Preparing Your Records for Inspection in The Covid-19 Era

While the organic record-keeping requirements for certified operations aren’t likely to change any time soon, the way organic operations are asked to present their records may be–at least temporarily.

During the Covid-19 pandemic, the USDA’s National Organic Program (NOP) office emphasizes that annual organic inspections must go on, though certifying agencies have been asked to take a more creative approach to inspections. The goal of this new approach is to reduce physical contact with people and the food they produce while still meeting organic regulations that require the inspection of all organic operations on an annual basis.

OneCert plans to continue annual inspections while taking steps to keep food, producers, and inspectors safe by using a combination of delayed inspections, virtual inspections, and “desk audits.”

Virtual inspections & desk audits are likely for many organic producers and processors this year. Face-to-face contact with your inspector may be limited to video conferencing, with records audits conducted remotely.  Because these modes of inspection are brand new to everyone, here are a few tips to streamline your 2020 inspection experience.

  • Keep your records up-to-date and in a format that’s easily understood. 
    • Bear in mind that traceability records need to be maintained for crops from seed to final sale, or from ingredient to final product for processed items.
    • An inspector reviewing records via video conference isn’t going to be able to sort through records to find what they’re looking for. Find a method of organizing your records. Your organizational style is up to you, but communicate your organizational method to your inspector.  
    • Remember that you’ll need to provide records for last year’s production and sales as well as records for the current season. (Bear in mind that the organic regulations require organic operations to maintain records for no less than 5 years beyond their creation, so you may be asked for additional information as needed.)
  • Strongly consider digitizing your records. 
    • If OneCert performs a “desk audit” of your operation, you’ll be required to provide copies of your records–either to the OneCert office, or directly to your inspector. It’s very likely that you’ll be asked for the documents necessary for a desk audit in 2020, so if you keep paper records, make copies of them now– and consider making digital copies too.
    • This year’s inspector may need to look at all of your records remotely, which means emailing them may be the easiest way to provide your inspector with required information.
    • Digitizing your records helps prevent the spread of the virus by reducing contact with physical records that may have been handled by many people.
    • The NOP requires that certifying agencies continue to conduct unannounced inspections during the Covid-19 pandemic. If your operation is chosen for an unannounced inspection, you’ll be required to provide records just as quickly as if an inspector were on-site. You’ll be notified a maximum of 4 hours in advance of an unannounced remotely-conducted records audit.
    • If you digitize your records, you’ll be well-prepared to provide any requested records to your inspector during an unannounced inspection or a scheduled annual inspection.
  • Work with your inspector to make virtual meetings happen as planned.
    • Inspections must happen annually without exception. Cancelling or not showing up to a scheduled virtual inspection means you’ll likely receive a notice of noncompliance. 
    • Treat virtual inspections with the seriousness you would treat an in-person visit from an inspector.
    • Not responding to a request for records for a desk audit means you’re out of compliance with the organic regulations. The NOP considers any refusal to provide records a “willful violation” of the standards. 
    • If you’re unclear about what records to provide, please ask. 
    • If you have technological limitations, communicate them to your inspector and to OneCert so that we can work with you to find a reasonable solution.
  • Many operations may still have on-site inspections this year. 
    • Depending on your location, type of operation, proximity to your inspector, and other factors, on-site inspections may still happen for many operations. 
    • You may be asked to participate in a desk-audit or virtual inspection in addition to an on-site inspection if an inspector can safely visit at least part of your facility.

Conclusions: The USDA hasn’t relaxed organic certification requirements during the Covid-19 pandemic. Be prepared for a combination of virtual audits and on-site inspections this year by taking the necessary steps in advance to put your records into a format compatible with out-of-the-ordinary inspection modes. Keep the lines of communication open between you & your inspector so that we can all do our part to keep people and food safe.