What about organic inspections?

The purpose of organic inspections is to confirm that your operation meets the NOP standards and regulations both before it is certified and every year after as long as it remains certified. Inspectors do this by confirming that what you say in your application, called an Organic System Plan (OSP), is what you are doing in practice.

An excellent, low-cost resource titled Preparing for Organic Inspection, which includes checklists and other resources, is available from NCAT's Sustainable Agriculture Project.

Inspection Reports: The inspection report will follow the OSP line by line. A CCOF qualified inspector will conduct the inspection in an efficient manner.

You can reduce the cost of inspections in a variety of ways. For more information, please read Sean Feder's article below.

Inspections for New Applicants

In your Organic System Plan (application) you explain what your do, how you do it, and what you use to do it with. Once the CCOF home office receives and reviews your application, your inspection assignment will be forwarded to an appropriately experienced inspector in your area. That inspector will contact you to set up a mutually agreeable time for your inspection.

The inspector will verify that your practices are in compliance with the National Organic Program (NOP) and any international requirements you request. This is performed through verification that your organic system plan accurately depicts your practices and procedures.

Inspections for Existing Client

Currently certified operations will be assigned an inspection annually by your Regional Service Representative (RSR). If you are concerned about when your inspection will occur, or who the inspector is, contact your local RSR.

Controlling Your Inspection Costs

The onsite inspection is an integral part of organic certification. The inspector bills CCOF for the time and expenses of each inspection. CCOF in turn bills the inspected party. The costs of inspections vary widely. Usually the major cost factor is the scope and complexity of an operation. Other factors may include the producer's knowledge of applicable organic standards, previous conditions, noncompliances or potential noncompliances, inspector travel distance, inspector efficiency, quality and accuracy of the Organic System Plan, accessibility and clarity of records, uninterrupted focus during the inspection, and timely submission of additional information requested. As the inspected party, you have some control over many of these factors.

All operations have potential compliance issues. Understand the organic standards applicable to your operation, and identify your potential compliance issues. Be proactive about these "issues of concern" for your operation. The greater the potential for something to be out of compliance, the more information the inspector needs about that item. For example, mixed operations often have potential for commingling and contamination. Show the inspector that you understand these issues, and explain your clear and documented system for addressing them. If you are well organized and prepared to present these issues to the inspector, you will save the inspector from having to sort out the situation.

What happens at the inspection?

Before the Inspection:

• Organic System Plan (OSP). This is the central document of organic certification. The OSP must be completed before the inspection. The inspector will compare your OSP with their observations, interview, and audit of records. An excellent OSP includes all applicable sections, thoroughly answered questions, with all required attachments (e.g. labels, parcel maps, land history documentation, sanitizer MSDS sheets, lists of non-organic seeds and planting stock, etc.). Special attention should be given to compliance issues such as buffer crops, use of boiler chemicals, cleaning documentation for processing equipment, identity preservation, and audit trail for mixed operations. An accurate and thorough OSP will help guide the inspector through your operation, clearly delineating how your operation is in compliance with organic standards and what precautions are in place to prevent contamination and commingling.
• Inspection Scheduling. Members can help control inspection costs by being flexible and responsive in scheduling the inspection. This helps the inspector group inspections, thereby reducing their travel costs, which are passed on to members. Frequently the inspector tries to line up an entire day of inspections. Inspectors spend a surprising amount of time on this, as it can become complex. Few inspectors bill all the time they actually spend scheduling, but they are entitled to do so. Please return inspector calls promptly, and try to be flexible in scheduling.
• Preparation. Ask the inspector what they want to see, who they want to talk to, and what records and copies to have ready. Some inspectors send out pre-inspection letters listing these items. If you want it written out, request it.
• Records. The audit of records can be the longest part of the inspection. Operations with clear and complete records will have faster inspections. Some complex operations have records that are easier to review than some simple operations. Records relevant to organic certification generally fall into two categories: 1) audit trail and 2) organic integrity.

“Audit trail” includes all records of purchases, internal movement, and sales of inputs, ingredients, intermediates, and final products. Have these records organized and accessible. The inspector will probably focus on records from the past year, but NOP requires all records to be kept for 5 years, so these should be accessible as well. Prepare a copy of your Organic Farm Input Report (OFIR), to show all inputs going back to the last inspection. If there are many redundant input applications, you may prepare a summary OFIR that lists each material applied. Mixed operations (organic and non-organic) should separate organic records so they are more accessible and easy to understand. Processors and handlers must be prepared to track final products back through processing stages to starting ingredients. The inspector must understand the audit trail before s/he can test it. Frequently, inspectors have to dig and ask a lot of questions to understand an audit trail. Be prepared to explain how your audit trail works. Prepare a flow chart if your audit trail is complex. Teach the inspector how your records work; this will make their job easier and faster.

Organic integrity records are often required to document measures used to prevent potential noncompliances, such as commingling or prohibited materials contamination. Equipment that contacts non-organic product, or that is exposed to prohibited substances like pesticides or cleaning agents, requires a cleaning log for each organic use (e.g. harvest bins, transport trailers, packing lines, processing equipment, holding tanks, etc.). Buffer crops or purged product require disposal records. If you use non-organic seed, then keep a journal of your organic seed research. Log your calls to seed suppliers (date, supplier, result), and log your searches of seed catalogs or web sites. Spare the inspector having to prompt you, piece by piece, for all these things. If you anticipate these types of situations, have your management plan and appropriate log forms prepared in advance.

• Line up people and inspection sites. Determine which personnel the inspector wants to meet with, and make sure they are available. Arrange access to all materials storage areas, organic food handling rooms, farming parcels, and off-farm handling facilities certified under your operation.

During the Inspection:

• Focus on the inspection. Limit distractions such as phone calls or other interruptions.
• Stay on topic. The inspector has to collect and verify many kinds of specific information. They will go about this in a more or less organized sequence. Be aware of what topic the inspector is on and help them gather the relevant information.
• Explain how your operation is in compliance with organic standards, how potential noncompliances are prevented, how your audit trail works, etc. When it comes to potential noncompliances (e.g. buffers, shared equipment), the inspector needs the most and clearest information.

After the Inspection:

Promptly provide all additional information requested, such as additional OSP sections, land history documentation, or letters from neighbors regarding prohibited material usage. Generally if you provide these documents within 10 days, they can be sent directly to the inspector and will be included in the inspector's report. After 10 days, they should probably be sent to your Regional Service Representative. Contact your inspector and/or RSR to determine what's best.

By being knowledgeable and prepared, you can work smoothly and efficiently in partnership with the inspector. Help them understand each part of your operation. Supply them the information they need on each topic, and remember, it all hinges on a good Organic System Plan!