#Understanding a noncompliance notice
OTCO issues noncompliances to currently certified operations — or operations in the certification application process — when an inspection, review, or investigation reveals operations are not compliant with the requested standards (e.g., USDA National Organic Program, Bee Better Certified™, etc.).
Noncompliances are most often issued when OTCO has reason to believe that the items are correctable and submission of a written, documented corrective action from the operation can bring the issue to a resolution.
Each noncompliance notice provides:
- Description(s) of the noncompliance(s)
- Clear reference and connection to the applicable regulation and/or standard
- Basis for noncompliance notice (e.g., observations, evidence, etc.)
- Due date for submission of a written response (e.g., corrective action or rebuttal)
When an operation adequately demonstrates that each noncompliance was appropriately addressed — a combination of the written response, corrective actions, and any needed follow-up — OTCO will send the operation a written notification of resolution or need for further action. If we receive a partial or incomplete response, OTCO will immediately send correspondence with notification of outstanding items that require response and actions, as well as due dates. Only after each noncompliance has been sufficiently addressed can we proceed with the next steps of your certification.
#Steps for resolution
In the event that you receive a noncompliance, a timely and thorough response is critical for bringing your situation to a resolution. Be sure to read and understand the noncompliance issue, and what is being requested of you to address it. We will provide supporting documents, as appropriate, to show additional context for the cited issue. For example, we will include specific references to sections of your inspection report if the noncompliance is based on findings at the time of your inspection.
Considerations for resolution of a noncompliance:
- Compile the requested information (e.g., records, pictures, letters, etc.)
- Outline your response to each item, describing all the actions you’ve taken to ensure future compliance. OTCO will look specifically at how the issue was corrected and how it will be prevented in the future.
- If you plan to take future actions, be sure to detail in your response the actions, implementation dates, and dates of completion.
OTCO reviews the response once it is submitted and may request additional information from you or supporting documents or evidence. If you have questions at any point in the process, contact the staff person in your official notice to discuss and walk through the noncompliance together.
Learn more about taking the necessary steps on handling a noncompliance as well as measures to prevent issues in the future with our Big Q&A: Noncompliances summary.