1. Inspection of the Internal Control System in the ICS Office
Internal Control System (ICS)
3.2 Description of activities
5.1 ICS structure & responsibilities
5.2 ICS manual
5.3 Internal organic standard
5.4/5.5/5.6 Documented & effective procedures for internal farm inspection, internal approval/sanctions
5.7 Personnel is qualified; no conflicts of interest
5.8 Training of farmers
Numbers refer to the sections and compliance criteria in the ICS report

2. Basic Description of Activities
3.2.1 An overview of the organic operation sites must be available, including a general overview of the farming system and agricultural practices of participating farmers
May be part of the ICS Manual or as separate project description
Description is important because inspector needs this information for a risk-based inspection approach
ICS submits evidence that it is aware of all activities under its responsibility (all activities that will need monitoring)
3.2.2 There must be a description of all the steps that take place from harvest to final sales, including an indication of which entity is responsible for the product at each stage
Make sure to consider all handling activities in the detailed inspection schedule at the beginning of inspection.

3. ICS Organization
5.1.1 ICS operator has an organizational chart or table of responsibilities One person has overall responsibility for the ICS and coordination with the organic certification body.
This position is usually called ICS-Coordinator
He/She can delegate responsibilities so that for each procedure or task of the ICS, one person is in charge.
Coordinates the internal inspection
Coordinates with external certification body
5.1.3 ICS has assigned at least one person to take approval and sanction decisions
Often = ICS coordinator, but may be somebody else; responsibility must be clear
Better if it is more than on person taking the decision

4. Number of Internal Inspectors
5.1.4 There is a sufficient number of inspectors to perform 100% internal inspection each year
Check how many inspectors, average number of farmers inspected by day.
Can the internal inspections be thorough? E.g. if doing 20 inspection per day once a year???
Don‘t forget to also consider time for other duties of inspectors (e.g. extension) when calculating whether capacities are sufficient.
Are 2 inspectors sufficient for inspection & training of 250 farmers?

5. The ICS Manual
5.1.1 There is an ICS manual, i.e. a set of documented policies, procedures and forms for the internal control system (B)
Often not organized as manual, only forms and possibly a few written procedures - OK for first inspection, but missing parts must be defined
If for some activities no written procedures yet - ask about standard practices (whether they have standardized procedures even if not written down)
5.1.2 The ICS manual covers in principles all relevant procedures (and their documentation) (B)
internal organic standard (farm production rules)
farm registration, internal inspection, internal approval/sanctions
selling/buying, product handling
rather general first / rough evaluation of completeness of manual

6. Effective Use of the ICS Manual
5.1.3 Internal ICS staff has up-to-date forms at hand and is aware of the valid ICS procedures as described in the manual (C)
Do they have documents at hand?
Are documents used up to date? (some delay in starting to use a new form is acceptable)
do the ICS staff know their respective procedures (as described in the manual)?
5.1.5 The ICS Manual reflects IN PRINCIPLE the internal procedures (B)
Overall assessment at the end of the inspection.
Small differences are very common, but somehow there must be a link between written procedures and reality.

7. Updating of the ICS Manual
5.1.4 The ICS Manual is reviewed regularly and updated when necessary (B)
e.g., updated each year before start of new season
Manual will need to be changed if internal procedures are modified/improved.
Manual must be changed if major changes in applicable regulations/standards.
Manual may need to be changed because requested by the certifier (certification conditions).
If updating - how is the new document approved and distributed? Version management?
Version 3,

8. What is an ‘Internal Organic Standard’?
Describes the relevant organic farm production requirements
Is a local interpretation of the applicable organic standards „What do our members need to do to be organic farms?“
Takes into consideration all applicable standards and own quality expectations
Is written in simple, practical language in order to be understood by farmers and ICS staff
Prepare compost
No chemical fertiliser
No synthetic pesticides
Control soil erosion

9. The Internal Organic Standard
5.3.1 There is an ‘Internal Organic Standard’ (B)
Sometimes the rules of production are included in the contract. Some parts may even be somewhere else in the ICS manual  important is that the requirements are defined, not in which document.
The term „internal regulation“ (IMO-Naturland ICS Manual) includes the organic production rules (= internal organic standard) but also some procedures, e.g. on registration.
In some cases also the “external” standard can be accepted, if all requirements of the standard are effectively implemented in the ICS and are well known. Usually not suitable.

10. Minimum Content of the Internal Organic Standard
5.3.2 The ‘Internal Organic Standard’ regulates the following aspects:
Organic and non-organic farm units
Soil management & fertilization (incl. inputs)
Plant protection (incl. inputs)
Seeds and planting stock
Prevention of drift (buffers, etc.) and contamination
Livestock husbandry
Post-harvest treatments/processing on the farm
Conversion period
Are at least all minimum requirements of applicable standards (your certifier’s interpretation) included, at least as far as relevant?

11. Principles of Organic Production to be Included in the Internal Organic Standard (1)
NOTE: highly dependent on the applied standard & the certifier’s interpretation of the standard
Organic and Non-organic Production Unit
The farm has to convert all crops & areas to organic farming OR ensure a clear separation of organic and non-organic fields.
All crops on the organic field must be managed organically.
The same organic crops may not be also produced in non-organic quality.
Separation of input storage, prevent any contamination of organic fields.
Sustainable Soil Management
crop rotation, green manure, cover crops, mulching
use of compost (plant residues, livestock manure)
restricted use mineral fertilizers (list in standard)
no chemical fertilizer (e.g., no urea)

12. Principles of Organic Production to be Included in the Internal Organic Standard (2)
Plant Protection and Weed Management
Control of pests, diseases, weeds by appropriate cultivation measures (incl. crop rotation), mechanical measures, protection/propagation of natural enemies
Restricted use of organic pesticides (list in standard), no chemical pesticides
No chemical herbicides, weed control by slashing/hoeing
Organic Seeds or Planting Stock
Organic seeds/planting stock; conventional material only under certain conditions
No GMO
Animal Husbandry (if livestock not certified)
Animal welfare
Organic fodder where possible, no preventive medication, no contamination of organic fields
Harvest and Post-Harvest Procedures
Separation
No contamination

13. Form of the Internal Organic Standard
5.3.3 The internal standard is written in a language and manner that can be clearly understood by all ICS staff (B)
In language of ICS staff?
Clear and okay to read for the ‘typical’ ICS staff?
The (summary of) the internal organic standard is presented to farmers in a language/form that they can be understand.
Summary can be given, e.g., in contract
Simple language? Available in local language?
If farmers are not literate, are the requirements still communicated to them in an appropriate way (illustrations/training)?

14. Understanding the Organic Requirements
5.3.5 All ICS staff is trained, knowledgeable, & competent in implementation of internal standard and internal approval requirements (B)
Even if no formal internal organic standard is yet available, staff awareness of all relevant requirements can be checked.
5.3.6 The internal approval staff is familiar with the overall standard requirements of the external certification standard
Do they have the (external) certification standards available?
Are they familiar with the most important requirements (even if slightly different from internal organic standard)?

15. Exercise: Internal Organic Standard ‘KNCU’
Documents:
Complete ICS manual, incl. contract form
 Evaluate internal organic standard
 Complete inspection report chapter 5.3

16. Minimum Farm Documentation
The following documentation is needed for each farmer. The documentation is usually kept in farm files:
Formal commitment of growers to fulfill the internal standard (written contract)
Basic Farm Data Form / Farm Entrance Form with field history
Updated production information
Maps (if required for single farmer)
Notes on important training or advice given to the farmer by field officer / other important notes from field officers
Annual ‘Farm Inspection Checklist’

17. Summary of the Internal Control
The result of the internal control needs to be resumed as follows:
Farmers List with information on
Name and code of the farmer
Total area and area under organic crop
Date of registration and date of last use of forbidden products
Date of internal inspection and result
Name of internal inspector
List of sanctioned farmers with reason and duration of the sanction
 Are farmers lists complete? Does the information correspond to the information registered in the farmer’s documentation?

18. General Aspects of the ICS Documentation
Because internal control systems are complex and documentation individually designed, the information is not always registered in the same way (in the various documents).
If you do not find the information as shown in a particular form, check if it is available in another document (e.g., the plot list is not registered on the farm entrance form but on the internal checklist each year).
In low-input systems, minor deficiencies in the documentation can be accepted (e.g., if the quantities of inputs are not registered), but the more complex the inputs, the more detail is needed.

19. Evaluation of the ICS Documentation
Ideally ICS forms are available to the inspector before the inspection
Evaluation of the forms usually starts with preparation of the inspection
Assessment is continued during the ICS office inspection when observing how the forms are actually used

20. Exercise: Evaluation of ICS Documentation Case Study I, Coffee Union XXX
Received documents:
Complete ICS manual, incl.
Contract
Farm entrance form
Internal inspection report
- Farmers list (1 sample page)
Evaluate the following documents (overall comments)
 Contract
Internal inspection report form
Farmers list

21. Commitment Declaration/Farmers Contract
5.4.1 & The written contract (commitment declaration) needs to include:
Obligations of the farmer:
to comply with the requirements of the internal organic standard (A)
to give access to the fields, stores and documents (B)
to accept sanctions in case of deviations (B)
Organic Production Rules
summary of internal organic standard or reference to internal organic standard (B)
For each farmer a signed complete contract must be available before buying

22. The Farmers Contract Other aspects often included in the contract
ICS operator to provide advice to the farmers and to co-ordinate the internal and external inspection and to organise the purchase.
Prices, product quality requirements.
Rules for leaving the project / cancellation of contract.
Farmer needs to announce non-conformities of fellow farmers to the ICS.

23. Contract or Commitment Declaration?
Some ICS operators choose to sign the actual contract with farmers only shortly before the farmers reach organic status and their products will be bought.
In this case there needs to be at least a commitment declaration to adhere to organic rules from the beginning of the certification (often in basic farm data form/farm entrance form). This is an A-requirement.
Contract
Commitment declaration in the basic farm data form

24. The Basic Farm Data Form
5.4.3 & The basic farm data form/farm entrance form needs to include:
Registration data of the farmer: name, address, code (A)
Description of all area under management of the farmer (B)
Organic crops and their respective area or number of plants (B)
Number of animals (B)
The date of the last application of prohibited inputs must be recorded for all plots (A)
Plot/area registration is critical. List of all plots may be most appropriate. Sometimes better to describe the situation per crop or to indicate the cropping information in maps.
System must be adapted to the situation and must allow an overview of ALL organic/non-organic fields and crops under management of the farmer ( also fields for non-certified crops)
In many cases it is better to record field history for each plot (crops of past years) than just the last date of application of prohibited inputs

25. Maps
5.4.5 An overview map (village or community map) must be available (A-B)
shows the location of each farm with the code numbers for each farmer
5.4.6 If rotating annual crops are grown or if there is a conventional farm unit, there must be a farm map for each farmer (B)
Needs to show each plot/field and the respective crops
Neighboring fields, their cultivation system, and risks of drift should be indicated
Landmarks and streets/paths should be indicated
Neighboring farms may be combined – if still possible to identify each plot and its crops
All maps must be dated

26. Sample Map

27. Sample Map
Counting each plant might be appropriate in some cases (intercropped agroforestry system)

28. Sample Map

29. Content of the ‘Internal Farm Inspection Report’
5.4.9 The ‘Internal Farm Inspection Report’ covers all certification-relevant farm aspects 
Evaluation of cultivation measures: fertilization & soil conservation, plant protection measure, use of inputs, use of seeds
Verification if there is a risk of contamination (drift, storing of inputs, use of sprayers etc.)
Measures in case of part-conversion
Sustainable animal husbandry (if required by standard)
Yield estimates (can also be kept in separate documentation)
Harvest and post-harvest handling (if relevant)
The report checks management of all crops (like the inspection) with main focus on the organic plots and all crops on these plots.    

30. Compliance Check in the Internal Farm Inspection Report
5.4.9 The internal inspection report should make a clear compliance statement
Evaluation of the compliance of the farmer with internal organic standard
Determination of sanctions in case of non-compliance
Evaluation of the fulfilment of previous conditions
Signed by the farmer and the internal inspector
Contains sometimes also approval decision of the organisation

31. Update Farming Records (5.4.8)
Records for low input use
Sufficient to register the following information in the annual internal control checklist:
Use of inputs (incl. homemade preparations)
Harvested quantities
New fields/changes in area
Better: a farm diary kept additionally by the farmer
Records for high use of inputs or complex production systems
Annual update information needs to be available:
Main cultivation measures
Use of inputs (seeds, fertilizers, pesticides)
Changes in area
Continuous recording necessary (either farmer or field officer)
Information needs to be consolidated (in farm inspection report or annual update questionnaire)

32. Verification of the Farm Files at the ICS Office
Do forms correspond to minimum requirements? Are all relevant topics addressed?
Has each farmer received a documented internal inspection visit?
Are farm files complete and all required documents available for each farmer?
Are documents completely filled in, signed, and dated? Does the ICS seem to know how to use the form?
Are all documents for each farmer consistent with one another and consistent with farmers list?
Can sanctions be seen in the farm files?