4.

2 Inspection of the Internal Control System 1

Internal Inspection

Each registered farmer is inspected by the internal control at

least once a year. The inspection is documented.

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Difference between Inspection and Extension?

• Internal inspection checks

compliance with ALL aspects of
the internal organic standard

 Covers more than an average

extension visit with focus on
advice and documentation

• Internal inspection of each farmer is

substituted for external inspection;
thus it is a formal and documented
complete check of the whole farm
and its activities by a neutral
person

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100% Internal Inspection

5.5.1: 100% of all growers are inspected annually

by the ICS
• I.e., ALL registered farmers: active farmers, conversion farmers, new
farmers, passive farmers (remain in the organic program but no
purchase planned for respective year)
• In case of annual crops (time from planting to harvest is less than 8
months) there has to be one inspection per growing season (if many
short seasons twice/yr sufficient)
• If the internal inspections are not yet finalized at the time of inspection,
will the ICS be able to finalize 100% inspection in time?  will need to
submit proof on 100% inspection

• Check farmers list (should contain inspection details)

• Ask ICS Coordinator for current overview of inspections
• Understand how the system ensures 100% inspection

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What has to be Checked in the Internal Inspection?

Organic fields and

non-organic fields

Farmers records
(if available) Harvest
Inspection must activities, Farm
cover processing

Storage Boundaries, Livestock

(products Risks of
and inputs) contamination

The internal inspection always includes a physical field visit and an

interview of the farmer (or representative)

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Critical Control Points of Internal Inspections

Have all crops that grow on the organic fields been checked?
• e.g., intercropping conventional cardamom in the organic pepper plot
• is production of all crops on the organic plot(s) checked?
• incl. seeds of intercrops in organic fields

Are all fields that are managed by the farmer registered?

• no parallel production
• overall activities of farmer must be known
• be aware of inputs for conventional fields (where stored???)
• important to know for various private organic standards
• registration is the very minimum, and usually a spot check of conventional
fields is required (if they are close, they shall be checked)

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Effectiveness of the Internal Inspections

5.5.5 Internal inspections are

thorough; all non-compliances with
the internal (and external) standard
have been duly identified.

5.5.6 Appropriate sanctions are

communicated to the farmer. ICS
has followed up.

5.5.7/8 The inspection report is

completed and signed
by the inspector (A)
and by the farmer (B).

5.5.12 Noncompliances found by

extension, etc. (not during internal
inspection) are also documented.

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4.2 Inspection of the Internal Control System 7

Yields

5.5.9 There is a system to estimate

yields before beginning harvest
• by field officers and/or
• during internal inspection, etc.

5.5.10 Yield estimates are reasonably

accurate.

5.5.11 Yield estimates are ready

before harvest

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Approval Procedures

5.6.1 The organization must have procedures to

approve or reject farmers
 • Is there an approval procedure in place?
 X E.g., the ICS Coordinator screens all reports and, if found ok,
signs the report and updates the information in the farmers list.
• Who makes approval/sanction decisions?

 Approval Manager (may be ICS Coordinator) or approval

committee?

5.6.2 & 5.6.3 From second certification onwards, the
farmers lists reflect at least the internal approval
 status for each farmers: OK, passive, sanctioned,
etc. (A) or states even the exact conversion status:
eg: org. / conversion 1/ conversion 2 etc. (B)

• Conversion status: according to rules agreed upon with certifier

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Sanction Procedures

5.6.4 & 5.6.5 If minor, medium, or major noncompliances

have been identified, appropriate measures have been
 taken to correct them

 X • Check all sanctions imposed by ICS since last inspection

• What happens in case of noncompliances? Types of sanctions?

 • How are sanction measures implemented? Who is responsible

for taking action? How is it assured that all relevant staff is being
 informed?
• How and where are sanctions documented? Can the sanctions
 also be seen in farm files and in farmers lists used for purchase?
• 5.6.6. If any contaminated product that has already been sold as
organic, it must have been de-certified, and the ICS must have
followed up and taken appropriate measures (see examples
later).

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What Should Be Done if There Are Problems?

Investigate Decision
• What happened? • by organic approval
• Why? manager /OAC
Problem • When ? • Sanctions
• What products/ lots • Corrective measures
are concerned?

Act!
Note: Serious problems should Document!
always be reported immediately to
the ICS Coordinator

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Examples of Types of Sanction

Sanction Situation when sanction applies

• Written condition • Minor deficiencies in record keeping, weak

farm management. Minor violations of the
standards or regulations

• Penalty • Repeated written condition for similar problem

ICS will fine farmers $5 Not responding to conditions
Major deficiencies in record keeping

• Repeated minor violations

• Suspension for a fixed period until the farmer Clear violation of the standards but not
takes corrective actions requested (remains threatening the organic integrity of the
certified) product.

• Clear violation of the standards threatening

• Decertification of farmers --> Renewed conversion the organic integrity of the product.
period of 36 months
• Obvious fraud, intentional obstruction of the
inspection process, refusal to respond to
• Farmer banned from ICS membership either written requests
permanently or for a set time.

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4.2 Inspection of the Internal Control System
Examples of Non-compliances & Sanctions
Example of Noncompliance
Farmer has sprayed his/her organic crops
Farmer has sprayed home consumption
crops intercropped with organic crop
Farmer has sprayed home consumption
garden far away from organic garden but not
allowed per internal regulation
Farmer has neglected his farm and has not
taken any soil improvement measures
De-certified coffee has been mixed with
organic coffee of fellow farmers in village
Farmer sells double his estimated harvest
Buying officer has bought from uncertified
farmers
12
Example of Sanction / Reaction
Farmer de-certified for 3 years (new conversion)
Possibly expelled from organic program
Check whether products already purchased
Farmer de-certified for 3 years (new conversion)
Possibly expelled from organic program
Check whether products are already bought
Farmer suspended as punishment for 1 yr.
Sprayed plot recorded on map as conventional
Additional training for farmer
Written/oral condition to farmer
Additional training
If repeatedly: discuss whether shall remain member
Find out which lots are “contaminated”
Mark these lots as conventional
Send field officer to investigate in the fields
If farmer has sold products of somebody else – expel
from organic program
Find where the conventional product is now,
downgrade product to conventional. If already sold,
inform certifier.
Train buying officer (or dismiss him if fraud)
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4.2 Inspection of the Internal Control System
Examples of Non-compliances & Sanctions
Example Non-compliance
Farmer has sprayed his/her organic crops
Farmer has sprayed home consumption
crops intercropped with organic crop
Farmer has sprayed home consumption
garden far away from organic garden but not
allowed by internal regulation
Farmer has neglected his farm and has not
taken any soil improvement measures
De-certified coffee has been mixed with
organic coffee of fellow farmers in village
Farmer sells double his estimated harvest
Buying officer has bought from not certified
farmers
13
Example Sanction / Reaction
Farmer de-certified for 3 years (new conversion).
Possibly expelled from organic program.
Check whether products already bought.
Farmer de-certified for 3 years (new conversion).
Possibly expelled from organic program.
Check whether products are already bought.
Farmer suspended as punishment for 1 yr.
Sprayed plot recorded on map as conventional.
Additional training for farmer.
Written/oral condition to farmer.
Additional training.
If repeatedly: discuss whether shall remain member.
Find out which lots are “contaminated”; mark these
lots as conventional.
Send field officer to investigate in the fields.
If farmer has sold products of somebody else – expel
from organic program.
Find where the conventional product is now,
downgrade product to conventional. If already sold,
inform certifier.
Train buying officer (or dismiss him if fraud).
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Consequences and Necessary Measures after Detection

of Farmer’s Use of Prohibited Inputs

The fields of the farmer must once again

undergo the full conversion period Document the sanction in the farm file,
farmers list (take farmer on sanctioned
list), and purchase list

Check whether the farmer has

already delivered produce Assure that the farmer remains
sanctioned for the next 3 years

If produce has been commingled, the

Check whether his produce has certifier needs to be notified
been commingled with other immediately and the commingled
organic produce produce kept separate until further
instructed.

Inform the field officer and purchase staff that purchasing from
this producer is not allowed during the period of sanction

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Exercise: Evaluation of Approval/Sanctions

Case Study II, Spice Project ZZZ (does not exist on CD)
Basics: 800 farmers, organized by NGO, certified for 3 years

Received documents:
 Complete ICS manual, incl.
- ‘Internal regulations’
- ‘Internal Control System for small farmers’
X - Summary farm records, sample purchase lists
- Documents on sanctions

 Evaluate the approval & sanction system

 Overall impression of the ICS manual
  Clear approval system?
 Clear sanction system?
 Are sanctions documented? – is the sanctioned farmers
 list sufficient?
 Are sanctions appropriate (standard list of sanctions)?
Any indication of other measures taken in cases of
use of prohibited inputs?
 Questions to ask ICS Coordinator?
 Any additional info for special focus during next re-inspections?

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ICS Personnel

5.7.2 The internal inspectors are qualified for a thorough

and objective inspection. Each inspector receives at
least one training per year
• Qualification of inspectors can be
checked during farm re-inspections,
witness audits, and through interviews
• Can they really do thorough
inspections? (e.g., they may be too
young to ask elders critical questions)
• Good ideas for effective inspectors
trainings may include accompanied
inspections and on farm-training in
inspection methods
• Participation and content of training
must be documented

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Conflicts of Interest

5.7 The objectivity of decisions made by the ICS may not

be jeopardized by conflicts of interest
• ICS needs conflicts of interest
declarations for inspectors & approval
staff.

• Conflicts of interest must be avoided.

A person may not inspect/approve
his/her own farm, nor the farms of
neighbors, close friends, or family

• If there have been potential conflicts An inspector cannot inspect his close friends or family
of interest – check that they have not
resulted in unfair assessment or
neglect of important facts

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Inspection vs. Field Advice

• Field extension service (farm advice) is an important aspect of an organic

project and often field extensionists are at the same time internal inspectors.

• However, field extensionists tend to be very close to the farmers; they often
live in the same village and therefore are often not “neutral” enough for the
actual inspection.

• Many ICS Operators solve this problem by exchanging field officers

(advisors) among project regions for internal inspections.

• However, in certain cases it can also be accepted that one person does both
the field extension and the internal inspection, but, at minimum, they should
be clearly separate events. This is only possible if the advisor is “distant”
enough from farmers to ensure an impartial inspection.

• Informing the farmers of the standard requirements and the functioning is not
considered consultancy. An internal inspection may also include some
advice.

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Farmers Training

5.8 Each farmer needs to receive at least one initial training (or long
advisory visit) in organic agriculture.

• Participation and content of trainings must

be documented.

• Farmers must be aware of certification

requirements
 check during sample inspections.

• Farmers must be familiar with organic

farming methods (this is a long-term
development criterion)

Field training –are there any pests?

Training Manual on Evaluation of the Internal Control Systems