Objectives of External Farm Re-Inspections 5. External Farm Re-Inspections & Witness audits 1 Objectives of External Farm Re-Inspections Assess the efficiency of the internal inspection - have they detected everything? Assess quality of ICS (documentation, staff qualification, etc.) Risk assessment Cross-check different information with the farmer and others Training Manual on the Evaluation of Internal Control Systems

Information Collected during Re-Inspections 5. External Farm Re-Inspections & Witness audits 2 Information Collected during Re-Inspections Has the farmer complied with the external and internal production standard? Does the farmer know the inspector and confirm that he has been inspected? Is farmer aware of his/her obligations and trained in organic farming? Are the findings of the inspector the same as findings of the internal inspector? Are all critical issues thoroughly checked by ICS? How well have the results of the internal control been documented? Qualification of internal inspectors & extensionists Cross-check with purchase data Does the documentation (maps, field data, yield estimates) reflect reality? Are the defined ICS procedures really implemented (e.g., thorough & complete annual inspection with interview) Assessment of other control mechanisms Training Manual on the Evaluation of Internal Control Systems

Number of farms to be re- inspected 5. External Farm Re-Inspections & Witness audits 3 How to Select Farmers for Re-inspection? Number of farmers at each site, any new farmers? How many project sites? (different region, different crops?) any new sites? How many centers of internal control? How many internal inspectors? New inspectors? Risk assessment of different sites/crops Sanctioned farmers? Critical farmers (big farmers, conventional unit, etc.)? Problems identified in previous inspections Planned Number farms/site (inspect each site) Some random choice Some critical cases All big farms Number of farms to be re- inspected Farmers lists, ICS reports ICS manual/project overview, risk assessments Training Manual on the Evaluation of Internal Control Systems

Important Aspects of Planning Re-Inspections 5. External Farm Re-Inspections & Witness audits 4 Important Aspects of Planning Re-Inspections Since the aim is mainly to assess the ICS, you need sufficient time for the inspection and other related sources of information  don’t plan to do more than 5-7 inspections/day (even if close to each other) It is crucial that you chose the “right” farmers, so you need to plan carefully and try to find all potentially critical aspects beforehand. Then you can be more focused during the inspections Possibly you need to revise your risk assessment and plans during the course of the inspection, so you also need to be a bit flexible. After having inspected only very few farmers yourself, you need to feel confident that 100% of all farmers comply with the regulations... Training Manual on the Evaluation of Internal Control Systems

Re-Inspection Procedures 5. External Farm Re-Inspections & Witness audits 5 Re-Inspection Procedures “Normal” Farm Inspection: Visit farm, storage, processing Interview the farmer Check farmer’s documentation Assessment of the Internal Control Cross-check with internal documentation Cross-check with results of the internal inspection Try to understand the “real” ICS procedures, possibly with witness audit(s)  Was the internal inspection complete & thorough ? Other sources of information for evaluation of the ICS: neighbors, marketplace, village leaders, etc. agrochemical stores Training Manual on the Evaluation of Internal Control Systems

Farm Re-Inspection Visit to organic fields (selection of fields) 5. External Farm Re-Inspections & Witness audits 6 Farm Re-Inspection Visit to organic fields (selection of fields) Visit to conventional fields (spot checks), check buffer zones Interview with the farmer Evaluation of the internal farm documentation in the farm file Check farm boundaries Brief evaluation of animal husbandry Evaluation of harvest and post- harvest activities as well as storage Evaluation of input storage, sprayers, garbage pits around the house, etc. Fill in sample farm inspection report form Training Manual on the Evaluation of Internal Control Systems

ICS Evaluation during Re-Inspections 5. External Farm Re-Inspections & Witness audits 7 ICS Evaluation during Re-Inspections Take the internal inspector and preferably also the extensionist with you on at least some of your re- inspections Find out how much they know about the farm’s activities, how familiar they are with the internal standard. Cross-check your own findings with the internal documentation, incl. farmers list, with the internal checklist and with the oral info from internal inspectors. Also cross-check with, e.g., buying lists of ICS. Has the farmer been trained and knowledgeable about organic production? Does he/she know the requirements? Training Manual on the Evaluation of Internal Control Systems

Important Aspects of Re-Inspections 5. External Farm Re-Inspections & Witness audits 8 Important Aspects of Re-Inspections Try to find out as much as you can about the ICS and other social control mechanisms and how things really work. Try to find where the system is still weak and where this could potentially cause problems. You have seen a few farmers; find out whether the situation is really the same for other registered farmers in the area or whether some farmers in same area might have different problems, of which the ICS is not yet aware (e.g., conventional intercrops). Be thorough during the farm inspection; only then you can find out whether the ICS was also thorough. The higher the risk on farm level, the more detail you should investigate (ask detailed questions about all intercrops, etc.) Training Manual on the Evaluation of Internal Control Systems

The Farm Re-inspection Report Form 5. External Farm Re-Inspections & Witness audits 9 The Farm Re-inspection Report Form FARM RE-INSPECTION REPORT (SAMPLE INSPECTION REPORT) The ‘Farm Re-inspection Report Form’ is filled out for each re- inspected farmer. Farmer Name, village Farmers code ICS Operator External inspector Date Inspection Internal Inspector Standards according to which certification is proposed by ICS Persons present during inspection Regulation 2092/91 NOP Farmer Field Officer Other: Others Area Organic Cash Crop N° plots Products. CROPS to be certified (intercrops) Organic status Area other crops org. managed Crops. Comments Area Nonorganic Unit Crops TOTAL FARM AREA The form contains all details of a “regular” farm inspection plus evaluation of the internal control for this farmer. Control Point Part Conversion Farms OK PF NF n.r. 15.1 There is no parallel production 15.2 There is sufficient separation between organic and nonorganic fields of the farmer 15.3 Conventionally managed crops are not grown on the organic fields (e.g. intercropped) Description Fertilisation (org. managed fields) Yes No Comments Livestock Manure used Composted? External Product Fertilisation Manufacturer/supplier/specification Quantity (kg/yr) Permitted? YES NO A B Description Pest Management (org. managed fields) Yes No Description Pest Management Yes No External inputs used for pest and disease management Home made preparations Product or preparation Manufacturer/supplier/specification Crop/Quantity (kg/yr) Permitted? YES NO A B C Planting Material Crop (seed/plant) Quality (organic, nonorganic, GMO treated) free Details (treatment, origin, attempts to obtain organic propagation material, GM declaration) A B C Control Point Contamination OK PF NF n.r. There is no pesticide drift from neighbouring farmers Spraying equipment is used ONLY for organic treatments (or carefully cleaned) There are no unallowed inputs stored on the farm (except if there is nonorganic unit & clear separation input storage) Other contamination sources (malaria eradication programmes, heavy pollution): omments Training Manual on the Evaluation of Internal Control Systems

5. External Farm Re-Inspections & Witness audits 10 Witness Audits The external inspector accompanies an internal inspector and witnesses a complete internal inspection: Preparation Complete farm inspection with field visit and interview Filling in the report, reporting results to the office Training Manual on the Evaluation of Internal Control Systems

What Can We Find Out in Witness Audits? 5. External Farm Re-Inspections & Witness audits 11 What Can We Find Out in Witness Audits? How familiar and confident is inspector with documentation? How thorough are the internal inspections? Knowledge of organic requirements Do the inspections cover all aspects of organic farming? Is there really an internal inspection? Are inspectors and farmers familiar with the situation? Was an inspector, e.g., weak only in reporting, but thorough in his inspection? Knowledge of organic farming methods and problems of specific crops Training Manual on the Evaluation of Internal Control Systems

How Many Witness Audits Are Needed? 5. External Farm Re-Inspections & Witness audits 12 How Many Witness Audits Are Needed? It is highly recommended that at least a few witness audits be done with internal inspectors to assess the quality of their inspection work. When deciding on how many witness audits should be conducted, the following aspects shall be considered: accompany “weaker” inspectors (poor reports, no sanctions although other inspectors found major deviations, etc.) focus on areas/crops with rather high risks, e.g., with conventional crops are the witness audits useful? Do they provide additional information on the ICS? If yes, do for example one audit per internal inspector in the first year and a few per year the following years Witness audits could count as the external sample inspection (for inspection rate), but certifiers may chose to do witness audits in addition to sample farm inspections. Training Manual on the Evaluation of Internal Control Systems

5. External Farm Re-Inspections & Witness audits 13 Other Sources of Information during a Re-Inspection Tour (same for Risk Assessment) Neighbors (not part of project) Informal information about the organic farmers. Do they know/suspect that not all is as organic as it seems? How do they cultivate the same crops (incl. intercrops) - what inputs do they use? Agrochemicals Village agrochemical store What do farmers commonly use on which crops (critical crops, information what farmers might be tempted to use)? Assessment of what % of all farmers buy agrochemicals (for specific crops) Does the shopkeeper know some organic farmers as customers? Local village soda shop Possibly some informal information about the project or farmers from complete outsiders Training Manual on the Evaluation of Internal Control Systems