Accredited Certifiers Association

PO Box 85 Mabel, MN 55954

(844) 783-7974
www.accreditedcertifiers.org

Guidance on Organic Inspector Qualifications

February, 2018

Summary and Background

With rapid growth in the organic industry, certifiers experience a pressing need to recruit, train, and
oversee new organic inspectors. Within the National Organic Program (NOP) regulations, section
205.501(a)(1) states that certifying agents and their staff must “have sufficient expertise in organic
production or handling techniques to fully comply with and implement the terms and conditions of the
organic certification program under the Act and the regulations…” On April 27, 2012, the Deputy
Administrator of the NOP issued a statement to accredited certifying agents stressing the importance
the role organic inspectors play and the importance of assessing candidates to ensure appropriate
expertise. At that time, the NOP planned to release draft guidance on specific qualifications. However,
this draft guidance has not yet been provided. In the meanwhile, certifiers have implemented varying
criteria for training and assessment of new inspectors. The ACA assembled a working group to develop
guidance for increasing consistency in terms of training, knowledge, and experience of inspectors across
certification agencies. With that goal in mind, the working group was also conscientious to avoid
outlining recommendations so rigid that they would disqualify good inspectors from alternative
backgrounds. As such, it is noted that the document may not be be inclusive of all useful skills and
knowledge and might not necessarily disqualify an inspector who possesses alternative attributes
deemed appropriate by certification agencies.

In this document, ACA inspector criteria are considered within the four scopes of the National Organic
Program (NOP) Regulations, i.e., crop production, wild crop harvesting, livestock production, and
handling. The document also provides suggestions for continuing education and evaluation of
experienced inspectors.

These recommendations are based on a draft document produced by the International Organic
Inspectors Association (IOIA) for the NOP, “Criteria for Inspectors and Reviewers working for NOP
Accredited Certifying Agencies,” which was used with the NOP’s permission.

Knowledge
There are six bodies of knowledge and facts required of organic inspectors.

a. Regardless of the type of inspection (crop, wild crop, livestock, handling), a good understanding
of inspection (auditing) techniques and protocols is required.

b. Inspectors must have a demonstrated understanding of organic certification and inspection

processes, knowing their role and limitations within them.
 ACA Guidance on Organic Inspector Qualifications
February, 2018
c. Specific to the inspection scope, a demonstrated understanding of the applicable organic
regulations (CFR Title 7 Part 205 NOP and OFPA) are required. This does not just mean knowing
what the regulations say and where to find it, but most importantly, how to apply the regulations
to practical situations. The inspector must be able to explain applicable standards and certification
procedures to the operator.

d. Sufficient understanding of production/handling processes and the capacity to evaluate process

flow is a critical requirement. Knowledge of current practices in an operations conventional
counterpart is a necessary tool for organic inspectors, enabling effective identification of risks to
organic integrity in the organic production/handling process.

e. Inspectors should be proficient – and current – in their understanding of the specific procedures,
documentary requirements and forms of each certifier for whom they work. Certifiers each have
their own versions of Organic System Plans and Inspection Report formats, as well as their own
methods of organizing the OSP information such as organic product recipes, input profiles, and
finished product labels.

f. Organic inspectors should be aware of other rules and regulations applicable to the inspection
scope, notable food safety requirements. Although such regulations are technically beyond the
scope of organic inspections, if the organic inspector observes obvious violations of them, they
are typically addressed in an addendum to the inspection report, for the certifier’s attention.

Skills/Areas of Expertise
Several skills (areas of expertise) are needed to conduct organic inspections and enable the organic
inspector to fulfill inspection assignments effectively and efficiently.

a. Observation skills: When conducting evidence-based inspections, a significant part of the on-site
time is spent in the field or on the production floor, understanding the ‘big picture’ of a production
system and observing the details which support (or contradict) the Organic System Plan.

b. Communication:

1. Interviewing is a technique inspectors use to gather information so appropriate

interviewing techniques are required. Some good interview techniques are 1 asking open
ended questions, asking the same question a different way and paraphrasing.
2. Documenting/writing 2: This includes correct grammar and spelling; accurate writing that
is clear, concise, and easily understood by the operator and reviewer; facts vs. opinion;
reference supporting documentation; citation of appropriate NOP regulations; and
explanation of issues of concern.
3. Active listening: Active listening is a structured way of listening and responding. The
elements of active listening are comprehending, retaining, and responding. The listener
asks questions and paraphrases back to the speaker to clarify understanding. Listening
carefully to operator responses reduces redundancy during the inspection, improves
accuracy, and shows respect.

1
IFOAM/IOIA Inspection Manual 2.3.5; ASQ Auditing handbook; ISO 19011 6.5.4
2
ISO 19011 6.6.1; ASQ Auditing Handbook p 141
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P.O. Box 85, Mabel, MN 55954
www.accreditedcertifiers.org (844) 783-7974
 ACA Guidance on Organic Inspector Qualifications
February, 2018

c. Intermediate Math skills: Inspectors need to be able to convert easily from one unit of measure
to another, calculate yields, calculate annual feed requirements in livestock operations, use
formulas to verify in/out balances, and use percentages to validate recipes and production reports
etc.

d. Organization and time management 3: managing preparation time, travel time, on-site time (e.g.,
multiple sites) and reporting time efficiently; respect certifier deadlines; use travel resources
efficiently. Inspectors need to plan well, be prepared 4, and be on-site at a time when organic
operations can be verified 5. The inspections must be conducted with the authorized operator
representative is present, moving smoothly from one area of operations to another.

e. Information management skills 6

are required, both in the office and on-site. Specific risks and
conditions to certification are flagged in the preparation before inspection; these areas must be
properly investigated, observations noted in an orderly way, and conclusions communicated to
the certifier. Evidence of potential non-compliances must be substantiated, documented, tracked
and accurately reported. Working documents need to be kept secure, archived and/or
destroyed7, as appropriate. Basic computer skills including demonstrated proficiency in word
processing, use of spreadsheets and database management may be required by individual
certifiers.

f. Investigative skills 8are required for all inspections, and especially those where the inspector finds
inconsistencies during the on-site inspection (i.e., if prohibited substance use is suspected), when
conducting complaint related inspections and in cases of suspected fraud.

g. Sampling procedures: Correct sampling methods, appropriate handling of samples (packing,

labeling, shipping) and proper chain of custody impact the validity of test results. These activities
must be done according to the certifier’s policies and contracted laboratory procedures.
Individual certifiers may not require all inspectors to be trained on sampling procedures. An
inspector must only take samples if they have been trained and are authorized by the certifier.

h. Skills specific to inspection scope: Additionally, numerous skills specific to the scope of the
inspection are required. The following table gives several examples for each scope but this list is
by no means exhaustive.

3
ISO 19011 7.3.1; ASQ Auditing Handbook
4
ISO 19011 6.4.1 and 6.4.3
5
NOP 205.403 (b)(2)
6
IOIA Training program guide; ACA inspector position descriptions
7
ARC job description, IOIA training manual
8
ISO 19011 7.3.1; ASQ Auditing Handbook p 141
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Accredited Certifiers Association
P.O. Box 85, Mabel, MN 55954
www.accreditedcertifiers.org (844) 783-7974
 ACA Guidance on Organic Inspector Qualifications
February, 2018

Inspection Examples of skills specific to inspection scope. Skills outlined in Wild Crop
scope and Livestock scopes are in addition to skills needed for Crop Scope.

Crop ● ability to recognize weeds and assess impact

● ability to assess production capacity
● ability to assess soil structure and fertility by consulting soil test results,
observing crop performance and observing signs of compaction, good tilth
etc.
● ability to assess possible sources of contamination and recognize signs of
pesticide injury to crops or other vegetation9
● ability to assess natural resource conservation and biodiversity
● ability to assess crop rotations and management of pasture as a crop
● ability to evaluate farm inputs
● ability to evaluate manure and compost management

Wild crop ● ability to assess sustainability of harvesting practices

● ability to read maps
● ability to recognize possible source of contamination and signs of damage
to wild crops or other vegetation
● ability to determine damage to harvested crop and dependent species
(plant and/or animal) by harvesting or over-harvesting 10
● ability to assess natural resource conservation and biodiversity

Livestock ● ability to calculate dry matter intake for ruminant animals

● ability to assess native and tame pasture production
● ability to assess overall condition of herd/flock (animal behavior, physical
appearance)
● ability to assess adequate nutrition and evidence of malnutrition or
parasites etc. 11
● ability to assess pasture quality and grazing practices for ruminant animals
● ability to assess the general animal husbandry practices used for species on
operation
● ability to assess inputs for farms with livestock
● ability to assess feed handling procedures to avoid contamination on split
operations

9
IFOAM/IOIA International Organic Inspection Manual 4.1.1
10
IFOAM/IOIA International Organic Inspection Manual 4.8
11
IFOAM/IOIA International Organic Inspection Manual 5.1.2
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Accredited Certifiers Association
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www.accreditedcertifiers.org (844) 783-7974
 ACA Guidance on Organic Inspector Qualifications
February, 2018

Inspection Examples of skills specific to inspection scope. Skills outlined in Wild

scope Crop and Livestock scopes are in addition to skills needed for Crop
Scope.

Handling ● ability to compare proposed recipes, actual production and finished

product labels
● ability to verify compliance of organic ingredients, non-organic ingredients,
food additives and processing aids
● ability to assess compliance of facility pest management protocols
● ability to assess equipment for commingling or contamination potential
● ability to assess label compliance
● ability to assess production capacity
● ability to identify and report major and obvious food safety concerns 12

Abilities (capacity, talents)

Beyond knowledge and specific skills, it is recommended that organic inspectors develop certain
abilities to facilitate their work:
a. Analytical
b. Accuracy
c. Consistency
d. Attention to detail without losing sight of the whole
e. Ability to differentiate between technical assistance, inspection and consulting 13
f. Discernment 14: ability to differentiate between evidence and opinions 15
g. Judgment: ability to interpret and adapt general guidelines to specific situations
h. Awareness of trends and developments in conventional and organic aspects of agriculture
or food science
i. Self-assessment: ability to recognize own opportunities for improvement, can accept
constructive criticism and ask for a second opinion when the situation exceeds their
knowledge capacity.

12
IFOAM/IOIA International Organic Inspection Manual 6.2 and 6.3

13
NOP 205.501(a)(11); IOIA curriculum; NOP 2614 Technical Assistance
14
ISO 19011 6.5.5; ASQ Auditing Handbook p 141; IOIA Training program guide
15
IOIA curriculum
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P.O. Box 85, Mabel, MN 55954
www.accreditedcertifiers.org (844) 783-7974
 ACA Guidance on Organic Inspector Qualifications
February, 2018
Personal Attributes
Inspectors should possess personal attributes16 to enable them to perform inspections in
accordance with principles of auditing. An inspector should be:

a. Honest and ethical. Integrity of the certification system rests on the integrity of its players,
including inspectors. and reviewers. In quality systems, inspectors must be free of
conflicts of interest with the operations for which they inspect. Conflicts of interest are
declared annually17 and inspectors should defer any inspection assigned to them by a
certifier with which they have a conflict of interest. Confidentiality18 is also important.
Information learned about operations must be kept confidential in order to gain trust of
operators and not be used by inspectors for personal gain. Inspectors also have a
responsibility to report suspected fraud.

b. Impartial and non-discriminatory. Inspectors should be fair and objective 19 during

inspections and when reporting their observations to certifiers. Inspectors should be
open-minded to the types of people and management strategies they encounter. They
need to treat all operators with respect and without bias. An inspector should also be
aware of the cultural environment in which he/she is working. 20

c. Professional in their conduct. Inspectors must be fit and in good mental health. As most
inspectors work alone, they need to be self-reliant and able to function autonomously
and decisively. During the inspection, the inspector represents a certifier and must follow
certifier policies and procedures. They must follow all governmental laws that apply to
their status, whether employees or contractors (ex. valid driver's license, reporting
income, etc.) They should be punctual for appointments as well as meeting certifier
deadlines. Inspectors should wear appropriate attire, pay attention to biosecurity
requirements, and have an awareness of personal safety. They should turn down work if
too busy or if a proposed assignment is beyond their realm of competence. Inspectors
must be willing to travel and should strive to efficiently group inspections in order to meet
the expense expectations of the certifier. Timely, thorough response to certifier inquiries,
and communication related to inspection status, scheduling, etc., is critical.

16
This is a compilation from a variety of sources: NOP Regulations; ISO 19011 6.6.2 and 7.2; ASQ Auditing
Handbook; Codex Alimentarius 6.6.a; ISO 65 4.2.f; IOIA Codes of Conduct and Ethics, IOIA training program
guide; IOIA crops and handling curriculum; IFOAM Accreditation Criteria 1.4.11; and ACA inspector position
descriptions.
17
NOP 205.504 (c)(2) requires that inspectors file an annual conflict of interest disclosure report form, identifying
any food or agriculture related business interests, including business interests of immediate family members that
cause a conflict of interest.
18
NOP 205.501 (a)(10) requires inspectors hold information confidentially.
19
The USDA prohibits discrimination in all its programs and activities on the basis of race, color, national origin,
gender or marital status (not all prohibited status apply to all programs),
20
IOIA promotes a 2 defect guideline when inspecting foreign operations (see IOIA Code of Conduct and Ethics,
which refers to knowledge of culture, language and crop.) Also addressed in ARC job description.
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 ACA Guidance on Organic Inspector Qualifications
February, 2018
d. Curious and tenacious. Asking open-ended questions is an important method used by
inspectors to gather information. They must be curious about the systems they are
observing in order to ask appropriate questions. They also must be systematic and
continue asking questions until they have a good understanding of whether an operation
is in compliance.

e. Perceptive and versatile. Inspectors must be perceptive to quickly grasp an understanding of the
variety of operations they encounter. They should have the flexibility to adjust to different
situations and people.

f. Diplomatic. Inspectors must strive to maintain a pleasant and non-confrontational atmosphere

throughout the inspection even while asking difficult questions and responding to conflict. The
inspection can be an exhausting process for the operator. It covers many areas of his/her
operation in a relatively short period of time and patience of the operator may wear thin.

g. Support goals of organic farming and handling. This last personal attribute is important as the
attitude of the inspector toward his/her work is evident to the operator during an inspection. A
lack of support can undermine the authority needed by an inspector.

Work Experience
Organic inspectors should have a minimum of one year work place experience in the scope 21 in which
they will be inspecting. Examples of possible workplace experience are given below:

Inspection scope Examples of workplace experience

Crop ● Growing up on a farm and actively participating in daily and seasonal tasks
● Operate own farming operation
● Employment on farming operation
● Farm manager
● Agricultural educator
● Other applicable industry experience
Wild crop In addition to experience as a crop inspector:
● Experience as harvester of wild crops
● Work in a field of natural resource management
● Other applicable industry experience
Livestock In addition to experience as a crop inspector:
● Growing up on a livestock farm and actively participating in daily and
seasonal tasks
● Operate own livestock farming operation
● Employment on livestock operation
● Livestock farm manager
● Herdsman
● Veterinarian or veterinary assistant
● Extensive 4-H or FFA experience
● Agricultural educator

21
IOIA training prerequisite
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P.O. Box 85, Mabel, MN 55954
www.accreditedcertifiers.org (844) 783-7974
 ACA Guidance on Organic Inspector Qualifications
February, 2018
● Other applicable industry experience
● Experience appropriate to scale and production system
Handling ● Production worker in food processing facility
● Management or shift foreman
● Employment in food retail and/or preparation
● Research and development in food processing
● Food science educator
● Other applicable industry experience
● Site appropriate experience in assessing compliance

Training
It is recommended that five kinds of training be required before beginning supervised
inspection work:
1. Education in the scope
2. General auditor training
3. Standards training
4. Specific organic inspection training
5. Training to certifier procedures and paperwork

Initially, this training will be intense and over an extended period of time. As inspection
experience is gained, training will take the form of refresher courses or specialty modules,
addressed below in the section called “Recommended Professional Development Activities.”
Initial inspector training requirements are summarized in the table below.

Training Topic Recommended Training

Sector education ● College degree in agriculture or food science or related field, or relevant
workplace experience
Auditor training ● ISO auditing overview or equivalent auditing protocol training (1-2
hours)
Standards training ● Basic standards training
○ Crop (6 hours)
○ Wild Crops (Crop Training +1 hour focused wild crop training)
○ Livestock (6 hours)
○ Handling (6-8 hours)
Organic inspection ● Basic organic inspection training in appropriate scope (IOIA level 100 or
training equivalent.) 4.5 days/scope 22
● Recommended: 2-3 mentored inspections or IOIA Field Training, and 7
monitored reports. 23 The inspection performed at the IOIA Basic

22
IOIA basic trainings have traditionally been 4.5 days per scope, on site (not web-based), with 4 days of instruction
and 0.5 day of testing
23
Note: It is not feasible to apply all requirements, especially field training, to the wild crop scope separately from
crop. It is recommended that any inspector qualified to inspect crops could also inspect wild crops, provided they
received training specific to wild crop standards and inspection. At this time, wild crop inspection has been included
in 100 level training content. Specific 200 level wild crop training could be required for wild crop inspection.
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 ACA Guidance on Organic Inspector Qualifications
February, 2018
Training could count toward number of monitored inspection reports,
but not the number of mentored inspections.
● Certifiers might utilize different processes for determining what
mentoring and monitoring looks like at their organization.
● A field evaluation as a “capstone” to the mentoring process can provide
clarity about inspector readiness to inspect independently.
● Qualifications for mentoring inspectors will be determined by the
certifier. Mentors should be highly experienced in the specific scope.
Certifier procedures Training to certifier procedures and paperwork

It should be noted that the above training recommendations apply to brand new inspectors, or
inspectors who are brand new to a scope. Inspectors who are simply new to a specific
certification agency will require training on the new certifier’s paperwork and procedures,
along with routine quality monitoring.

Specialized training is required for inspectors dealing with:

• Operations that handle imports and/or exports.
• Operations with complex recipes and correspondingly complex in-out balances.
• Long or complex supply chains, especially when certified organic ingredients/product
are sourced through uncertified handlers.
• Operations in which fraud is suspected, especially to ensure the Inspection Report will
withstand legal scrutiny.

Certification agencies need to be sure their Organic System Plans clearly capture the necessary
details prior to inspection assignment.

Inspection Experience
Only in exceptional circumstances can a perfect combination of knowledge, skills, abilities,
personal attributes, prior work experience and training be sufficient to autonomously conduct
organic inspections. Some certifiers ensure that new inspectors are mentored by experienced
inspectors. Inspections are conducted by the apprentice under supervision of the mentor; exit
interview documents and reports are written by the apprentice but approved and co-signed by
mentor.

Furthermore, it is recommended that beginning inspectors should only be assigned simple

inspections. Certifiers should have a systematic way to document the level of inspector and the
corresponding level of complexity of the operations they have been assigned. In this way,
operators will work with inspectors sufficiently trained for their type of operation, inspections
will be efficient, and organic compliance issues will be systematically addressed.

Performance Evaluation Standards

Annual performance evaluations contribute to the continuous improvement of inspectors as well
as being a requirement pursuant to the NOP Final Rule, 205.501(a)(6) and 205.510(a)(4).
Observation during inspection by a representative from the certifier would be periodic but not
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 ACA Guidance on Organic Inspector Qualifications
February, 2018
necessarily annual. Observation during inspection may also include an inspection witnessed by a
peer (another inspector). An evaluation checklist (attached) has been developed by IOIA with
feedback from a number of certification agencies, and may be used for evaluation with
permission from IOIA. Alternatively, evaluation forms may be developed by individual
certification agencies. The below tables provide competencies to be evaluated in three categories
along with evaluation criteria and method of evaluation.

Area of Competence to be Evaluation Criteria Evaluation

Evaluated Method
Responsibilities Review file and assignment from Inspection well-prepared Feedback from
certifier; prepare an inspection (audit plan, checklist for use operators;
plan and make arrangements during inspection); Observation during
with operator, taking care to Inspection appropriately inspection;
schedule the inspection at a time scheduled. Interview inspector.
in the production cycle when
organic operations can be
observed
Conduct an opening interview Opening interview covers Observation during
with the operator and relevant essential elements (scope, inspection.
personnel audit plan, safety/bio-
security, confidentiality,
verifying accuracy of
information provided, etc.
Verify accuracy of OSP and all Organic Control Points Observation during
other information, with systematically verified. inspection.
particular attention to areas Materials appropriately Review of inspection
where organic integrity is at risk reviewed. report.
(buffers, inputs, split operations)
Verify production/handling Record keeping system Review of inspection
capacity (yield estimates); assessed. reports.
conduct on-site inspection of Random trace back Observation during
in/out balance and traceability conducted. inspection.
In/out balance completed.
Verifying label and packaging Labels and packaging Review of inspection
verified. reports.
Observation during
inspection.
Clarify issues of concern which Issues of concern which Review of
were identified in the pre- were identified in the pre- inspection reports.
inspection review. inspection review are Observation during
clarified. inspection.
Assess corrective actions taken Previous conditions Review of inspection
to address minor non- reviewed and verified. reports.
compliances for certified Observation during
operators. inspection.
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 ACA Guidance on Organic Inspector Qualifications
February, 2018
Area of Competence to be Evaluation Criteria Evaluation
Evaluated Method
Identify and summarize areas Potential areas of non- Review of
of potential non-compliance compliance identified and inspection reports.
summarized. Observation during
inspection.

Identify and communicate Missing information Review of

additional information to be identified and inspection reports.
submitted by operator. communicated. Observation during
inspection.
Gather samples, provide receipt, Samples gathered as per Review of inspection
maintain chain of custody, and certifier and contracted reports.
according to certifier procedures laboratory procedures. Observation during
inspection.
Conduct and document an exit Exit interview conducted, Review of inspection
interview with the operator covering all essential reports.
according to certifier procedures elements. Observation during
inspection.
Communicate the findings to the Report filed punctually. Review of inspection
certifier according to certifier Report well-written, clear, reports.
procedures. concise and needing no
further information from
inspector.
Knowledge Auditing techniques protocols Auditing protocols Review of training
followed. record, course
content and result.
Observation during
inspection.
Organic certification and Certification and Observation during
inspection processes inspection procedures inspection.
understood and followed.
NOP regulations Organic requirements Review of training
understood; could clearlyrecord, course
explain to operator. content, and result.
Review of inspection
reports
Observed inspection.
Organic (and conventional) Understands system being Review of training
production and handling inspected; using record, course
processes terminology specific to content and result
system being inspected; Observation during
thorough assessment of inspection
Organic Control Points.

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 ACA Guidance on Organic Inspector Qualifications
February, 2018
Area of Competence to be Evaluation Criteria Evaluation Method
Evaluated
Certifier procedures Uses certifier forms Review of training
correctly. record, course
Follows certifier content and result
procedures. Review of inspection
reports
Feedback from
reviewers

Optional: Related laws and Asks questions and makes Review of training
regulations. observations during record, course
inspection pertaining to content and result
related laws and Observation during
regulations. inspection
Accurately reports findings. Review of inspection
report
Skills Observation Attention to detail Observation during
Relevance of questions inspection
Communication: Interviewing, Use of open-ended Observation during
Documenting/writing, Listening questions, paraphrasing inspection
Correct grammar, spelling Review of
Accurate, clear, concise inspection reports
Active listening

Evaluation Analyzes data, draws Observation during

conclusions based on inspection
evidence, identifies and Review of
assesses OCPs inspection reports
Math Verification of rations, DMI, Review of training
recipes etc. record, course
Verification of in/out content and result
balances Review of inspection
Logical analysis of results reports

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 ACA Guidance on Organic Inspector Qualifications
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Area of Competence to be Evaluation Criteria Evaluation Method
Evaluated
Organizational skills and Plans well. Observation during
time management Punctual. inspection
In control of agenda. Review of time
Efficient. began and time
ended inspection
Submission of
inspection report
Information management Well organized; prepares Observation during
and uses checklists; inspection
Demonstrates appropriate Review of inspection
computer skills. report
Investigative skills Asks good questions; Observation during
Is inquisitive; inspection
Documents findings; Review of inspection
Evidence based approach. report
Sampling procedures Samples gathered as per Review of training
certifier and contracted record, course
laboratory procedures. content and result
Maintains sample integrity
and chain of custody.
Skills specific to inspection Demonstrates Observation during
scope (see examples in table competence specific to inspection
2.2.2.i) inspection scope. Review of reports
Feedback from
operators
Abilities Attention to detail Satisfactory performance: Observation during
Inspectors demonstrate inspection
attention to detail during Review of reports
the inspection. Reviewers Feedback from
do not need to get further reviewers
information from the
inspector, inspection
paperwork is clear and
complete as submitted.

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 ACA Guidance on Organic Inspector Qualifications
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Area of Competence to be Evaluation Criteria Evaluation
Evaluated Method

Able to differentiate between Does not provide advice Observation during

inspection and advice to the operation; does not inspection.
assist operators to
overcome barriers to
certification.
Discernment Demonstrates good sense Observation during
of judgment; shows ability inspection.
to interpret and adapt Review of reports.
general guidelines to
specific situations.

Analytical Demonstrates logical Observations during

approach. inspection
(specifically
traceability tests).
Accuracy Absence of error. Review of reports.
Feedback from
operators.
Consistency Methodical approach. Review of reports.
Feedback from
reviewers.
Awareness of trends and Appears to be up to date Review of training
developments in conventional and knowledgeable. records.
and organic – aspects of
agriculture or food science
Capacity for self-assessment Open to constructive Annual performance
criticism. review; Field
Proactive in seeking evaluation.
additional training Response to
opportunities. Feedback

Integrity, confidentiality, Satisfactory performance Feedback from

Personal freedom from conflict of declarations kept current operators.
attributes interest, ethical behavior, open- (confidentiality, C of I). Observation during
mindedness, diplomacy, inspection.
perceptiveness, versatility, Review of
tenacity, decisiveness, self- complaints filed
reliance, punctuality; does not naming the
provide advice for inspected inspector.
operations; professional in their Review of annual
conduct at all times; documentation.
be fit and in good mental health;
economical in their use of travel
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 ACA Guidance on Organic Inspector Qualifications
February, 2018
allowances; cultural sensitivity,
willingness to travel

Professional Development Activities

A wide range of professional development activities are available for ongoing inspector training.
Trainings should be documented and included in the inspector’s résumé, supported by course
certificates and content lists whenever possible. This is a partial list of possible professional
development activities and topics:

● Residue testing
● Fraud detection and investigation
● Conferences
● Workshops
● Community college and university courses
● eOrganic webinars
● ATTRA
● On-farm demonstrations
● Subscriptions to trade magazines
● Independent study/reading
● Networking24 (professional associations, list-serves, etc.)
● Peer Field Evaluation
● Performance review from certifiers: Per NOP regulation and accreditation
requirements, certifiers must conduct an annual performance review of their
inspection staff/contractors. At a minimum, reports, training records, feedback from
operators, and complaints naming the inspector must be reviewed. Additionally, it is
recommended that periodically (not every year) a qualified certifier representative
accompany the inspector on an inspection and assess their performance, then meets
with the inspector to give verbal and written feedback and discuss opportunities for
improvement.
● Private coaching
● IOIA 200 level courses and 300 level courses (IOIA Training Institute intermediate,
advanced and specialty modules)
● IOIA training modules with tests25
● NOP Trainings (including The Path interactive video), webinars, Program Handbook
● Non-organic training
● Food safety (GAP, HACCP, FSMA)
● Participation in committees and working groups
● Local chapter meetings
● Preparation of training modules

24
Documentation can be through verification of membership, list-serve email, etc.
25
Testing and exams rated fairly highly in the 2010 IOIA certifier survey
Page 16 of 17
Accredited Certifiers Association
P.O. Box 85, Mabel, MN 55954
www.accreditedcertifiers.org (844) 783-7974
 ACA Guidance on Organic Inspector Qualifications
February, 2018
● Updates from the certifier on paperwork, procedures, etc.
● Training in related disciplines
● Relevant training from private training providers
● Annual update to standards and national list
● Scope-specific training on changes to standards, processes, procedures

Page 17 of 17
Accredited Certifiers Association
P.O. Box 85, Mabel, MN 55954
www.accreditedcertifiers.org (844) 783-7974
 Cover Page Inspector Evaluation Checklist

Inspector:

Evaluator:

Date of Field Evaluation:

Organic Scope(s):

Certifier of Operation:

Brief Description of Operation Inspected:

Final Score (Finding from the Rating Summary Page):

Final Score:

Scoring is as follows:
5: Exceptional: Performance outstanding. Practices are demonstrated at the highest level.
4: Exceeds Expectations: Performance is high. Practices demonstrate a high level.
3: Competent: Performance is effective. Practices are demonstrated at an acceptable level.
2: Acceptable with Conditions: Performance requires improvement.
1: Unsatisfactory: Performance is ineffective and requires extensive improvement.
N/O: Not Observed.
N/A: Not Applicable.

I attest that the information provided above and on the attached pages is complete and
accurate to the best of my knowledge.

Evaluator:
[Signatures are not required; however, space is provided if you would like to enter your electronic signature].

Date of
Report:

IOIA Evaluation Checklist Version 11.2 May be used with IOIA permission Cover Page / Page 1 © IOIA 2016
Organization
Skills and
Direct Observations Score 5-1 Comments
Time
Management

Materials

Has certifier instructions and recent

correspondence, if applicable. Has
organic system plan (OSP), all
1
appropriate international
plans/applications, and a list of current
certified products.
Has current standards [i.e. National
Organic Program (NOP) Standards],
2 applicable standards and/or
equivalency agreements (hard or
electronic copy).
Has inspection document (template or
3
form in printout or electronic version).

Has all tools necessary to complete

4 the inspection (for example: camera,
scanner, calculator, etc.)?

Inspection Preparation &

Scheduling

Is attired according to GMPs or GAPs.

5 Employs appropriate biosecurity
precautions.

Reviewed file and was prepared for

6
inspection.

Arrives on time or if unable to do so,

7 notifies client appropriately with
reasonable advance notice.

Total (7) 0

IOIA Evaluation Checklist Version 11.2 May be used with IOIA permission Organization / Page 2 © IOIA 2016
 On-Site
Direct Observations Score 5-1 Comments
Tasks

Inspection Flow

8 Is in control of the inspection agenda.

Conducts opening meeting (1) Introduces himself/herself
and other authorized participants; (2) Clearly
communicates the purpose of the inspection; (3)
9 Explains/Discusses the inspection flow process; (4)
Asks the operation's representative if they have any
questions. (See IOIA Opening Meeting Procedure for
reference.)
Conducts an exit interview with client according to
10 applicable regulations and certifier procedures. (See
IOIA Exit Interview Procedure for reference.)
Summarizes next steps in certification process during the
11
exit interview.
Action Items Addressed
Addresses and follows up on any non-resolved
12 compliance issues identified during the pre-inspection
document review.
Assesses corrective actions taken to address non-
13
compliance.
Verifies that the application, OSP and supporting
14
documentation are complete and accurate.
Asks for additional information and minor OSP updates,
15
per certifier policy.

Document Items
Verifies that the products grown, handled or
16 manufactured are consistent with those listed or
requested for certification.
Verifies cleaners, sanitizers, and crop materials were
used or to be used are consistent with those listed in the
17
OSP, that they are compliant, and all annotations have
been followed.
Verifies pest control materials and practices are
compliant and consistent with OSP, including required
18
preventative practices, and if applicable, pest hierarchy
and all annotations.
Reviews all appropriate records:
Processing: Product formulations vs batch records,
ingredients (organic and non-agricultural), receipts,
production, compliance documents and manufacturing
activities, sanitation practices, labels;
19
Crop/Livestock: Input records/receipts, seeds/receipts,
parcel history (for new parcels), equipment cleaning logs,
buffer harvest, feed, maps, raw manure app. time,
fertility, rotation, cover cropping practices, pest control
hierarchy, health inputs.
20 Conducts an appropriate audit traceback.
Conducts an appropriate verification audit (in/out
21
balance, ingredients and/or harvest/yield).
Verifies that current labels and labeling are consistent
22
with OSP and with applicable standards.

Addresses potential natural resource or biodiversity

23
issues on the operation.

Facility/Operation Premises
Inspects all areas of premises as appropriate to the
operation:
Processing: receiving, ingredient, product, packaging
24 and sanitizer storage, materials, all processes, pest
control; Crop/Livestock: parcels, material and seed
storage, buffers, boundaries, animals, housing, feed
storage.
Confirmed points of potential contamination, including
25 identifying risks to organic integrity (organic control
points).

Total (18) 0

IOIA Evaluation Checklist Version 11.2 May be used with IOIA permission On-Site Tasks / Page 3 © IOIA 2016
Knowledge,
Skills and Direct Observations Score 5-1 Comments
Abilities

Organic Regulations

Refers to the organic regulations during

26
inspection, when needed.

Understands organic regulations, and can

27
clearly explain to client when needed.

Organic and Conventional Production and

Processes

Understands both the organic and conventional

28
counterpart to the operation, as applicable.

Certifier Procedures

Demonstrates an understanding of certifier

29
procedures, and forms.

Professionalism

Displays a positive and professional behavior

30 with client and represents the certifier in a
positive and professional manner.

Demonstrates the ability to differentiate between

31
inspection and consulting.

Responds accurately and helpfully to questions

32 from client regarding applicable regulations and
ACA certification procedures and requirements.

Communication

33 Active listening skills.

Open ended questions (inspector does not

34 answer questions for producer); pertinent
questions asked.

Sampling

35 Is prepared to take a sample.

Gathers samples per procedure, provides

36 inspected party with a receipt and maintains
chain of custody.

Total (11) 0

IOIA Evaluation Checklist Version 11.2 May be used with IOIA permission
Knowledge, Skills, Abilities / Page 4 © IOIA 2016
 Reporting Direct Observations Score 5-1 Comments

Reporting

Thoroughly completes inspection document

37
according to established procedures.

Clearly communicates all issues of concern

38
and applicable regulations.

Clearly communicates requests for

additional information and/or documents
39
sufficient for certifier to make a certification
decision.

Applies and communicates applicable

40
regulations accurately.

41 Report is complete, clear and concise.

Report accurately reflects all issues noted

42 during the inspection and listed on the Exit
Interview.

Report is submitted to Evaluator within

43
certifier due date.

Total (7) 0

IOIA Evaluation Checklist Version 11.2 May be used with IOIA permission Reporting / Page 5 © IOIA 2016
 Rating
Grading Score Summary Score Comments
Summary

Total Organization

Total On-Site Tasks

Total Knowledge, Skills, Abilities

Total Reporting

Total 0

Divided by Total Questions (43); Deduct N/A Answers.

Average Rating

Scoring is as follows:
5: Exceptional: Performance outstanding. Practices are demonstrated at the highest level.
4: Exceeds Expectations: Performance is high. Practices demonstrate a high level.
3: Competent: Performance is effective. Practices are demonstrated at an acceptable level.
2: Acceptable with Conditions: Performance requires improvement.
1: Unsatisfactory: Performance is ineffective and requires extensive improvement.
N/O: Not Observed.
N/A: Not Applicable.

IOIA Evaluation Checklist Version 11.2 Rating Summary / Page 6 © IOIA 2016 (May be used with IOIA permission)