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.

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.

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”.

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

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

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

Relative Importance of Criteria In principle all ‘A’ Requirements must be fulfilled for certification Additionally, a certain percentage of ‘B” requirements should be 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’ requirements need to be fulfilled in medium term; i.e. a certain timeframe has to be set for fulfilling these requirements. B C

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.

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?

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.

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.

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.

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?

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.

Reporting to the Certifier Inspection report (computerized/more comments included) Checked farmers list APPENDICES

Certificate for the group Certification Organic Certificate + Certified farmers list (‘original’; i.e. with stamp, signature, date) Certificate for the group Group XXX Adress - 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