Understanding inspection

#OSP review pre-inspection

At its core, the purpose of the organic inspection is to verify that your Organic System Plan (OSP) is accurate on paper and in person. An inspector will work to confirm that your operation, its owner, and the employees are working in line with the OSP and regulations. We strongly recommend setting aside time for an in-depth review of the operation’s OSP prior to your inspection.

When and how do I review my OSP?

Don’t wait until the last minute to review your OSP. All clients have access to their complete OSP using our online certification tool, MyOTCO. To access your OSP, log in to MyOTCO and use the “files” menu option.

What parts of my OSP should I review to prep for inspection?

First, we recommend checking that all information is accurate and up to date. Second, examine your listed materials for accuracy and possible de-listing if a material is no longer used. And lastly, review all communications from OTCO since the date of your previous inspection. This includes verifying and preparing documentation to demonstrate all reminders are being met and/or that any outstanding settlements or corrective actions are in process or completed.

What if I need to make changes to my OSP before the inspection?

If your review finds that changes are necessary to your OSP, make all updates prior to your inspection (if you have at least two weeks or more). If your inspection is set to occur in less than two weeks, contact your client service team to make the necessary changes.

#Inspection requirements and expectations

Good planning, clear organization, and complete documentation is required for an inspector to track your organic product throughout its lifespan.

How often do I need to be inspected?

All certified operations are subject to a mandatory annual inspection within the calendar year. Operations that make substantial production or operational changes during the course of a certification year may be required to undergo an additional inspection. All operations may be selected for an unannounced or sample inspection at any time.

What do first-time organic certification operations need to know about inspection requirements?

All new crop and livestock certified organic farms must be inspected prior to the harvest of their first organic crops or selling livestock derived products. All new certified organic processors must be inspected before any organic production can start. Please make sure to review the rest of this page prior to your first inspection, as it contains important information and FAQs for operations new to organic certification. You will also find the Pre-Inspection Checklist helpful in preparing for your first inspection. NOP requires that we conduct new applicant inspections within 6 months of being deemed ready to inspect.

What do I need to know about supporting inspectors?

Inspectors must be granted complete access to your operation, including non-certified production areas, structures, and all records (including financial) associated with organic and non-organic production.

An authorized and informed representative of the operation must be present during inspections, as well as any other relevant staff to answer questions and provide explanations.

Inspections will occur at a time when land, facilities, and activities that demonstrate compliance (i.e., during grazing season), or the ability to comply, can be observed.

How long will the inspection take?

The on-site inspection can take anywhere from hours to days depending on the size and complexity of your operation.

When can I expect to see the results of my inspection?

The inspection report is made available in your MyOTCO account within a few weeks of your inspection. Review of the report by certification officers and a certification decision takes approximately 30 days — and as many as 45 days during peak season — depending upon the issuance of any noncompliances or requests for additional documentation.

What should I expect during an inspection?

Preparation and organization are key. Throughout the year, check to make sure your internal controls and quality assurance measures are up-to-date and accurate. It’s best to review (and organize if needed) pre-inspection checklists and common records that will be inspected. In addition, conducting practice audit exercises can provide you with a better understanding of how to support the inspection process.

#Scheduling an inspection

To minimize inspection costs, we work with local and regional inspectors and bundle your inspection with nearby operations whenever possible.

How will an inspector be selected for my farm or food business?

Following an initial review of your OSP, we will select an inspector with the appropriate, availability, training and experience to inspect your operation’s activities.

As an applicant or renewing client, when will my inspection be scheduled?

You will receive a confirmation letter or email — typically within two to three weeks of completion of your initial review — with the contact information and a date range to schedule the inspection. The Inspections Team will contact you to schedule the inspection within 30 days of the confirmation notice. If you have not been contacted within this time, you can reach out to the Inspections Team at inspections@tilth.org.

What happens if I need to cancel my inspection?

We understand that things beyond our control happen. Whenever possible, contact us as soon as you know you won’t be able to do the inspection. For cancellations of one week or less prior to a scheduled date, we typically will charge for the inspector’s pre-inspection prep time, reimbursable expenses the inspector has incurred, as well as an administrative fee of $100 USD. If you experience an emergency or disaster, please contact our Inspections Team at inspections@tilth.org.

If I pay for expedited services, when will my inspection be scheduled?

We will work to secure an appropriate inspector for your operation upon receipt of payment of the certification and/or expedited fees for land or facility additions. We cannot begin the search for an inspector until both fees have been paid. If you are a current client and have already paid your yearly certification fee, you will only be required to submit payment of the expedited fee. For new applicants, an expedited request still requires completion of an initial review.

Is there a difference in inspection costs for expedited requests?

It’s likely that the cost of inspection for expedited requests will be higher than normal due to shortened timeframes to arrange inspector travel.

Who do I contact if I have issues contacting my inspector?

You may contact our Inspections Department at any time with questions at inspections@tilth.org or (541) 237-7108.

What options are available if I object to my assigned inspector?

We will request you submit your objection(s) in writing to inspections@tilth.org. Acceptable objections include but are not limited to: unprofessional encounters with the inspector, a previous relationship outside of a defined conflict of interest area (e.g. a former neighbor, etc.), or the inspector having commercial interests in your operation. The Inspections Department will review your objections and provide counsel regarding all of our available options, including potential reassignment of the inspection.

#Inspection audit trails

Developing good quality recordkeeping and documentation is important for traceability (commonly referred to as an “audit trail”).

What does an inspector look for when performing an audit trail?

The most important element of a good audit trail is seeing a common link between all of your production steps and all of your records. For instance, using lot code numbers easily allows an inspector or you to work through each phase of your operation — ordering, receiving, processing, and distribution to name a few — to make documentation trackable.

How do I prepare for an audit trail?

During the inspection, you should expect to walk your inspector through at least two audit trail exercises to determine the effectiveness and accuracy of your recordkeeping systems.

What types of exercises happen during an audit trail?

A sales audit verifies the relationship between sales of organic product(s) and the income from the sales over a specific period of time. It verifies the quantity of product sold in comparison with the quantity produced and income received.

A trace-back audit verifies that your records are sufficient to track organic products from the time of acquisition until departure from your operation, including all activities in between. It examines that your records about the production of a specific lot of a finished crop/product or invoice of a crop/product sold match.

A mass balance audit verifies that the organic ingredients/inputs purchased and used by the operation were sufficient in quantity to produce the organic crops/products that were sold.

What if I have organic and non-organic production?

If you have organic and non-organic production, you will need to make available documents related to production of both upon request.

What if no organic production will take place prior to inspection?

If your operation is organic-only, and no organic production will take place prior to the inspection, but you have a complete recordkeeping system in place that demonstrates auditability of the system (e.g., a set of production records from a test or validation batch), these records may be sufficient to verify this requirement.

What if I have no recordkeeping trail yet for an audit?

If there are no records available to audit at the time of inspection, or the inspector is not able to effectively audit your recordkeeping system for organic production, we will require an additional inspection.

#Pre-inspection checklists

Preparation and organization is key for maintaining your organic certification and having a successful inspection.

OTCO has developed pre-inspection checklists to help you organize paperwork in advance of inspection, and provide a useful overview of what to expect during an audit.

#Unannounced inspections

As an accredited, third-party certification agent of the USDA’s National Organic Program, we are required to uphold the integrity of all of our clients’ certified organic products and operations.

We have developed internal protocols and policies for the use of unannounced inspections as a compliance monitoring tool, and annually conduct unannounced inspections.

Unannounced inspections may be conducted onsite or fully remote depending on the nature of the unannounced inspection.

Who can be given an unannounced inspection?

All operations may be selected for an unannounced inspection at any time.

How is an unannounced inspection different from an annual inspection?

We conduct routine randomized unannounced inspections to verify that current conditions are similar to those reported during the most recent organic inspection. In addition, we perform risk-based unannounced inspections where the criteria includes, but is not limited to: response to a complaint, follow-up on a previous noncompliance(s), concerns around commingling and contamination, residue test results, crops known to concentrate pesticide residues, buffer area issues, and concerns raised during the certification process.

Am I able to change or refuse an unannounced inspection?

Refusal to undergo an unannounced inspection is grounds for suspension or loss of certification. Noncompliances identified during unannounced inspections will require appropriate corrective actions.

How much does an unannounced inspection cost?

OTCO covers the costs associated with conducting unannounced inspections except in extenuating circumstances such as requiring an unannounced inspection as part of a corrective action or settlement agreement.

Get Forms & Documents

Download the documents and forms you need.

Access Blank Forms

Still need help?

Our team is here to assist you.

Contact Support