Federal officials are considering how to implement unannounced inspections of certified organic operations and beef up qualification criteria for inspectors, at the recommendation of the National Organic Standards Board.
In a March 21 memo to the NOSB, the deputy administrator of the National Organic Program, Miles McEvoy, responded to those and other recommendations the standards board made at its 2011 fourth-quarter meeting.
Recommendations for inspector qualifications are:
•A baseline pre-requisite expertise for initial organic inspectors;
•Continuing education requirements for inspectors; and
•Accreditation criteria for certifying agents to ensure adequate oversight.
McEvoy said in the memo that the NOP will use the recommendation to develop baseline criteria. He also said NOP has commissioned “additional work in this area” with the International Organic Inspectors Association.
In response to the NOSB recommendation for unannounced inspections, McEvoy said the NOP will “explore ways to implement inspection requirements to enhance organic integrity.”
The standards board had three specific recommendations regarding unannounced inspections, which the board members contend would help “uphold organic integrity” for the U.S. Department of Agriculture’s organic certification seal.
The standards board wants mandatory unannounced inspections for at least 5% of certified operations each year. The board recommended the inspections could be random, risk-based or the result of a complaint or investigation.
The scope of unannounced inspections, as recommended by the NOSB, could be limited, with the collection of samples depending on individual situations. The NOSB recommended that an unannounced “full inspection” could serve as the annual on-site inspection for a certified operation.
The NOSB also recommended that the NOP regulate material review organizations. Currently NOP has accreditation processes for third-party organic certifiers for crops, livestock, handling and wild harvest, but not for the review of materials used in organic operations.
Members of the standards board recommend that accreditation of material review organizations include:
•A requirement that they use the NOP material classification guidance — which is still in development — to determine whether a material is synthetic or non-synthetic;
•Implementation of a quality management system with detailed review protocols and policies as required by ISO Guide 65 accreditation standards;
•Mandatory use of the NOP’s guidance for permitted generic substances, which is under development;
•A requirement that part of their financing come from manufacturers of products seeking review; and
•Adoption of the appeals process used by certifying agents.
The standards board also recommended that material review organizations be subject to compliance and enforcement actions of the NOP.
McEvoy’s memo did not indicate whether the NOP would develop an accreditation process for material review organizations. He merely said the NOP would report back to the NOSB “on how we plan to proceed with these recommendations.”