1400 Independence Avenue, SW.

Room 2642-South, STOP 0268

Washington, DC 20250-0268

July 31, 2020

MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD

FROM: Jennifer Tucker, Ph.D.

Deputy Administrator

National Organic Program

SUBJECT: Request for Discussion and Recommendations: Human Capital Strategy for 

Organic Inspectors and Reviewers

The National Organic Program (NOP) requests that the National Organic Standards Board 

(NOSB) facilitate a public discussion and provide recommendations related to a Human Capital 

Strategy for Organic Inspectors and Reviewers.

Human capital refers to the skills, knowledge, and experience held by an individual or 

population, and is generally considered one of the most important intangible assets that 

contributes value to an organization or community. As a public-private partnership, organic 

certification is a shared responsibility across the organic community, making the effective 

management of human capital an essential element of success in protecting the USDA organic 

seal.

Organic stakeholders, including certifiers and organic farms and businesses, have raised the 

problem of a known shortage in well-qualified organic inspectors and reviewers. With the 

increasing size and complexity of organic supply chains, engaging in near-term and long-term 

efforts to develop, recruit, and retain a strong community of well-trained and well-qualified 

inspectors and reviewers is essential for organic integrity.

We are initiating this work agenda item to facilitate discussions about this topic across the 

organic community in a public and open way. We are not currently seeking recommendations 

for Instructions, Guidance, or Rulemaking. Instead, we seek to create a forum for communitydriven or NOP-facilitated solutions that will address this shared challenge across multiple 

stakeholders. To that end, the attached document captures key topics to help start and shape this 

discussion, based on previous activities; informal communication with the Compliance, 

Accreditation, Certification Subcommittee (CACS); and communication with organic 

stakeholders.

We thank you in advance for your work, and we look forward to the discussion and your

recommendations.
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USDA Agricultural Marketing Service (AMS) | National Organic Program (NOP)

Human Capital Strategy for Inspectors and Reviewers

Human capital refers to the skills, knowledge, and experience held by an individual or 

population, and is generally considered one of the most important intangible assets that 

contributes value to an organization or community. As a public-private partnership, organic 

certification is a shared responsibility across the organic community, making the effective 

management of human capital an essential element of success in protecting the USDA organic 

seal.

Organic certifiers and businesses have raised the problem of a known shortage in well-qualified 

organic inspectors and reviewers. This is a critical problem, because these professionals often 

have the most direct connection with the operations and records of organic farms and businesses. 

This problem has been caused by several factors, including a rapidly expanding industry, the 

need for specialized skills, and competition for well-qualified individuals both inside the organic 

community and with other industries.

With the increasing size and complexity of organic supply chains, engaging in near-term and 

long-term efforts to develop, recruit, and retain a strong community of well-trained and wellqualified inspectors and reviewers is essential for organic integrity.

This paper discusses the different elements of human capital management, focusing specifically 

on organic inspectors and reviewers.

Background

The Organic Foods Production Act states that to be accredited as a certifying agent, the certifier 

must have sufficient expertise in organic farming and handling techniques as determined by the 

Secretary. The USDA organic regulations state that certifying agents and their inspection and 

certification personnel must have sufficient expertise in organic production and handling 

techniques to fully comply with and implement the USDA organic regulations (7 CFR 

205.501(a) General requirements for accreditation).

Certifiers meet these requirements by hiring, training, and retaining both staff and contracted 

inspectors and reviewers. The choice to use in-house or contract personnel is up to certifiers, 

however, personnel must collectively meet the requirements of the Act and USDA organic 

regulations. Certifiers do this by hiring or contracting with already qualified personnel and/or 

training new personnel on a regular basis.

The topic of inspector and reviewer qualifications and training has been of interest to the 

National Organic Program (NOP) and the organic community for several years. In February 

2018, the Accredited Certifiers Association (ACA) published a document Guidance on Organic 

Inspector Qualifications. In Spring 2018, the National Organic Standards Board (NOSB) 

completed a proposal (see file pages 9-50) and passed a recommendation related to Inspector 
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Qualifications Training. The NOSB’s proposal included work previously done by the 

International Organic Inspectors Association (IOIA) for the NOP in 2011.

In May 2019, the NOP launched the Organic Integrity Learning Center, which offers free online 

training in a formal Learning Management System. The Learning Center was designed to 

support the professional development and continuing education of all professionals working to 

protect organic integrity including certifiers, inspectors, reviewers and compliance specialists. 

As of July 2020, more than 2,000 people have Learning Center accounts.

In January 2020, the ACA, which has offered annual face-to-face training for certifier staff for 

several years, partnered with IOIA to broaden its training days to include inspectors. This 

expansion reflects the vital role that both staff and contract inspectors play in organic 

certification. The NOP also emphasized the broader importance of human capital in organic 

certification during its training days with ACA in both Texas in January 2020 and Nurnberg, 

Germany in February 2020.

Finally, the Strengthening Organic Enforcement proposed rule, posted in July 2020, includes 

proposals to establish specific qualification and training requirements for certifying agent 

personnel, including inspectors and certification reviewers. Requiring that personnel meet 

minimum education and experience qualifications and requiring continuing education will ensure 

quality and consistency of certification activities performed by certifying agents.

To date, much of the work on this topic has focused on the qualifications and training of organic 

inspectors and reviewers. This paper continues and expands that dialogue, by summarizing a 

broader set of human capital dimensions that are needed to develop, support, and retain a robust 

and well-supported pipeline of these professionals over time. The goal is to initiate a broader 

discussion on these topics across the organic community.

Human Capital Dimensions

There are several dimensions involved in human capital planning. These dimensions span many 

phases of a person’s possible interaction with a professional community, from the nurturing of 

potential future applicant pools through succession planning to prepare the next generation of 

professionals. The dimensions below are addressed in many human capital models, but 

particularly draw from the Office of Personnel Management’s Human Capital Framework. They 

include: 

• Strategic Workforce Planning 

• Talent Management: Pipeline Development 

• Talent Management: Recruitment and Matching

• Performance Management and Evaluation

• Professional Support and Educational Infrastructure
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For each dimension, this paper offers a brief description, and then poses questions to support 

discussion across the organic community.

Strategic Workforce Planning

Consistent with the public-private structure of organic certification, human capital management 

has traditionally been highly decentralized. Certifiers have generally determined their own 

approach to staffing and skills development, and have generally pursued recruiting, talent 

development, assignments, and retention independently.

Human capital, however, is emerging as a “precompetitive problem” in the organic industry, that 

is, a problem that occurs before product or service development, about which organizations may 

choose to collaborate rather than compete. This paper assumes that organic certification 

stakeholders would benefit from developing shared approaches for cultivating and supporting 

human capital, as an insufficient pool of organic professionals hurts organic integrity for all.

Questions for community consideration include:

• What is going well and reflects strengths with respect to human capital in the organic 

community? What weaknesses create risks for certifiers and the market? Where do 

opportunities lie? What are the threats if human capital is not strategically managed?

• What are the pre-competitive problems related to human capital that many or all certifiers 

face? For example, what challenges do many certifiers share in identifying, attracting, 

developing, and retaining talent? What are the largest gaps in the current talent pool? 

What are the future risks that could be planned for today?

• What forums exist or could be created to facilitate strategic workforce planning between 

and among certifiers, to better understand and plan for existing and future human capital 

demands?

• How could certifiers conduct a shared Needs Assessment based on industry trends and 

metrics, to determine the target talent pool and skills that need to be further cultivated in 

the future?

Talent Management: Pipeline Development

Talent Management begins with developing and cultivating pipelines of people who are prepared 

to enter critical roles in the organic certification community. Investing to build shared sources of 

talent provides candidates who are then ready to be recruited for specific work opportunities 

across the community.

Today, expertise is needed not only in organic agriculture, but also in quantitative methods (to 

conduct traceback and mass balance audits), supply chain dynamics, and forensic accounting and 

investigative skills. Legal skills are helpful in assessing whether a proposed adverse action will 

stand up in court, and interpersonal and communication skills are essential for success in organic 

certification.
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People with these talents may be found in specialized academic programs, such as sustainable/ 

organic agriculture, forensic sciences, food/materials science, legal studies, and business/ 

accounting studies. However, there may also be other sources of talent in different industries or 

sectors, such as other types of food regulatory or inspection programs, or other fields where 

people have gained experience in conducting investigations of wrongdoing.

Questions for community consideration include:

• What are possible goals and opportunities for building long-term relationships with 

academic programs, in either specialized approaches (supporting the development of an 

organic agriculture specialty track) or multi-disciplinary tracks (cross-Department 

training in agriculture, law/investigations, and business)? How could these conversations 

be initiated or expanded?

• What are possible options for developing Apprentice Programs for career changers who 

need specialized experience in organic before being ready for inspector or reviewer roles?

• What other sectors may include the types of professionals that might have backgrounds 

and qualifications that provide a strong foundation for a move to organic agriculture? 

How could the community identify and reach out to those possible communities in 

creative ways?

• How can these candidate pipelines be developed in a way that maximizes diversity and 

inclusion, so that those working in the organic community represent the diversity of the 

public we serve?

Talent Management: Recruitment and Matching

The decentralization of the organic certification public-private partnership creates a complex 

networked organic certification community, making it difficult to gain an overarching 

perspective on the placement of human capital and possible systemic gaps. How can the 

community best ensure that there is an adequate number of appropriately skilled inspectors and 

reviewers at the right times in the right places? This includes recruiting and developing

inspectors who understand local agricultural dynamics and patterns, as well as the local 

language.

In other cases, there may be well-qualified inspectors in an area, but no systematic ways to 

connect them with certifiers who need their services. These difficulties in connecting resources 

with needs can apply both for certifiers recruiting in-house talent and certifiers seeking contract 

staff.

Questions for community consideration include:

• What are possible needs and opportunities for a shared job board to advertise either 

employment or contract opportunities across the organic certification community?
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• A recent ACA and IOIA working group raised the possibility of developing an inspector 

registry, to better share the profiles of inspectors who wish to share their qualifications 

and availabilities. What would be the benefits and risks of such a system? How could 

such a system work, and how could it be implemented?

• What are some other approaches for connecting organic certification talent with existing 

needs?

• What steps could the organic community take to foster a diverse candidate pool that 

represents the public over time?

Performance Management and Evaluation

Once onboard, performance management becomes an important aspect of human capital 

management. Elements of this dimension include regular performance evaluations and feedback 

from both management and customers; performance-based compensation and rewards; and 

ongoing skills development. Evaluation also relates to the metrics and analytics that provide 

feedback to the community about its human capital investments.

Questions for community consideration include:

• What changes are needed to ensure that well-qualified and highly experienced inspectors 

and reviewers are appropriately rewarded for their professional qualifications and 

achievements? How should the organic industry best reflect the need and value-added of 

a robust and complete organic inspection process, with a highly qualified and wellcompensated inspector?

• Some inspectors have noted that recent high-profile enforcement actions have increased 

their concerns about the possible legal risks involved in conducting inspections and 

reporting on possibly fraudulent or noncompliant activities at high-risk operations. What 

are ways that the community can address this concern?

• Some certifiers have asked for a systematic mechanism to share information about both 

high-performing and poor-performing inspectors with the NOP and with other certifiers. 

What mechanisms might allow for this, while protecting privacy and due process?

• What avenues might be possible for elevating strong performers that are able to serve 

multiple certifiers (e.g., contract staff)? How can high performers be identified for 

advanced development opportunities to support both retention and succession planning?

• How do/will we know there are sufficient well-qualified inspectors and reviewers to 

serve the organic community as it evolves?

• What other system-level performance measures will tell us that our collective human 

capital strategies are working to protect organic integrity?

Professional Support and Educational Infrastructure

The ACA and IOIA are important organizations connecting certifiers and inspectors for specific 

purposes, such as knowledge sharing, training, and networking. However, there is no umbrella 

organization that supports group benefits for the sector, such as health insurance or liability 
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insurance. Part of a robust support infrastructure also includes diverse opportunities for

specialized and ongoing education, training, and development.

A robust and effective infrastructure supports community development, the ongoing 

professionalization of the field, and the retention of highly qualified individuals.

Questions for community consideration include:

• What services are most needed by independent inspectors or reviewers in the organic 

community that are not currently provided by an existing entity?

• What might some options for providing these services be? What type of organization(s) 

may be able to help?

• In addition to current resources, what other continuous learning and training and 

development opportunities are needed to support and retain well-qualified organic 

inspectors and reviewers?

• How could academic institutions, particularly those with specialized programs in organic 

and/or sustainable agriculture, be engaged in providing ongoing educational resources 

and/or community support for organic inspectors and reviewers?

• How could the community overall support the retention of well-qualified professionals in 

the organic community, even if they move between organizations?

Next Steps

The goal of this paper is to initiate a dialogue within the organic community about the broad set 

of human capital dimensions that may support the ongoing development of a robust and wellsupported pipeline of organic professionals over time. We welcome the ongoing discussion of 

these issues and related recommendations from the National Organic Standards Board and 

broader community.