1400 Independence Avenue, SW

Room 2646-S, STOP 0268

Washington, DC 20250-0201

NATIONAL ORGANIC PROGRAM RESPONSE TO 2018 PEER REVIEW

May 30, 2019

FROM: Jennifer Tucker, Ph.D.

Deputy Administrator

National Organic Program (NOP)

SUBJECT: National Organic Program Corrective Actions:

Response to 2018 Peer Review Audit

Background

The peer review process is a vital component of the U.S. Department of Agriculture (USDA) 

Agricultural Marketing Service National Organic Program’s (NOP) commitment to continuous 

improvement. The peer review process is described in NOP 1031 “Peer Review of the National 

Organic Program (NOP) Accreditation.” For its 2018 peer review, the NOP contracted with the 

American National Standards Institute (ANSI). The 2018 ANSI Peer Review Panel evaluated 

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

quality standard. Consistent with the NOP’s priorities in introducing risk-based oversight 

approaches, the program asked ANSI for specific feedback related to this area.

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

policies and procedures, and ISO/IEC 17011.

Opportunities for Improvement

ANSI recommended ten areas for improvement as NOP introduces more risk-based oversight 

approaches.

Personnel

1. The NOP Organizational Chart does not show the Quality Manager position.

2. The NOP does not have a sufficient number of auditors.

3. Satellite offices of certifiers are not audited on a frequent enough basis to reduce risk and 

prevent potential fraud.

4. There is insufficient NOP personnel to handle the number of complaints and enforcement 

actions required of the C&E division.

Process Improvement

5. Procedures for residue sampling are not clearly understood or followed by international 

certifiers.

6. NOP should establish stronger quantitative objectives and key performance indicators to

effectively measure and monitor the program’s progress towards goals.

7. Several documents were found to be out of compliance with the document control 

procedure.
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8. There is an opportunity for NOP to provide further protections for its USDA Organic 

seal.

Recordkeeping

9. The accreditation certificate does not identify all premises from which one or more key 

activities are performed and covered by the accreditation and the physical addresses 

associated with the certification body.

10. There is no documentation for the relationships between the NOP and related bodies; and 

no evidence of the participation of the interested parties.

NOP Corrective Actions

Since the 2018 Peer Review was completed, NOP has focused significant resources on 

improving processes, addressing personnel needs, and developing training. In response to the ten

ANSI findings, the NOP is implementing the following corrective actions:

Personnel

1. NOP Organizational Chart. The NOP hired a Quality Manager in May of 2019, and 

updated NOP 1001 “Organizational Chart.” The updated organizational chart includes the 

Quality Manager position, as well as other personnel changes made during 2019.

2. Insufficient Number of Auditors. The NOP received approval to hire full time auditors 

to increase the program’s capacity. In April of 2019, the NOP advertised a job 

announcement for the new position and intends to hire up to four full time auditors. The 

NOP will also advertise job announcements for additional Accreditation Managers in 

2019.

3. Frequency of Satellite Office Auditing. As noted above, NOP is hiring full time 

auditors to begin in 2019. This will increase its capacity to conduct audits, including 

audits of certifier satellite offices. NOP has developed a new quarterly risk assessment 

approach; this tool will be used as an input to evolve towards a risk-informed approach to

audit scheduling by late 2019, so certifier satellite offices with increased risk will be a 

higher priority for assessment.

4. Insufficient NOP Personnel to Handle Complaints. The Compliance and Enforcement 

(C&E) Division has increased its capacity to address complaints by partnering with a 

contractor team. This work began in September 2018 and added additional people to 

review and analyze complaints. The bulk of the complaints processed by C&E concern

uncertified operations and simple labeling violations, which are now handled by the 

contractor. This change has allowed C&E investigators to concentrate their work on more 

complex complaints. NOP has also advertised a job announcement for Livestock 

Compliance specialists to support complex complaints related to this scope.

Process Improvement

5. Residue Sampling. In April 2019, the NOP launched the Organic Integrity Learning 

Center, to provide free online training for organic professionals, including certification 

staff, inspectors, and reviewers. NOP plans to develop and launch training on sampling 

and testing in the Learning Center in 2019-2020.
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The NOP also plans to conduct training on NOP 2613 “Responding to Results from 

Pesticide Residue Testing” during the 2020 BioFach International Auditor’s Training in 

Germany. In 2020 the NOP will include a presentation on residue sampling in the agenda

to increase international certifiers’ understanding of how to respond to residue test 

results.

6. Stronger Quantitative Objectives and Key Performance Indicators. The NOP 

developed four primary goals for 2019, with quantitative objectives and indicators 

associated with each goal. The goals are aligned with agency wide goals and include 

specifics that are tracked on a monthly basis. These goals are also reflected as target 

performance measures in manager and staff performance plans.

7. Document Control Procedure. The NOP’s quality management system document NOP 

1010 describes the process by which documents are reviewed and cleared for public 

distribution. All Guidance documents, Policy Memos, and Instructions undergo Office of 

General Counsel review as part of the review process. The NOP is reviewing its 

procedures in the 4000 quality management series, which focuses on Compliance and 

Enforcement topics. NOP plans to officially incorporate the revised procedures into the 

internal quality manual in 2019. The NOP will also continue to maintain an updated NOP 

1006 (master list of NOP quality system documents). The new Quality Manager will help 

NOP continue to improve its oversight and active facilitation of the quality management 

system.

8. Protections for USDA Organic Seal. ANSI provided the NOP with feedback related to 

certifier control of the USDA organic seal, noting the opportunity to highlight certifier 

responsibilities for protecting the seal in the Terms of Accreditation. In response to this, 

the program notes there are significantly higher risks associated with the use of the seal 

by uncertified or suspended operations, or those who have surrendered certification. 

These operations are not under the control of certifiers. NOP has not identified any 

systemic concerns with respect to certifier control of the organic seal. As such, the 

program would prefer to focus its Terms of Accreditation on the items of highest impact, 

and not adopt this recommendation. Instead, we will focus efforts on continuing to pursue 

complaint cases where there is clear evidence of seal misuse by companies not under the 

jurisdiction of a certifier.

Recordkeeping

9. Accreditation Certificate. Future accreditation postings on the AMS website will 

include the address of satellite offices conducting key certification activities. This may be 

done through a certificate addendum or listings in the Organic Integrity Database. NOP 

will implement this approach by Fall 2019.

10. Documentation of NOP Relationships. The NOP follows many rules and policies that 

effectively identify and manage possible conflicts of interest with external parties. The 

NOP will consolidate those policies into a summary of the measures it takes to avoid 

conflicts of interest. That summary will be shared at the fall 2019 National Organic 

Standards Board (NOSB) meeting and will be posted as part of the meeting’s NOP 

update presentation.
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Recommendations

ANSI provided the NOP with two recommendations regarding training for auditors and 

certification staff, including inspectors. ANSI noted that by providing centralized training 

materials with easy access, the NOP could assist the certifier community in delivering 

high quality and consistent inspections across all certifiers.

The NOP held a Risk-Based Audit training for auditors in fall 2018 and launched the 

Organic Integrity Learning Center in May of 2019. The Learning Center is a formal 

Learning Management System, that supports the professional development and 

continuing education of professionals working to protect organic integrity. The NOP sent 

a memo to all certifiers notifying them of the new Learning Center, and the trainings 

available for certification staff and inspectors. The Learning Center already has over 700 

registered users, and the NOP will be adding additional training courses on Dairy 

Compliance, Materials Review, Certification Administration, and Residue Sampling and 

Testing in 2019-2020.

Next Steps

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

seriously, and will continue to evolve our records management practices, address personnel 

needs, and conduct regular training for auditors and certifiers. With a focus on quality 

accreditation processes, NOP continues to support the organic community and maintain organic 

integrity for all.