Group Certification and the Risk Assessment
This policy establishes the guidelines for risk assessment of smallholder group certification by ADITI.
In an organic farming, there is always risk of contamination from chemical, physical and biological substances at every stage of production. It is necessary to assess such risks and take corrective measures to keep the organic integrity of the certified products.
Normative framework :
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.
5.4.2 Internal inspectors
Adequate number of internal inspectors shall be identified from within the group. The inspectors shall be qualified and well versed with the standards to perform internal inspections.
5.10.3 List of farmers who have been issued sanctions with the reason and the duration of the sanction (if relevant).
5.10.4 The risk shall be assessed by IQS manager for the grower group every year. The risk assessment should be made at the farm level, processing, transporting and during trade. The IQS will take all measures to minimize the identified relevant risks.
18.104.22.168 Critical control points for risk assessment
- Measures taken by the farmers to deal with part conversion (if farmers still grow some non-organic crops).
- Conversion period
- Production rules for the whole production unit, e.g., seeds, fertilization and soil management, pest management, approved inputs, prevention of drifts, animal husbandry.
- Harvest and post harvest procedures.
- Processing and handling standards
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:
6. Size of holding
7. Number of the members in the group
8. Degree of similarity between the production system and crop system
9. Inter-mingling / contamination
10. Local hazards
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 certifier, 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
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.
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.
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.
Re-inspection rate for different size of the grower group shall be based on the following table given below: -
|Number in the grower group (N)||Number of producers to be inspected|
|Initial audit||Reassessment||Surveillance visit|
|Number to be inspected (n=√ N)||% of total||Number to be inspected (n=0.8√ N)||% of total||Number to be inspected (n=0.6√ N)||% 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 respective 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.
|Situation||Use of chemicals in the area||ICS||Risk factor||Total number of producers|
|Number of producers to be re-inspected|
ADITI’ role in preparation of ICS and IQS:
As a minimum, ADITI will implement the above-mentioned requirement as per NPOP Standards. In addition to this, Aditi investigate the risk involved in a project and the number of farms/farmers to be re-inspected against the operators internal inspections (reference form 22.214.171.124-Risk Factor & re-inspection rate). It is mandatory to inspect the number of farms/farmers as per the formula mentioned above. 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 responsible can obviously decide, whether these task are performed by own their staff, by ADITI, or by external consultants.
Staff and training :
ADITI strongly believes that competent staff is the key to a successful 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.
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