2023 ANAB Peer Review Report 

For 

Agricultural Marketing Services (AMS)

National Organic Program (NOP) 

Dates of Review Panel:

September 18 to September 28, 2023 

Prepared by

ANSI NATIONAL ACCREDITATION BOARD 

1899 L Street, 11th Floor

Washington, DC 20036

Document: 2023-USDA-PeerReviewPanel-01-1-PeerReviewTeam
ANAB 2023 Peer Review Report

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I. TABLE OF CONTENTS

I. TABLE OF CONTENTS ...................................................................................................... 2

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

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

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

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

V. CONCLUSION.................................................................................................................. 7
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I. GENERAL INFORMATION

Accreditation Body

Name of Reviewed Body United States Department of Agriculture

Agricultural Marketing Services (AMS)

National Organic Program

Address 1400 Independence Avenue S.W.

Room 2648 South Building

Washington, DC 20250

Telephone 202-720-3252

Review by: 

Type of Review Peer Review Panel Evaluation

On-site Peer Review Dates September 18, 19, 26, 27 and 28, 2023

Review Standard(s)

US 7 CFR Part 205, National Organic Program 

 ISO/IEC 17011:2017 Conformity Assessment – General 

requirements for accreditation bodies accrediting conformity 

assessment bodies

Peer Review Team

Lead Reviewer: Mario Llerenas

Technical Reviewer: Susan Ranck

Technical Reviewer: Jean Richardson

ANSI Staff: Nikki Jackson, ANAB Senior Accreditation Director

Report Prepared by:

 Mario Llerenas

Jean Richardson

Susan Ranck

Submitted on: November 3, 2023
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II. SCOPE

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

requirements. ANSI National Accreditation Body (ANAB) convened this panel on July 14, 2023.

The peer review panel is tasked to:

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

Part 205 and ISO/IEC 17011;

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

and

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

National Organic Standards Board.

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

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

III. INTRODUCTION

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

U.S. Department of Agriculture (USDA) and is the organization responsible for activities relating to the 

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

and the USDA organic regulations. Key functions of the NOP include:

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

• Enforcing organic production, handling, and labeling standards

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

Panel Members

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

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

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

ISO/IEC-trained

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

Evaluator; ANAB Food Safety Lead Assessor

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

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

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

the personnel to interview during the remote assessment was created on September 8th, 2023, and

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

remote assessment, and the findings are included in this report.

Assessment Plan

The remote assessment plan was issued on July 25, 2023; this version was approved and signed by the 

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

the ANAB database.

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

The QMS Peer Review was conducted on September 18 to 19, 2023; the Technical Peer Review was 

conducted on September 26 to September 28, 2023.

Opening / Closing Meetings

In accordance with the assessment plan, the opening meeting was conducted on Monday, September 18, 

2023, at 11:00 am with six NOP senior staff and the ANAB Peer Review team in attendance. At the end 

of the opening meeting, the NOP Deputy Administrator, Jennifer Tucker, explained the key changes in the 
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organizational structure of the NOP, the accreditation process, and its relationship with other 

governmental departments.

The closing meeting for the remote Peer Review was conducted on Thursday, 28 of September 2023 at

4:00 pm with five NOP staff and the Peer Review team in attendance. The results of the remote 

assessment were discussed during the technical closing meeting:

Zero opportunities for improvement (OFI) and six comments with observations for NOP to 

consider in its management system were identified during this remote Peer Review.

Additional Comments

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

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

NOP was able to establish and put in place significant improvements since the 2022 Peer Review in both 

the QMS and the Accreditation Process. NOP implemented more risk-based based processes and have 

transitioned to a unified SharePoint document sharing system.

NOP personnel demonstrated sound knowledge in both the management system and technical 

requirements. NOP program management also demonstrated commitment to continuous improvement as 

evidenced through the resolution of internal and peer review-identified risks.

IV. RESULTS OF PEER REVIEW PANEL EVALUATION

1. METHODOLOGY - The Peer Review team verified the compliance of USDA NOP to 7 CFR Part 

205 and ISO/IEC 17011:2017 based on the sampling of documents, interviews, and records; the 

Peer Review team selected five accreditation files as well as associated NOP qualified assessors

and staff personnel records in order to verify the accreditation process and competency. The 

conclusions of the Peer Review team are based on objective evidence collected and observed 

during the assessment and are contained in this report as compiled by the lead and technical 

evaluators.

2. Previous OFIs – There were no findings documented by the Peer Review team during the 2022

remote assessment to verify.

2022 Opportunity for 

Improvement

2023 Verification of the effectiveness

Not Applicable

3. 2023 Opportunities for Improvement. During this remote assessment, the Peer Review team 

did not identify any finding/opportunity for improvement.

4. 2023 Comments. During this remote assessment, the Peer Review team identified six 

observations classified as Comments. These comments originated from the Peer Review team 

and can be considered by NOP as examples of good practices in the accreditation process.

COMMENT # 1

NOP 1010 NOP Quality Management System Section 4.6 says “Obsolete Documents requires 

the Quality Manager adds an “Archived” watermark to the document.”

The procedure for communication distribution and watermarking obsolete documents are not 

always following by NOP.

Reference: ISO/IEC 17011 Document Control 9.3
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COMMENT # 2

NOP’s current policy is to keep records indefinitely. NOP is developing a new file plan for

records retention and disposition:

Document: NOP Records File Plan and Disposition Schedule – WIP. The document is still in 

Draft and in process to be finalized and approved. 

Reference: ISO/IEC 17011 Records Control 9.4

COMMENT # 3

The Quality Manual in the section 9.6 Improvement includes the section 9.6.1 Preventive 

Actions and makes reference to the NOP 1020 Corrective and Preventive Actions; however, 

there is no reference to the actions related to the risks identified by NOP.

Evidence of these risk-based actions were observed in the Management Review meeting

notes. However, the Quality Manual does not include the preventative actions documented 

during management reviews.

Reference: ISO/IEC 17011 Improvements 9.6

COMMENT # 4

NOP should maintain optimum staffing levels and training, to ensure NOP has adequate 

staffing for the March 2024 implementation of Strengthening Organic Enforcement.

Reference: ISO/IEC 17011 Competence of Personnel 6.1

COMMENT # 5

NOP and prior peer reviews have identified the timeline for mid-term and renewal assessments 

(from initiation to reaccreditation) to be excessive (>18 months). NOP has made strides in 

reducing this time frame and was recently observed to complete a midterm assessment in less 

than 12 months. It is necessary the NOP continues to emphasize meeting average acceptable 

time frames.

Reference: ISO/IEC 17011 Accreditation Decision-making 7.7

COMMENT # 6

NOP has one person responsible for appeal reviews and recommendations, and an additional 

staff person trained on the intake of appeals in the absence of the primary person. However,

there is significant risk associated with the lack of additional persons familiar with the appeals 

process.

Reference: ISO/IEC 17011 Appeals 7.13

2023 Strengths. The Peer Review team identified positive processes and activities during the 

2023 remote assessment. The following are the strengths identified by the team:

NOP PROCESS COMMENTS

Quality Management 

System The NOP Quality Management System is documented in accordance 

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

NOP demonstrated that the system is well documented and 

implemented.
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NOP objectives and goals 1. Strengthening Organic Enforcement completed the rulemaking 

process and NOP, and certifiers are providing education for the 

March 19, 2024, implementation due date.

2. NOP improved its access to all documents and records by 

implementing SharePoint and is expected to be fully integrated 

by the end of 2023.

Collaborative Teamwork 1. All staff interviewed demonstrated a collaborative team 

approach to their work, which resulted in increased efficiencies 

on all aspects of the accreditation process.

2. Staff seek input and effectively collaborate across all divisions.

3. Staff indicate knowledge of the Strategic Plan.

4. Staff were consistently articulate and passionate in describing 

their work.

Team Leadership 1. Staff consistently describe the Deputy Administrator’s leadership

style as open, transparent, and collaborative which empowers 

them in their work and leads to successful outcomes.

2. NOP auditors and management staff exhibited a strong crossfunctional understanding of the goals and methods of 

accreditation specific to the program. There is a consistent and 

far-reaching passion for the work and mission as exhibited by 

interviews with various positions within the organization.

Assessment 1. NOP has finalized a risk-based approach to audits, and is now 

able to schedule audits more efficiently, many months ahead of 

time, and grouped in geographic areas of the world.

2. NOP has established a comprehensive risk-based program in 

India with the intention of carrying this forward to other high-risk 

regions.

Competency 1. All NOP staff interviewed and taking part in the Peer Review 

demonstrated competency.

2. NOP continues to expand learning opportunities for certifiers 

and inspectors.

Number of Staff The NOP has and continues to hire staff in all divisions to administer the 

Program efficiently.

NOP Responsive to 

Public Comment

1. NOP continues to seek stakeholder input through its 

collaborative work with the National Organic Standards Board

(NOSB). 

2. NOP continues to effectively use the NOSB for guidance, 

rulemaking, and National List review.

V. CONCLUSION

This report completes the work of the 2023 ANAB Peer Review for the USDA NOP accreditation body.

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

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

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

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

six observations classified as comments were identified during this remote assessment. 

NOP management consistently demonstrated their commitment to improvement to the Peer Review team. 
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The Peer Review team would like to express appreciation to USDA NOP personnel for their cooperation 

and commitment during the Peer Review assessment.

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