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NOSB Recommendation 

Adopted October 20, 2002 

Criteria for Certification of Grower Groups 

Introduction: 

 Grower group certification refers to the certification of a group of producers whose farms are uniform in 

most ways, and who are organized under one management and marketing system. Grower group 

certifications have historically been used for the certification of cooperatives or groups of producers located 

in a geographical or social region, whose crops are marketed collectively. Primary crops produced by grower 

groups include coffee, cocoa, tea, spices, and tropical fruits. 

Background: 

In section 205.2, the final rule defines “person” as “an individual, partnership, corporation, association, 

cooperative, or other entity.” 

In section 205.400 “General requirements for certification,” the final rule states: 

“A person seeking to receive or maintain organic certification under the regulations in this part must: 

(a) Comply with the Act and applicable organic production and handling regulations of this part; 

(b) Establish, implement, and update annually an organic production or handling system plan that is 

submitted to an accredited certifying agent as provided for in § 205.200; 

(c) Permit on-site inspections with complete access to the production or handling operation, including 

noncertified production and handling areas, structures, and offices by the certifying agent as provided for in 

§ 205.403; 

(d) Maintain all records applicable to the organic operation for not less than 5 years beyond their creation 

and allow authorized representatives of the Secretary, the applicable State organic program's governing State 

official, and the certifying agent access to such records during normal business hours for review and copying 

to determine compliance with the Act and the regulations in this part, as provided for in § 205.104; 

(e) Submit the applicable fees charged by the certifying agent; and 

(f) Immediately notify the certifying agent concerning any: 

(1) Application, including drift, of a prohibited substance to any field, production unit, site, facility, 

livestock, or product that is part of an operation; and 

(2) Change in a certified operation or any portion of a certified operation that may affect its compliance with 

the Act and the regulations in this part.” 

Given the fact that the rule includes “cooperative” and “association” in the definition of “person”, and given 

the fact that section 205.400 indicates that it is a “person” who seeks organic certification, it can be 

concluded that grower groups, organized as cooperatives or associations, can seek certification as one 

operation under the NOP without a change to the rule. 

Grower groups are different from other entities seeking certification in that they are comprised of numerous 

producers who are certified as one entity, rather than being certified as individual sole proprietors. 

Historically, not all grower group members’ farms are individually inspected by the certifying agent 

annually. This means that the grower group must have a quality system, or internal control system, in place 

to assure that all members of the group operate according to the system plan in compliance with the organic 

standard. The quality system of the grower group is inspected at least annually, but only a set percentage of 

the member operations are visited by the certifying agent. Individual site inspections are conducted primarily 

to validate the functioning of the quality system. 
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Rationale: 

Many products sold as organic in the United States, including coffee, cocoa, tea, spices, and tropical fruits, 

are produced by grower groups. These types of operations are certified by certifying agents who have 

received NOP accreditation. While there is no need to change to the final rule, there is a need to provide 

guidance to the NOP to assure that certifying agents who operate grower group certification programs follow 

consistent procedures. There is also a need to assure that such certifying agents are evaluated according to set 

criteria during the accreditation review of their programs. 

Recommendation #1: 

Criteria for the Certification of Grower Groups 

The NOSB recommends that, in order to be certified as a grower group, the following conditions must be 

met: 

• The crops and farming practices of the producers must be uniform and reflect a consistent process or 

methodology, using the same inputs. 

• The group must be managed as a legal entity under one central administration that is uniform and 

consistent. 

• Participation in the group is limited to producers who sell all of their organic production through the 

group. 

• Producers who are certified as part of a grower group do not possess individual certificates. Rather, 

the grower group is certified as a unit. 

• Grower groups must establish and implement an internal control system (quality system), with 

supervision and documentation of production practices and inputs used at each producer's operation 

to insure compliance with the USDA’s National Organic Standard. 

• Grower groups must ensure that all members understand the US National Organic Standard and how 

it applies to their specific operations. 

• Grower groups must utilize centralized processing, distribution, and marketing facilities and systems. 

The certifying agent shall have policies and procedures for determining how many growers must receive an 

annual inspection by the certifying agent. For each grower group it certifies, a certifying agent must 

document its method for determining the number of growers to be inspected. This determination must 

include consideration of: 

• The number of operations participating in the grower group; 

• The size of the average operation in the grower group; 

• The degree of uniformity between the group’s operations; 

• The complexity of the group’s production system(s); and 

• The management structure of the group’s internal control system. 

Recommendation #2: 

The NOSB recommends that the following information be included in the NOP Accreditation Manual: 

A. Inspection of Grower Groups

 Information provided. The first step of any grower group inspection is to review the material from the 
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certifying agent to determine the scope of the project. Grower groups are often very complex. They may 

include hundreds if not thousands of producers. These types of operations do not easily fit normal inspection 

protocols. Therefore, much supplemental data is necessary in addition to normal certification documents. 

The following is a list of information that the certifying agent must provide to the inspector prior to the 

inspection: 

• 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. Many grower 

groups maintain individual producer records such as parcel maps and grower agreements which are 

generally reviewed at the time of inspection. 

• Organic system plan, certification questionnaire, or application. 

• Name of contact persons with phone numbers, both home and work. It is important to have access to 

at least two contacts in case the primary contact person cannot be reached. 

• A description of the project to understand how it is organized. A previous inspection report should be 

provided for certification updates. 

• Handling plans, questionnaires/applications, if there is any processing. (Many grower groups operate 

processing and/or storage facilities.) 

• Information on final sales and distribution. This is important to determine if any off-site export or 

storage facilities need to be inspected. 

• In the case of certification updates, the inspector should be provided with the past certification letter 

with all conditions for certification clearly stated. As indicated, the past inspection report can be 

extremely valuable, and should be reviewed. 

 Review internal control documents. Upon arrival at the inspection locale, meet with the management to 

plan the inspection itinerary. You should clearly understand the organizational management of the project 

prior to heading out into the field. You will need documentation of the internal control system to properly 

verify local oversight efforts, education programs, product flow, and production practices. It is advisable to 

review internal control documents and other records before heading out into the field. This information can 

help you choose where to focus your inspection site visits. 

 Select the sites to visit. Make sure that you have the freedom to select any part of the project for 

inspection. Do not allow the grower group manager to “direct” the inspection. Keep in mind that the further a 

group of producers are from the main office or the internal control system administrator, the weaker the 

control may be. Attempt to visit remote producers to best assess the system. 

 Interview grower group members. Once the inspection begins, it is best to follow the product flow 

starting with the production sites, followed by primary processing, final processing, packaging, storage, and 

distribution. When visiting the producers, in addition to observing production practices and organic control 

points specific to the operation, the inspector must verify aspects critical to the overall project. Interview 

producers directly. Ask questions not only about their farms, but also about other project programs. How 

well does the producer understand what organic farming and certification means? 

 Ask direct questions. It is also important to ask producers, point blank, "When was the last time you 

used agro-chemicals?" You may want to ask specifically if this includes urea or Roundup or other brand 

name products common to the area. Often producers in a remote area do not clearly understand that these 

substances are prohibited. Do not assume anything. Individual farm integrity usually reflects the producer's 

understanding of organic certification, which is directly linked to the project's educational and oversight 

efforts. 
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 Understand local issues. It is critical to understand the local culture, traditions, and common inputs. It is 

advantageous to invite a local inspector to accompany you. A local inspector can help build trust with 

producers and help you understand local issues. Such cooperative arrangements can help empower 

indigenous inspectors. 

 Office audit. Once all aspects of the project have been inspected, a final visit to the project office will 

likely be required for an audit. The audit of the entire project is best done at the end of the inspection, when 

the inspector has a more thorough understanding of the entire operation. Additionally, it will most likely be 

necessary to verify different pieces of information gathered during the field inspection. 

 

 Exit interview. An exit interview with the project management is necessary in order to answer remaining 

questions. This gives the inspector a last chance to secure missing information, obtain required signatures, 

clarifying confusing, inconsistent, or inaccurate information, and communicate issues of concern. 

B. The Internal Control System and Organic Control Points (OCPs) 

 Assess the internal control system. The most critical component of both the grower group inspection 

and the grower group inspection report is the assessment of the internal control system. (A grower group 

inspection is in fact an evaluation of the internal control system.) The report must address the steps taken by 

the internal control system to enforce compliance with organic standards. 

• Have the operators been provided copies of the standards in a language or format they understand? 

• Does the internal control system use individual inspection reports to assess operator compliance? 

 If not, how is compliance assessment documented? 

• How often do official representatives of the control system visit each operation? 

• What kinds of documents are generated to verify these visits? 

• Are new operators inspected prior to being added to the GG? 

• Have all grower group members signed a contract stating that they will comply with the organic 

standards and permit annual inspections? 

• Are operators provided assistance to comply with the standards? 

• What happens when non-compliance is suspected or detected? 

• Are there records of the actions taken when non-compliance has been investigated? 

• Does the control system have an official "sanctions" policy? If so, submit a copy with your report. 

 Report inconsistencies. It is important to clearly describe the consistency of the project from producer to 

producer. As indicated, different certifying agents may have different requirements for grower group 

inspections. Some may require spreadsheets with information on each producer; others may require site visit 

sheets signed by the farmer at the farm; others require inspecting only a percentage of the total number of 

producers. If you find prohibited practices and you are only inspecting 20% of the operations, it is a good bet 

that you have only found 1/5 of the problems. Removal of the individual producer is not necessarily the final 

answer. The situation may be an indication that the project is not providing proper oversight. Internal records 

should match your findings and the findings of the certification program. Present your findings in the 

inspection report, along with any inconsistencies and unresolved issues. 

 OCPs. It is very important to describe the organic control points of the overall operation, where loss of 

organic integrity may occur. The inspector should report the preventative steps taken to protect organic 

products, and identify deficiencies where organic control points are not sufficiently addressed. 

 The following is a list of examples of organic control points encountered during grower group 
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inspections: 

• Unclear registers of grower group members. 

• Unclear or inadequate maps. 

• Inclusion of new fields or new producers with no conversion or documentation. 

• Use of synthetic fertilizers - A producer may think that because he or she uses no herbicides or 

pesticides, the operation is organic. 

• Use of used agrochemical bags or containers for harvested products. 

• Contamination during storage or transport, e.g.: boats with gas and water in bilge, or storage under 

the house with gas and paint on top of product. 

• Insufficient buffers or non-separation from other crops that have chemicals e.g.: cacao 

inter-planted with plantain, with urea used to fertilize the plantain. 

• Inclusion of crops from neighbors or relatives who are not on the producer list. 

• Intentional chemical use. "I only used a little bit." 

• Shared use of backpack sprayers which are also used for applying prohibited materials. 

• Unclear internal purchase and transaction records within the grower group. 

 Processing by grower groups. Finally, grower group reports may include process inspection reports for 

all of the processes performed by the grower group. Make sure that the grower group has submitted a 

handling system plan, as applicable, and that the plan has been approved by the certifying agent. Follow 

handling inspection protocols and submit a handling inspection report. 

C. Grower Group Inspection Report Guide 

 The grower group inspection report basically follows the outline for a farm inspection report. However, 

sections may need to be expanded, added, or modified. For example, a section on Organizational 

Management is helpful to describe many aspects of the project. This section should describe the structure and 

assess the functioning of the internal control system. It should also list the names of communities, number of 

producers in each, hectares of each, and, if possible, estimated yields, with totals. 

 The following outline summarizes the general areas of grower groups that should always be inspected, 

and provides a list of the additional topics which must be covered in a grower group inspection report: 

1. Background 

2. Project headquarters and audit trail information; organization, accessibility, and accuracy of 

information; projected yields of products requested for certification 

3. Organization management, internal control system, and compliance mechanisms, including 

records maintained 

4. List of communities 

5. Grower lists 

6. All processing facilities, both on-farm and off-farm 

7. Transportation systems 

8. Storage facilities 

9. Field conditions; inspector observations 

10. Risk assessment; adjoining land uses; other organic control points 

11. Inputs used 

12. Equipment used 

13. Packaging materials 

14. Producer interviews; inspector observations 

15. Education program – producer understanding of organic principles and standards 
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16. Split operations - production of non-organic crops/products by grower group members 

17. Other considerations 

18. Summary 

19. Attachments 

D. Outline for Organization and Assessment of the Internal Control System (ICS) 

1. Field officers 

Field officers are employed by the grower group. They have mixed roles: 

a. Information/extension 

b. Registration of growers 

c. Internal control 

d. On-farm research 

Field officers often become part of the community. Because field officers have internal control and education 

functions, they may have conflict of interest issues. This can be solved by rotation of field officers or field 

officers from other areas handling the internal control function. There should be a minimum of one field 

officer per maximum 500 farmers. 

2. Principles of ICS 

a. analyses/description of situation 

b. appropriate, documented system 

c. awareness raising, information and instruction, contracting, verbal and written, social controls, 

 monitoring, corrective actions, risk analyses 

3. ICS documents 

a. Project description 

 1. Basic project outline 

 2. Farmer and farm profile, grower lists, site maps 

 3. Farming practices 

 4. Farmer support system 

 5. Stakeholder analyses 

 6. Risk-assessment 

 b. The ICS itself 

 1. ICS personnel and the ICS office 

 2. Documentation & record keeping (forms) 

 3. Monitoring and corrective actions 

 4. The buying system arrangement 

 5. Product storage and handling procedures 

 6. Code numbering and product tracing 

 c. Updating the system (annual report) 

 1. Compliance with standards 

 2. Corrective actions undertaken 

 3. Farm/project economy – financial report 

 4. Update of documents 

E. Evaluation of the Internal Control System (ICS) 

The outline below contains further methodology for evaluation of the ICS by the third party inspector: 
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 a. At the ICS office 

 1. Review of the documented system (Is it sufficient for the current situation?) 

 2. File check to see whether system is being adhered to (Is office, are documents, is staff, is the 

 system functioning?) 

 3. Review cases of farmer non-compliance 

 4. Identification of problem areas/risk assessment 

 5. Construct a plan for field visits: 

 • Select some to get a general feeling, at random 

 • Select some targeted at problems/risk areas and distant production sites 

 This work can be done in one day if the office and staff are well organized. The inspector 

 should use a format/checklist/reporting form for this office work. 

 b. In the field 

 1. Field visits 

 • Conduct some farm re-inspection visits 

 • Inspect some at random (can even be demonstration farm or village elders) 

 • Inspect some focused on the problem/risk areas 

 • Meet with community, second parties 

 • Evaluate social control mechanisms 

 • Meet with third parties 

 As soon as a non-compliance is detected, the inspector will want to determine whether the non- 

 compliance is the odd exception or whether it is widespread. 

 c. Back in ICS office (exit interview) 

 1. Share evaluation of the field visits with field staff. 

 2. Identify OCPs and potential non-compliance issues. 

 3. Discuss strategies to address areas of non-compliance with management and field staff.