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Peer Review; ANSI Assesses NOP

A critical part of the National Organic Program’s (NOP) mission is to accredit and oversee the work of third party accredited certifying agents (certifiers). The USDA organic regulations and NOP’s quality system requires periodic peer reviews to assess NOP’s accreditation program and to see how well it aligns with the requirements of ISO/IEC 17011 (which describes standards for accreditation programs).

In 2014, the NOP contracted with the American National Standards Institute (ANSI) to conduct its peer review. ANSI reviewed all phases of NOP accreditation from initial application through final decision, NOP’s ongoing surveillance and renewal activities, and management system. ANSI’s onsite review included: reviewing public and internal documents, interviewing personnel, reviewing certifying agent and auditor records, and reviewing NOP’s management system.

Opportunities for Improvement

The 2014 ANSI peer review identified 14 opportunities for improvement, which included evidence that some NOP procedures need revisions or do not exist. As a result, the NOP will be taking the actions listed below.

• The NOP will ensure that the qualification for personnel performing internal audits includes knowledge in ISO/IEC 17011 and auditing skills per ISO 19011. In August 2014, several new and current staff members underwent a three-day training on the international standards governing the NOP’s accreditation process.

• The NOP is committed to maintaining impartiality by both staff members and certifiers, and will continue to address its importance in its policy documents.

• The NOP will schedule an internal audit pursuant to current NOP policies and procedures. • The NOP will continue to improve its quality management system by updating and revising its internal and external procedural documents to accurately reflect the NOP’s policies and procedures.

• The NOP’s internal procedures will specify a timeframe for updating all internal and external documents.

• The NOP is continually improving its quality management system, and will continue to review the system to remove outdated documents and determine when document revisions are necessary.

• The NOP has developed a procedure for record retention and file disposition, but has been seeking AMS approval for the last year. In the meantime, the NOP follows National Archives and Records Administration (NARA) record retention policies, but will continue to work on finalizing its own procedure.

• The NOP will revise its Terms of Accreditation to require certifiers to notify the NOP of any changes to scope or other activities that would affect their accreditation.

• The NOP will revise its procedures to identify which NOP personnel are responsible for reviewing applications for accreditation.

• The NOP is developing a procedure for extending its activities.

• The NOP will develop a procedure for addressing complaints related to the NOP’s operations and what actions are needed when the complaint requires the NOP to make changes.

• The NOP will revise its procedures to clarify the steps to be performed to extend a certifier’s scope of accreditation.

• The NOP will revise its procedures to clarify which NOP Division is responsible for actions related to suspension, withdrawal and reduction of accreditation when the decision is made by the Accreditation and International Activvities (AIA) Division.

• The NOP is revising its procedures to clarify renewal assessment processes. AIA staff will be trained on this procedure at a future AIA staff meeting.

Peer reviews evaluate NOP’s accreditation process and provide information for continual improvement to the NOP accreditation system. We look forward to reporting our progress on the activities above, and thank ANSI for its work on this peer review project.


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