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NP7100LLA CC GCIA 012918 Page 1 of 5

NATIONAL ORGANIC PROGRAM: CORRECTIVE ACTION REPORT

AUDIT AND REVIEW PROCESS

An onsite renewal assessment of Georgia Crop Improvement Association’s (GCIA) organic

program was conducted on April 10-14, 2017. The National Organic Program (NOP) reviewed

the auditor’s report to assess GCIA’s compliance to the USDA organic regulations. This report

provides the results of NOP’s assessment.

GENERAL INFORMATION

Applicant Name Georgia Crop Improvement Association (GCIA)

Physical Address 2325 South Milledge Avenue, Athens, Georgia 30605

Mailing Address 2325 South Milledge Avenue, Athens, Georgia 30605

Contact & Title Terry Hollifield, Executive Director

E-mail Address [email protected]

Phone Number (706) 542-2351

Reviewer & Auditors Rebecca Claypool, NOP Reviewer;

Alan Kohles and Jason Lopez, On-site Auditors.

Program USDA National Organic Program (NOP)

Review & Audit Dates

Corrective action review: January 29, 2018

NOP assessment review: July 19, 2017

Onsite audit: April 10 – 14, 2017

Audit Identifier NP7100LLA

Action Required No

Audit & Review Type Renewal Assessment

Audit Objective To evaluate the conformance to the audit criteria; and to verify the

implementation and effectiveness of GCIA’s certification

Audit & Determination

Criteria

7 CFR Part 205, National Organic Program as amended

Audit & Review Scope GCIA’s certification services in carrying out the audit criteria during the

period: September 14, 2015 through April 10, 2017

Georgia Crop Improvement Association (GCIA) was accredited by the USDA National Organic

Program (NOP) as a certifying agent on April 29, 2002 for accreditation scopes of crops,

livestock, and handling. GCIA’s office is in Athens, GA and GCIA conducts certification

services in Georgia, Alabama, South Carolina, North Carolina, Florida, and Kentucky. GCIA

certifies 125 operations to the following certification scopes: 46 crops, 7 livestock, and 72

handler. GCIA does not certify grower groups.

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mailto:[email protected]

NP7100LLA CA GCIA 012918 Page 2 of 5

GCIA’s organic certification program is staffed by the following five positions: Program

Director, Organic Program Manager, Organic Certification Reviewer, Organic Auditor, and an

Organic Administrative Assistant.

The NOP auditors conducted two witness audits during the renewal assessment. The first witness

audit was conducted on an annual inspection of a handling operation. The second witness audit

was conducted on an annual inspection of a crops/livestock operation.

NOP DETERMINATION:

NOP reviewed the onsite audit results to determine whether GCIA’s corrective actions

adequately addressed previous noncompliances. NOP also reviewed any corrective actions

submitted as a result of noncompliances issued from Findings identified during the onsite audit.

Non-compliances from Prior Assessments

Any noncompliance labeled as “Cleared,” indicates that the corrective actions for the

noncompliance are determined to be implemented and working effectively. Any noncompliance

labeled as “Accepted” indicates acceptance of the corrective actions and verification of

corrective action implementation will be conducted during the next onsite audit.

NP5257MMA.NC1 – Cleared
















NP5257MMA.NC7 – Accepted. 7 C.F.R. §205.404(b) states, “The certifying agent must issue a

certificate of organic operation which specifies the: (1) Name and address of the certified

operation; (2) Effective date of certification; (3) Categories of organic operation, including crops,

wild crops, livestock, or processed products produced by the certified operation.” NOP 2603,

Organic Certificates, Section 3.1 states, “Organic certificates should be issued in English and

include the following (* identifies elements required by 7 CFR §205.404 of the USDA organic

regulations): 1. Certified operation’s name (all legal names) and address(es), including a physical


address if the mailing or legal address is not the physical location of the operation*; 2. Certifying

agent’s name, address, Web site, and phone number*; 5. Anniversary date (when the certified

operation must submit its annual update); 9. The statement, “Certified to the USDA organic

regulations, 7 CFR Part §205.” This differentiates USDA organic products from those certified

to other organic standards; and 10. The statement, “Once certified, a production or handling

operation’s organic certification continues in effect until surrendered, suspended or revoked.” Comments: Seven organic certificates issued by GCIA were reviewed. None of the seven GCIA

certificates issued included GCIA’s website; an anniversary date; the statement, “Certified to

the USDA organic regulations, 7 CFR Part 205”; or the statement, “Once certified, a

production or handling operation’s organic certification continues in effect until surrendered,

suspended, or revoked.” Two of the seven certificates reviewed had a post office box and did not

include a physical address of the operations. Two certificates issued to livestock operations

stated “Organic Poultry Certificate” as opposed to livestock; and two certificates issued to crop

operations stated “Organic Farm Certificate” as opposed to crop. 2016 Corrective Action: GCIA developed new certificate templates that complies with the

requirements of NOP 2603. Training on NOP 2603 will be conducted during the training

scheduled for later this year. 2017 Verification of Corrective Action: GCIA organic certificates do not comply in the

following ways:

The statement “Certified to the USDA organic regulations, 7 CFR Part 205” is not correct

on the certificate.

The statement, “Once certified, a production or handling operation’s organic certification

continues in effect until surrendered, suspended, or revoked.” is not correct on the

certificate.

GCIA issued a certificate with the scope of “Poultry Livestock.” The certificate should

indicate the certification scope of “Livestock.” 2017 Corrective Action: GCIA updated their organic certificate template to include the correct

statements and correct scopes of accreditation. GCIA submitted a certificate for each scope of

accreditation – Livestock, Crops and Handler/Processor – with the required updates. GCIA will

continue to issue corrected certificates during 2018 renewals.

Non-compliances Identified during the Current Assessment

Any noncompliance labeled as “Accepted,” indicates that the corrective actions for the

noncompliance are accepted by the NOP and will be verified for implementation and

effectiveness during the next onsite audit.

NP7100LLA.NC1 – Accepted. 7 C.F.R. §205.403(c) (2) states, “The on-site inspection of an

operation must verify: That the information, including the organic production or handling system

plan, provided in accordance with §§205.401, 205.406, and 205.200, accurately reflects the

practices used or to be used by the applicant for certification or by the certified operation;” Comments: The witness audit of the livestock operation revealed that the inspector did not

accurately verify several sections of the OSP:


Products used during the milking process.

Livestock feed inputs.

Livestock health veterinary supplies.

Cattle inventory. 2017 Corrective Action: GCIA conducted a second inspection of the operation noted by the

auditor to verify the areas of the operation missed during the witness audit. GCIA trained staff

and inspectors on June 27, 2017 on conducting inspections that verify the OSP. GCIA submitted

training materials and the inspection report of the additional inspection.

NP7100LLA.NC2 – Accepted. 7 C.F.R. §205.504(b)(1) states, “A private or governmental

entity seeking accreditation as a certifying agent must submit the following documents and

information to demonstrate its expertise in organic production or handling techniques; its ability

to fully comply with and implement the organic certification program established in §§205.100

and 205.101, §§205.201 through 205.203, §§205.300 through 205.303, §§205.400 through

205.406, and §§205.661 and 205.662; and its ability to comply with the requirements for

accreditation set forth in §205.501: (b) Administrative policies and procedures. A copy of the

procedures to be used to evaluate certification applicants, make certification decisions, and issue

certification certificates.”

Comments: GCIA does not have procedures for the following activities:

The initial review process

Noncompliance tracking

Criteria for assigning inspections to inspectors. (Expertise, availability, number of times

visited). 2017 Corrective Action: GCIA updated their Administrative and Policy Manual and developed

the following procedures: Procedures for Organic Application Clerical Review, Application

Distribution to Program Manager and Reviewer, and Final Disposition of Application;

Noncompliance spreadsheet; and a Standard Operating Procedure (SOP) for Assigning Audits to

Inspectors. GCIA developed the updated policies as a staff, so all personnel are aware of the

updated procedures.

GCIA’s SOP for the Administrative Assistant includes conducting an initial review of

applications for completeness and sending operations an Incomplete OSP Notification if

more information is needed. GCIA developed the Certification Status Checklist for use

by the Administrative Assistant to track the progress of applications through the

certification cycle, and GCIA updated their Administrative and Policy Manual to include

the initial review process.

GCIA developed a weekly SOP for the Administrative Assistant to send notices of

noncompliance to operations that have missed a deadline. GCIA developed a

noncompliance tracking spreadsheet which is updated by the Administrative Assistant to

ensure notices are issued on time. GCIA updated their Administrative and Policy Manual

to include noncompliance tracking as part of the Administrative Assistant’s duties.

GCIA developed an SOP for the Program Manager to follow for assigning inspections,

giving consideration to inspector availability, training, performance and experience along

with other considerations. The SOP states that inspectors will not inspect the same

operation more than two consecutive times.


NP7100LLA.NC3 – Accepted. 7 C.F.R. §205.501(a)(1) states, “A private or governmental

entity accredited as a certifying agent under this subpart 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 established under the Act and the regulations in

this part;”

Comments: The GCIA staff does have not have sufficient knowledge of international

agreements. Interviews with staff and inspectors revealed they were unable to identify countries

that have an organic international arrangements with the U.S. GCIA was able to access the

international paperwork on the NOP website but were unfamiliar with what paperwork should

be available for review and unfamiliar with how to complete documents for products being

exported under the agreements. 2017 Corrective Action: GCIA updated their OSPs to include questions about import/export

activities. GCIA developed a procedure, Appendix C, referring staff to the NOP international

website and Handbook when an OSP notes that products are imported or exported in order to

evaluate compliance with the specified agreement. GCIA will train staff on the NOP’s

international trade agreement requirements to increase knowledge during the first quarter of

2018. GCIA submitted Appendix C and the updated OSP sections.

NP7100LLA.NC4 – Accepted. 7 C.F.R. §205.662(c)(3) states, “... The notification of proposed

suspension or revocation of certification shall state: The impact of a suspension or revocation on

future eligibility for certification;”

Comments: GCIA’s notice of proposed suspension/revocation template does not state the

impact of suspension or revocation. 2017 Corrective Action: GCIA updated their notice of proposed suspension/revocation

templates to include the impact of suspension or revocation on the future eligibility for

certification. GCIA removed the old templates from their server to ensure that only the current

templates are used. GCIA submitted a copy of the revised templates.


MP5257MMA CA GCIA 081216 Page 1 of 10

NATIONAL ORGANIC PROGRAM: CORRECTIVE ACTION REPORT AUDIT AND REVIEW PROCESS

The National Organic Program (NOP) conducted a mid-term assessment of Georgia Crop Improvement Association, Inc. (GCIA). An onsite audit was conducted, and the audit report reviewed to determine GCIA’s capability to continue operating as a USDA accredited certifier. GENERAL INFORMATION

Applicant Name Georgia Crop Improvement Association, Inc. (GCIA) Physical Address 2325 South Milledge Avenue, Athens, Georgia 30605 Mailing Address 2325 South Milledge Avenue, Athens, Georgia 30605 Contact & Title Terry Hollifield, Executive Director E-mail Address [email protected] Phone Number (706) 542-2351 Reviewer(s) &

Auditor(s) Rebecca Claypool, NOP Reviewer; Miguel A. Caceres, Lars Crail, On-site Auditors.

Program USDA National Organic Program (NOP)

Review & Audit Date(s) NOP Corrective Action Review : June 24, 2016 NOP assessment review: May 5, 2016 On-site audit: September 14 – 17, 2015

Audit Identifier NP5257MMA Action Required None

Audit & Review Type Mid-Term Assessment

Audit Objective To evaluate the conformance to the audit criteria; and to verify the implementation and effectiveness of GCIA’s certification system.

Audit & Determination Criteria

7 CFR Part 205, National Organic Program as amended

Audit & Review Scope GCIA’s certification services in carrying out the audit criteria during the period: February 2014 through September 2015

Georgia Crop Improvement Association, Inc. (GCIA) was accredited as a USDA National Organic Program (NOP) certifying agent on April 29, 2002 for crops, livestock, and handling operations. The GCIA list of certified operations includes 110 certified operations, consisting of 42 crop operations, 2 livestock operations, and 66 handlers. There are no grower groups certified by GCIA. GCIA operates out of its sole office in Athens, GA and has certified operations in Alabama, Florida, Georgia, and North Carolina.

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NOP DETERMINATION: NOP reviewed the onsite audit results to determine whether GCIA’s corrective actions adequately addressed previous noncompliances. NOP also reviewed any corrective actions submitted as a result of noncompliances issued from Findings identified during the onsite audit. Noncompliances from Prior Assessments Any noncompliance labeled as “Cleared,” indicates that the corrective actions for the noncompliance are determined to be implemented and working effectively. Any noncompliance labeled as “Outstanding” indicates that either the auditor could not verify implementation of the corrective actions or that records reviewed and audit observations did not demonstrate compliance. NP2296MMA.NC4 – Cleared. NP4057JHA.NC1 – Cleared. Noncompliances Identified during the Current Assessment Any noncompliance labeled as “Accepted,” indicates that the corrective actions for the noncompliance are accepted by the NOP and will be verified for implementation and effectiveness during the next onsite audit. NP5257MMA.NC1 – Accepted. 7 CFR §205.402(a)(1-2) states, “Upon acceptance of an application for certification, a certifying agent must: (1) Review the application to ensure completeness pursuant to §205.401; (2) Determine by a review of the application materials whether the applicant appears to comply or may be able to comply with the applicable requirements of subpart C of this part” Comments: The review of certification applications by GCIA do not consistently identify when applications are incomplete. A review of seven files verified that two handling operation files did not contain sufficient information. GCIA identified the deficiency for one of the handler applications but not the others. The handler’s incomplete application which was not identified as a noncompliance by GCIA was lacking information as follows:

a. The facility purges equipment, but there was no information on the purge procedure. b. Records are kept of pesticides applied, but did not include information on what

pesticides had been or would be applied; c. Requested a description of the lot numbering system but the OSP did not contain one; d. Did not include information on what, if any, monitoring activities are conducted and

the frequencies at which they were to be conducted. OSPs include sections for operations to list material inputs used or intended for use; however, operations in many cases are not listing specific brand names. The design of OSPs does not allow operations to provide sufficient information for GCIA to evaluate inputs for compliance. Specifically:

e. Whether the input is listed by OMRI, WSDA, EPA and/or GCIA; f. Where the material input will be used; g. Whether there are restrictions associated with the use of the material input.


2016 Corrective Action: GCIA updated its Administration and Policy Manual to include a requirement that the Administrative Assistant assess applications for completeness using the Organic Audit Trail checklist. Incomplete applications will be sent a notice of noncompliance by the Administrative Assistant. GCIA also updated its Crop, Livestock, and Processor/Handler Materials Input Inventory forms to include an area for reviewers to note whether the material is allowed or restricted, and the name of the organization that has approved the material. GCIA developed a training agenda to address the change in policy, and plans to conduct staff training later this year. NP5257MMA.NC2 – Accepted. 7 CFR §205.402(b)(1-2) states, “The certifying agent shall within a reasonable time: (1) Review the application materials received and communicate its findings to the applicant; (2) Provide the applicant with a copy of the on-site inspection report, as approved by the certifying agent, for any onsite inspection performed.” NOP 2609, Unannounced Inspections, Section 4.1.7 states, “An inspection report must be written by the inspector, sent to the client, reviewed by the certifying agent, and the results communicated to the clients pursuant to §205.403(e), §205.404(a), and the certifying agent’s internal protocols.” Comments: Unannounced inspection reports are not reviewed for compliance, and the inspected operations are not informed of the results of the inspection. Additionally, the unannounced inspection reports reviewed do not contain the following facts allowing a reviewer to fully understand the context of the inspection and determine compliance:

a. Purpose or scope of the unannounced inspection. b. Whether advance notice was given to the operator and how much advance notice was

given. c. The name of the operation’s representative. d. Whether a pesticide residue sample was obtained or applicable to the inspection.

2016 Corrective Action: GCIA updated their Policy and Procedures for Conducting Unannounced Inspections of Certified Organic Operations, which will be added to the Administration and Policy Manual. GCIA’s policy requires the inspector to prepare an inspection report, which will be reviewed by the Program Manager and then sent to the client. GCIA’s Unannounced Inspection Report was updated to include the missing items noted by the auditor. The Program Administrator will train staff on the updated policy and procedures upon approval by the NOP. NP5257MMA.NC3 – Accepted. 7 CFR §205.403(c)(1-3) states, “The on-site inspection of an operation must verify: (1) The operation's compliance or capability to comply with the Act and the regulations in this part; (2) That the information, including the organic production or handling system plan, provided in accordance with §§205.401, 205.406, and 205.200, accurately reflects the practices used or to be used by the applicant for certification or by the certified operation; (3) That prohibited substances have not been and are not being applied to the operation through means which, at the discretion of the certifying agent, may include the collection and testing of soil; water; waste; seeds; plant tissue; and plant, animal, and processed products samples.” Comments: During the witness audit of a handling operation the inspector did not verify all areas as required by the standards. Areas not reviewed and/or verified during the witness audit


included: Product which was exported to Canada (Wheat Grass Powder); the pre-weigh and work in progress areas of the handling operation; and the cleaning materials used to ensure they were the same as those included in the OSP. During the witness audit of the crop operation there were a large number of input materials not listed on the Organic System Plan (OSP) and there were a number of input materials on the OSP that were not clearly identified (i.e. brand names) making it difficult for the inspector to verify compliance during the inspection. The inspector did not verify compliance for all of the input materials found on the farm. 2016 Corrective Action: GCIA updated its Crop, Livestock and Processor/Handler OSPs, Audit Reports, and Certification Decision Checklists to include questions to verify whether the operation exports its products. GCIA also updated its Material Input Inventory form to include areas for the operation to specify the brand name, for the reviewer to note how the material is listed, and to note whether it is restricted. Inspectors will compare the materials listed on the operator’s Materials Input Inventory form with application records and materials in storage during the onsite inspection. Materials not listed will be noted in the inspection report and evaluated. Training will be provided to all staff on the updated forms during the training scheduled for later this year. NP5257MMA.NC4 – Accepted. 7 CFR §205.403(d) states, “The inspector must conduct an exit interview with an authorized representative of the operation who is knowledgeable about the inspected operation to confirm the accuracy and completeness of inspection observations and information gathered during the on-site inspection. The inspector must also address the need for any additional information as well as any issues of concern.” Comments: The following “issues of concern” were not addressed by the inspector during the witness audit of a crop operation:

a. §205.201(1-2) There were significant sections of the OSP that were incomplete and although the majority of the missing information was collected by the inspector during the inspection, this issue of concern was not identified during the exit interview.

b. §205.206(d) Erosion control. The inspector and operator briefly discussed erosion and determined that there was none; however, inside the entrance to the production parcel, significant erosion is present and was not identified as an issue of concern during the exit interview.

2016 Corrective Action: The GCIA Program Administrator plans to provide training to the inspection staff about how issues of concern should be addressed at the exit interview during the training scheduled for later this year. NP5257MMA.NC5 – Accepted. 7 CFR §205.403(e)(1) states, “At the time of the inspection, the inspector shall provide the operation's authorized representative with a receipt for any samples taken by the inspector.” Comments: For three out of three files reviewed by the auditor, there was no record to verify that the operation was provided a receipt for the samples collected. An interview of the inspector responsible for sample collecting confirmed that no receipt is provided to operators at the time of inspection; instead, the GCIA inspector stated that he photocopies the collection record and sends it to the operation after the inspection.


2016 Corrective Action: GCIA developed a carbon copy Collection Sample Receipt so that a copy of the receipt can be left with the operator at the time of the inspection. The GCIA Program Administrator will provide training to staff on the proper use of the new form. NP5257MMA.NC6 – Accepted. 7 CFR §205.403(e)(2) states, “A copy of the on-site inspection report and any test results will be sent to the inspected operation by the certifying agent.” Comments: Unannounced inspection reports are not sent to the operations inspected by GCIA. 2016 Corrective Action: GCIA updated the Administration and Policy Manual to include a requirement for the Administrative Assistant to send a copy of the unannounced inspection report to the inspected operation. The policy states, “Upon completion of audits clients will be sent a copy of the completed audits and /or test results, to include but not limited to on-site, unannounced and required sampling audits.” The Program Administrator will provide training to the Administrative Assistant on the updated policy. NP5257MMA.NC7 – Accepted. 7 CFR §205.404(b) states, “The certifying agent must issue a certificate of organic operation which specifies the: (1) Name and address of the certified operation; (2) Effective date of certification; (3) Categories of organic operation, including crops, wild crops, livestock, or processed products produced by the certified operation.” NOP 2603, Organic Certificates, Section 3.1 states, “Organic certificates should be issued in English and include the following (* identifies elements required by 7 CFR §205.404 of the USDA organic regulations): 1. Certified operation’s name (all legal names) and address(es), including a physical address if the mailing or legal address is not the physical location of the operation*; 2. Certifying agent’s name, address, Web site, and phone number*; 5. Anniversary date (when the certified operation must submit its annual update); 9. The statement, “Certified to the USDA organic regulations, 7 CFR Part §205.” This differentiates USDA organic products from those certified to other organic standards; and 10. The statement, “Once certified, a production or handling operation’s organic certification continues in effect until surrendered, suspended or revoked.” Comments: Seven organic certificates issued by GCIA were reviewed. None of the seven GCIA certificates issued included GCIA’s website; an anniversary date; the statement, “Certified to the USDA organic regulations, 7 CFR Part 205”; or the statement, “Once certified, a production or handling operation’s organic certification continues in effect until surrendered, suspended, or revoked.” Two of the seven certificates reviewed had a post office box and did not include a physical address of the operations. Two certificates issued to livestock operations stated “Organic Poultry Certificate” as opposed to livestock; and two certificates issued to crop operations stated “Organic Farm Certificate” as opposed to crop. 2016 Corrective Action: GCIA developed new certificate templates that comply with the requirements of NOP 2603. Training on NOP 2603 will be conducted during the training scheduled for later this year. NP5257MMA.NC8 – Accepted. 7 CFR §205.405(d)(1-3) states, “A notice of denial of certification must state the reason(s) for denial and the applicant's right to: (1) Reapply for certification pursuant to §205.401 and §205.405(e); (2) Request mediation pursuant to §205.663 or, if applicable, pursuant to a State organic program; or (3) File an appeal of the denial of certification pursuant to §205.681 or, if applicable, pursuant to a State organic program.”


Comments: The only denial of certification issued by GCIA was not in accordance with the requirements. The notice of denial of certification issued to the applicant did not include an applicant’s right to reapply for certification at any time with any certifying agent; the right to request mediation; or the applicant’s right to appeal. 2016 Corrective Action: GCIA updated its Denial of Certification template to include the option to reapply for certification at any time to any certifier, as well as request mediation or file an appeal. NP5257MMA.NC9 – Accepted. 7 CFR §205.406(c) states, “If the certifying agent has reason to believe, based on the on-site inspection and a review of the information specified in §205.404, that a certified operation is not complying with the requirements of the Act and the regulations in this part, the certifying agent shall provide a written notification of noncompliance to the operation in accordance with §205.662.” Comments: GCIA is not properly reviewing files and identifying noncompliances to the standards.

a. A review of labels in one file verified that GCIA was allowing the use of non-organic pork casings by a handler without requiring the handler to verify that organic pork casings were not commercially available. The same label did not identify the celery powder as organic. A further review verified that the celery powder was included on the Organic Product Profile as “Veg Stable 504”. Documents provided by the handler for the Veg Stable 504 verified the “Ingredient Declaration:” for the product was “Celery Powder (or Natural Flavors), Sea Salt and Silicon Dioxide (anti-caking)."

b. There were four files reviewed for labeling requirements for products labeled as “100 percent organic” or “organic”. In one handler’s file there were ten labels which did not have the “Certified Organic by” statement under the handlers name and in one of the ten the statement was above the handler’s name.

c. Three GCIA “Made with organic…” labels did not meet the requirements for properly identifying organic ingredients. The “Made with organic…” labels approved for a handling operation stated “Made with organic ingredients” on the principle display panel and did not specify which ingredients or groups are organic, thus implying all ingredients are organic.

d. GCIA did not ensure that one handling operation’s pest control measures were in accordance with the requirements. The handling operation was fogging their warehouse where incoming raw materials are stored. This activity was taking place on a weekly basis between production runs (on weekends) and had been going on for the last year due to a moth infestation. While the practice was acceptable to contain the infestation at first; it was currently being conducted as a preventative measure without considering employing the practices required in 205.271(a), (b), or (c) of the Final Rule.

e. There was no evidence that a minor issue or noncompliance was issued to the operation when the unannounced inspection report noted an “Identified concern” for failure to document attempts to acquire organic seed. ‘


2016 Corrective Action: a. GCIA updated its Certification Decision Checklist forms to ensure that documentation

of commercial availability is submitted when needed. GCIA contacted the client regarding the pork casings, and required the operation to demonstrate commercial availability. GCIA also contacted the client regarding the celery powder, which was reformulated without the use of silicon dioxide. GCIA will train staff on label review and ingredient verifications during the training scheduled for later this year.

b. GCIA contacted the client in regards to the incorrect placement of the “Certified Organic by ***” statement, and a new compliant label template was approved. The Program Administrator will train staff on the proper placement of the “Certified Organic by ***” statement using the NOP Policy Memorandum PM12-2, and regulations as references during the training scheduled for later this year.

c. GCIA contacted the client in regards to the incorrect “Made with organic…” statement. Updated labels with a compliant statement were submitted to GCIA. The Program Administrator will provide training to staff on the “Made with organic…” labeling requirements during the training scheduled for later this year.

d. A letter of noncompliance was issued on Sept 24, 2015 to the operation. The client responded on Oct. 23, 2015 and stated that all preventive fogging had stopped, and a new SOP for pest control was submitted to GCIA. Training on pest control standards was added to the training agenda, and an emphasis will be on the importance of using allowed and/or restricted materials as a last step control during the training scheduled for later this year.

e. GCIA will address identified concerns and issue noncompliances using the Notice of Noncompliance Form. They will enhance their review process with additional training and assigning follow up duties to the Administrative Assistant.

NP5257MMA.NC10 – Accepted. 7CFR §205.501(a)(4) states, “A private or governmental entity accredited as a certifying agent under this subpart must: (4) Use a sufficient number of adequately trained personnel, including inspectors and certification review personnel, to comply with and implement the organic certification program established under the Act and the regulations in subpart E of this part.” Comments: Inspectors conducting unannounced inspections are not aware of the unannounced inspection protocols. Two GCIA inspectors were interviewed and asked about the four hour advance notice that is allowed in NOP 2609, Unannounced Inspections, and they were not aware that any advance notice was allowed. In one of the unannounced inspection reports reviewed, “NA” was marked by the inspector for “maintaining or improving the natural resources.” This requirement (§205.200) is applicable to all operations including handler/processor operations. 2016 Corrective Action: GCIA will conduct training on unannounced inspections and NOP 2609 for inspectors and staff. GCIA will also train inspectors and staff that processor/handlers also must comply with 205.200 as it relates to “maintaining or improving the natural resources”. NP5257MMA.NC11 – Accepted. 7 CFR §205.501(a)(8) states, “A private or governmental entity accredited as a certifying agent under this subpart must: (8) Provide sufficient information to persons seeking certification to enable them to comply with the applicable requirements of the ACT and the regulations in this part.” NOP 2609, Unannounced Inspections, Section 4.1.13


states, “A certifying agent should clearly disclose the protocols for unannounced inspections to certified operations.” Comments: GCIA has not established written procedures or instructions to inform operations when immediate updates to the OSP are required to be submitted. For example, there are no written instructions provided to operations on how to obtain approval or determine compliance of material inputs. GCIA also does not have a written procedure to disclose the protocols regarding unannounced inspections to operations as specified in NOP 2609. 2016 Corrective Action: GCIA updated their Crop, Livestock, and Processor/Handler OSP’s to include instructions to operators that changes to their OSP must be submitted to GCIA for review. OSP templates were submitted. GCIA developed Appendix B “Policy and Procedures for Conducting Unannounced Inspections of Certified Organic Operations,” and added it to the Administration and Policy Manual. The Program Administrator will train staff on the new documents after approval of the NOP. NP5257MMA.NC12 – Accepted. 7 CFR §205.501(a)(21) states “A private or governmental entity accredited as a certifying agent under this subpart must: (21) Comply with, implement, and carry out any other terms and conditions determined by the Administrator to be necessary.” NOP 4009, Who Needs to be Certified states, “When organically producing or handling agricultural products, a certified operation may not: Allow an uncertified operation to produce or handle agricultural products, under contract or other arrangement, on the uncertified operation’s land or premises.” 7 CFR §205.100(a) What has to be certified states, “Except for operations exempt or excluded in §205.101, each production or handling operation or specified portion of a production or handling operation that produces or handles crops, livestock, livestock products, or other agricultural products that are intended to be sold, labeled, or represented as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s))” must be certified according to the provisions of subpart E of this part and must meet all other applicable requirements of this part.” Comments: GCIA allows uncertified operations to produce or handle organic agricultural products for certified operations. A review of the files verified that two operations had organic agricultural products produced and/or handled at uncertified locations and by uncertified operations. The certification of one livestock operation included five uncertified sites with pullet and layer houses under contract to produce eggs for the certified operation. A review of a crop file verified that pecans were being transported from the certified crop operation to an uncertified cleaning facility and then transported to the certified handling operation for shelling. A memo was completed September 16, 2015 (during the assessment) stating that the cleaning operation was inspected as part of the handler’s inspection in 2014, and that the cleaning and supervision of the facility and equipment would be inspected by the owner of both the certified sheller and the certified farm. There was no record of the cleaning operation being inspected during the 2014 or the 2015 inspections, nor was the cleaning operation included in the OSP of the certified client.

2016 Corrective Action: GCIA responded that each of the poultry facilities has an OSP, was inspected, and will be issued a separate certificate. The cleaning facility was leased by the certified operator and is now included in the certified operator’s OSP with a lease agreement. The certified operator cleans the facility before processing the organic pecans. GCIA’s Program


Administrator will provide additional training to staff during the training scheduled for later this year. NP5257MMA.NC13 – Accepted. 7 CFR §205.501(a)(21) states “A private or governmental entity accredited as a certifying agent under this subpart must: (21) Comply with, implement, and carry out any other terms and conditions determined by the Administrator to be necessary.” NOP Memo, RE: Exporting USDA Organic Products to the European Union states, “This memo provides instructions for NOP-accredited organic certifying agents per §205.501(a)(21) to ensure that organic products exported to the EU meet the terms of the trade partnership. Labeling, Bulk Products, Lot number must be present that allows for a complete audit trail to verify the product’s integrity.” Comments: GCIA was not verifying the labeling requirements for bulk organic products exported to the EU. A review of an EU Certificate of Inspection and the documents which accompanied the certificate from a handling operation verified there was no lot number present to allow for a complete audit trail and to verify the product’s integrity. The organic pecan halves were exported to Denmark in 30 pound bulk cases. 2016 Corrective Action: GCIA developed Appendix C “Policy and Procedure for Reviewing and Verifying the Terms of US and Other Countries Organic Equivalency Arrangements,” and added it to the Administration and Policy Manual. The procedures require staff to note which operations plan to export products, and verify that the terms of the applicable trade agreement are met. The Program Administrator will provide training to staff utilizing the May 25, 2012 Exporting USDA Organics Products to the European Union and NOP website resources. NP5257MMA.NC14 – Accepted. 7 CFR §205.504(b)(1) states, “A private or governmental entity seeking accreditation as a certifying agent must submit the following documents and information to demonstrate its expertise in organic production or handling techniques; its ability to fully comply with and implement the organic certification program established in §§205.100 and 205.101, §§205.201 through 205.203, §§205.300 through 205.303, §§205.400 through 205.406, and §§205.661 and 205.662; and its ability to comply with the requirements for accreditation set forth in §205.501: (b) Administrative policies and procedures. (1) A copy of the procedures to be used to evaluate certification applicants, make certification decisions, and issue certification certificates.” Comments: GCIA does not have documented procedures or processes in place for reviewing and verifying the terms of the EU – U.S. Organic Equivalency Arrangement or the U.S. – Canada Organic Equivalency Arrangement. GCIA does not have written procedures and sufficient records to demonstrate whether all inputs used or intended for use by operations are compliant with USDA organic regulations. 2016 Corrective Action: GCIA developed Appendix C “Policy and Procedure for Reviewing and Verifying the Terms of US and Other Countries Organic Equivalency Arrangements,” and added it to the Administration and Policy Manual. The policy and procedures provide guidance to the inspector, reviewer and Administrative Assistant to determine whether the terms of the applicable trade agreement are met. GCIA staff are required to note which operations plan to export products, and then use Appendix C to verify compliance.


NP5257MMA.NC15 – Accepted. 7 CFR §205.510(b)(2) states, “Certifying agents must maintain records according to the following schedule: (2) Records created by the certifying agent regarding applicants for certification and certified operations must be maintained for not less than 10 years beyond their creation.” Comments: For one of the three files reviewed by the auditor for pesticide residue samples collected, there was no documentation or record for the auditor to verify that the sample activity occurred. The records did not provide details of the sample collection to determine compliance.

2016 Corrective Action: GCIA developed a carbon copy Collection Sample Receipt so that a copy can be left with the operator at the time of the inspection. The receipt includes information regarding the sample collection, source and time. The Program Administrator will provide training to staff on the proper use of the new form. NP5257MMA.NC16 – Accepted. 7 CFR §205.662(c) states, “When rebuttal is unsuccessful or correction of the noncompliance is not completed within the prescribed time period, the certifying agent … shall send the certified operation a written notification of proposed suspension or revocation of certification…” Comments: In one of seven notices of noncompliance which were reviewed, GCIA gave a handling operation until December 21, 2014 to address the noncompliance. There was no response from the operation and no follow up by GCIA. 2016 Corrective Action: GCIA updated its Administration and Policy Manual to require that the Administrative Assistant follow up on notices of noncompliances issued in order to ensure timely follow-up occurs. NP5257MMA.NC17 – Accepted. 7 CFR §205.662(c)(1-4) states, “The notification of proposed suspension … of certification shall state: The reasons for the proposed suspension or revocation; The proposed effective date of such suspension or revocation; The impact of a suspension or revocation on future eligibility for certification; and The right to request mediation pursuant to §205.663 or to file an appeal pursuant to §205.681.” Comments: GCIA is accepting corrective actions after issuing operations a notification of proposed suspension. 2016 Corrective Action: GCIA is no longer accepting corrective actions once a Notice of Proposed Suspension is issued. GCIA updated its Notice of Proposed Suspension letter template to only include options of appealing or requesting mediation. A copy of the Notice of Proposed Suspension was submitted.


NP4057JHA GCIA May 30, 2014 Page 1 of 3

NATIONAL ORGANIC PROGRAM REPORT AUDIT AND REVIEW PROCESS On February 26-27, 2014, the USDA National Organic Program (NOP) conducted a compliance audit of the Georgia Crop Improvement Association, Inc. (GCIA). GCIA responded with corrective actions on May 1 and May 20, 2014. GENERAL INFORMATION

Applicant Name: Georgia Crop Improvement Association, Inc. (GCIA)

Est. Number: N/A

Physical Address: 2325 South Milledge Avenue, Athens, Georgia 30605

Mailing Address: 2325 South Milledge Avenue, Athens, Georgia 30605

Contact & Title: Terry Hollifield, Executive Director

E-mail Address: [email protected]

Phone Number: (706) 542-2351

Auditor(s): Betsy Rakola

Program: USDA National Organic Program

Audit Date(s): May 1-20, 2014

Audit Identifier: NP4057JHA

Action Required: No

Audit Type: Corrective action review

Audit Objective: To verify continuing compliance to the audit criteria; and to verify the implementation and effectiveness of corrective actions in addressing the previous noncompliances.

Audit Criteria: 7 CFR Part 205 National Organic Program, Final Rule, dated December 21, 2000; as amended

Audit Scope: GCIA’s corrective actions

Location(s) Audited: GCIA office in Athens, Georgia GENERAL INFORMATION: GCIA was accredited as a USDA organic certifying agent on April 29, 2002, for crops, livestock, and handling operations. The GCIA list of certified operations include 88 certified operations, consisting of 39 crop operations, 1 livestock




operation, and 48 handlers. There are no grower groups certified by GCIA. The certified operations are located in Alabama, Florida, Georgia, and North Carolina. The GCIA office is located in Athens, Georgia, and all certification activities are finalized in this office. All staff are full-time employees based out of the Athens office, and they all conduct other duties for GCIA in addition to their work for the organic certification program. A renewal assessment of the GCIA organic program was conducted in October 2012, and as part of the terms of accreditation. GCIA agreed to an additional audit to be conducted prior to the required mid-term assessment. NOP DETERMINATION NOP’s assessment and accreditation decision of GCIA’s compliance to the USDA organic regulations is based on a sample of its certification system records and activities. This section describes the NOP’s review and determination of the certifying agent’s noncompliance response. The NOP has accepted the corrective actions. During the next on-site audit, the NOP will verify corrective actions for implementation and effectiveness.

Prior Non-compliance Corrective Actions The NOP auditor reviewed information during the assessment to verify that the certifying agent effectively implemented the corrective actions from previous assessments. The auditor was able to verify all the items below which are labeled “cleared.” One noncompliance was not cleared, NP2296MMA.NC4, and therefore certifying agent was required to address those issues by providing revised corrective actions to the NOP. NP2296MMA.NC1 – cleared NP2296MMA.NC2 – cleared NP2296MMA.NC3 – cleared NP2296MMA.NC5 – cleared NP2296MMA.NC6 – cleared NP2296MMA.NC7 – cleared NP2296MMA.NC8 – cleared NP2296MMA.NC9 – cleared AIA030613BJR.NC10 – cleared AIA13311RAM.NC1 – cleared

Non-Compliances – Certifier Response Accepted Observations made, interviews conducted, and procedures and records reviewed verified that GCIA is currently operating in compliance to the requirements of the audit criteria, except as identified below. One new noncompliance was identified during the compliance assessment.


NP4057JHA.NC1 – Accepted. NOP §205.662(c)(2) states, “The notification of proposed suspension or revocation of certification shall state: The proposed effective date of such suspension or revocation.” While the GCIA Notices of Proposed Suspension (NoPS) describe effective dates of a suspension, within 3 of 4 NoPS reviewed, the suspension effective date is in effect from the date of receipt of the NoPS. The notices state that the operation is suspended upon receipt of the NoPS for an identified time period. The NoPS also stated that after the suspension period is completed, the operation may be issued a Notice of Indefinite Suspension. The implication is that the NoPS had the same impact as a suspension, and that a possible result of a Notice of Proposed Suspension may be the issuance of an indefinite suspension where the suspension period is for an unidentified length of time. GCIA corrective action (May 2014): GCIA stated that the indefinite suspension template is no longer in use. GCIA submitted a sample of a Notice of Proposed Suspension, which included the following improvements:

1. The proposed effective date was clearly listed as one month after the date of the letter. 2. The proposed timeframe was clearly stated as six months. 3. There was no reference to an indefinite suspension.

GCIA reviewed this procedure with the responsible staff during the exit interview with the NOP auditor. NP2296MMA.NC4 – Accepted. NOP §205.405(a)(1) states, “When the certifying agent has reason to believe, based on a review of the information specified in §205.402 or §205.404, that an applicant for certification is not able to comply or is not in compliance with the requirements of this part, the certifying agent must provide a written notification of noncompliance to the applicant…The notification of noncompliance shall provide a description of each noncompliance.” Three notifications of noncompliance issued to applicants for certification were reviewed. Of the three, one did not include a description of the noncompliances. Instead, the notification stated what the client had to submit in order to correct the noncompliance. Corrective action: GCIA submitted a revised template, which contained a space to insert descriptions of the noncompliance. GCIA also submitted a Notice of Noncompliance issued in February 2013, showing references to the USDA organic regulations and descriptions of each noncompliance at issue. The GCIA Program Administrator will review all Notices of Noncompliance during the next six months to ensure correct implementation of the new procedures. Verification of corrective action (February 2014): GCIA is using its current Notice of Noncompliance template, providing a description of evidence why the regulation has been violated, and citing the USDA organic regulation number, but not a description of the regulation. For one file reviewed, the reasons described for the noncompliances were not clearly associated with regulation numbers cited. GCIA corrective action (May 2014): GCIA submitted a revised Notice of Noncompliance template, which included spaces for staff to type the relevant regulatory references. All noncompliance notices are issued by one staff member at GCIA. The GCIA Program Administrator will continue to review noncompliance letters for accuracy.


AUDIT INFORMATION

Applicant Name: Georgia Crop Improvement Association, Inc. (GCIA)

Est. Number: N/A

Physical Address: 2425 South Milledge Avenue, Athens, GA 30605

Mailing Address: Same

Contact & Title: Terry Hollifield, Executive Director

E-mail Address: [email protected]

Phone Number: 706-542-2351

Auditor(s): Miguel A. Caceres (ARC)

Program: USDA National Organic Program (NOP)

ARC Audit Date(s): March 18 – June 2, 2010

ARC Audit Identifier: NP9272MMA

Action Required: No

Audit Type: Corrective Action Audit

Audit Objective: To verify that corrective actions adequately address the non-compliances

identified during the Mid-Term audit

Audit Criteria: 7 CFR Part 205, National Organic Program, Final Rule, dated December 21,

2000; revised February 17, 2010.

Audit Scope: The submitted corrective actions

Location(s) Audited: Desk

Reviewer(s): Catherine Cash (NOP)

NOP Review Date(s): November 23, 2010

Georgia Crop Improvement Association, Inc. (GCIA) submitted corrective actions to the NOP which

were received by the auditor on January 8, 2010, addressing the noncompliances identified in the

Mid-Term Audit. Additional corrective actions were requested by the auditor on March 22, 2010 and

submitted by GCIA on April 7, 2010.

The reviewer contacted GCIA on October 22nd, 28th and 29th, 2010 to discuss and request further

corrective actions taken by GCIA regarding noncompliances NP9272MMA.NC1 - 2. On November

4, 2010, GCIA submitted corrective action evidence that adequately addressed all noncompliances.

FINDINGS

The corrective actions submitted by GCIA adequately addressed both of the noncompliances

identified during the Mid-Term Audit.

NP9272MMA.NC1 – Adequately Addressed – NOP §205.501(a)(5) states, “A private or

governmental entity accredited as a certifying agent under this subpart must: Ensure that its

responsibly connected persons, employees, and contractors with inspection, analysis, and decision-

making responsibilities have sufficient expertise in organic production or handling techniques to

successfully perform the duties assigned.” NOP §205.504(a)(4) states, “A private or governmental

entity seeking


accreditation as a certifying agent must submit the following documents and information to

demonstrate its expertise in organic production or handling techniques…(4) A description of any

training that the applicant has provided or intends to provide to personnel to ensure that they comply

with and implement the requirements of the Act and the regulations in this part.” GCIA does not have

a training process in place for training new certification committee members when they are selected

to serve on the voluntary committee. Additionally, there were no training records to verify the part

time inspector was trained to conduct inspections of handling operations. Corrective Action: The

GCIA corrective actions proposal stated that GCIA had a training process and included on what

would be included in the instruction for new certification committee members and for part time

organic inspectors. However, the procedure itself was not submitted for review. The auditor of record

requested additional information and supporting documents to find out other than in the corrective

actions proposal where in the GCIA procedures is the new training procedure for committee

members and part time inspectors and to see if there had been any training conducted or scheduled

since the on-site audit. The GCIA response stated that they will have a sign in sheet and it will be

kept in the folder that contains the training material and no training had been conducted. The

noncompliance remains outstanding because not all of the requested information was provided, there

were no supporting documents for the corrective actions provided, and no training has been

conducted or scheduled since the Mid-Term audit.

Reviewer actions: On October 29, 2010, the reviewer discussed the noncompliance with GCIA

staff.

On November 4, 2010, GCIA submitted GCIA’s updated Quality Manual for Organic Certification

and Program Administration and Policy Manual, each of which reference training for inspectors and

committee members. GCIA also included training documentation that indicated that staff had

undergone trainings in January 2010 and August 2010. The modifications to the Quality and Program

Manuals, coupled with inspector training documents, fully address the noncompliance.

NP9272MMA.NC2 – Adequately Addressed – NOP §205.504(b)(6) states, “A private or

governmental entity seeking accreditation as a certifying agent must submit… (6) A copy of the

procedures to be used for sampling and residue testing pursuant to §205.670.” GCIA does not have

procedures in place for sampling soil, tissue, and/or product for residues. Corrective Action: The

GCIA corrective actions proposal stated that when there is a need or a requirement to sample soil,

tissue, and/or product for residues, GCIAOCP will contact an acceptable entity and/or approved

accredited laboratory for proper sampling and testing protocol. The auditor of record sent GCIA an

email requesting additional information and informed GCIA that there must be sampling procedures

in place so that samples can be collected should the NOP direct GCIA to collect samples or the need

should arise during an inspection. The GCIA response stated, “Sorry but I don’t know what to do

here. The possibilities of what “may” need to be sampled or endless. Anything from soil to air to

compost to leaf tissue. I don’t see how we can have a protocol for every possible thing. I still think

our reply is on target. If soil samples are needed, we contact the soil analysis lab for protocols. If leaf

tissue needs sampling we contact the laboratory for their sampling protocols.” The noncompliance

remains outstanding because there were no actual corrective actions provided.

Reviewer actions: On October 29, 2010, the reviewer discussed the noncompliance with GCIA

staff.

On November 4, 2010, GCIA submitted GCIA’s updated Quality Manual for Organic Certification

and Program Administration and Policy Manual, each of which reference procedures for sampling

and residue testing. The sampling guidelines provide detailed information including sampling

methods, sample selection criteria and lab location. The modifications to the Quality and Program

Manuals fully address the non-compliance.

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