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7.

Reporting, Evaluation and Certification 1

Reporting

• The overall findings of the ICS


inspection are summarized during the
inspection in the inspection report form.

• Usually this means that the report


format is roughly completed on paper
(mainly compliance check, few
keywords for descriptive portion); the
table of non-conformities/corrective
measures is completed.

• The findings are discussed with the ICS


manager, who then countersigns the
report.

• If needed, the same format is used after


the inspection to prepare an electronic
report with more details/descriptions as
basis for certification.

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 2

How to Use the Report Format

Descriptive parts will be completed mainly after inspection


(also based on information in ICS manual). Some parts are
narrative (text), one part is a selection of descriptions to check
(‘x’).

Each compliance criterion is checked whether it is


• OK = criterion fully met
• PF = PARLY FULFILLED; criterion in met in principle but
minor corrections are needed
• NO = NOT FULFILLED
• N/A= NOT APPLICABLE
(if box is grey – no ‘not applicable’)

For any case of PARTLY FULFILLED or NOT FULFILLED,


details must be given below the table, with respective number
of the criterion.

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 3

Example: How To Use The Report Form

General: Various existing documents could not be checked during inspection because they are in the ICS Coordinator’s
private home. For next inspection, ALL relevant ICS documents must be presented to the inspector.
10.1 & 10.2 : There is a very simple commitment declaration (“I confirm that I understand the rules for organic production.”)
included in the farm entrance form. The actual contract that outlines in writing the organic production rules will be signed only
at the end of the conversion period. If this is to be accepted, the commitment declaration in the farm entrance form needs to
be improved and translated to Kiswahili.
10.3: In the farm entrance form there is no indication of last prohibited inputs for the “other crops”. Also the table field history
for “other crops” has been used incorrectly as importance grading of different crops (e.g., 01-crop = maize, because it is the
most important crop for farmer). There is no field history for the pineapple fields, which would have been better than only the
indication “last use of prohibited inputs”.

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 4

Checking Farmers Lists

• List complete? Last update of list?


• Check whether total number of farmers on
list corresponds with information from the
ICS Coordinator.
• Spot check cross-checking of farmers list
with ICS documents (already done during
sample inspections)
• Spot-check list with last certified farmers
list (same farmers? Major changes in the
area? Correct conversion status for all
farmers?)
• Number farmers present year = Number
farmers last year –
sanctioned/withdrawing + new farmers
• If farmers list = also summary of internal
control, check whether 100% inspection
has been completed

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 5

Additional Annexes to the Inspection Report

• Farm re-inspection reports


• Sanctioned farmers list
• ICS manual / ICS forms and
procedures
• 2-3 sample farmers files (esp.
problematic cases)
• Sample training or staff files
• Copy purchase registers
• Labels
• Processing documentation

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 6

Evaluation for Certification

The criteria are weighed


A: MAJOR non-compliance, pre-requirement for certification
B: Minor non-compliance to be corrected short term
C: Minor non-compliance to be corrected medium term
D: Recommendation

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 7

Relative Importance of Criteria

A In principle all ‘A’ Requirements must be fulfilled for certification

Additionally, a certain percentage of ‘B” requirements should be

B fulfilled. Partly fulfilled counts as ½ fulfilled.


• First inspection/first certification according to the proposed
new system: app. 50-70% of all compliance criteria
• Follow-up inspection: 60-80%
• From 3rd year onwards app. 90%
(rough guideline only)

C ‘C’ requirements need to be fulfilled in medium term; i.e. a


certain timeframe has to be set for fulfilling these requirements.

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 8

Less Than 100% Internal Inspection

Less than 100% of all farmers were inspected by


ICS in a certain year.

Option 1: the missing inspection can be done


immediately and still count for the respective year
 set conditions for next year to ensure 100% ON
TIME.
(possibly additional external inspection)

Option 2: only those farmers who were internally


inspected are considered for certification.

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 9

Major Non-compliances Not Detected (1)

A non-compliance that threatens the organic integrity of a


product was not detected by the internal control.
E.g., organic crop or an intercrop on an organic plot was sprayed with
pesticide
Detailed Investigation

• Why was it not detected?


• When was the internal inspection?
• Was the problem openly declared or
was there an attempt to cheat?
• Reaction of field officer/internal
inspector?
• Problem of inspector or general
problem?
• Localize problem!
• Number of cases?
Training Manual on the Evaluation of Internal Control Systems
7. Reporting, Evaluation and Certification 10

Major Non-compliances Not Detected (2)

Case: The ICS clearly failed to detect the problem in several cases

• The inspection is finalized (but with number of farm


inspections for highest risk level).
• ICS is given a warning to immediately improve the ICS and
correct the problem and to conduct a second round of
internal inspections, etc.
• The inspector informs the certifier immediately of the
situation, and the certifier confirms the sanction in writing.
Usually the certification will need to be suspended.
• The correction of the problem usually has to be verified in
a second inspection before certification can be granted.
• Depending on the scope of the problem, the second
inspection will only focus on the identified weaknesses or a
complete new round of farm inspections, etc., may be
necessary.

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 11

Major Non-compliances Not Detected (3)

Case: The ICS failed to detect the problem in a few cases, but
due to obvious reasons
(e.g., spraying occurred after internal inspection, although in principle
inspection was timed well)
 Increase inspection rate to high-risk situation, ensure
that the problem was really a single problem, not a
general pattern that indicates a structurally inefficient
ICS.

 If this happens for the first time, a warning to improve


the ICS will usually be sufficient. Ensure that all
potentially concerned farmers are immediately
inspected a second time by the ICS.

 Correction of reasons for the problem (e.g., additional


training for weak inspector, etc.) is required. Proof of
correction is required before certification.
Training Manual on the Evaluation of Internal Control Systems
7. Reporting, Evaluation and Certification 12

Other Non-compliances Not Detected by the ICS

Findings of the ICS differ considerably from findings of the


external inspection, but the undetected problem does not
threaten the organic integrity; i.e., the problem will not lead to
de-certification of the farm or of products.

Examples:

• ICS failed to detect processing aids, but they were permitted


• ICS failed to detect use of copper or other allowed substances
• ICS failed to find out that a farmer still had conventional units

Corrective measures to improve the internal


inspections.

A second round of internal inspections may possibly


be necessary.

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 13

Principles in Dealing with a Weak ICS

• Overall, the ICS inspection and quality assurance must be sufficient to


grant the organic certificate on basis of the assessment of the ICS.
• If the ICS is not yet functioning well, it needs to be improved. The ICS
should not be “replaced” by high external control rates in the long run.
• In most cases  let the ICS make certain improvements  come back
for second inspection.

• If ICS not really functional at all  improvement will need time 


transitional high re-inspection rates may be needed until ICS is fully
functional.

• Only “formal aspects” of an ICS are not yet fulfilled, or, in fact no fully
working monitoring system / quality assurance system in place?

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 14

Co-mingling

Organic products have been mixed (at any stage) with


conversion or conventional products

• Thorough investigation: what happened, who was


responsible, how was it possible, etc.
• Is there a consistent lot number system or has the
whole batch been commingled?
• De-certification of the concerned lots.
• Additional corrective measures to prevent the same
incident.
• Usually additional sanction: unannounced
additional inspection during next purchase.

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 15

Reporting to the Certifier

Inspection report
(computerized/more Checked farmers list
comments included)

APPENDICES

Training Manual on the Evaluation of Internal Control Systems


7. Reporting, Evaluation and Certification 16

Certification

Organic Certificate

+ Certified farmers list


(‘original’; i.e. with stamp, signature,
Certificate for Group XXX date)
Adress
the group
- Soil erosion must be controlled
better
- check of previous farming
practices to be improved
- better training for inspectors
- receipts have to be given to farmers
- farm maps to be improved

Certification decision with


necessary corrective measures

Training Manual on the Evaluation of Internal Control Systems

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