Formal Recommendation 

From: The National Organic Standards Board (NOSB)

To: The National Organic Program (NOP)

Date: October 26, 2023

Subject: Consistent Location Identification

NOSB Chair: Nate Powell-Palm

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: 

Guidance Statement: 

Other: The NOP should choose the appropriate vehicle to convey this.

Statement of the Recommendation: 

The NOSB recommendation includes non-substantive changes to the Subcommittee proposal, 

made at the meeting, to address a public comment request for clarification. 

The amended recommendation reads as follows: The NOSB recommends that the NOP advise 

all accredited certifiers to record consistent location information (e.g., geocodes, legal parcel 

identification (ID), legal address, physical address) that can lead to GPS coordinates of all 

applicants for certification and certified operations (parcels, production units - grower groups, 

handling locations, importers, brokers, etc.). This will result in the harmonization of location 

data of all parcels, enabling certifiers to streamline cross-checks and share information 

internally between the operator, certifier, and inspector. 

Rationale Supporting Recommendation:

Since the Fall of 2022, the Certification, Accreditation, Compliance Subcommittee (CACS) has 

received feedback from the community that parcel location collection is inconsistent across 

NOP-accredited certifiers. While some certifiers have a complete database of the location of 

every parcel they certify, other certifiers cannot independently verify the location and 

boundaries of the fields they certify based on the information they collect from their clients. 

The CACS heard from stakeholders across the community that, generally, there is consensus 

that a consistent, industry-wide standard parcel location collection system would boost 

certifiers’ ability to verify information and more effectively monitor those parcels they certify. 

As one commenter mentioned, “The Strengthening Organic Enforcement (SOE) Rule should 

reduce the risk of fraud in the organic marketplace. However, enforcement efforts depend 

upon sufficient and accurate information about each operation.” A consistent process for 

locating certified organic operations, including fields, would aid in executing parts of the SOE, 

including cross-checking and supply chain verification. 
An additional certifier commenter stated, "Geolocation will enable greater ease in organic 

oversight across certifiers and supply chains by applying fixed, traceable, and universally 

understood markers on individual plots of land that will not change over time.”

Consistency in parcel identification and location should be required to comply with the SOEmandated supply chain traceback requirements. 

NOSB Vote: 

Motion to accept the proposal on Oversight Improvements to Deter Fraud: Consistent Location 

Identification 

Motion by: Amy Bruch

Seconded by: Nate Powell-Palm

Yes: 13 No: 0 Abstain: 0 Recuse: 0 Absent: 2 

 

Motion Passed 
National Organic Standards Board

Certification, Accreditation, Compliance Subcommittee (CACS)

Oversight Improvements to Deter Fraud: Consistent Location Identification Proposal

August 1, 2023

Intro:

Since the fall of 2022, the Certification, Accreditation, Compliance Subcommittee (CACS) has received 

feedback from the community that parcel location collection is inconsistent across NOP accredited 

certifiers. While some certifiers have a complete database of the location of every parcel they certify, 

other certifiers have no ability to independently verify the location and boundaries of the fields they 

certify based on the information they collect from their clients. The CACS heard from stakeholders across 

the community that generally there is consensus that a consistent, industry-wide standard parcel location 

collection system would boost certifiers’ ability to verify information and more effectively monitor those 

parcels they certify. 

At the spring 2023 National Organic Standards Board (NOSB) meeting, public commenters requested 

clarification on how the CACS defined a parcel of land. Certifiers use various names such interchangeably: 

sites, fields, and parcels. For the purpose of this proposal the CACS is defining “parcel” as the legal parcel 

included within the boundaries of the legal property lines for that unit of land. The CACS acknowledges 

that farmers may subdivide their legal parcels into sub-field designations. 

The CACS recommends that NOP advise provide guidance to certifiers that all parcels should be located 

via GPS, and it will be the responsibility of the certifier and inspector to coordinate the intake of 

information to meet this requirement. The goal of this guidance is database consistency.

Challenge: 

The location of certified organic operations, including each production parcel, must be more consistently 

recorded and managed across certifiers. This challenges the industry, leading to a gap in certifiers' ability 

to accurately cross-check the operations and fields they certify with other certifiers. Furthermore, some 

certifiers cannot conduct independent verification or unannounced inspections of fields because they 

don’t have mapping capabilities of all field locations.

Solution:

Certifiers located both domestically and internationally can harmonize the data intake from clients when 

producers request to certify new fields for organic certification. By requesting the geolocation or 

information that can lead to geolocation information (Global Positioning Coordinates, parcel identification 

numbers, street address, etc.) of certified operations, certifiers will be able to receive consistent data that 

is easily managed while also allowing the inspectors to confirm the accuracy of the data during the 

inspection and use it as a cross-check. 

Background:

The Strengthening Organic Enforcement (SOE) rule will make supply chain tracebacks and mass balances 

mandatory. Complete supply chain tracebacks will require certifiers to work bi-directionally up and down 

the supply chain in cooperation with other certifying bodies.

In addition to the SOE, the USDA Organic Transition Initiative currently being rolled out across the US 

discusses ways to improve existing programs that support organic transition and markets. Consistency of 

certified operation location identification and verification of land eligibility is essential. It can be 

accomplished by requiring geolocation data for all certified operations. 
Applications for certification for a new field typically include a name for the field and the number of acres. 

Some certifiers also request the address or driving directions. Still, many certifiers confirmed that if 

asked, they could not locate each field they certify via google maps or other interactive GPS database . 

This lack of data impedes certifiers’ ability to act quickly in the case of aggregated mass balance 

investigations across clients or in the case of a major contamination event. 

Consistent Location Identification: 

Consistency in parcel identification and location should be required to comply with the SOE-mandated 

supply chain traceback requirements. 

In the Fall of 2021, the NOSB received the following comment/question regarding the proposed rule on 

Strengthening Organic Enforcement (SOE): "Will the final rule require mandatory data reporting to NOP 

by crop type, acreage, and location; and a number of animals by livestock type and location, at least on an 

annual basis to the Organic Integrity Database (OID)? A requirement for certifying agents to report 

production area certified by crop/livestock and location, on at least an annual basis, to the OID is one of 

the most impactful single actions that can be taken to increase integrity in the global organic control 

systems." This commenter’s question provided a road map for CACS. 

1. At the Fall 2022 NOSB meeting, the proposal, "Oversight Improvements to Deter Fraud: Acreage 

Reporting," was unanimously passed by the Board. 

a. The key aspect of the recommendation was a balance and cross-check to ensure that the 

volume of certified acres (under the NOP) ultimately supports the volume of organic 

products produced and sold (under the NOP). 

2. At the Spring 2023 NOSB meeting, the discussion document “Oversight Improvements to Deter 

Fraud: Consistent Location Identification” received public comment and was discussed by the 

NOSB. For the Fall 2023 NOSB meeting, the community will review a proposal with the same 

topic, and the NOSB will vote on it. 

a. The proposal aims to establish the structure and system for universal field location 

identification for organic producers, certifiers, inspectors, and the NOP, to register, verify, 

and cross-check the location of all acres certified under the NOP, both domestically and 

internationally. 

The Strengthening Organic Enforcement (SOE) Rule:

The SOE states, "Certifying agents must be able to conduct unannounced inspections of any operation 

they certify. Therefore, AMS requires that certifying agents only accept applications for certification or 

continue certification from operations for which the certifying agent can conduct unannounced 

inspections. To ensure consistency, transparency, and accountability, certifying agents are expected to 

describe the areas where they operate in the written materials they provide to applicants and certified 

operations and review the locations of all operations during their application or annual review. A 

certifying agent that cannot conduct unannounced inspections in an applicant’s or certified operation’s 

location due to logistical challenges, staffing, security, or other reasons, is considered not to have the 

administrative capacity for certification activities in that area, consistent with § 205.501(a)(19)”.

As one commenter mentioned, “The Strengthening Organic Enforcement Rule should reduce the risk of 

fraud in the organic marketplace. However, enforcement efforts depend upon sufficient and accurate 

information about each operation.” A consistent process for locating certified organic operations, 

including fields, would aid in executing parts of the SOE, including cross-checking and supply chain 

verification. 
An additional certifier commenter stated, "Geolocation will enable greater ease in organic oversight 

across certifiers and supply chains by applying fixed, traceable, and universally understood markers on 

individual plots of land that will not change over time.” 

History, Evolution, and Benchmarking of Geo-Referencing Information:

1. Global Navigation Satellite Systems (GNSS) and Global Positioning Systems (GPS) - In the 1970s, 

the United States military began using a form of GNSS called GPS for navigation, which became 

publicly available in the early 2000s. 

a. GPS allows for navigation to any point of interest, anywhere in the world. 

b. According to GPS.gov, “GPS is a U.S. - owned utility that provides users with positioning, 

navigation, and timing (PNT) services.....24 operating satellites are transmitting one-way 

signals that give current GPS satellite position and time.” GPS is generally expressed as 

specific latitude and longitude coordinates

c. Russia, China, and the European Union also have a GNSS similar to GPS. 

i. Japan and India have regionally based systems. 

d. The GPS is the oldest of all the GNSS. 

i. GPS.gov states, “the American taxpayer pays for the GPS service enjoyed 

throughout the world. All GPS program funding comes from general U.S. tax 

revenues....there are no plans to privatize GPS, as US Law and policy require the 

civil GPS service to be provided free of direct user fees.” 

ii. One commenter highlighted that three certifiers are currently requesting GPS 

coordinates (CCOF, OOTC, and WSDA), with several other certifiers requesting 

GPS coordinates from international operations that are certified to NOP 

standards. 

2. Keyhole Markup Language (KML) and Keyhole Markup Language Zipped (KMZ)

a. KML is a file responsible for storing map locations that can be viewed with the following: 

i. Geographical Information Systems (GIS) such as ArcGIS

ii. Geospatial Tools such as Google Earth Pro

b. KMZ is a Zip-compressed version of a KML 

i. One commenter highlighted that KMZ files, which display field shapes and 

acreages, are maintained in WSDA’s database. 

The precedence of geo-referenced data is found within the USDA currently:

1. Risk Management Agency (RMA):

a. Having exact location information provides enhanced transparency and oversight. The 

Risk Management Agency’s General Standards Handbook Section 1.c. of the Maintaining 

Organic Records states, “a requirement for organic producer’s record keeping is that 

“insured must have, e.g., aerial or GIS (Geographical Information System) maps, from the 

organic farming operation that show the exact location of each field for certified organic, 

transitional, buffer zone, and conventional acreage not maintained under an organic 

practice.”

2. Certifier Community + Neighbors to the South:

a. Several Certifiers are already collecting town, range, and section (TRS) data with others 

using “GPS Coordinates.” How can those certifiers share with other ACAs their intake 

process?
b. One certifier creates a KMZ, in Google Earth Pro, for every "site" (synonymous with field 

or parcel ). The business provides location and latitude/longitude; inspectors verify that 

info and create a KMZ file. 

c. Several certifiers require GPS coordinates for all farms outside of the USA that are 

certified to the NOP standard. 

i. A public commenter mentioned that “the practice of incorporating and tracking 

GPS coordinates, whether as degrees-minutes-seconds or digital coordinates, is 

universal among those certifiers that are accredited to the Mexican “Ley de 

Productos Orgánicos” Standard (LPO), as the practice is already required under 

that standard.”

Low Burden - One-Time Collection:

By requiring a consistent method of location identification information through GPS coordinates, it will be 

easy and low-burden to achieve consistency across all geographic locations, domestic and international. 

The information can be easily obtained once and then used from that point forward for organic 

operations that do not have access to this information. GPS is free and accessible globally and can be the 

logical path forward for consistently capturing location information domestically and internationally. 

According to two certifiers, via the public comment process, the burden is low and outweighed by 

improved resolution. Additionally, a certifier went on to state that the “benefits will be seen internally for 

each certifier with greater long-term visibility and tracking on field data and management and that the 

use of geolocation will enable greater ease in organic oversight across certifiers and supply chains by 

applying fixed, traceable, and universally understood markers on individual plots of land that will not 

change over time.” 

GPS proposed framework for location information: 

1. One GPS coordinate (including latitude and longitude) for identification of each location, such as a 

certification office, brokerage or importer office, manufacturing facility, handling facility, field, 

production unit - a field in a grower group, etc.

a. A GPS coordinate in the center of the field can be a best practice.

Spring 2023 Discussion Summary:

During the Spring 2023 meeting, the NOSB discussed the Consistent Location Identification discussion 

document and reviewed public comments, which involved answering several questions regarding 

collecting field-level location information and verification methods.

The inspector community that commented was in complete support of requiring more consistent 

methods of field location information. Inspector comments from the Spring of 2023 consistently 

confirmed the challenge. They even stated, “The pandemic presented an opportunity to test the ability to 

verify the location of a field without the operator being available. In the best case - each field has an 

address & each address maps to the frontage of the field, and in the worst case - a field without means to 

navigate to and/or a hand-drawn or low-quality map with indistinguishable features, often due to having 

been faxed and/or copied too many times. In these cases, there is practically no way to identify where a 

field is located without the operator. Most fields can be found eventually, but only after extensive effort 

and significant time.” The NOSB is requesting that we commit as a community to solving this easy 

challenge, so inspectors have more time to find the fraud versus spending time finding the field. 
The NOSB reviewed comments from members of the community, including certifiers that wanted to 

ensure clarity of the information; through public comments and NOSB discussion, clarity was received, 

and a summary is listed below:

1. Several members noted that trying to keep GPS locations updated for diverse and small farms is 

difficult.

a. Once the farm is located, GPS, a standardized system, doesn’t deviate and doesn’t need 

to be continuously updated by the operation. 

i. This recommendation does not require annual GPS information for each crop nor 

does is require details such as row feet. 

b. The macro field border or parcel does not change based on crop production, the type of 

crop, or how a producer segments the field or parcel. The recommendation is for the 

macro border of each field or parcel, not how a producer segments out the field or parcel 

to grow crops.

c. Should GPS coordinates be unavailable due to technology access or other barriers, the 

following suggestions based on public comment should be used as acceptable alternatives 

as all three ways, with additional steps, will lead to GPS-coordinate capture.

i. Parcel numbers (standard property identifiers that each county recognizes)

ii. Address (not mailing route such as Rt 2 Box 176, but a street address if applicable)

iii. Legal address including Section / Township / Range

Recommendation:

The CACS recommends that the NOP provide guidance to advise all accredited certifiers to obtain 

consistent record consistent location information (e.g., geocodes, legal parcel identification (ID), legal 

address, physical address) that can lead to GPS coordinates of all applicants for certification and certified 

operations (parcels, production units - grower groups, handling locations, importers, brokers, etc.). This 

will result in harmonization of location data of all parcels enabling certifiers to streamline cross-checks 

and share information internally between operator, certifier, and inspector.

Vote in Subcommittee:

Motion to accept the proposal on Oversight Improvements to Deter Fraud: Consistent Location 

Identification 

Motion by: Amy Bruch

Seconded by: Nate Powell-Palm 

Yes: 9 No: 0 Abstain: 0 Recuse: 0 Absent: 0