United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-5

Agricultural Marketing Service Room 2648 South Building Effective Date: August 25, 2014 

National Organic Program Washington, DC 20250 Page 1 of 7

National Organic Program 

Witness Audit Checklist for Grower Group

Witness Audit - General Information

This checklist is used in conjunction with the Tables 1 through 3 of NOP 2005 NOP 

Accreditation Assessment Checklist. NOP 2005-3 Certification File Review Worksheet must be 

completed prior to conducting the witness audit. This checklist is used to record evaluation 

information for grower groups. NOP 2005-4 Witness Inspection Checklist must be used when 

witnessing a regular operation inspection.

Witness audit date:

Name of operation:

Location of operation:

Scope of certification requested:

Scope of certification granted:

Actual or demonstration inspection:

Scope of the inspection:

Witnessed portions of the inspection:

Inspector’s name:

Subcontracted or staff inspector:

Verify inspector’s conflict of interest and confidentiality 

status:

Name of knowledgeable representative of the operation:

Name(s) of anyone else present during the inspection:

Time inspection started:

Time inspection completed:

Was there enough time allocated for the inspection?

Did the inspector verify the corrective actions on 

previous noncompliances as applicable?

General information on type of grower group to include: 

crops grown, number of producers in grower group, 

storage facilities, staging areas, and handling operations

General information on materials and inputs used and 

whether they are in compliance with the National List 

(NL) and annotations

NOP 2005-5 Witness Audit Checklist for Grower Groups Rev05 Authorized Distribution: Public
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-5

Agricultural Marketing Service Room 2648 South Building Effective Date: August 25, 2014 

National Organic Program Washington, DC 20250 Page 2 of 7

As appropriate did the organic system plan (OSP) adequately address the requirements 

for:

General

Maintain or improve natural resources (§ 205.200)

Crops

Land requirements (§ 205.202) 

Soil fertility and crop nutrient management practice 

standard (§ 205.203)

Seeds and planting stock practice standard (§ 205.204) 

Crop rotation practice standard (§ 205.205) 

Crop pest, weed, and disease management practice 

standard (§ 205.206) 

Wild Crops

Wild-crop harvesting practice standard (§ 205.207)

Livestock

Origin of livestock (§ 205.236) 

Livestock feed (§ 205.237) 

Livestock health care practice standard (§ 205.238) 

Livestock living conditions (§ 205.239) 

Pasture practice standard (§ 205.240)

Handling

Organic handling requirements (§ 205.270)

Facility pest management practice standard (§ 205.271)

Commingling and contact with prohibited substance 

prevention practice standard (§ 205.272)

Sampling

Was a sample pulled during the inspection? (§ 205.670)

What was sampled and why?

Verify sampling procedures, chain of control, etc. 

(§ 205.670(c))

Did the inspector provide the applicant with a receipt for 

any samples taken? (§ 205.403(e))

Did the sampling process follow the certifier’s sampling 

procedure?

Was the inspector charged for the samples?

(§ 205.403(e))

Did the certifier pay for the testing? (§ 205.670(b))

Labels

Were labels verified during the onsite inspection? 

(§ 205.403(c)(2)) 

NOP 2005-5 Witness Audit Checklist for Grower Groups Rev05 Authorized Distribution: Public
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-5

Agricultural Marketing Service Room 2648 South Building Effective Date: August 25, 2014 

National Organic Program Washington, DC 20250 Page 3 of 7

Were the labels being used the same as those approved 

by the certifier?

How was the inspector made aware of which labels were

approved by the certifier?

Exit Interview (§ 205.403(d))

Document information addressed by the inspector during the exit interview

Was the exit interview conducted with a knowledgeable 

representative?

Did the exit interview address the accuracy and 

completeness of the inspection observations?

Did the exit interview address the need for additional 

information?

Did the exit interview address issues of concern 

identified during the inspection?

Questions for the inspector:

As the inspection progresses insert additional questions to ask the inspector on areas of the 

inspection/operation that need clarification.

What did the inspector receive from the certifier in order 

to conduct the inspection?

Did the inspector receive: Yes No

A general map indicating the general region of the production zone?

A more detailed map indicating the location of each of the communities to be 

inspected?

Grower lists by community, listing producers, producer codes or numbers, amount 

of land area under production by each producer, crops, estimated yields, and past 

production history?

OSP, certification questionnaire, or application?

Name of contact persons with phone numbers, both home and work?

A description of the project to understand how it is organized?

Previous inspection report?

Handling plans, questionnaires/applications. Are there any processing or storage 

facilities?

Information on final sales and distribution?

In the case of certification updates, was the inspector provided with the most 

recent certification letter with all conditions for certification clearly stated?

Additional Questions:

Does the inspector have a copy of the USDA organic 

regulations?

If applicable, was the inspector knowledgeable of recent 

updates to the regulations or policy clarifications? 

How is the inspector informed of the certifier’s policies 

and procedures and changes to them?

Does the inspector provide consulting services of any 

NOP 2005-5 Witness Audit Checklist for Grower Groups Rev05 Authorized Distribution: Public
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-5

Agricultural Marketing Service Room 2648 South Building Effective Date: August 25, 2014 

National Organic Program Washington, DC 20250 Page 4 of 7

kind? If so, how is this information provided to the 

certifier?

What is the inspector’s background (experience, training, 

and education) in relation to grower groups in general,

and specific to the type of grower group being 

inspected? 

Criteria and guidance for annual sampling percentage rate

(Based on NOSB Recommendation 2008, section III.D.1)

Once the certifier determines the annual sampling percentage rate, the highest risk subunits are 

identified and inspected. Of the remaining samples to be inspected, at least 25% of these subunits 

should be selected at random. This helps to prevent the complacency that might be inadvertently 

encouraged by a certifier focusing only on higher-risk members of the multi-site operation.

Example 1: 100 subunits. Sample rate determined by the certifier: 10%. 3 subunits are identified 

by the certifier as “high risk” and inspected. Of the remaining 97 subunits, 7 more will need to be 

inspected to reach the 10% rate. At least 2 of those (25%) should be selected for inspection at 

random. 

Example 2: 100 subunits. Sample rate determined by the certifier: 30%. 10 subunits are identified 

as “high risk” and inspected. Of the remaining 90 subunits, 20 more will need to be inspected to 

reach the 30% rate. At least 5 of those (25%) should be selected for inspection at random.

It is the certifier’s responsibility to instruct the inspectors on which high-risk subunits must be 

inspected and the number of lower-risk subunits that should be sampled based on their 

determination of the group’s overall risk. The certifier will ensure that this protocol is transparent.

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

A. Annual sampling percentage rate established by certifier:

B. Total number of subunits in the Producer Group Operation (PGO):

C. A multiplied by (x) B = number of subunits to be inspected by certifier:

D. Number of subunits identified as high risk by certifier and must be inspected:

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

F. E multiplied by (x) 25% = (minimum number of subunits to be selected at 

random):

Yes No

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

inspected?

Was the required number of high risk subunits inspected? (“D” above)

Were a minimum of 25% of subunits randomly selected? (“F” above)

Were the remaining subunits inspected based on the criteria in the 2008 NOSB 

Recommendation, section III.D.1?

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

Did the certifier properly identify members within the production unit that processed 

NOP 2005-5 Witness Audit Checklist for Grower Groups Rev05 Authorized Distribution: Public
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-5

Agricultural Marketing Service Room 2648 South Building Effective Date: August 25, 2014 

National Organic Program Washington, DC 20250 Page 5 of 7

or consolidated product from more than one member and have them inspected 

annually in accordance with the 2008 NOSB Recommendation, section III.C?

Remarks:

Questions for the Applicant/Certified Operation:

As the inspection progresses, insert additional questions to ask the operation’s representative on 

areas of the operation that need clarification

Did the certified operation receive a copy of the previous 

inspection report, if applicable?

Did the operation receive a certificate from the certifier?

Does the client have a current copy of the USDA organic 

regulations?

If applicable, how did the operation receive information 

on temporary variances?

Overall did the inspection verify:

That the operation was in compliance or was able to 

comply with the USDA organic regulations? 

(§ 205.403(c)(1))

That the OSP accurately reflected the practices used by 

the operation? (§ 205.403(c)(2)) 

That prohibited substances had not been and were not 

being applied to the operation? (§ 205.403(c)(3))

Did the inspection include an inspection of all new 

entrants into the grower group since the previous 

inspection? 

Was there an inspection of all members within the 

production unit that processed or consolidated product 

from more than one member? 

Was the annual sampling percentage rate provided to the 

inspector?

Was the inspector informed by the inspector which 

subunits were classified as high risk and had to be 

inspected?

Did the inspection include a review of the grower 

group’s internal control system (ICS)?

Did the inspection include a review of the ICS sanctions 

policy for members that do not comply with the OSP and 

NOP 2005-5 Witness Audit Checklist for Grower Groups Rev05 Authorized Distribution: Public
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-5

Agricultural Marketing Service Room 2648 South Building Effective Date: August 25, 2014 

National Organic Program Washington, DC 20250 Page 6 of 7

USDA organic regulations? 

Did the inspection include a review to ensure the ICS 

policy required reporting irregularities and minor and 

major noncompliances to the certifier? 

Did the inspection include a review of the ICS 

organizational chart to determine if it was maintained 

and its accuracy? 

Did the inspection include a review of the ICS policy for 

documentation of personnel’s disclosure of potential 

conflicts of interest? 

Did the inspection include a review of the ICS policy for 

internal inspectors to ensure there was no conflict of 

interest with the operations they inspect? 

Did the inspection include a review of the ICS training 

program?

Was at least one annual training session conducted by an 

external specialist?

Were ICS personnel with key program responsibilities 

knowledgeable of the NOP requirements?

Did the inspection include a review of all boundaries and 

verification of adequate buffers for the producers visited?

Witness Audit – Auditor findings and citations

Finding 1

Finding 2

Finding 3

Finding 4

NOP 2005-5 Witness Audit Checklist for Grower Groups Rev05 Authorized Distribution: Public
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 2005-5

Agricultural Marketing Service Room 2648 South Building Effective Date: August 25, 2014 

National Organic Program Washington, DC 20250 Page 7 of 7

Witness Audit – Auditor follow up requests or activities

NOP 2005-5 Witness Audit Checklist for Grower Groups Rev05 Authorized Distribution: Public