Understanding inspection

#Requirements

A lot of planning, organizing and documentation is required for an inspector to track your organic product throughout its lifespan.

Alert

All certified operations must be inspected each year in order to maintain their certification.

What do new clients need to know about inspection requirements?

  • All new crop clients must be inspected prior to the harvest of their first organic crops
  • All new livestock clients must be inspected prior to selling any product obtained from organic livestock
  • All new processing/handling clients must be inspected before any organic production may begin

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

Regarding access, timing and staffing requirements for inspections
Inspectors must be granted complete access to the operation, including non-certified production areas, structures, all documentation (including financial), and records 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, or the ability to comply, can be observed.

#Scheduling

To minimize inspection costs, we work with regional inspectors and bundle your inspection with nearby operations to minimize travel and lodging costs.

New client inspection
Following an initial review of your OSP, OTCO will select an inspector with the appropriate training and experience to review your operation’s activities. You will receive a confirmation letter or email — typically within two to three weeks of completion of the initial review — with the inspector’s contact information and a date range for the inspection.

The inspector will contact you to schedule the inspection within 30 days of the confirmation notice. If your inspector has not contacted you within this time, contact our inspection team at <http://www.privatedaddy.com/?q=UExcXl9gW3lDDjNoZX1yBysyYWJqdFN4Qg-3D-3D_19>.

Renewing client inspection
After submission of your certification renewal, OTCO staff will schedule your inspection. For all questions, or to discuss inspector selection.

After confirmation of an appropriate inspector, you will receive a letter or email — typically within two to three weeks of completion of the initial review — with the inspector’s contact information and a date range for the inspection. The inspector will contact you to schedule the inspection within 30 days of the confirmation notice. If your inspector has not contacted you within this time, and efforts to coordinate directly with the inspector have gone unanswered, contact our Inspection Department.

Note

You may contact our Inspection Department at any time with questions at <http://www.privatedaddy.com/?q=UExcXl9gW3lDDjNoZX1yBysyYWJqdFN4Qg-3D-3D_19> or (503) 378-0690.

Expedited requests for all new clients and land/facility additions
OTCO will work to secure an appropriate inspector for your operation upon receipt of payment of the certification and expedited fees. 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.

Alert

An expedited request still requires completion of an initial review for new applicants, and review for land or facility addition requests. The inspection will not occur until an applicable review is completed.

Be aware that the cost of inspection for expedited requests will likely be higher than normal due to shortened timeframes to arrange inspector travel. For more information, see info about expedited certification services.

#Review your OSP

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 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.

What to review

  • Verify that all information is accurate and up to date
  • Examine your listed materials for accuracy and possible de-listing if no longer used
  • Review all communications from OTCO since the date of your previous inspection, as well as verify and prepare documentation to demonstrate all reminders are being met and/or that outstanding settlements or corrective actions are in process or completed

Post-review updates
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 our hotlines to make the necessary changes: Farmer Hotline at (503) 378-0690 ext. 102 or our Processor Hotline at (503) 378-0690 ext. 101.

Tip

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 “documents” menu option.

#Pre-inspection checklists

Preparation and organization is key for maintaining your organic certification. Throughout the year, check to make sure your internal controls and quality assurance measures are up-to-date and accurate.

OTCO has developed simple pre-inspection checklists of common documentation required for organic certification reviewed at the time of inspection. The checklists enable operations to organize paperwork in advance of inspection, and provide a useful overview of what to expect during an audit.

Resource

ATTRA’s Preparing for an Organic Inspection, a short guide for preparing and reviewing information for your mandatory annual inspection, is a helpful reminder of what to account for when regulating your operation’s compliance.

#Audit trail(s)

One of the core practices of your certified organic operation is developing good quality recordkeeping and documentation (commonly referred to as an “audit trail”). The most important element of a good audit trail is establishing a common link between all steps and all documents in your control system. For instance, using lot code numbers can easily allow an inspector or you to work through each phase of your operation — ordering, receiving, processing and distribution to name a few — to make documentation traceable, timely and transparent.

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.

There are three types of audit trail exercises:

Sales/financial audits

  • Verifies the relationship between sales of organic product(s) and the income from the sales over a specific period of time
  • Verifies the quantity of product sold in comparison with the quantity produced and income received

Backtrack or trace-back audits

  • Verifies that records are sufficient to track organic products from the time of possession until departure from your facility
  • Verifies documentation associated with the production of a specific lot of a finished product or invoice of a product sold

In/out balance or mass balance

  • Verifies that the organic ingredients/inputs purchased and used by the operation were sufficient in quantity to produce the organic products that were sold

Note

Review detailed examples of audits by scope: crop audits,
livestock audits and processing/handling audits.

#Crop records

The inspection of your operation’s recordkeeping system is a critical part of the annual on-site inspection. An inspector will require full access to well-organized and comprehensive documentation for all parts of your organic production to verify your certification.

Alert

Consult pages 54-55 of the USDA Organic Crop Producers Guide for a detailed list of all records that may be requested during an inspection.

For crop inspections, the following records are commonly reviewed:

  • Receipts for all purchased materials, including but not limited to: seeds, soil amendments, weed management inputs, and pest management inputs
  • Input application documentation by date, material, location, and rate of application
  • Harvest records by date, quantity, crop, and field/location
  • Sales invoices by quantity, date, crop, crop status (e.g., organic, transitional, conventional)
  • Label information for all purchased fertility and weed/pest management inputs
  • Transitional and/or buffer crop(s) harvest and sales documentation
  • Equipment clean-out log(s)
  • Seed labels or tags
  • Composting process records
  • Storage records

#Livestock records

The inspection of your operation’s recordkeeping system is a critical part of the annual on-site inspection. An inspector will require full access to well-organized and comprehensive documentation for all parts of your organic production to verify your certification.

Alert

Please consult pages 80-81 of the USDA Organic Livestock Producers Guide for a detailed list of all records that may be requested during an inspection.

For livestock inspections, the following records are commonly reviewed at inspection:

  • Receipts for all purchased materials, including but not limited to: seeds, soil amendments, weed management inputs, and pest management inputs
  • Input application documentation by date, material, location, and rate of application
  • Harvest records by date, quantity, crop, and field/location
  • Sales invoices by quantity, date, crop, and crop status (e.g., organic, transitional, conventional)
  • Label information for all purchased fertility and weed/pest management inputs
  • Transitional and/or buffer crop harvest and sales documentation
  • Equipment clean-out log(s)
  • Seed labels or tags
  • Composting process records
  • Documentation of purchased livestock (e.g., receipts, organic certificates, bills of lading)
  • Health input records by date, material used, animal/batch treated, age/stage, dosage, and reason
  • Purchased feed and/or feed supplement documentation (e.g., receipts, organic certificates, bills of lading)
  • Feed and/or medication labels
  • Feed storage records
  • Breeding and/or birthing records
  • Culling records
  • Slaughter and/or butcher records
  • Somatic cell and/or plate count documentation
  • Livestock production and sales documents
  • Shipping and/or transportation documents
  • Individual animal identification records
  • Veterinarian bills

#Handling records

The inspection of your operation’s recordkeeping system is a critical part of the annual on-site inspection. An inspector will require full access to well-organized and comprehensive documentation for all parts of your organic production to verify your certification.

Alert

Consult page 44 of the USDA Guide for Organic Processors for a detailed list of all records that may be requested during an inspection.

For processing and handling inspections, the following records are commonly reviewed:

  • Quality assurance plan (i.e. HACCP, GMP)
  • Audit trail flowchart demonstrating documentation used to track ingredients and finished products
  • Receiving and shipping documentation of all inputs and finished goods
  • Storage documentation (e.g., inventory, off-site warehouses, etc.)
  • Processing Documentation (e.g., batch sheets, recording charts, flowcharts, floor plan, etc.)
  • Listing of all co-packers and/or co-pack customers
  • Cleaning/sanitation procedures and documentation (e.g., SSOP’s, pre-op checklists)
  • Last available water analysis for water used in processing
  • Pest control reports
  • MSDS for all cleaning/sanitation and pest control products used
  • List of all boiler chemicals and documentation for each (if products contact steam or water)
  • Current product formulation sheets and master products list for all products
  • Labels currently in use, and all packaging information
  • Current master ingredient list, including all suppliers of organic/non-organic ingredients
  • Current, valid organic certificates for all organic inputs
  • Detailed ingredient information for all non-organic inputs and natural flavors, including written verification each (a) is not genetically engineered; (b) has not been irradiated; (c) is not produced using sewage sludge; and, (d) was produced in compliance with any relevant National List annotations

#Other inspection FAQs

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.

What to expect during an inspection?
Preparation and organization are key for maintenance of your organic certification. 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 for crop, livestock, and handling operations that will be inspected. In addition, conducting practice audit exercises can provide you with a better understanding of how to support the inspection process.

Tip

Review our pre-certification FAQs on inspection to get a sense of what to expect and how to be prepared for your inspection.

What options are available if I have objections to my assigned inspector?
If you object to the assignment of a specific inspector, we will request you submit the objection(s) in writing to the inspection manager. Acceptable objections may be based on any of the following reasons:

  • Past encounters with the inspector were not positive or were unprofessional
  • A previous relationship outside of a defined conflict of interest area (e.g. a former neighbor, etc.)
  • Operator is not confident in the inspector’s abilities for their particular operation

The Inspection Manager will review your objections and provide counsel regarding all of our available options, including potential reassignment of the inspection.

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 — possibly up to 45 days during peak season — depending upon the issuance of any non-compliances or requests for additional documentation.

#Unannounced inspections

OTCO is 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. Typically, unannounced inspections are either:

  • Routine randomized unannounced inspections
    Verify that current conditions are similar to those reported during the most recent organic inspection
  • Risk-based unannounced inspections
    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 staff/inspector recommendation (based on review concerns)

Alert

Refusal by an operator to undergo an unannounced inspection is grounds for suspension or revocation. Noncompliances identified during unannounced inspections will require appropriate corrective actions.

Our staff will evaluate, recommend, and conduct a pre-set percentage of planned, routine unannounced inspections — not including risk-based unannounced inspections — for each standard annually:

  • USDA National Organic Program: A minimum of 5 percent, up to 10 percent
  • Canadian Organic Regime (COR): 3 percent of client representation for crop and livestock operations and 5 percent for all other COR clients
  • Global Organic Textile Standard (GOTS): 5 percent of client representation
  • ACB EU Equivalence Standard: 10 percent of client representation

Note

You will not be charged a fee for an unannounced inspection.

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