jurisdiction formally recognizes the competence of an 

inspection and/or certification body to provide 

inspection and certification services. For organic 

production, the competent authority (official 

government agency having jurisdiction) may delegate 

the accreditation function to a private body.

Codex Alimentarius 

2.2

Organic control point 

(OCP)

Any point or procedures in an organic production, 

processing or handling system where there is a high 

probability that improper control may cause, allow 

or contribute to the loss of integrity. OCPs are 

points where there is contamination or commingling 

risks to organic crops or products. 

IFOAM/IOIA 

International 

Organic 

Inspection 

Manual, p 45 

Organic production A production system that is managed in accordance 

with the Act and regulations in this part to respond to 

site specific conditions by integrating cultural, 

biological, and mechanical practices that foster 

cycling of resources, promote ecological balance and 

NOP 205.2
IOIA Draft 3 TASK 1 Page 32 of 37

conserve biodiversity.

Organic System Plan 

(OSP)

A plan of management of an organic production or 

handling operation that has been agreed to by the 

producer or handler and the certifying agent, and that 

includes written plans concerning all aspects of 

agricultural production or handling described in the 

Act and the regulations in subpart C of this part.

NOP 205.2

Public-Private 

Partnership (PPP)

A contractual agreement between a public agency 

and a private sector entity. Through this agreement, 

the skills and assets of each sector (public and 

private) are shared in delivering a service.

National Council for 

Public-Private 

Partnerships, 

www.ncppp.org

Records Any information in written, visual or electronic form 

that documents the activities undertaken by a 

producer, handler or certifying agent to comply with 

the Act and regulations in this part.

NOP 205.2

Residue testing An official or validated analytical procedure that 

detects, identifies and measures the presence of 

chemical substances, their metabolites or degradation 

products in or raw or processed agricultural products.

NOP 205.2

Responsibly connectedAny person who is a partner, officer, director, holder, 

manager or owner of 10 or more of the voting stock of 

an operator or a recipient of certification or 

accreditation

NOP 205.2

Skill Expertness, practiced ability Oxford American 

Dictionary 1999

State Organic Program 

(SOP)

A State program that meets the requirements of 

section 6506 of the Act, is approved by the Secretary, 

and is designed to ensure that a product that is sold 

or labeled as organically produced under the Act is 

produced and handled using organic methods.

NOP Regulations 

205.2

Traceability test or 

trace-back

Verification that an operator has a recording keeping 

system in place which enables

● Backward tracking of sales through 

production to ingredient/input purchasing

● Forward tracking of inputs though production, 

warehousing and sales to final customers

IOIA training

Witness audit The witnessing of the certification body's conformity 

assessment activities during an inspection of a 

supplier, including an examination of the inspector's 

preparation for the inspection and the implementation 

of the certification body's inspection procedures. The 

inspection of the supplier may be a demonstration 

when it is not possible to conduct an actual 

inspection.

USDA AMS ARC 

ISO Guide 65 

Program: 

Accreditation for 

Certification Bodies 

Section 4: 

Definitions
IOIA Draft 3 TASK 1 Page 33 of 37

5 References

● ACA Compilation of Certifier Position Descriptions for Inspectors and Reviewers; August 

2011

● IFOAM /IOIA International Organic Inspection Manual; 2000. 

● ISO 19011 Guidelines for quality and/or environmental management systems auditing; 2002

● Organic Products Regulation (Canada) 2009 SOR/2009-176; current to July 11 2011

● Guidelines for the Production, Processing, Labeling and Marketing of Organically produced 

foods, adopted by the 23rd session of the Codex Alimentarius commission in 1999; revised in 

2001

● National Organic Program Handbook (Winter edition 2011)

● NOP Online Training: Investigating Complaints: What ACAs Should Know, Compliance & 

Enforcement Branch, June 2009

● National Organic Program Final Rule 7 CFR, 2010

● National Organic Standards Board Principles of Organic Production and Handling, 2001

● ATTRA Workbooks, Checklists, OSP Technical Guide, Templates and Documentation 

Forms and Inspection forms IFOAM Accreditation Criteria for Bodies Certifying Organic 

Production and Processing, version 2005

● ISO/IEC Guide 65, 1996

● Organic Food Production Act (OFPA) of 1990 (USA)

● IOIA Accreditation Program August 2002 

● OCC/IOIA Inspector Apprenticeship Program December 1998 

● IOIA Apprentice-Mentor Guidelines October 2007 

● IOIA Basic Training curriculum - Crops revised 2007

● IOIA Basic Training curriculum – Livestock revised 2008

● IOIA Basic Training curriculum – Handling revised 2008

● IOIA Code of Ethics revised 2001

● IOIA Code of Conduct revised 2001

● IOIA Draft Inspection Guide April 2006

● IOIA Training Institute Summary April 2011

● IOIA Training Program Guide revised 2008 

● USDA AMS ARC ISO Guide 65 Program: Accreditation for Certification Bodies, Section 4 

Definitions
IOIA Draft 3 TASK 1 Page 34 of 37

6 Appendices

Guidelines for Preparation, Inspection and Reporting Times

Level of 

complexity

Example Preparation 

time estimate

On site 

inspection 

time estimate

Post inspection 

time estimate102

Apprentice 15 acres organic strawberries, in 

rotation with green manures; one 

location; no conventional or transition, 

no on-farm processing

0.5 hr 2-3 hr 1 hr

400 acres organic cash crops; one 

location; no conventional or transition, 

no on-farm processing

0.5-1 hr 3 hr 1 hr

Organic pasta production, 10 

employees, one location, no 

conventional 

0.5-1 hr 3-4 hr 1.5-2 hr

Licensed 30 acres organic vegetables, in 

rotation with green manures; 2 

locations; no conventional or 

transition, no on-farm processing

0.5-1 hr 4-5 hr 1.5-2 hr

250 acres organic feed crops, 40 

head organic dairy herd, no 

conventional or transition, no on-farm 

processing

0.5-1 hr 4-5 hr 1.5-2 hr

Organic pasta sauces, 80 employees, 

50% organic products, 50% 

conventional products, off-site 

warehousing

1-2 hrs 6-8 hrs 2-3 hrs

Specialty crops /innovative processes

Master 1800 acres cash crops, 8 locations, 

some land still in transition and under 

conventional management; 2 storage 

sites; on-farm cleaning and bagging

2 hrs up to 1.5 days 2-3 hrs

2000 head organic cow/calf; organic 

pasture; multiple locations, purchased 

feeds, custom slaughter house; 

custom sausage making. 15 different 

recipes, some in 95%, some 70%+, 

some MWO.

4 hrs 2 days or more 4-5 hrs

Processes with in-process inventories 

(fermentations for example) 

Inspections (un-announced or followup) related to suspected fraud or 

serious complaints
IOIA Draft 3 TASK 1 Page 35 of 37

7 Endnotes

1 NOP 205.403 (c) (1)

2 ISO 19011 6.2.5 and 6.3 and 6.4.1

3 ISO 19011 6.5.1

4 NOP Handbook ‘Five steps to certification’

5 A common oversight identified by ARC auditors was the lack of follow-up to previous minor noncompliances.

6 ISO 19011 6.5.2 and 6.5.5

7 NOP 205.403(d)

8 NOP 205.403 (c) (3) and 205.403 (e) ; NOP Handbook ‘Five steps to certification’

9 NOP 205.403 (d); ISO 19011 6.5.7

10 IOIA Training Program Guide p2 

11 see Definition of Terms

12 Hereafter, first time operators and certified operators will be jointly referred to as operators.

13 Although the NOP does not specify a % of operators who must be targeted annually by un-announced inspections, 

ACA procedures normally set a target percentage.

14 IOIA Basic curriculum ‘Drawing the circle around an operation’

15 ISO 19011 recommends 40 hours of auditor training for all entry level auditors

16 NOP 205.403 and section 500; 

17 ACA inspector position descriptions

18 NOP Program Handbook PM-11-6

19 IFOAM/IOIA Inspection Manual 2.3.5; ASQ Auditing handbook; ISO 19011 6.5.4

20 ISO 19011 6.6.1; ASQ Auditing Handbook p 141

21 ISO 19011 7.3.1; ASQ Auditing Handbook

22 ISO 19011 6.4.1 and 6.4.3

23 NOP 205.403 (b)(2)

24 IOIA Training program guide; ACA inspector position descriptions

25 ARC job description, IOIA training manual

26 ISO 19011 7.3.1; ASQ Auditing Handbook p 141

27 IFOAM/IOIA International Organic Inspection Manual 4.1.1

28 IFOAM/IOIA International Organic Inspection Manual 4.8

29 IFOAM/IOIA International Organic Inspection Manual 5.1.2

30 IFOAM/IOIA International Organic Inspection Manual 6.2 and 6.3

31 NOP 205.501(a)(11); IOIA curriculum; ISO 65 42.2.o

32 ISO 19011 6.5.5; ASQ Auditing Handbook p 141; IOIA Training program guide

33 IOIA curriculum

34 ISO 19011 6.5.5

35 This is a compilation from a variety of sources: NOP Regulations; ISO 19011 6.6.2 and 7.2; ASQ Auditing 

Handbook; Codex Alimentarius 6.6.a; ISO 65 4.2.f; IOIA Codes of Conduct and Ethics, IOIA training program 

guide; IOIA crops and handling curriculum; IFOAM Accreditation Criteria 1.4.11; and ACA inspector position 

descriptions.

36 NOP 205.504 (c)(2) requires that inspectors file an annual conflict of interest disclosure report form, identifying 

any food or agriculture related business interests, including business interests of immediate family members that 

cause a conflict of interest. 

37 NOP 205.501 (a)(10) requires inspectors hold information confidentially. 38 The USDA prohibits discrimination in all its programs and activities on the basis of race, color, national origin, 

gender or marital status (not all prohibited status apply to all programs), 

39 IOIA promotes a 2 defect guideline when inspecting foreign operations (see IOIA Code of Conduct and Ethics, 

which refers to knowledge of culture, language and crop. Also addressed in ARC job description.
IOIA Draft 3 TASK 1 Page 36 of 37

 40 IOIA training prerequisite

41 This category describes entry-level inspectors who have completed basic training plus field training with a 

mentor. Other terms considered but not used were ‘apprentice’ and ‘provisional’. These could confer a connotation 

of inadequacy and were discarded in preference for the neutral term ‘inspector’. A one-year time frame was 

considered, but rejected. Some inspectors could move to licensing quite quickly while field training might take 

longer than 1 year for others. Mentor shortage could also lengthen time frames. 

42 IOIA basic trainings have traditionally been 4.5 days per category, on site (not web-based), with 4 days of 

instruction and 0.5 day of testing

43 Note: It is not feasible to apply all requirements, especially field training, to the wild crop scope separately from 

crop. It is recommended that any inspector qualified to inspect crops could also inspect wild crops, provided they 

received training specific to wild crop standards and inspection. At this time, wild crop inspection has been included 

in 100 level training content. Specific 200 level wild crop training could be required for wild crop inspection.

44 The term ‘licensed inspector’ is used for those who have taken the step to become competent to do solo 

inspections, including 200 level training and successful completion of a licensing exam.

45 Documentation can be through verification of membership, listserve email, etc.

46 IOIA Training Institute draft

47 Testing and exams rated fairly highly in the 2010 IOIA certifier survey

48 NOP 205.402

49 NOP 205.404(a) 

50 NOP 205.501(a)(11)(vi) 

51 NOP 205.402(a)(1)

52 NOP 205.402 (a)(2)

53 NOP 205.402(a)(4)

54 NOP 205.402(a)(3)

55 See ‘TERMS: Materials Evaluation Program’

56 NOP 205.404(a)

57 According to IOIA 2010 survey, some ACAs need to refer back to inspectors up to 50% of the time, before being 

able to complete the final review.

58 NOP 205.402(b)(2) and NOP 205.403(d)(2)

59 NOP 205.405(a)(3), NOP 205.405(b)(1)

60 NOP 205.405(c)(1)

61 ACA reviewer position descriptions

62 NOP 205.402(a)(1-2); ISO 19011 6.3

63 NOP Handbook 2601 Instruction “Five Steps to Certification”

64 NOP subpart D

65 NOP subpart D

66 NOP 205.402(a)(3)

67 NOP 205.402(b)

68 NOP 205.501(a)(18)

69 ISO 19011 6.2.4

70 NOP205.406(a)

71 ACA reviewer position descriptions

72 NOP 205.403 e(2)

73 NOP 205.403 e(2)

74 ISO guidelines for Quality system management use the terms Corrective Actions (measures taken to correct 

identified non-conformances) and Preventive Actions (measures put in place to ensure an identified Non 

conformance does not recur). ISO guidelines also differentiate between major and minor non-conformances. 
IOIA Draft 3 TASK 1 Page 37 of 37

Although such terms can be very helpful, in the present document the authors have intentionally remained faithful to 

the language in the NOP Regulations.

75 NOP 205.404(a)

76 NOP 205.405(a); note that 205.405(c) details how notices of denial are to be issued

77 NOP 205.501(a)(18)

78 NOP 205.501(a)(15) and NOP 205.662 and NOP 205.665 

79 NOP 205.501(a)(2); ACA reviewer position descriptions

80 Since not all NOP Accredited Certifying Agents are accredited to ISO 65, this has been kept general.

81 ACA inspector position descriptions

82 NOP 205.501(a)(1)

83 Most of the skills in section 3.2 are based on the ACA inspector position descriptions

84 It seems that most review work is done by staff, but some review work is contracted out, often to inspectors.

85 NOP Handbook PM-11-6

86 ACA inspector position descriptions

87 ACA inspector position descriptions

88 This is a compilation from a variety of sources: NOP Regulations; ISO 19011 6.6.2 and 7.2; ASQ Auditing 

Handbook; Codex Alimentarius 6.6.a; ISO 65 4.2.f; IOIA Codes of Conduct and Ethics, IOIA training program 

guide; IOIA crops and handling curriculum; IFOAM Accreditation Criteria 1.4.11; and ACA inspector position 

descriptions.

89 NOP 205.504 (c)(2) requires that inspectors file an annual conflict of interest disclosure report form, identifying 

any food or agriculture related business interests, including business interests of immediate family members that 

cause a conflict of interest. 

90 NOP 205.501 (a)(10) requires inspectors hold information confidentially. 

91 The USDA prohibits discrimination in all its programs and activities on the basis of race, color, national origin, 

gender or marital status (not all prohibited status apply to all programs),

92 ACA inspector position descriptions

93 ACA inspector position descriptions

94 IFOAM 1.4.2; ACA reviewer position descriptions

95 IOIA inspector training in the appropriate category (crops, livestock, handling) is required by many ACAs for 

their reviewer positions. Some ACAs even require that new reviewers accompany inspectors as part of their training. 

However, at present, IOIA training is geared more for inspectors than for reviewers. This speaks to the need for 

developing reviewer-specific training modules. 

96 ACA reviewer position descriptions

97 ACA reviewer position descriptions

98 NOP 205.501 (a)(6) and 205.510(a)(4)

99 ISO 65 4.4(c) requirement for contracted personnel – ISO specifically states “obtain the applicant’s consent” 

100 The narrative text includes a list of peripheral responsibilities conferred to reviewers which do not pertain to file 

review. The authors have chosen NOT to include those peripheral responsibilities in the proposed performance 

evaluation.

101 This can be documented by membership verification, listserve email, etc.

102 Reporting time is very variable depending on ACA reporting procedures. Some ACAs have no post-inspection 

reporting (all reports completed on site) so in those cases, post-inspection time could be zero. Some ACAs require 

more narrative in reports. The times shown in this table are likely low for that reporting format.