Group Certification and Internal Control Systems (ICS)
This policy establishes the guidelines for smallholder group certification by ADITI.
The cost of certification is a serious obstacle for many growers, especially smallholders, making access to organic markets for them difficult. Since nearly 20 years ago, group certification with internal control systems have been developed as an alternative. These systems have now obtained a certain level of official acknowledgement.
Normative framework :
5.1 SCOPE :
This system shall be based on the internal quality system.
- It shall apply to producer groups, farmer‘s cooperatives, contract production and small scale processing units.
Basic Requirements of the group :
- The producers in the group must apply similar production systems and the farms should be in geographical proximity.
- Farms with land holding of 4 ha and above can also belong to a group but will have to be inspected annually by the external Inspection and Certification Agency.
- The total area of such farms shall be less than 50% of the total area of the group.
- Processors and exporters can be a part of the same group but will have to be inspected annually by the external Inspection and Certification Agency.
- The group will have a legal status, organization structure with clear responsibilities to carry out the internal control.
II SYSTEMS :
5.3 & 5.4 Internal Quality System (IQS) and its development :
IQS is based on the concept of an Internal Quality System comprising of the following :
- Implementation of the internal control system
- Internal standards
- Risk assessment
External certification body shall evaluate by checking the IQS documentation, staff qualifications and re-inspecting some farms.
IQS minimum requirements :
- Development of Internal Control System (ICS)
- Identification of producer groups
- Creation of awareness about group certification.
- Identification of qualified personnel for maintaining the internal control system
- Give necessary training in production and IQS development
- Preparation of IQS manual containing policies and procedures
- Implementation of the policies and procedures
- Review and improvement of the IQS document for maintaining a harmonized IQS.
III STAFF :
5.4.1 IQS Manager
- Overall responsibility of ensuring compliance with the standards.
- Developing and implementing IQS
- Organize internal inspections
5.12 EXTERNAL INSPECTIONS
The external Inspection and Certification Agency will re-inspect some of the farms for the evaluation of the grower group for efficient internal control system for compliance with the NPOP Standards.
The sampling plan for inspection shall be based on the inspector‘s perception of risk based on the following factors:
- Size of holding
- Number of the members in the group
- Degree of similarity between the production system and crop system
- Inter-mingling / contamination
- Local hazards
5.13 YIELD ESTIMATES
Yields will be estimated for each crop for individual farmer in the group. This activity should be carried out especially during harvesting and should be counter-checked with the estimates during buying.
5.14 INTERNAL APPROVALS
The IQS manager will have a defined procedure to approve or impose sanction on the farmers in the group. All internal farm checklist are screened by internal approval staff with special focus on the critical control points of risk / difficult cases.
The approval committee for providing internal certification status will check the
- Assessment of the internal inspector. If necessary, conditions will be set out for achieving compliance with the NPOP.
- The next competent person or committee must confirm results of the internal inspection in an approval procedure.
5.15 NON-COMPLIANCES AND SANCTIONS
In case of non-compliances, the IQS shall take corrective or mitigating measures.
- Procedures for implementation of sanctions will be defined in case of noncompliance.
- Sanctions have to be documented (list of farmers issued sanctions, documentation of identified non-conformities in the files).
- Farmers who have used prohibited inputs on their farms must undergo again the full conversion period (if they remain in the group). In such cases, it has to be checked whether the farmers have already delivered produce and whether this (now no longer certified) produce has been mingling with other produce. If this has been the case, the certification body needs to be notified immediately and the mingled produce kept separate until further instructions.
5.16 TRAINING OF IQS PERSONNEL
- Each internal inspector will be trained annually by a competent person.
- The date of the training, list of participants will be documented.
- The date of participation and content of the training of all IQS staff needs to be documented in the staff files.
5.17 TRAINING OF FARMERS
The IQS manager will organize regular training to the farmers in the group :
- Each farmer needs to receive at least one initial advisory visit by the extension service or in a organized training.
- The list of participants and content of the training needs to be documented.
5.18 BUYING PROCEDURES
To ensure genuineness of the products from the group, the following minimum requirements should be followed during buying :
- The status of the farmer in the group should be checked.
- The supplied amount should be compared with the harvested amount and estimated yield. In case of doubt, the produce is kept
- Identification of the product at all stages of product flow during transition.
- Segregation of organic products from in-conversion products.
- Fumigation of containers, irradiation / ionization, etc. are prohibited.
- The location in the warehouse during storage must be labeled as ‘organic’ or ‘in-conversion’.
During the handling of the produce, the documentation must be checked for compliance with the NPOP standards.
- The external inspection and certification body will inspect central processing units.
- Ingredients and processing aids must be used as defined in Annexe-4 and 5 of Section-3 of NPOP standards.
- During the product flow (transition), the products should be separated from non-organic products.
- The processing steps will be documented.
The US National Organic Standard (NOP) (205.101) establishes that operations with less than 5,000 USD annual agricultural gross income from organic sales, are exempt from certification. These producers are not allowed to use the USDA-NOP seal. This paragraph is intended more for individual growers, who sell their produce directly to consumers, not for groups, whose total gathered sales usually exceed the above-mentioned sum. Nevertheless, it gives a legal frame for systems of organic market access without individual inspection by professional approved certifiers. From 2001 to 2003, the International Federation of Organic Agricultural Movements (IFOAM) organised three workshops on group certification, with stakeholders from all over the world. The result was a “compilation” document (IFOAM ICS Compilation 03-03), which is a rich source of ideas, experiences, and proposals for producer groups and certifiers.
Internal Control System (ICS): is a tool of quality assurance, where the external certifier delegates part of his work to the organisation. The proper work of the certifier is then to evaluate the ICS’ performance.
Group : Groups can be organised on their own, but also by external entities, like e.g. processing or trading companies.
They must have a formal structure, and, as a minimum, internal exchange of information. Re-inspection rate: The sample, which is inspected by the external certi-fier, to evaluate the ICS’ performance.
Eligibility for group certification :
Obviously, any producer group can and should have its tools for quality assurance, independently from requirements of, or acknowledgement by external certifiers.
In the context of group certification, however, ADITI requires that a group must fulfil the following conditions, to use an ICS as a tool for group certification:
- The group must have at least 15 members
- Producers must be within geographic proximity and have similar production schemes.
- The group must legally established, structured and should conduct least two meetings per year, where issues of organic production and marketing are discussed, among others.
- Farms with land holding of 4 ha and above are inspected annually and total area of such farms are not more than 50% of the total area of group
ICS can be applied for crop or livestock production, including beekeeping. Collective farms with a centralized decision structure, where the individual farmer has no power of decision on crop management, do not need formalised ICSs.
Internal Quality System :
The group must have written internal rules, which can be very brief. Rules must include the basic requirements of the respective organic standard(s) for the specific crop(s) and local conditions, but can, of course, go far beyond this.
- These rules must include a catalogue of sanctions for different infringements of the rules. The group should work out sanctions, although the certifier must check, whether the infringements are adequately defined.
- The rules must include
Internal inspectors :
The group must have a sufficient number of internal inspectors.
Internal inspectors must be adequately trained. They must have appropriate knowledge of :
- Their role as inspectors
- The essential requirements of organic farming standards
- Management techniques of the respective crop(s) or livestock
- Inspection procedures
- Sanctions established by the group
- Report writing
Besides their knowledge, internal inspectors must have a high level of personal integrity and reliability.
Conflicts of interest :
In case that internal inspectors are producers themselves, they should, if possible, perform inspections in other villages or subgroups, not in their own.
In case they are farm advisors, they should, if possible, not perform inspections in the same villages or subgroups where they do consulting. As a minimum requirement, consulting and control activities must be clearly separated, concerning time, budgets, etc.
Performance of internal inspections :
As a minimum, internal inspections must take place twice a year. When new groups start, or in high risk situations, ADITI may request that more internal inspections per year take place. In high-risk situations, at least 20% of internal inspections must take place without previous announcement. Internal inspections are not just a matter of “filling in forms”. Internal inspectors must basically perform the same control procedures as external inspectors, including double-checking of information provided by the operator.
Depending on the size and complexity of the farms, inspectors should spend sufficient time on a farm unit for inspection. For normal smallholdings with a single crop to be certified, this will be between 1 and 2 hours. For bigger, more complex or high risk farms, a lot more time must be spent. This means that the group must have a sufficient number of internal inspectors. Big groups must be subdivided in appropriate subgroups.
Internal inspections must cover the whole operation, including plots in other places, and at least a sample of crops, which are not requested for certification.
During announced inspections, the farmer or another responsible person must be present. An inspection report must be written, containing all relevant information concerning the holding, and outlining non-conformities and corrective actions to be taken. We recommend the use of ADITI forms, but own forms can be used, if they contain equivalent information.
The report must bear a date and be signed by the producer and by the inspector. A farm map or drawing of all plots and farm buildings must be attached to the report and updated yearly.
Internal approval body :
The internal approval body can be a group of persons, e.g. the management board of the organisation. Nevertheless, in many situations it may be more functional that only one or two persons are assigned to perform this role.
The functions of the internal approval bodies are :
- To supervise permanently the internal inspectors.
- To evaluate the internal inspection forms, fill in the internal inspection review matrix (IIRM) and, based on this, work out the organic management plan and internal audit report for the organisation.
- To establish corrective actions and sanctions for the members.
- Pre-approval of the producers’ list.
Producers’ list and map :
A complete, updated and transparent list of producers is one of the most essential requirements for group certification.
As a minimum, the list must include the following information for all farmers :
- Complete name
- Complete address
- Whole farm area
- Area of crop(s) to be certified
- Potential yield
- Real yield, at least for the last year
- Dates of the first and the last internal and external inspections
- Dates of the last use of chemical inputs
- Certification status
- Besides, it is highly recommended that the producers’ list is managed as a real database, including complete information on:
- Harvested and delivered quantities throughout the years
- Dates of all internal and external inspections performed
- Non-conformities, corrective actions, and their fulfilment.
The group must establish privacy rules for access to this database. The information must be available for the certifier, but not necessarily for all group members.
The internal approval body can suggest the inclusion of new members in the producers’ list, but the external certifier must approve the new members, before their products can be purchased as organic. The producers’ list approved by the certifier, is an essential attachment to the group certificate. Only in the case of very experienced and reliable organisations, the certifier can concede the power of temporary approval of new members to the internal approval body.
A regional map must be provided, highlighting locations of all farmers (or, in case of big organi-sations with several subgroups, at least location of these groups), wholesale points, storage rooms, and processing or packing units.
Parallel production :
Parallel production in the stricter sense means that the same crop is planted within the same farm on organic and conventional plots. Though NPOP and NOP do not prohibit it, in producers groups with internal control systems, ADITI does not allow this form of parallel production, because we consider the risk of commingling too high.
Parallel production of fields with organic and transitional status within the same farm is possible for perennial crops, in case that a conversion plan exists and complete separation during and after harvest is assured and supervised by the organisation.
Transitional and organic producers can be part of the organisation, even in case of annual crops, if a complete harvest and post-harvest separation is assured.
In case that the organisation includes both organic and conventional producers, the conventional producers not planning to convert to organic in the near future, the organic producers have to establish some kind of subgroup, which assures separate post-harvest handling, specific organic consulting, training, and internal control.
Conversion period :
Conversion normally starts with the first documented internal inspection – except for the cases explained in ADITI policy on organic conversion period.
Post-harvest handling :
In many cases, the really critical points in farmer groups are not so much related to crop management, but to post-harvest handling. Risks of commingling certified and non-certified products exist on the farms (farmers, who also trade with the respective products), during transport, storage, packing, processing, etc. Farmers are often not even aware of this problem, especially in cases, where no major differences exist between crop management on certified and non-certified farms.
All post-harvest facilities have to be visited by the external inspector. Nevertheless, the organisation is responsible for assuring and supervising correct separation, documentation, and traceability at all these points. In the case of very advanced and reliable ICSs, ADITI can reduce external control of post-harvest facilities to a sample, which has to be determined by the inspector in coordination with the certification officer.
The organisation is responsible for training all members, explaining them, how important it is, to keep certified and non-certified products separate.
Approved farmers lists must be available at all wholesale points, where farmers deliver their products. The organisation has to establish reliable mechanisms, which allow responsibles at wholesale points to assess realistic quantities, which can be delivered by each producer.
From the moment on, where the product leaves the farm, it has to be transported in some kind of closed container (e.g. bags or boxes) and labelled.
Transports have to be accompanied by way-bills.
Farmers, who trade with the same products, for which they request certification, must be dealt with as traders. They have to keep records on purchased, stored, processed, and sold quantities. Some kind of “invoice”, signed by the producer/seller of the product, has to be filed. These “trading farmers” have to be subject to annual external inspections.
“Trading farmers” are allowed to handle both certified and non-certified products only in case that they have achieved a high level of professionalism, concerning separation, record keeping, labelling, and traceability.
The external certifier has a contract with the organisation as a whole, not with the individual producer. Each member has to sign a contract with the organisation. As a minimum, this contract must include a commitment to fulfil organic standards (specifying the most important of them), and to give free access to internal and external inspectors to the farm, including all plots and buildings, and to the necessary information and documents.
Instead of individual contracts, group contracts are accepted. Fingerprints can be used instead of signatures in the case of illiterate members.
Re-inspection rate :
Re-inspection rate for different size of the grower group shall be based on the following table given below :
|Number inthe growergroup (N)||Number of producers to be inspected|
|Initial audit||Reassessment||Surveillance visit|
|% of total||Number to
|% of total||Number to
|% of total|
As suggested by the NPOP and IFOAM guidelines, we use the square root approach for establishing the re-inspection rate: as a minimum, the external certifier must inspect the square root of all members. Besides this, a “risk factor” is used to calculate the re-inspection rate:
y = r * √x
(x = total number of producers
y = minimum number of producers to be inspected by certifier
r = risk factor)
The minimum number of producers to be re-inspected is 10.
Risk assessment and reinspection rate :
Differing from the above-mentioned guidelines, our risk factors (r) vary not only from 1 to 1.4, but from 1 to 4.
The Risk assessment is based, among others, on the following criteria :
- Performance of the ICS: a good ICS means lower risk, a poor ICS high risk
- Risk of commingling certified and non-certified products
- Risk of use of non-allowed substances, especially chemical pesticides and fertilisers
- Records: a good record system, from the level of the individual producer up to the export level, reduces risks
- Price difference between organic and conventional products: the bigger the difference, the higher the risk of fraud.
- The evaluation of the performance of internal inspectors is not only an issue of quantities, but also even more of quality. To get a real insight in the work of internal inspectors, it is not enough to evaluate their reports. Therefore, ADITI will always perform witness audits of in-ternal inspector performance during external inspections.
The following table presents examples of a high, a medium, and a low risk situation, and the re-spective size of the sample to be re-inspected by the certifier. Obviously these are just some examples. The real risk assessment and determination of re-inspection rate will be performed by ADITI inspectors, in coordination with the responsible certification officer.
The external inspector uses the risk assessment reinspection spreadsheet to calculate the reinspection rate before setting out on the inspection.
|ICS||Risk factor||Total number of producers|
|Number of producers to be re-inspected|
Steps to certification:
New groups applying for group certification should take the following steps towards certification :
- Basic training of all interested members concerning organic farming principles, standards, and techniques.
- Establishment of IQS, selection of internal approval body and internal inspectors.
- Training of internal inspectors and internal approval body.
- Performance of internal inspections.
- Revision of internal reports, filling in the Internal Inspection Report Revision Spreadsheet and working out the organic management plan and internal audit report.
- Correction of non-conformities detected during (d) and (e).
- External inspection. As a minimum, 80% of internal inspections must have taken place, be-fore the external inspection is performed (obviously, 100% is much better!).*
- Eventually, corrective actions imposed by ADITI have to take place. 100% of inspections have to be completed, if this was not the case before.
- If all relevant requirements are fulfilled, the group certificate can be issued.
* Please note, that minimum 80% refers to the inspection date. As mentioned otherwise, 100% must have been performed before the certificate can be issued.
ADITI’ role in preparation of ICS and IQS :
To avoid conflicts of interest, ISO guide 65, which is the basis of our certification work, does not allow certifiers to get involved in performing consulting activities for the same clients, for whom we do certification. According to our understanding, however, this does not apply to the preparation of ICS or IQS and training of internal inspectors. Internal inspections must be conceived as part of the certifier‘s control activity, delegated to the group or company. Thus, training internal inspectors is considered as equivalent to training our own inspectors. If we get directly involved in preparation of ICS and internal inspector training, we can expect that things are performed according to our policies and procedures. Nevertheless, the group responsibles can obviously decide, whether these task are performed by own their staff, by ADITI, or by external consultants.
Staff and training
ADITI strongly belives that competent staff is the key to a successfull ICS. The projects should establish a competency matrix and to the maximum possible extent identify and assign competent staff from the group or outside. ADITI will require at least one training for the internal inspector (preferably the whole team) from a competent person for the internal inspectors and one external training for the whole team in 3 years. The IQS manager may attend the external trainings and train the other staff. All the new staff should receive an initial training on the IQS and internal standards. All the trainings should be documented and available for inspector.
Certification, corrective actions, and sanctions :
Group certification means that the organisation is treated as one entity. The group must be aware that this may lead to situations, where infringements by one or several producers are punished by sanctions or decertification affecting the whole group. This is especially the case, when products from different growers are mixed, making it impossible to separate the product proceeding from the growers, who do not comply with the standards.
Conditions, which must be fulfilled, before the first group certificate is issued :
- Internal inspectors have adequate knowledge
- 100% of internal inspections have been performed, documented and evaluated.
- The producers’ list with complete and reliable information is presented
- All producers have received at least some basic training in organic farming
- Reliable information on last use of chemical inputs is available for all producers, and allows to assign a status (conventional, transition, organic) to each of them
- The organisation has established a system, which avoids post-harvest commingling with non-certified products.
In case that different group members have a different organic status, the group must also establish a system, which assures separate purchase and post-harvest handling of these products. If this is not possible, the whole group is assigned the lowest status (e.g. 1st year of transition, even though some members would already qualify for organic).
Besides the normal catalogue of remediation measures and sanctions, typical group measures are :
- Exclusion of members who do not comply with essential rules.
- Increase of the re-inspection rate.
- Obligation to improve training and/or supervision of producers and/or internal inspectors.
Access to this policy :
This policy is available to all parties interested in group certification by ADITI It must be handed out to all ADITI certification and inspection personnel.