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 and thoroughly answered questions, with all required attachments (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: You 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 you. 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 these items written out, please request it.
- 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.
- 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: audit trail and 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 the NOP requires all records to be kept for five years, so these should be accessible as well. Prepare a copy of your Organic Farm Input Report (OFIR) (see sample), 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 (harvest bins, transport trailers, packing lines, processing equipment, holding tanks, etc.). Buffer crops or purged products require disposal records. If you use non-organic seed, keep a journal of your organic seed research. Log your calls to seed suppliers (date, supplier, result) and 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, please have your management plan and appropriate log forms prepared in advance.
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. Your inspector 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 complies with organic standards, how you prevent potential noncompliances, and how your audit trail works. When it comes to potential noncompliances (e.g. buffers, shared equipment), the inspector needs detailed and clear 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 be sent to your Certification Service Specialist. Contact your inspector and/or Certification Service Specialist to determine what's best.
By being knowledgeable and prepared, you can work smoothly and efficiently in partnership with the inspector. Help the inspector understand each part of your operation. Supply the inspector the information she or he needs on each topic, and remember: it all hinges on a good Organic System Plan!
For additional information check out “Why do I need an organic inspection?” and “How can I control the cost of my organic inspection?”.