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A Study of accredited certification organizations under the national organic program

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Title:
A Study of accredited certification organizations under the national organic program
Creator:
Siddiki, Saba
Weible, Christopher M.
Brett, John
Chonaiew, Sara Miller
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Denver, Colo.
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School of Public Affairs, University of Colorado
School of Public and Environmental Affairs, Indiana University
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English

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Abstract:
The following report discusses findings from a study designed to capture the experiences of USDA accredited certification organizations in implementing the National Organic Program (NOP) regulation. The research presented is the result of collaboration among the Accredited Certifiers Association (ACA) and a research team representing Indiana University-Purdue University Indianapolis and the University of Colorado Denver. Data for this study were collected through formal interviews and an online survey of NOP accredited certification organizations. In the spring of 2013, the research team conducted interviews with 11 such organizations. These interviews helped researchers identify implementation challenges and successes, develop survey questions, and explore relationships between the certifiers and the Accredited Certifiers Association. Following the interviews, an online survey was sent to representatives at 88 accredited certification organizations. Forty three survey responses were received for a response rate of 48.9%.

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A Study of Accredited Certification Organizations under the National Organic Program
Report presented to the Accredited Certifiers Association February 21, 2014
Dr. Saba Siddiki, ssiddiki@iupui.edu Sara Miller Chonaiew, schonaie@iupui.edu School of Public and Environmental Affairs Indiana University-Purdue University Indianapolis
801 West Michigan Street, BS 3027 Indianapolis, IN 46202 Phone: 317-274-4177 Fax: 317-274-7860
Dr. Christopher M. Weible,
chris.weible@ucdenver.edu
David P. Carter, david.carter@ucdenver.edu
School of Public Affairs
University of Colorado Denver
1380 Lawrence Street, Suite 500
Denver, CO 80217
Phone: 303-315-2010
Fax: 303-315-2229
*
SCHOOL OF PUBLIC AND ENVIRONMENTAL AFFAIRS
Dr. John Brett, john.brett@ucdenver.edu University of Colorado Denver Department of Anthropology Campus Box 103 Administration Building 270D Denver, CO 80217-3364 Phone: 303-556-8497 Fax: 303-556-8501
School of Public Affairs
UNIVERSITY OF COLORADO DENVER
NDIANA UNIVERSITY IUPUI


Acknowledgements
We are grateful for the individuals who volunteered their time to participate in this study. The study reported here is part of a research project funded by the National Science Foundation (#1124541) entitled "Assessing Policy Designs and Improving Outcomes: An Institutional and Behavioral Analysis of the U.S. National Organic Program. In this research project, researchers from Indiana University-Purdue University Indianapolis, the University of Colorado Denver, and Duke University seek to gain a better understanding of the perceived appropriateness and effectiveness of the NOP, and to learn more about how the NOP policy design impacts implementation. Any opinions, findings, conclusions, or recommendations expressed in this report are those of the authors and do not necessarily reflect the views of the National Science Foundation. In conducting the research and preparing this report, we are grateful for the assistance of Alison Kent and, especially our colleagues from Duke University: Xavier Basurto and Ainsley Smith.
Citing this Summary Report
Sara Miller Chonaiew, Saba N. Siddiki, David P. Carter, Christopher M. Weible, and John Brett 2013. "A Study of Accredited Certification Agencies under the National Organic Program Produced by Indiana University-Purdue University Indianapolis and the University of Colorado Denver.
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Table of Contents
Executive Summary 4
Section 1: Project Overview 7
Project Background 7
Project Data Collection Methods 7
Section 2: Detailed Results 9
Survey Respondent Characteristics 10
Organization characteristics 12
Results Relating to Study Objectives 18
Section 3: Summary of Results 3 5
Section 4: Conclusions 37
Appendix A: Interview Question Guide 38
Appendix B: Survey Questionnaire 42
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Figures and Tables
Table 1. Professional roles of respondents 10
Table 2. Respondent role in development of the NOP regulation 11
Table 3. Business structure 14
Table 4. Products certified by respondents 15
Table 5. Countries where certification is provided 16
Table 6. Labeling standards 17
Table 7. Alignment on NOP functions 19
Table 8. Activities performed by certification organizations 21
Table 9. Accreditation challenges 22
Table 10. Mandated accreditation tasks 23
Table 11. Implementation challenges 25
Table 12. Purpose of ACA interaction 30
Table 13. Evaluation of ACA performance 32
Figure 1. Respondents by number of certified operations 12
Figure 2. Respondents by type and number of employees 13
Figure 3. Frequency of interactions 26
Figure 4. Tone of interactions 28
Figure 5. Frequency of interactions with ACA 30
Figure 6. Tone of interactions with ACA 31
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Executive Summary
The following report discusses findings from a study designed to capture the experiences of USDA accredited certification organizations in implementing the National Organic Program (NOP) regulation. The research presented is the result of collaboration among the Accredited Certifiers Association (ACA) and a research team representing Indiana University-Purdue University Indianapolis and the University of Colorado Denver.
Data for this study were collected through formal interviews and an online survey of NOP accredited certification organizations. In the spring of 2013, the research team conducted interviews with 11 such organizations. These interviews helped researchers identify implementation challenges and successes, develop survey questions, and explore relationships between the certifiers and the Accredited Certifiers Association. Following the interviews, an online survey was sent to representatives at 88 accredited certification organizations. Forty three survey responses were received for a response rate of 48.9%.
Project Objectives and Findings
The table below includes the four objectives guiding the study and highlights corresponding findings.
Objective Findings
To understand the strengths and weaknesses of the NOP, including the alignment of rules and actual practices of organic producers, handlers and certifiers, from the perspective of organic certifiers All respondents agree the NOP is necessary to maintain consistency in organic food production (strength) According to results, some feel the NOP does not address the concerns of organic producers (weakness) 92% believe their organizations goals either "Completely align or "Mostly align with the goals of the NOP (strength) A small percentage of respondents (16%) helped develop the initial design of the NOP; today, a larger percentage of respondents (68%) regularly communicates with the NOP to discuss the regulation
To understand the emerging and evolving challenges organic certifiers face implementing the NOP rules and the strategies employed to overcome these challenges Most organizations manage a website to disseminate information and provide resources to certified operations about the NOP regulation Paying accreditation fees and preparing for the USDA audit are the most difficult accreditation tasks for certification organizations Most certification organizations perceive inflexibility in interpreting mandated accreditation tasks The biggest implementation challenge for certifiers is waiting for clarification on questions posed to the NOP
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Objective
Findings
To understand interactions within the community of organic certifiers, between the organic certifiers and the USDA, as well as among the ACA and its members
To identify the benefits of the ACA for member organizations, as well as opportunities for better services to the organic certifier community
Certifiers interact more frequently with their clients compared to their interactions with the USDA or other certifiers
Certifiers interact with the NOP most often to resolve questions not addressed in the NOP regulation; few do so to report fraud
Certification organizations interact with other certifiers on the ACA Listserv or directly consult each other on specific products or scopes
Respondents report positive interactions with clients, the USDA, the ACA, and other certifiers.
Almost 80% of the respondents are members of the ACA Several non-member respondents indicate they are located outside of the U.S.
The most popular reason for interacting with the ACA was for training
Interaction between certification organizations and ACA personnel is characterized as always or usually positive by 94% of the respondents
ACA is most effective in providing a forum for networking and
discussion among its members
Respondents report ACA could be more effective by:
Incorporating issues related to the globalization of the organic industry
Finding ways to summarize useful Listserv discussions
Offering more training
Respondents appreciate the work and benefits of the ACA
Conclusions
The interview and survey responses reveal challenges faced by certification organizations, both in pursuing and maintaining accreditation and implementing the NOP regulations. Specifically, both preparing for USDA audits and paying the accreditation fee present obstacles to certifiers in the accreditation process. Many certification organizations indicated implementation challenges are the result of interpretation issues like "Waiting for clarification on questions posed to the NOP and "Applying the NOP penalty matrix.
Overall, the study shows most certification organizations understand the mandated accreditation requirements of the NOP regulation, interact with one another in positive ways, and appreciate the services provided by the ACA. Many certification organizations are diversifying the services they offer to their clients and believe the ACA can aid the efforts of certifiers by extending training beyond the NOP regulation.
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The expanding global market for organic products may present opportunities for growth for the ACA. Several survey responses were received from organizations located outside of the United States. Many of the international respondents expressed interest in joining the ACA.
Finally, certification organizations expressed desire for a convenient way to review the ACA Listserv discussions. Some would like a summary of the exchange while others requested an archive that could be searched via keywords.
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Section 1: Project Overview
Project Background
The USDAs Agricultural Marketing Service enacted the National Organic Program (NOP) in 2002 to implement provisions of the Organic Farming Production Act of 1990. In the decade since the inception of the NOP, the organic industry has experienced profound growth in sales of organic commodities, number of certified organic producers and handlers, as well as increased share of the global food market.
The increase in organic producers and handlers highlights the important role of accredited certification organizations. These groups are accredited by the USDA and evaluate operations seeking organic certification on behalf of the USDA. Certification organizations have authority to approve or deny certification based on an operations ability to comply with the NOP regulation.
The growth and popularity of the organic products has also given rise to professional organizations that serve industry stakeholders. Some, like the Organic Trade Association, serve consumers while others, like the Organic Seed Growers and Trade Association, support producers. For the benefit of certification organizations, the Accredited Certifiers Association (ACA) was formed. The mission of the ACA is to facilitate standard implementation of the NOP by offering training, support, and a forum for discussion about implementation issues.
This report is part of a research project funded by the National Science Foundation (#1124541) entitled "Assessing Policy Designs and Improving Outcomes: An Institutional and Behavioral Analysis of the U.S. National Organic Program. In this research project, researchers from Indiana University-Purdue University Indianapolis, the University of Colorado Denver, and Duke University seek to gain a better understanding of the perceived appropriateness and effectiveness of the NOP and learn more about how the NOP policy design impacts implementation. In-depth exploration of certification organizations as industry stakeholders, including the role of the ACA, is one phase of the broader research agenda. Any opinions, findings, and conclusions or recommendations expressed in this report are those of the authors and do not necessarily reflect the views of the National Science Foundation or the Accredited Certifiers Association.
Project Data Collection Methods
This report summarizes data collected from interviews and a survey of NOP accredited certification organizations.
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Interviews
In the spring of 2013, the research team interviewed 11 individuals from NOP accredited certification organizations, all of whom were ACA members. The individuals interviewed were selected according to their number of clients and geographic location to provide a representative sample of certification organizations. Interview respondents were either the directors or administrative staff within the certification organizations, all directly engaged in accreditation activities. Individuals were interviewed from public, nonprofit, and private certification organizations. The organizations ranged from very small, regional organizations with only a few employees, to large certifiers with dozens of employees engaged in certification both domestically and internationally. The interviews lasted approximately 60 minutes. The interview question guide appears as Appendix A of this report.
Online Survey
To capture a wider diversity of viewpoints and to supplement the information from the interviews, the research team created and administered an online survey. Some of the answers recorded in the certifier interviews aided the question construction on the survey. The intent was to measure prevailing perceptions among all certification organizations accredited by the NOP. An active web link to the survey instrument was sent via electronic message to 88 certifiers in all. Of the 88 individuals to whom the survey was sent, 43 individuals responded, yielding a 48.9% response rate. The questionnaire is provided in Appendix B of this report.
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Section 2: Detailed Results
The following section provides a summary of results for each of the questions asked in the online survey, along with contextual notes from the interviews. This report covers demographic information and respondent attributes including sex, age, and organizational role followed by characteristics of the organizations represented, such as organization size by both number of employees and number of certified operations. To further define the organizations represented, the report also describes the business structure, the commodities certified, the locations where certification is offered and other certification services conducted by the organization. Finally, the four objectives outlined above are restated and the survey results supporting each objective are detailed.
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Survey Respondent Characteristics
The survey was sent to the contact person and email address identified on the NOP list of accredited certification organizations. The survey included a few demographic questions about the individual survey respondents.
Sex
Thirty five individuals provided an answer to the question: "Are you male or female? Respondents were nearly equally distributed with 17 females (49%) and 18 males (51%).
Age
Of the 34 respondents who indicated their age on the survey, a little over half of them (55%) appear in the uppermost age ranges, 46-55 (26%) and over 55 (29%). Six of the respondents were ages 36-45 (18%) while nine were ages 26-35 (26%). No respondents indicated their age was under 25 years old.
Organizational role
Respondents were asked to identify their role within the certification organization they represented. This question included the option to "check all that apply allowing respondents to select multiple roles. A large majority of respondents who answered this question indicated the role of Owner or Manager (89%). Table 1 lists all of the roles and number of corresponding responses for each role.
Table 1. Professional roles of respondents (n=35)
Role Respondents Percent of Total Respondents
Owner or Manager 31 89%
Inspector 9 26%
Compliance officer 9 26%
Marketing specialist 2 6%
Other: Reviewer 2 6%
Administrative assistant 1 3%
Accountant 1 3%
Human resources manager 1 3%
Other: Outreach coordinator 1 3%
Other: Quality manager 1 3%
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Respondent role in NOP regulation development
Respondents were asked to specify their role in the development of the NOP regulation.
The possible roles and activities ranged from involvement with the early stages of NOP rulemaking through current NOP policy engagement. Respondents could select all activities that apply. For each activity shown in Table 2, there is a corresponding number of respondents as well as the percentage of total respondents. The results show a majority of respondents indicated regular communication with a USDA representative to discuss the NOP regulation. A minority of respondents reported that they contributed to the initial development of the NOP regulation.
Table 2. Respondent role in development of the NOP regulation (n=37)
Development Activity Response Percent of Total Respondents
In the last five years, I have regularly communicated with USDA representatives to discuss the NOP regulation. 25 68%
In the last five years, I have been a regular participant in public meetings regarding the NOP regulation. 18 49%
I have not participated in the development of the NOP regulation. 14 38%
In the last five years, I have served on at least one advisory committee or participated in processes that provided recommendations to the USDA about the NOP regulation. n 30%
I contributed to the initial development of the NOP regulation. 6 16%
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Organization Characteristics
To provide background information about organizations represented by respondents, this study included a set of questions to understand variations in the certification organization structures.
Number of certified operations
Respondents were asked to indicate the number of operations currently certified USDA Organic by their organizations. The largest portion of respondents (42%) was in the range of 50-200 certified operations. Figure 1 displays the count of total respondents for a range of certified operations.
Figure 1. Respondents by number of certified operations (n=38)
Fewer than 50 -200 201-400 401 -600 601- 1000 More than
50 1000
Number of Certified Operations
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Number of employees
Respondents were asked to indicate the number of full time employees, part time employees, and the number of contract or seasonal workers involved in their certification organization. The results indicate 60% of the respondents represented small organizations of 10 or fewer full time staff and two employ one part time employee. Figure 2 illustrates the range of answers provided for each employee type.
Figure 2. Respondents by type and number of employees (n=37)
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Full Time
Part Time Seasonal or Contract
Zero 1-5 6-10 11- 21- 31- 41- Over 20 30 40 50 50
Number of Employees
Number of years operating
Respondents were asked to indicate in the survey the number of years their certification organization has been in operation. Of the 37 respondents who answered, 43% represented certification organizations operating for more than 15 years. Thirty five percent were from organizations operating between 11 15 years, 16% represent organizations operating for 6-10 years and 5% were from organizations operating between 1 -5 years. There were no respondents from certification organizations operating for less than one year.
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Business structure
Respondents were asked to identify the business structure of the certification organization they represent. Table 3 shows the number of responses and percentage of the total respondents for each of the business structure categories. Most of the respondents (55%) were from private organizations.
Table 3. Business structure (n=38)
Type of Business Structure Respondents Percent of Total Respondents
Private 21 55%
Non-profit 9 24%
Public 7 18%
Other* 6 16%
Part of university extension 0 0
*Other included: LLC, Not for profit, State Department of Agriculture, County government, State Government, Part of University Regulatory Services
Organic commodities certified
Respondents were asked to indicate which organic commodities are produced by the operations certified by their organization. Ninety five percent of the respondents organizations certify vegetable crops, while herb crops (87%), tree crops (87%) and field crops (89%) rank high as well. All of the responses are listed in Table 4 below.
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Table 4. Products certified by respondents (n=38)
Organic Commodity Responses Percent of Total Respondents
Vegetable crops 36 95%
Grains, alfalfa, mixed hay, other field crops 34 89%
Herb crops 33 87%
Tree or vine fruit, nut crops 33 87%
Brambles, berries 30 79%
Nursery, floriculture, greenhouse crops 26 68%
Beef 23 61%
Eggs 23 61%
Poultry 22 58%
Dairy products 21 55%
Other* 15 39%
Pork 15 39%
Lamb 14 37%
Honey 14 37%
Apiculture 13 34%
*Other products identified are listed below. The number in parentheses identifies the number of responses if listed by more than one respondent.
Bison Goats Olive oil Spray dried products
Cheese HABA Pasture Tea
Coffee Llamas Peanuts Wild crops (2)
Cosmetics Maple Processed organic product (4) Wine
Cotton Maple syrup Processed tea Wool
Flavorings Mushroom Rice Yaks
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Certification services outside of the United States
Twenty one respondents (55%) indicated their organization provides certification services in countries other than the United States. Of the 38 respondents to this question, 17 indicated their organization only offers certification services within the United States. Twenty respondents identified 48 different countries outside of the United States where their organization provides certification services. Some respondents identified regions such as Latin America or continents including Europe, Asia, and Africa. The entire list of countries appears in Table 5 below. Countries identified more than once appear with the number of responses in parentheses.
Table 5. Countries where certification is provided (n=20)
Albania (2) Hungary Morocco South Korea
Argentina Iceland Nepal Sri Lanka
Austria India Nicaragua Sweden
Bosnia Herzegovina Indonesia (2) Papua New Guinea Switzerland
Canada(9) Iran Paraguay Taiwan
Chile Iraq Peru (2) Tanzania
China (5) Italy (2) Philippines Tunisia
Ecuador Japan (3) Romania Turkey (3)
Egypt Lebanon(2) Samoa (2) United Arab Emirates
El Salvador Macau Serbia United Kingdom
Germany Malaysia Singapore Uruguay
Guatemala Mexico (9) Solomon Islands Vietnam
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Certification for other labeling services
Respondents indicated whether or not their organization provides certification for labeling standards other than the USDA Organic program. Of the thirty seven organizations responding, 70% indicated their organization provides certification services for other labeling standards. Table 6 below shows the additional labeling standards identified by the respondents. The number in parentheses identifies the number of responses if listed by more than one respondent.
Table 6. Labeling standards (n=26)
American Grassfed (3) EC 834/2007 (4) GOTS (5) Peru (2)
Argentine Law EC 889/2008 (2) IBD Standards (including Non GMO and EcoSocial) (3) Private standards
Bio Suisse (3) Canada (equivalence) IFOAM (5) Restaurant Certification
Bird Friendly EU (equivalence) (2) Japanese Agricultural Standard (10) Seed certification
Brazilian Legislation Japan (equivalence) Kosher TE
BRC Equiv Taiwan (equivalence) KRAV Transitional
CAN/CGSB 32.310, 32.311. 32.312 EU (8) Material inputs (organic) Tunisian Regulation
Canadian Organic Regime (7) Fair Trade National Standards Australia Turkish Regulation
CARTV (Quebec) Food Alliance Natrue UEBT
CCOF International Standard Food safety Naturland UTZ(2)
COSMOS GlobalG.A.P. (4) Non-GMO
DEMETER International (2) Gluten Free (3) NSF/ANSI 305 (2)
Organic Agricultural Product and Organic Agricultural Processed Product Certification Management Regulations for Food Labeling
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Study Objectives
In the following section, we summarize survey and interview results as they relate to the studys four objectives.
Objective 1: To understand the strengths and weaknesses of the NOP, including the alignment of rules and actual practices of organic producers, handlers and certifiers, from the perspective of organic certifiers.
To address the first objective in this study, respondents were asked to indicate their level of agreement with certain statements related to the NOP regulation. Given a scale ranging from "Strongly disagree (-2) to "Strongly agree (+2) for each statement, respondents provided their perceptions of the NOP regulation. Respondents showed the most agreement with the statement: "The NOP regulation is necessary to maintain consistency in organic food production among different producers. The strongest disagreement was with the following statement: "The NOP regulation addresses the concerns of organic producers. The total responses are displayed in Table 7 below, ordered from the most to least agreement.
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Table 7. Alignment on NOP functions (n=36)
Strongly Disagree Neither Agree Strongly Mean
disagree agree agree
nor
disagree
(-2) (-1) (o) (+1) (+2)
The NOP Regulation...
is necessary to maintain consistency in organic food production among different producers. 0 0 0 44.4% 55-6% 1.6
supports economic development by creating highly valued commodities. 0 0 16.7% 52.8% 30.6% 1.1
maintains the ecological health of agricultural lands. 0 2.8% 16.7% 50% 30.6% 1.1
addresses public concerns about the integrity of organic commodities. 0 0 16.7% 61.1% 22.2% 1.1
provides predictable monitoring and enforcement 0 5-6% 8.3% 61.1% 25% 1.1
mechanisms in organic food production.
protects the health of 0 8.3% 30.6% 30.6% 30.6% 0.8
consumers.
protects the health of farm employees. 0 5-6% 36.1% 30.6% 27.8% 0.8
addresses the concerns of organic producers. 2.8% 13-9% 36.1% 33-3% 13-9% 0.4
Survey respondents were also asked to indicate to what extent the goals of their organization align with the goals of the NOP. Of the 36 respondents, 92% (33 responses) believed their organizations goals either "Mostly align (67%, 24 responses) or "Completely align (25%, 9 responses) with the goals of the NOP. Only 3 respondents (8%) believed the goals of their organization only "Somewhat align with the goals of the NOP and no respondents believe their goals "Do not align at all.
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Interview responses reflected the overall patterns reported in Table 7, above. Virtually all interviewees commented on the importance of standardized organic practices, and the role of NOP regulation in encouraging consistent standards. Differences between certifier expectations and NOP directives for how the regulations are enforced, however, came up frequently in the interviews. For example, one certifier highlighted the desire to rely on the "principle of continual improvement in which the certifier uses its regulatory authority subjectively to encourage learning on the part of each certified operation, as opposed to the NOP expectation that noncompliance requirements are objective and applied neutrally across operations.
Objective 2: To understand the emerging and evolving challenges organic certifiers face implementing the NOP rules and the strategies employed to overcome these challenges.
From interview responses, the range of activities that certifiers engage in with their clients, and the manner in which they conduct those activities, varies widely across the certifier community. To fulfill the second objective of this project, the research team asked respondents about their organizations implementation activities and efforts to resolve or avoid possible implementation challenges.
In relation to implementation activities, survey respondents were asked to consider some of these activities and indicate ones their organization completes. Nearly all of the respondents (92%) reported their organization manages a website that conveys informational resources relating to NOP regulation. The results for each activity are listed in Table 8.
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Table 8. Activities performed by certification organizations (n=37)
Activities Respondents Percent of Total Respondents
Manage a website that contains informational resources relating to the NOP regulation 34 92%
Engage in informal discussions with clients regarding the NOP regulation or the organic certification process 28 76%
Regularly send a newsletter or other document to clients containing information relating to NOP regulation 22 59%
Offer training or workshops to help clients understand the content and requirements in the NOP regulation 21 57%
Host venues for clients to meet and exchange information regarding NOP regulation and the organic certification process 12 32%
Other* 6 16%
*Other activities described by respondents: Answer client questions Exhibit or speak at organic conferences and field days (3) Conduct inspector training or workshops (2)
In relation to Table 8, interview responses indicated that organization structure plays an important role in determining what activities certifiers engage in, for example, if the organization has a separate education and advocacy arm. Organizational financial capacity was also identified as a common constraint in conducting activities. One certifier stated: "Its really based on the amount of money available to the certifier in how they can run their program.
To further reveal the challenges certifiers may face, respondents were asked to rate the difficulty of certain accreditation requirements. For each requirement, respondents specified whether each requirement is Not Difficult (0), a Minor Difficulty (+1), or a Major Difficulty (+2). Table 9 below shows the most challenging task for certification organizations is Paying accreditation fees, followed closely by Preparing for USDA audit.
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Table 9. Accreditation challenges (n=37)
Not difficulty (o) Minor difficulty (+1) Major difficulty (+2) Mean
Paying accreditation fees. 24.3% 37-8% 37-8% 1.1
Preparing for USDA audit once every five years. 16.2% 59-5% 24.3% 1.1
Submitting an annual report including an update of required information, results of the most recent performance evaluations and annual program review. 43.2% 48.6% 8.1% 0.7
Conducting an annual performance evaluation and program review. 48.6% 40.5% 10.8% 0.6
Maintaining records of required certification information. 59-5% 29.7% 10.8% 0.5
Interview responses provided a more detailed understanding to the survey response variance in Table 9. In regards to accreditation fees, several public certifiers noted the difficulty of predicting accreditation fee costs when constructing annual budgets. When discussing USDA audits, interviewees often commented on the necessity of audits, but expressed concern over the increasing frequency of intermediate desk audits. A central concern around the auditing process was that USDA auditors are unfamiliar with the NOP and NOP expectations of certifiers. A comment representative of this concern was expressed by one interviewee: [NOP staff] dont give you answers until the auditor comes out and cites you.. .theres too much guess work for us.
Consistent with survey results, interview responses generally indicated that the annual performance evaluations and program reviews represent at most minor annoyances. Several respondents stated that these are tasks their organization would "simply perform anyway. Interview responses regarding certification record maintenance varied widely. While several interviewees reported that recordkeeping has become a non-issue due to electronic databases that they have implemented, others maintained that recordkeeping constitutes a "major burden for their organizations.
Another implementation concern that surfaced in certifier interview responses was varied interpretations of the NOP regulation. To examine this concern further, survey respondents were asked about the practices and preparations related to the annual report made to the NOP by their organizations. The survey offered a list of specific tasks drawn
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directly from the NOP regulation. After reviewing each task, respondents marked whether they perceived the task to be Required, Optional, or Not Allowed in the standards.
All except one of the actions listed was Required according to the NOP regulation. As Table 10 shows, most of the respondents correctly identified the tasks as Required. The only task not expressly written in the standard as something a certifier "must do is shown in the bottom row of Table 10. The NOP regulation states a certifier "may conduct additional onsite inspections of applicants for certification and certified operations to determine compliance with the Act and the regulations in this part (7 C.F.R. § 205.403(a)(2)(i),
2013). However, the research team is aware of recent guidance from the NOP regarding mandatory inspections and residue testing expectations. Clearly, many respondents (65.7%) understood this task to be required at the time the survey was administered.
Table 10. Mandated accreditation tasks (n=35)
Required Actions__________________________________________________________________________
...ensure that its responsibly connected persons, employees, and contractors with 97.1% inspection, analysis, and decision-making responsibilities have sufficient expertise in organic production or handling techniques to successfully perform the duties assigned.
...ensure that the decision to certify an operation is made by a person different from 94.3%
those who conducted the review of documents and on-site inspection.
...submit to the administrator any notice of denial of certification issued pursuant 94-3%
to §205.405, notification of noncompliance, notification of noncompliance correction, notification of proposed suspension or revocation, and notification of suspension or revocation sent pursuant to §205.662 simultaneously with its issuance.
...charge applicants for certification and certified production and handling 91.4%
operations only those fees and charges for certification activities that it has filed with the Administrator.
...notify the inspector of its decision regarding certification of the production or 77.1%
handling operation site inspected by the inspector and of any requirements for the correction of minor noncompliance.
Optional Actions Required Optional
...conduct additional on-site inspections of applicants for 65.7% 34-3%
certification and certified operations to determine compliance with the Act and the regulations in this part.
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Among the required actions listed in Table 10, interview responses revealed variation in the relative ease with which certain actions are carried out. One challenge that regularly arose during the interviews was interpretation of terms such as "sufficient expertise.
While many certifiers interpreted this to mean intimate familiarity with relevant organic agricultural practices, others questioned the need for agriculture-specific experience and advocated for educational experience in areas such as environmental policy. One respondent held that while there exists wide variation among certifiers in terms of staff expertise, as far as the respondent knew, "no certifier has ever been cited or had their accreditation threatened or revoked for not meeting that standard.
During interviews, certifiers shared a variety of implementation experiences. Many experiences were positive but some were less than ideal. For example, while virtually all respondents recognized and appreciated the burdens and constraints placed on NOP staff, a common certifier concern was difficulty in getting answers from the NOP when inquiries were made about the appropriateness of specific practices under organic certification. A related challenge was the introduction of new products or practices to the organic industry, and a lack of guidance on the standards that should be applied to new entrants into the industry. For instance, at the time of the interviews at least half of the respondents reported that their organization did not certify apiculture due to a dearth of regulations that applied to the practice.
From the interview responses, the research team developed a list of implementation activities that may pose challenges to certification organizations. Respondents were asked to rank each activity as Not Difficult (0), a Minor Difficulty (+1), or a Major Difficulty (+2). There was also an option for the respondent to indicate the activity is not conducted by their organization. Concurrent with the interview responses, Table 11 illustrates the most difficulty is experienced by certifiers Waiting for clarification on questions posed to the NOP. Also indicated to be minor or major challenges for many certifiers were Applying the NOP Penalty Matrix and Spreading of organic practices to products not explicitly addressed by NOP regulations.
Although the NOP audits of certification organizations did not appear to be a "major difficulty according to the responses to the question above, the research team received quite a bit of feedback from the interview participants and in the comments section of the survey. Commonly discontent was raised over the cost of the audits, particularly the apparent inequity of the cost relative to organization size. One respondent said: "The small agencies like us seem to pay the same as big agencies without the client base to spread it over. Several interview respondents conveyed that auditors do not understand how certification organizations operate and that the auditors decisions are inconsistent from year to year. As one interview respondent stated: "Somehow the NOP needs to work with
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their auditors to come to some kind of agreement over what level of recordkeeping is enough.
Table 11. Implementation challenges (n=36-37)
Not difficult (o) Minor difficulty (+1) Major difficulty (+2) Do not complete (NA) Mean
Waiting for clarification on questions posed to the NOP. 8.1% 37-8% 54-1% 0 1.6
Applying the NOP Penalty matrix. 5-6% 50% 30.6% 13-9% 1.1
Testing products periodically for pesticide residue. 21.6% 45-9% 32.4% 0 1.1
Preparing for NOP monitoring audits of accredited certifiers in addition to the required accreditation audit that occurs every five years. 21.6% 51-4% 27% 0 1.1
Spreading of organic practices to products not explicitly addressed by NOP regulations. 5-4% 51-4% 24.3% 18.9% 1.0
Identifying genetically engineered organisms via product tests. 19.4% 33-3% 22.2% 25% 0.8
Responding to NOP investigation of clients of your organization. 29.7% 51-4% 13-5% 5.4% 0.8
Conducting unannounced inspections of organic operations in addition to annual certification inspections. 40.5% 43.2% 16.7% 0 0.8
Adhering consistently to the National List of Allowed and Prohibited Substances. 41.7% 44.4% 13-9% 0 0.7
Responding to growth of the US organic market to include imported internationally produced products. 29.7% 29.7% 10.8% 29.7% 0.5
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Objective 3: To understand interactions within the community of organic certifiers, between the organic certifiers and the USDA, as well as among the ACA and its members.
To meet this objective, the research team posed several questions about the interactions among certification organizations, their clients, and NOP personnel.
Respondents answered a series of questions about their interactions with each of the following groups: other certification organizations, NOP personnel, and their own clients. For each group the respondents revealed how often interactions occur, the purpose of those interactions, and finally the tone of the interaction (positive or negative). Results show the most frequent interaction occurs between the certification organizations and their clients, although many reported daily interaction with other certification organizations as well. Figure 3 below illustrates the frequent of interactions report on the survey.
Figure 3. Frequency of interactions (n = 34-36)
Certifying organization Certifying organization Certifying organization -NOP(n=36] Other certifying Clients (n= 34]
organizations [n=34]
Daily Weekly Monthly Annually
To further understand the interactions among certifiers, their clients, and the NOP, the study included questions about the nature or purpose of the communication. Respondents
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revealed two main reasons for interacting with NOP personnel: To resolve questions not addressed in the NOP regulation (92%) and To issue a notice of noncompliance (92%).
About 39% of the respondents indicated their organization contacts NOP personnel To seek clarifications on specific ingredients and about 33% do so To report fraud. Thirty-six total survey responses were recorded. Other reasons listed for certification organizations to interact with the NOP include:
To seek guidance on interpretation of the NOP regulation (2)
To express concern about NOP administrative decisions (2)
To discuss accreditation issues (2)
To communicate changes within the certification organization
To work through investigations with NOP compliance and enforcement
Interview responses generally reflected the reasons for interacting with the NOP consistent with survey results. Interview respondents from larger certification organizations consistently reported higher interaction frequency than those from smaller organizations, while also noting that the high interaction frequency was not reflective of certifiers as a population. Respondents from several small certifiers noted that communication with the NOP was generally one-sided, and that the NOP rarely initiates interaction with them. Similarly, one survey respondent observed that their organizations interactions with the NOP were too few to facilitate effective issue management saying, "Too often we are not aware of the direction of ongoing work, until we see the output, and then the certification community feedback leads to NOP retracting documents. Another offered, "I believe the NOP has a distant relationship with its certifiers.
Survey respondents provided answers to a similar question about the purpose for their contact with other certification organizations. There was less agreement among the 34 responses to this question as compared to the interaction with the NOP. The two most common responses chosen for this question include: To contribute to or respond to Listserv posts (71%) and To consult on specific products or scopes (68%). Another popular explanation for certifiers interactions (41%) was To discuss a shared client. Several other responses were offered centering around three main topics: To gain feedback on interpretation of NOP regulation (3), To discuss industry issues (2), and To casually visit.
Of the 35 individuals who responded to the question about the nature of interaction between certification organizations and their clients, 100% agreed the purpose was To respond to client inquiry. Thirty-four respondents (97%) answered To schedule a site visit and 71% indicated To make an unannounced site visit. Other interactions described include the following:
To seek remittance of application and inspection fees (3)
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To follow up on the submission of updated Organic System Plan (OSP) To share information about regulatory issues


Finally, to round out this objective, survey respondents were asked to characterize the typical nature of the exchanges. For each group of interactions, respondents selected from a scale of Always positive to Always negative to describe the overall tone of the communication. In Figure 4 below, the bar chart illustrates a comparison of the interactions among certification organizations and the NOP, other certification organizations, and clients all of which show a majority of "Always positive or "Usually positive answers.
Figure 4. Tone of interactions (n = 34-36)
Certifying organization Certifying organization Certifying organization -NOP(n=36] Other certifying Clients (n= 35]
organizations (n=34]
Always Positive Usually Positive Neutral
Usually Negative Always Negative
Interview responses indicated a variety of characterizations of the relationship and interactions between certifiers and the NOP. Despite the concerns of limited interactions with the NOP, the interactions that did occur were consistently reported to be almost always positive in nature and practically constructive. Overall, certifier perception of NOP staff was very positive, particularly in reference to recent years and the direction of Deputy Administrator Miles McEvoy. This positive perception was reflected in statements such as "[NOP staff] have made vast improvements in the quality of work and their transparency and their ability to maintain consistent guidance to certifiers. The Program has grown
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leaps and bounds since Miles has taken over running it and "We have the utmost respect with the current [NOP] staff that is in place and we work really well with them.
Objective 4: To identify the benefits of the ACA for member organizations, as well as opportunities for better services to the organic certifier community.
This study included a series of questions intended to further the goals of the Accredited Certifiers Association (ACA) by providing feedback about the organizations activities. These questions also contribute to the overall project by highlighting the role of this organization within the industry.
Membership participation
First, respondents were asked about their organizations membership in the Accredited Certifiers Association (ACA). Of the 35 respondents to this question, 77% are active members of the ACA, 23% are not. Respondents who indicated their organizations are not members of the ACA were further asked about the reasons why they choose not to participate. The most common reason listed for not joining the ACA was the location of the respondents organization outside of the United States. A couple of respondents were unsure of the value of the ACA to their organization and another respondent reported the inability to attend meetings as a limiting factor.
Interactions with ACA
Respondents were asked to consider their interactions with the ACA while answering a series of questions about the frequency, tone, and nature of the engagements. The largest portion of respondents (37%) interacts with the ACA on an annual basis but some indicated daily interaction (13%). The results of this question are illustrated in the bar chart in Figure 5.
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Figure 5. Frequency of interaction with ACA (n=30)
Annually Monthly Weekly Daily
0 2 4 6 8 10 12
Number of Respondents
When asked about the purposes for the interaction between their organization and the ACA, respondents most common answer was Training (77%). Table 12, shown below, includes the number of respondents and percent of the total respondents for each purpose. The table also contains a short list of reasons for interaction provided in the "Other category.
Table 12. Purpose of ACA interaction (n=30)
Purpose Respondents Percent of Total Respondents
Training 23 77%
During participation in working groups 20 67%
Serving on ACA Board 10 33%
Other* 6 20%
*Other purposes for interacting with Accredited Certifiers Association:
Listserv and email questions (2) Casual chatting Never interacted Conference calls Surveys
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Respondents were asked to consider the nature or tone of the interactions and assess those exchanges on a scale ranging from 1 (Always positive) to 5 (Always negative). A large majority of the 30 respondents to this question indicated the interactions were either "Always positive or "Usually positive. The answers are illustrated here in Figure 6.
Figure 6. Tone of interactions with ACA (n=30)
Always positive Usually positive Neither positive nor negative Usually negative Always negative
Number of Respondents
Effectiveness
To measure perceptions of the ACAs effectiveness among the certification organizations, respondents were asked to evaluate the Associations performance given a list of functions. The five-point scale ranged from Very ineffective (-2) to Very effective (+2). The responses, including the mean score, are shown in Table 13. According to the survey results, the ACA is most effective in providing a forum for networking and discussions.
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Table 13. Evaluation of ACA performance (n=31)
Very ineffective (-2) Ineffective (-1) Neither ineffective nor effective (o) Effective (+1) Very effective (+2) Mean
Providing a forum for discussion of issues impacting organic certification. 0 3.2% 3.2% 29% 64-5% 1.6
Providing networking opportunities for certification organizations. 0 3.2% 3.2% 35-5% 58% 1-5
Offering training for certifiers regarding NOP regulations. 0 0 9-7% 45-2% 45-2% 1-4
Developing uniform criteria
for implementation of the USDA National Organic Program. 0 3.2% 19.4% 48.4% 29% 1.0
Ensuring the integrity of organic certification in the U.S. 0 3.2% 22.6% 51.6% 22.6% 0.9
Interview responses indicated similarly positive assessments of the ACA. The ACA list serve was consistently cited as a productive mechanism for posing questions, sharing information, and building consensus among certifiers that supports consistency in certifier practices. As one interviewer commented, the ACA list serve helps to "level the playing field, encourage transparency, and reduce widely divergent practices that encourage "certifier shopping. Working groups and the ability to present unified certifier positions on a variety of the topic to the NOP were also cited as important services that the ACA provides certifiers. In a statement reflective of the leverage the ACA provides certifiers, one respondent said by "going through the ACA and presenting to the NOP...if theres five or six certifiers our size or larger, that absolutely is going to carry some weight. Another
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commented "Its a pretty powerful group that if something comes out of that group, the NOP tends to listen.
Finally, the research team asked survey respondents to describe how the ACA might be more effective in meeting the needs of organic certifiers. Respondents were allowed to enter free form text detailing their ideas. Twenty (20) respondents offered suggestions centered on a few recurring themes listed below including sample comments by survey respondents:
Internationalization
"Given the globalization of the organic food supply, the ACA is predominantly domestic with limited engagement from foreign certifiers. It would be good to have international representation."
"If the ACA could delve into the other programs outside of just the NOP (i.e. Canada and EU) to discuss certification, implementation, and interpretation issues, it would be helpful as a certifier and also to aid in consistency of implementation of those programs."
"Representation for international certifiers.
Communication
"Summarize the Listserv discussion including outcome or resolution. Provide a quarterly spreadsheet of the summary."
It would be helpful to encapsulate the general agreement of topics on the Listserv rather than having to search the threads."
Training Resources
"Provide resources to assist new certifiers, and their employees, such as best practice manuals for the certification process (input review, label review, etc.)"
"I would like ACA guidelines or instructions on Material Review."
"More training."
Certifiers interviewed for this project expressed clear appreciation for the ACA and the opportunity the organization provides for networking. Many survey respondents affirmed the actions and efforts of the ACA with their comments as well. The following comments represent the positive support for benefits the ACA provides:
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"Considering the diversity of the group, [theACA] does an excellent job and provides a much needed service. I cannot imagine not having theACA."
"I enjoy the conference calls associated with State agencies and unique issues with them versus private certifiers."
"I think [the ACA] has become more diverse and stronger... The services they provide there are great -1 don't know what else they could really do.
"I see no areas where they could improve. It is a very valuable resource for certifiers trying to consistently interpret the NOP rule."
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Section 3: Summary of Results
Objective 1: To understand the strengths and weaknesses of the NOP, including the alignment of rules and actual practices of organic producers, handlers and certifiers, from the perspective of organic certifiers.
All respondents agree the NOP is necessary to maintain consistency in organic food production (strength)
According to results, some feel the NOP does not address the concerns of organic producers (weakness)
92% believe their organizations goals either "Completely align or "Mostly align with the goals of the NOP (strength)
Small percentage of respondents (16%) helped develop the NOP but larger percentage regularly communicates with the NOP to discuss the regulation (68%).
Objective 2: To understand the emerging and evolving challenges organic certifiers face implementing the NOP rules and the strategies employed to overcome these challenges.
Most organizations manage a website to disseminate information and provide resources
Paying accreditation fees and preparing for the USDA audit are the most difficult accreditation tasks for certification organizations
Most understand what mandated accreditation tasks as required
Biggest implementation challenge for certifiers is waiting for clarification on questions posed to the NOP
Objective 3: To understand interactions within the community of organic certifiers, between the organic certifiers and the USDA, as well as among the ACA and its members.
Certifiers interact more frequently with their clients compared to their interactions with the USDA or other certifiers
Certifiers interact with the NOP most often to resolve questions not addressed in the NOP regulation; few do so to report fraud
Certification organizations interact among other certifiers on the ACA Listserv or directly consult directly on specific products or scopes
Respondents report mostly positive interactions among the with clients, the USDA, the ACA, and other certifiers
Objective 4: To identify the benefits of the ACA for member organizations, as well as opportunities for better services to the organic certifier community.
Almost 80% of the respondents represent ACA member organizations
Several non-member respondents indicate they are located outside of the U.S.
The most popular reason for interacting with the ACA was for training
Interaction is characterized as always or usually positive by 94% of the respondents
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ACA is most effective in providing a forum for networking and discussion among its members
Could be more effective by:
o Incorporating issues related to the globalization of the organic industry o Finding ways to summarize useful Listserv discussions o Offering more training
Respondents appreciate the work and benefits of the ACA
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Section 4: Conclusions
This study, part of a larger research project funded by the NSF ((#1124541) entitled "Assessing Policy Designs and Improving Outcomes: An Institutional and Behavioral Analysis of the U.S. National Organic Program, was undertaken with the Accredited Certifiers Association to investigate the implementation of the NOP regulation from the perspective of certification organizations. A specific objective of this research included an examination of the benefits offered by membership in the ACA and opportunities for enhanced services.
The interview and survey responses reveal challenges faced by certification organizations, both in pursuing and maintaining accreditation and implementing the NOP regulations. Specifically, preparing for USDA audits and paying the accreditation fee present obstacles to certifiers in the accreditation process. Many certification organizations indicated implementation challenges are the result of interpretation "Waiting for clarification on questions posed to the NOP and "Applying the NOP penalty matrix.
Overall, the report shows most certification organizations understand the mandated requirements of the NOP regulation, interact with one another in positive ways, and appreciate the services provided by the ACA. Many certification organizations are diversifying the services they offer to their clients and believe the ACA can aid the efforts of certifiers by extending training events beyond the NOP regulations.
The expanding global market for organic products may present opportunities for growth for the ACA. Several survey responses were received from organizations operating outside of the United States. Respondents expressed interest in joining the ACA.
Finally, certification organizations expressed desire for a convenient way to review the ACA Listserv discussions. Some would like a summary of the exchange while others requested an archive that could be searched via keywords.
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Appendix A: Interview Question Guide
Organizational Background
1. What are your responsibilities within your organization?
Probe: What activities do these responsibilities entail?
Probe: How do you responsibilities and activities relate to the NOP regulations?
2. What products does your organization certify?
3. How many organic operations does your organization currently certify and how long does a typical organic operation stay certified?
4. What are the different positions in your organizations, and what are the responsibilities associated with those roles?
Probe: Are certification tasks specified in the NOP regulations handled by different people/divisions within your organization?
5. Do you contract out any services (e.g., organic operation inspection)?
6. How are your personnel (in-house and/or contracted) trained about to NOP procedures?
7. [IF the organization is not a public state organization] Is your organization a private, for profit organization, or a non-profit, 501(c)(3) organization?
Objectives 1 and 2: To understand the implementation of and compliance with the NOP.
8. From our examination of the NOP regulations, there appears to be a sequence of activities associated with the continued accreditation process. We have simplified this sequence into five steps:
(1) Conducting an annual performance evaluation and program review;
(2) Submission of an annual report including an update of required information and the results of the most recent performance evaluations and annual program review;
(3) Payment of accreditation fees;
(4) A USDA audit once every five years, at a minimum;
(5) And, ongoing record keeping of required certification information.
How is this sequence of activities similar or dissimilar to how you perceive continuing accreditation for your organization?
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I am going to ask you about specific statements taken directly from the NOP about accreditation. Can you tell me about the extent that each statement is reflective of your actual practices, and how your practices may differ from each statement?
Certifying agents (for continued accreditation)...
a.....must submit a description of any training that the certifying agent 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.
b. ...must submit a description of the qualifications, including experience, training, and education in agriculture, organic production, and organic handling, for each inspector to be used by the applicant
c. ...must conduct an annual performance evaluation of all persons who review applications for certification, perform on-site inspections, review certification documents, evaluate qualifications for certification, make recommendations concerning certification, or make certification decisions
d. ...must have an annual program review of its certification activities conducted by the certifying agent's staff, an outside auditor, or a consultant who has expertise to conduct such reviews
Certifying agents (during certification)...
a. ...must submit to the administrator any notice of denial of certification issued pursuant to §205.405, notification of noncompliance, notification of noncompliance correction, notification of proposed suspension or revocation, and notification of suspension or revocation sent pursuant to §205.662 simultaneously with its issuance.
b. ... must notify the inspector of its decision regarding certification of the production or handling operation site inspected by the inspector and of any requirements for the correction of minor noncompliances.
c. ...must charge applicants for certification and certified production and handling operations only those fees and charges for certification activities that it has filed with the Administrator
d. ...may conduct additional on-site inspections of applicants for certification and certified operations to determine compliance with the Act and the regulations in this part.
e. ...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.
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f. ...must ensure that the decision to certify an operation is made by a person different from those who conducted the review of documents and on-site inspection
9. What aspects of the NOP Rule have been the most difficult to implement and how have you overcome these difficulties?
10. To what extent do certifiers strictly adhere to the NOP Rule?
Objective 3: To understand the relationship between 1) certifiers and the USDA; 2) certifiers with other certifiers; and 2) certifiers and organic operations.
11. How often do you (or members of your organization) interact with USDA personnel?
12. For what purposes do you (or members of your organization) interact with USDA personnel?
13. To what extent are these interactions positive or negative?
14. In reference to your more recent interactions, what extent have USDA enforcement personnel been effective in administering and assessing certifier compliance with the NOP rule?
Probe: Are enforcement personnel knowledgeable about organic farming processes, regulations, certification processes, the organic farming industry, etc.?
15. How often do you (or members of your organization) interact with other certifiers?
16. For what purposes do you (or members of your organization) interact with other certifiers?
17. To what extent are these interactions positive or negative?
Probe: To what extent do certifiers cooperate/compete with one another?
18. How often do you (or members of your organization) interact with organic operations?
19. For what purposes do you (or members of your organization) interact with organic operations?
20. To what extent are these interactions positive or negative?
Objective 4: To identify the benefits of the Accredited Certifiers Association for
member organizations, as well as opportunities for better services to the organic certifier community.
21. What activities/actions does the Accredited Certifiers Association perform that prove valuable to organic certifiers?
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Probe: How, if at all, have the services provided by the Accredited Certifiers Association changed over time?
22. What activities/actions not currently performed by the Accredited Certifiers Association would be helpful to organic certifiers?
23. What lessons have you learned over time relative to organic policy and organic certification?
24. Are there any questions regarding organic certification and the NOP that I have not asked you that you think I should have?
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Appendix B: Survey Questionnaire
Accredited Organic Certifier Survey
This survey seeks to understand national organic policy and certification in the United States, including:
National Organic Program (NOP) implementation and program administration; Certifier interpretation of, and action related to, the NOP regulation; Interactions between the NOP, accredited certifiers, and certified operations, and;
The benefits and possible opportunities for improvement of the Accredited Certifiers Association.
If you have questions about this survey please contact Sara Miller Chonaiew via email at schonaie@iupui.edu. Please click the Next button below to begin the survey.
1 How many operations does your organization currently certify as USDA organic?
O Fewer than 50
O 50-200 O 201-400 O 401-600 O 601- 1000 O More than 1000
2 How many employees does your organization currently employ?
_____Full time
_____Part time
_____Contract or Seasonal
3 For how many years has your organization been operating?
O Less than 1 year
O 1-5 years 0 6-10 years O 11-15 years O More than 15 years
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4 Which of the following business structures best describes your organization? Check all that apply.
Private
Non-profit
Other, please describe: _______________
Public
Part of university extension
5 Please indicate the categories of organic commodities produced by the operations you certify as USDA Organic. Check all that apply.
Vegetable crops
Herb crops
Nursery, floriculture, greenhouse crops
Apiculture
Brambles, berries
Tree or vine fruit, nut crops
Grains, alfalfa, mixed hay, other field crops
Other, please list:______________
Beef
Poultry
Dairy products
Lamb
Pork
Honey
Eggs
6 Does your organization provide certification services for operations in countries other than the U.S.?
O Yes O No
Answer If Does your organization provide certification services for... Yes Is Selected
6a Please list countries outside of the U.S. for which your organization provides certification services.
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7 Does your organization provide certification for labeling standards other than the USDA organic program?
O Yes O No
Answer If Does your organization provide certification for eco labe... Yes Is Selected 7a Please list the labeling standards for which your organization provides certification.
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8 In addition to certifying responsibilities included in the NOP regulation, please indicate
which of the following activities your organization performs. Check all that apply.
Offer training or workshops to help clients understand the content and requirements in the NOP regulation
Regularly send a newsletter or other document to clients containing information relating to NOP regulation
Manage a website that contains informational resources relating to the NOP regulation
Host venues for clients to meet and exchange information regarding NOP regulation and the organic certification process
Engage in informal discussions with clients regarding the NOP regulation or the organic certification process
Other, please describe: ________________
9 The NOP regulation lists general activities required for continued accreditation. Please indicate the level of difficulty associated with the following activities:
Not difficult Minor difficulty Major difficulty Do not complete
Conducting an annual performance O O O O
evaluation and program review. Submitting an annual report including an update of required information, results of the most O O O O
recent performance evaluations and annual program review. Paying o o o o
accreditation fees. Preparing for USD A audit once every o o o o
five years. Maintaining records of required o o o o
certification information.
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10 In consideration of your organization's practices and preparations for submitting the annual report to the NOP, please indicate which practices listed below you consider Required, Optional, or Not allowed.
Required Optional Not allowed
...notify the inspector of its decision regarding certification of the production or handling operation site inspected by the inspector and of any requirements for the correction of minor noncompliance. O O O
...charge applicants for certification and certified production and handling operations only those fees and charges for certification activities that it has filed with the Administrator. O o o
...conduct additional on-site inspections of applicants for certification and certified operations to determine compliance with the Act and the regulations in this part. o o o
...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. o o o
...ensure that the decision to certify an operation is made by a person different from those who conducted the review of documents and on-site inspection. o o o
...submit to the administrator any notice of denial of certification issued pursuant to §205.405, notification of noncompliance, notification of noncompliance correction, notification of proposed suspension or revocation, and notification of suspension or revocation sent pursuant to §205.662 simultaneously with its issuance. o o o
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11 Some certifying organizations have indicated challenges with the following implementation activities. Please indicate the level of difficulty associated with the following activities for your organization:
Not difficult Minor difficulty Major difficulty Do not complete
Applying the NOP Penalty O O O O
matrix.
Conducting unannounced inspections of organic operations in addition to O o o o
annual certification
inspections.
Testing products periodically for pesticide o o o o
residue.
Identifying genetically engineered organisms via o o o o
product tests.
Preparing for NOP "monitoring audits of
accredited certifiers in o o o o
addition to the required accreditation audit that

occurs every five years.
Responding to NOP investigation of clients of o o o o
your organization.
Adhering consistently to the National List of Allowed o o o o
and Prohibited Substances.
Waiting for clarification on questions posed to the NOP. o o o o
Spreading of organic practices to products not explicitly addressed by NOP o o o o
regulations.
Responding to growth of the US organic market to include imported internationally produced o o o o
products.
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12 Please specify your role in the development of the NOP regulation. Check all that apply.
In the last five years, I have been a regular participant in public meetings regarding the NOP regulation.
In the last five years, I have regularly communicated with USDA representatives to discuss the NOP regulation.
In the last five years, I have served on at least one advisory committee or participated in processes that provided recommendations to the USDA about the NOP regulation.
I contributed to the initial development of the NOP regulation.
I have not participated in the development of the NOP regulation.
13 Please indicate your level of agreement with each of the following statements relating to the NOP regulation. The NOP regulation...
Strongly Agree Neither agree Disagree Strongly
agree nor disagree disagree
is necessary to maintain consistency in organic food production among different o O O O O
producers.
addresses the concerns of o o O o O
organic producers.
addresses public concerns
about the integrity of organic commodities. o o o o o
maintains the ecological health of agricultural lands. o o o o o
protects the health of farm o o o o o
employees.
protects the health of o o o o o
consumers.
supports economic
development by creating highly valued commodities. o o o o o
provides predictable
monitoring and o o o o o
enforcement mechanisms in organic food production.

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14 To what extent do the goals of your organization align with the goals of the NOP?
O Completely align
O Mostly align O Somewhat align O Do not align at all
15 How often do you (or members of your organization) interact with NOP personnel?
O Daily
O Weekly O Monthly O Annually
16 For what purposes do you (or members of your organization) interact with NOP personnel?
Seek clarifications on specific ingredients
Resolve questions not addressed in the NOP regulation
Report fraud
Issue a notice of noncompliance
Other, please list:_______________
17 Are your (or members of your organization) interactions with NOP personnel generally positive or negative?
O Always positive O Usually positive O Neither positive nor negative O Usually negative O Always negative
18 How often do you (or members of your organization) interact with other certifying organizations?
O Daily O Weekly O Monthly O Annually
19 For what purposes do you (or members of your organization) interact with other certifying organizations?
Discuss a shared client
Consult on specific products or scopes
Contribute to or respond to Listserv posts
Other, please list: ______________
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20 Are your (or members of your organization) interactions with other certifying organizations generally positive or negative?
O Always positive O Usually positive O Neither positive nor negative O Usually negative O Always negative
21 How often do you (or members of your organization) interact with your clients?
O Daily
O Weekly O Monthly O Annually
22 For what purposes do you (or members of your organization) interact with your clients?
Respond to client inquiry
Visit site unannounced
Visit site scheduled
Other, please list:______________
23 Are your (or members of your organization) interactions with your clients generally positive or negative?
O Always positive O Usually positive O Neither positive nor negative O Usually negative O Always negative
24 Are you currently a member of the Accredited Certifiers Association?
O Yes
O No
Answer If Are you currently a member of the Accredited Certifiers A... No Is Selected
24a Please describe why you are not a member of the Accredited Certifiers Association.
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25 Please indicate how effective the Accredited Certifiers Association has been in performing the following functions:
Very effective Effective Neither effective nor ineffective Ineffective Very ineffective
Ensuring the integrity of organic certification in the U.S. Developing uniform criteria for O O O O O
implementation of the USDA National Organic Program. O o O O O
Offering training for certifiers regarding NOP regulations. Providing networking o o o o o
opportunities for certifying organizations. Providing a forum for o o o o o
discussion of issues impacting organic certification. o o o o o
26 How often do you (or members of your organization) interact with Accredited Certifiers Association personnel?
O Daily O Weekly O Monthly O Annually
27 For what purposes do you (or members of your organization) interact with Accredited Certifiers Association personnel?
Training
During participation in working groups
Serving on ACA Board
Other, please list: _______________
28 Are your (or members of your organization) interactions with the Accredited Certifiers Association personnel generally positive or negative?
O Always positive O Usually positive O Neither positive nor negative O Usually negative O Always negative
29 Please describe how you think the Accredited Certifers Association can be more effective in meeting the needs of organic certifiers.
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30 Please indicate your professional role(s) within your organization. Check all that apply.
Owner or Manager
Administrative assistant
Inspector
Accountant
Marketing specialist
Compliance officer
Human resources manager
Other, please describe:_______________
31 What is your age?
O Under 25
O 26-35 O 36-45 O 46-55 O Over 55
32 Are you female or male?
O Female
O Male
33 Is there anything else you would like to share with us related to organic accreditation, certification, and the NOP?
34 Would you like to receive a copy of the survey results?
O Yes
O No
Please click the Submit button below to complete the survey.
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Full Text

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A Study of Accredited Certification Organizations under the National Organic Program Report presented to the Accredited Certifiers Association February 21, 2014 Dr. Saba Siddiki, ssiddiki@iupui.edu Sara Miller Chonaiew, schonaie@iupui.edu School of Public and Environmental Affairs Indiana University Purdue University Indianapolis 801 West Michigan Street, BS 3027 Indianapolis, IN 46202 Phone: 317 274 4177 Fax: 317 274 7860 Dr. Christopher M. Weible, chris.weible@ucdenver.edu David P. Cart er, david.carter@ucdenver.edu School of Public Affairs University of Colorado Denver 1380 Lawrence Street, Suite 500 Denver, CO 80217 Phone: 303 315 2010 Fax: 303 315 2229 Dr. John Brett, john.brett@ucdenver.edu University of Colorado Denver Department of Anthropology Campus Box 103 Administration Building 270D Denver, CO 80217 3364 Phone: 303 556 8497 Fax: 303 556 8501

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Acknowledgements We are grateful for the individuals who volunteered their time to participate in this study. Th e study reported here is part of a research project funded by the National Science Foundation (#1124541) entitled Assessing Policy Designs and Improving Outcomes: An Institutional and Behavioral Analysis of the U.S. National Organic Program. In this research project, researchers from Indiana University Purdue University Indianapolis, the University of Colorado Denver, and Duke University seek to gain a better understanding of the perceived appropriateness and effectiveness of the NOP and to learn more abo ut how the NOP policy design impacts implementation. Any opinions, findings, conclusions or recommendations expressed in this report are those of the authors and do not necessarily reflect the views of the National Science Foundation. In conducting the research and preparing this report, we are grateful for the assistance of Alison Kent and, especially our colleagues from Duke University: Xavier Basurto and Ainsley Smith Citing this Summary Report Sara Miller Chonaiew, Saba N. Siddiki, David P. Carter, Christopher M. Weible, and John Brett. 2013. A Study of Accredited Certifi cation Agencies under the National Organic Program Produced by Indiana University Purdue University Indianapolis and the University of Colorado Denver. ACA Report October 2013 Page 1

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Table of Contents Executive Summar y 4 Section 1: Project Overview 7 Project Background 7 Project Data Collection Methods 7 Section 2: Detailed Results 9 Survey Respondent Characteristics 10 Organization characteristics 12 Results Relating to Study Objectives 1 8 Section 3: Summary of Results 3 5 Section 4: Conclusions 3 7 Appendix A: Interview Question Guide 3 8 Appendix B: Survey Questionnaire 4 2 ACA Report October 2013 Page 2

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Figures and Tables Table 1. Professional roles of respondents 10 Table 2. Respondent role in development of the NOP regulation 11 Table 3. Business structure 1 4 Table 4. Products certified by respondents 1 5 Table 5. Countries where certification is provided 1 6 Table 6. Labeling standards 1 7 Table 7. Alignment on NOP functions 19 Table 8. Activities performed by certification organizations 21 Table 9. Accreditation challenges 22 Table 10. Mandated accreditation tasks 23 Table 11. Implementation challenges 25 Table 12. Purpose of ACA interaction 30 Table 13. Evaluation of ACA performance 32 Figure 1. Respondents by number of certified operations 12 Figure 2. Respondents by type and number of employees 13 Figure 3. Frequency of interactions 2 6 Figure 4. Tone of interactions 28 Figure 5. Frequency of interactions with ACA 30 Figure 6. Tone of interactions with ACA 31 ACA Report October 2013 Page 3

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Executive Summary The following report discusses findings from a study designed to capture the experiences of USDA accredited certification organizations in implementing the National Organic Program (NOP) regulation. The research presented is the result of collaboration am ong the Accredited Certifiers Association (ACA) and a research team representing Indiana University Purdue University Indianapolis and the University of Colorado Denver. Data for this study w ere collected through formal interviews and an online survey of NOP accredited certification organizations In the spring of 2013, the research team conducted interviews with 11 such organizations. These interviews helped researchers identify implementation challenges and successes, develop survey questions, and explore relationships between the certifiers and the Accredited Certifiers Association. Following the interviews, an online survey was sent to representatives at 88 accredited certification organizations. Forty three survey responses were received for a response rate of 48.9%. Project Objectives and Findings The table below includes the four objectives guiding the study and highlights corresponding findings. Objective Findings To understand the strengths and weaknesses of the NOP, including the alignment of rules and actual practices of organic producers, handlers and certifiers, from the pe rspective of organic certifiers All respondents agree the NOP is necessary to maintain consistency in organic food production (strength) According to results, some feel the NOP does not address the concerns of organic producers (weakness) 92% believe their organizations goals either Completely align or Mostly align with the goals of the NOP (strength) A small percentage of respondents (16%) helped develop the initial design of the NOP ; today, a larger percentage of respondents (68%) regularly communicates with the NOP t o discuss the regulation To understand the emerging and evolving challenges organic certifiers face implementing the NOP rules and the str ategies employed to overcome these challenges Most organizations manage a website to disseminate information and provide resources to certified operations about the NOP regulation Paying accreditation fees and preparing for the USDA audit are the most difficult accreditation tasks for certification organizations Most certification organizations perceive inflexibility in interpreting mandated accreditation tasks ACA Report October 2013 Page 4

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Objective Findings To understand interactions within the community of organic certifiers, between the organic certifiers and the USDA, as well as among the ACA and its members Certifiers interact more frequently with their clients compared to their interactions wi th the USDA or other certifiers Certifiers interact with the NOP most often to resolve questions not addressed in the NOP regulation; few do so to report fraud Certification organizations interact with other certifiers on the ACA Listserv or directly consult each other on specific products or scopes Respondents report positive interactions with clients, the USDA, the ACA, and other certifiers. To identify the benefits of the ACA for member organizations, as well as opportunities for better services to the organic certifier community Almost 80% of the respondents are members of the ACA Several non member respondents indicate they are located outside of the U.S. The most popular reason for interacting with the ACA was for training Interaction between certification organizations and ACA personnel is characterized as always or usually positive by 94% of the respondents ACA is most effective in providing a forum for networking and discussion among its members Respo ndents report ACA could be more effective by: Incorporating issues related to the globalization of the organic industry Finding ways to summarize useful Listserv discussions Offering more training Respondents appreciate the work and benefits of the ACA Conclusions The interview and survey responses reveal challenges faced by certification organizations, both in pursuing and maintaining accreditation and implementing the NOP regulations. Specifically, both preparing for USDA audits and paying the accreditation fee present obstacles to certifiers in the accreditation process. Many certification organizations indicated implementation challenges are the result of interpretation issues like Waiting for clarification on questions posed to the NOP and Applying the NOP penalty matrix. Overall, the study shows most certification organizations understand the mandated accreditation requirements of the NOP regulation, interact with one another in positive ways, and appreciate the services provided by the ACA. Many certification organizations are diversifying the services they offer to their clients and believe the ACA can aid the efforts of certifiers by extending training beyond the NOP regulation. ACA Report October 2013 Page 5

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The expanding global market for organic products may present opportunities for growth for the ACA. Several survey responses were received from organizations located outside of the United States. Many of the international r espondents expressed interest in joining the ACA. Finally, certification organizations expressed desire for a convenient way to review the ACA Listserv discussions. Some would like a summary of the exchange while others requested an archive that could be searched via keywords. ACA Report October 2013 Page 6

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Section 1: Project Overview Project Background The USDAs Agricultural Marketing Service enacted the National Organic Program (NOP) in 2002 to implement provisions of the Organic Farming Production Act of 1990. In the decade since the inception of the NOP, the organic industry has experienced profound growth in sales of organic commodities, number of certified organic producers and handlers, as well as increased share of the global food market. The increase in organic producers and handlers highlights the important role of accredited certification org anizations. These groups are accredited by the USDA and evaluate operations seeking organic certification on behalf of the USDA. Certification organizations have authority to approve or deny certification based on an operation s ability to comply with the NOP regulation. The growth and popularity of the organic products has also given rise to professional organizations that serve industry stakeholders. Some, like the Organic Trade Association, serve consumers while others, like the Organic Seed Grower s and Trade Association, support producers. For the benefit of certification organizations the Accredited Certifiers Association (ACA) was formed. The mission of the ACA is to facilitate standard implementation of the NOP by offering training, support, and a forum for discussion about implementation issues. This report is part of a researc h project funded by the National Science Foundation (#1124541) entitled Assessing Policy Designs and Improving Outcomes: An Institutional and Behavioral Analysis of the U.S. National Organic Pr ogram. In this research project, research ers from Indiana University Purdue University Indianapolis, the University of Colorado Denver, and Duke University seek to gain a better understanding of the perceived appropriateness and effectiveness of the NOP and learn more about how the NOP policy design impacts implementation. In depth exploration of certification organizations as industry stakeholders, including th e role of the ACA, is one phase of the broader research agenda. Any opinions, findings, and conclusions or recommendations expressed in this report are those of the authors and do not necessarily reflect the views of the National Science Foundation or the Accredited Certifiers Association. Project Data Collection Methods Th is report summarizes data collected from interviews and a survey of NOP accredited certification organizations ACA Report October 2013 Page 7

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Interviews In the spring of 2013, the research team interviewed 11 individuals from NOP accredited certification organizations, all of whom were ACA members. The individuals interviewed were selected according to their number of clients and geographic location to provide a representative sample of certification organizations. Interview respondents were either the directors or administrative staff within the certification organizations, all directly engaged in accreditation activities. Individuals were interviewed from public, nonprofit, and private certification orga nizations. The organizations ranged from very small, regional organizations with only a few employees, to large certifiers with dozens of employees engaged in certification both domestically and internationally. The interviews lasted approximately 60 minutes. The interview question guide appears as Appendix A of this report. Online Survey To capture a wider diversity of viewpoints and to supplement the information f ro m the interviews, the research team created and administered an online survey. Some of the answers recorded in the certifier interviews aided the question construction on the survey. The intent was to measure prevailing perceptio ns among all certification organizations accredited by the NOP. An active web link to the survey instrument was sent via electronic message to 88 certifiers in all. Of the 88 individuals to whom the survey was sent, 43 individuals responded, yielding a 48.9% response rate. The questionnaire is provided in Appendix B of this report. ACA Report October 2013 Page 8

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Section 2: Detailed Results The following section provides a summary of results for each of the questions asked in the online survey along with contextual notes from the interviews T his report covers demographic information and respondent attributes including sex, age, and organizational role followed by characteristics of the organizations represented, such as organization size by both number of employees and number of certified operations. To further define the organizations r epresented, the report also describes the business structure, the commodities certified, the locations where certification is offered and other certification services conducted by the organization. Finally, the four objectives outlined above are restated and the survey results supporting each objective are detailed. ACA Report October 2013 Page 9

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Survey Respondent Characteristics The survey was sent to the contact person and email address identified on the NOP list of accredited certification organizations The survey included a few demographic questions about the individual survey respondents. Sex Thirty five individuals provided an answ er to the question: Are you male or female? Respondents were nearly equally distributed with 17 females (49%) and 18 males (51%). Age Of the 34 respondents who indicated their age on the survey, a little over half of them (55%) appear in the uppermost age ranges, 46 55 (26%) an d o ver 55 (29%). Six of the respondents were ages 36 45 (18%) while nine were ages 26 35 (26%). No respondents indicated their age was u nder 25 years old. Organizational r ole Respondents were asked to identify their r ole within the certification organization they represented. This question included the option to check all that apply allowing respondents to select multiple roles. A large majority of respondents who answered this question indicated the role of Owner or Manager (89%). Table 1 lists all of the roles and number of corresponding responses for each role. Table 1. Professional r oles of r espondents (n=35) Role Respondents Percent of Total Respondents Owner or Manager 31 89 % Inspector 9 26 % Compliance officer 9 26 % Marketing specialist 2 6 % Other: Reviewer 2 6 % Administrative assistant 1 3 % Accountant 1 3 % Human resources manager 1 3 % Other: Outreach coordinator 1 3 % Other: Quality manager 1 3 % ACA Report October 2013 Page 10

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Respondent role in NOP regulation development R espondents were asked to specify their role in the development of the NOP regulation. The possible roles and activities ranged from involvement with the early stages of NOP rulemaking through current NOP policy engagement. Respondents could select all activities that apply. For each activity sho wn in Table 2 there is a corresponding number of respondents as well as the percentage of total respondents. The results show a majority of respondents indicated regular communication with a USDA representative to discuss the NOP regulation. A minority of respondents reported that they contributed to the initial development of the NOP regulation. Table 2 Respondent r ole in d evelopment of the NOP r egulation (n=37) Development Activity Response Percent of Total Respondents In the last five years, I have regularly communicated with USDA representatives to discuss the NOP regulation. 25 68% In the last five years, I have been a regular participant in public meetings regarding the NOP regulation. 18 49% I have not participated in the development of the NOP regulation. 14 38% In the last five years, I have served on at least one advisory committee or participated in processes that provided recommendations to the USDA about the NOP regulation. 11 30% I contributed to the initial development of the NO P regulation. 6 16% ACA Report October 2013 Page 11

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Organization Characteristics To provide background information about organizations represented by respondents, this study included a set of questions to understand variations in the certification organization structures Number of certified operations Respondents were asked to indicate the number of operations currently certified USDA Organic by their organizations. The largest portion of respondents (42%) was in the range of 50200 certified operations. Figure 1 displays the count of tot al respondents for a range of certified operations. Fig ure 1. Respondents by n umber of c ertified o perations (n=38) 0 2 4 6 8 10 12 14 16 18 Fewer than 50 50 200 201 400 401 600 601 1000 More than 1000 Number of Respondents Number of Certified Operations ACA Report October 2013 Page 12

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Number of employees Respondents were asked to indicate the number of full time employees, part time employees, and the number of contract or seasonal workers involved in their certification organization. The results indicate 60% of the respondents represented small organizations of 10 or fewer full time staff and two employ one part time employee. Figure 2 illustrates the range of answers provided for each employee type. Figure 2. Respondents by t ype and n umber of e mployees (n=37) 0 2 4 6 8 10 12 14 16 18 Zero 1 5 6 10 11 20 21 30 31 40 41 50 Over 50 Number of Respondents Number of Employees Full Time Part Time Seasonal or Contract Number of years operating Respondents were asked to indicate in the survey the number of years their certification organization has been in operation. Of the 37 respondents who answered, 43% represented certification organizations operating for more than 15 years. Thirty five per cent were from organizations operating between 11 15 years, 16% represent organizations operating for 6 10 years and 5% were from organizations operating between 1 5 years. There were no respondents from certification organizations operating for le ss than one year. ACA Report October 2013 Page 13

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Business structure Respondents were asked to identify the busines s structure of the certification organization they represent. Table 3 shows the number of responses and percentage of the total respondents for each of the business structure categories. Most of the respondents (55%) were from private organizations. Table 3 Business structure (n=38) Type of Business S tructure Respondents Percent of Total Respondents Private 21 55 % Non profit 9 24 % Public 7 18 % Other* 6 16 % Part of university extension 0 0 Other included : LLC, Not for profit, State Department of Agriculture, County government, State Government, Part of University Regulatory Services Organic commodities certified R espondents were asked to indicate which organic commodities are produced by the operations certified by their organization. Ninety five percent of the respondents organizations certify vegetabl e crops, while herb crops (87% ) tree crops (87%) and field c rops (89%) rank high as well. All of the responses are listed in Table 4 below. ACA Report October 2013 Page 14

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Table 4 Products certified by respondents (n=38) Organic Commodity Responses Percent of T otal R espondents Vegetable crops 36 95 % Grains, alfalfa, mixed hay, other field crops 34 89 % Herb crops 33 87 % Tree or vine fruit, nut crops 33 87 % Brambles, berries 30 79 % Nursery, floriculture, greenhouse crops 26 68 % Beef 23 61 % Eggs 23 61 % Poultry 22 58 % Dairy products 21 55 % Other* 15 39 % Pork 15 39 % Lamb 14 37 % Honey 14 37 % Apiculture 13 34 % *Other products identified are listed below. The number in parentheses identifies the number of responses if listed by more than one respondent. Bison Goats Olive oil Spray dried products Cheese HABA Pasture Tea Coffee Llamas Peanuts Wild crops (2) Cosmetics Maple Processed organic product (4) Wine Cotton Maple syrup Processed tea Wool Flavorings Mushroom Rice Yaks ACA Report October 2013 Page 15

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Certification services outside of the United States Twenty one respondents (55%) indicated their organization provides certification services in countries other than the United States. Of the 38 respondents to this questio n, 17 indicated their organization only offers certification services within the United States. Twenty respondents identified 48 different countries outside of the United States where their organization provides certification services. Some respondents identified regions such as Latin America or continents including Europe, Asia, and Africa. The entire list of countries appears in Table 5 below. Countries identified more than once appear with the number of responses in parentheses Table 5 Countries where certification is provided (n=20) Albania (2) Hungary Morocco South Korea Argentina Iceland Nepal Sri Lanka Austria India Nicaragua Sweden Bosnia Herzegovina Indonesia (2) Papua New Guinea Switzerland Canada (9) Iran Paraguay Taiwan Chile Iraq Peru (2) Tanzania China (5) Italy (2) Philippines Tunisia Ecuador Japan (3) Romania Turkey (3) Egypt Lebanon (2) Samoa (2) United Arab Emirates El Salvador Macau Serbia United Kingdom Germany Malaysia Singapore Uruguay Guatemala Mexico (9) Solomon Islands Vietnam ACA Report October 2013 Page 16

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Certification for other labeling services Respondents indicated whether or not their organization provides certification for labeling standards other than the USDA Organic program. Of the thirty seven organizations responding 70% indicated their organization provides certification services for o ther labeling standards. Table 6 below shows the additional labeling standards identified by the respondents. The number in parentheses identifies the number of responses if listed by more than one respondent. Table 6 Labeling s tandards (n=26) American Grassfed (3) EC 834/2007 (4) GOTS (5) Peru (2) Argentine Law EC 889/2008 (2) IBD Standards (including Non GMO and EcoSocial) (3) Private standards Bio Suisse (3) Canada (equivalence) IFOAM (5) Restaurant Certification Bird Friendly EU (equivalence) (2) Japanese Agricultural Standard (10) Seed certification Brazilian Legislation Japan (equivalence) Kosher TE BRC Equiv Taiwan (equivalence) KRAV Transitional CAN/CGSB 32.310, 32.311. 32.312 EU (8) Material inputs (organic) Tunisian Regulation Canadian Organic Regime (7) Fair Trade National Standards Australia Turkish Regulation CARTV (Quebec) Food Alliance Natrue UEBT CCOF International Standard Food safety Naturland UTZ (2) COSMOS GlobalG.A.P. (4) Non GMO DEMETER International (2) Gluten Free (3) NSF/ANSI 305 (2) Organic Agricultural Product and Organic Agricultural Processed Product Certification Management Regulations for Food Labeling ACA Report October 2013 Page 17

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Study Objectives In the following section, we summarize survey and interview results as they relate to the studys four objectives Objective 1 : To understand the strengths and weaknesses of the NOP, including the alignment of rules and actual practices of organic producers, handlers and certifiers, from the perspective of organic certifiers. To address the first objective in this study respondents were asked to indicate their level of agreement with certain statements related to the NOP regulation. Given a scale ranging from Strongly dis agree ( 2) to Strongly agree (+2) for each stateme nt, respondents provided their perceptions of the NOP regulation. Respondents showed the most agreement with the statement: The NOP regulation is necessary to maintain consistency in organic food produ ction among different producers The strongest disag reement was with the following statement: The NOP regulation addresses th e concerns of organic producers. The total responses are displayed in Table 7 below, ordered from the most to least agreement. ACA Report October 2013 Page 18

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Table 7 Alignment on NOP functions (n=36) Strongly dis agree ( 2) Disa gree ( 1) Neither agree nor disagree (0) A gree ( + 1) Strongly agree ( + 2) Mean The NOP Regulation is necessary to maintain consistency in organic food production among different producers. 0 0 0 44.4% 55.6% 1.6 supports economic development by creating highly valued commodities. 0 0 1 6 .7% 52.8% 30.6% 1.1 maintains the ecological health of agricultural lands. 0 2.8% 16.7% 50% 30.6% 1. 1 addresses public concerns about the integrity of organic commodities. 0 0 1 6 .7% 61.1% 22.2% 1. 1 provides predictable monitoring and enforcement mechanisms in organic food production. 0 5.6% 8.3% 61.1% 25% 1. 1 protects the health of consumers. 0 8.3 % 30.6% 30.6% 30.6% 0.8 protects the health of farm employees. 0 5.6% 36.1% 30.6% 27.8% 0.8 addresses the concerns of organic producers. 2.8% 13.9% 36.1% 33.3% 13.9% 0.4 Survey respondents were also asked to indicate to what extent the goals of their organization align with the goals of the NOP. Of the 36 respondents, 92% (33 responses) believed their organizations goals either Mostly align (67%, 24 responses) or Completely align (25%, 9 responses) with the goals of the NOP. Only 3 respondents (8%) believed the goals of their organization only Somewhat align with the goals of the NOP and no respondents believe their goals Do not align at all. ACA Report October 2013 Page 19

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Interview responses reflected the overall patterns reported in Table 7 above. Virtually all interviewees commented on the importance of standardized organic practices, and the role of NOP regulation in encouraging consistent standards. Differences between certifier expectations and NOP directives for how the regulations are enforced, however, came up frequently in the interviews. For exampl e, one certifier highlighted the desire to rely on the principle of continual improvement in which the certifier uses its regulatory authority subjectively to encourage learning on the part of each certified operation, as opposed to the NOP expectation that noncompliance requirements are objective and applied neutrally across operations. Objective 2: To understand the emerging and evolving challenges organic certifiers face implementing the NOP rules and the strategies employed to overcome these challenges. From interview responses, the range of activities that certifiers engage in with their clients, and the manner in which they conduct those activities, varies widely across the certifier community. To fulfill the second objective of this project, the research team asked respondents about their organizations implementation activities and efforts to resolve or avoid possible implementation challenges. In relation to implementation activities, s urvey respondents were asked to consider some of these activities and indicate ones their organization completes Nearly all of the respondents (92% ) reported their organization manages a website that conveys informational resources relating to NOP regulation. The results for each activity are listed in Table 8 ACA Report October 2013 Page 20

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Table 8 Activities performed by certification organizations (n=37) Activities Respon dents Percent of Total Respondents Manage a website that contains informational resources relating to the NOP regulation 34 92 % Engage in informal discussions with clients regarding the NOP regulation or the organic certification process 28 76 % Regularly send a newsletter or other document to clients containing information relating to NOP regulation 22 59 % Offer training or workshops to help clients understand the content and requirements in the NOP regulation 21 57 % Host venues for clients to meet and exchange information regarding NOP regulation and the organic certification process 12 32 % Other* 6 16 % *Other activities described by respondents: Answer client questions Exhibit or speak at organic conferences and field days (3) Conduct inspector training or workshops (2) In relation to Table 8 interview responses indicated that organization structure plays an important role in determining what activities certifiers engage in, for example, if the organization has a separate education and advocacy arm. Organizational f inancial capacity was also identified as a common constraint in conducting activities. One certifier stated : I ts really based on the amount of money available to the certifier in how they can run their program. To further reveal the challenges certifiers may face, respondents were asked to rate the difficulty of certain accreditation requirements. For each requirement, respondents specified whether each requirement is Not Difficult (0) a Minor Difficulty (+1) or a Major Difficulty (+2) Table 9 below shows the most challenging task for certification organizations is Paying accreditation fees followed closely by Preparing for USDA audit ACA Report October 2013 Page 21

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Table 9 Accreditation challenges (n=37) Not difficulty (0) Minor difficulty ( + 1) Major difficulty ( + 2) Mean Paying accreditation fees. 24.3 % 37.8% 37.8 % 1.1 Preparing for USDA audit once every five years. 16.2 % 59.5 % 24.3 % 1. 1 Submitting an annual report including an update of required information, results of the most recent performance evaluations and annual program review. 43.2 % 48.6 % 8.1 % 0. 7 Conducting an annual performance evaluation and program review. 48.6% 40.5 % 10.8 % 0.6 Maintaining records of required certification information. 59.5 % 29.7 % 10.8 % 0.5 Interview responses provided a more detailed understanding to the survey response variance in Table 9 In regards to accreditation fees, several public certifiers noted the difficulty of predicting accreditation fee costs when constructing annual budgets. When discussing USDA audits, interviewees often commented on the necessity of audits, but expressed concern over the increasing frequency of intermediate desk audits. A central concern around the auditing process was that USDA auditors are unfamiliar with the NOP and NOP expectations of certifiers. A comment representative of this concern was expressed by one interviewee: [NOP staff] dont give you answers until the auditor comes out and cites youtheres too much guess work for us. Consistent with survey results, interview r esponses generally indicated that the annual performance evaluations and program reviews represent at most minor annoyances. S everal respondents stated that these are tasks their organization would simply perform anyway. Interview responses regarding c ertification record maintenance varied widely. While several interviewees reported that recordkeeping has become a nonissue due to electronic databases that they have implemented, others maintained that recordkeeping constitutes a major burden for their organizations. Another implementation concern that surfaced in certifier interview responses was varied interpretations of the NOP regulation. To examine this concern further, survey respondents were asked about the practices and preparations related to the annual report made to the NOP by their organizations. The survey offered a list of specific tasks drawn ACA Report October 2013 Page 22

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directly from the NOP regulation. After reviewing each task, respondents marked whether the y perceived the task to be Requ ired, Optional, or Not Allowed in the standards. All except one of the actions listed was Required according to the NOP regulation. As Table 10 shows, most of the respondents correctly identified the tasks as Required. The only task not expressly written in the standard as something a certifier must do is shown in the bottom row of Table 10. The NOP regulation states a certifier may conduct additional onsite inspections of applicants for certification and certified operations to determine compliance with the Act and the regulations in this part ( 7 C.F.R. 205.403(a)(2)(i) 2013). However, the research team is aware of recent guidance from the NOP regarding mandatory inspections and residue testing expectations. Clearly, many respondents (65.7%) understood this task to be required at the time the survey was administered. Table 10. Mandated a ccreditation t asks (n=35) Required Actions ...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. 97.1% ...ensure that the decision to certify an operation is made by a person different from those who con ducted the review of documents and on site inspection. 94.3% ...submit to the administrator any notice of denial of certification issued pursuant to 205.405, notification of noncompliance, notification of noncompliance correction, notification of proposed suspension or revocation, and notification of suspension or revocation sent pursuant to 205.662 simultaneously with its issuance. 94.3% ...charge applicants for certification and certified production and handling operations only those fees and c harges for certification activities that it has filed with the Administrator. 91.4% ...notify the inspector of its decision regarding certification of the production or handling operation site inspected by the inspector and of any requirements for the correction of minor noncompliance. 77.1% Optional Actions Required Optional ...conduct additional on site inspections of applicants for certification and certified operations to determine compliance with the Act and the regulations in this part. 65.7% 34.3% ACA Report October 2013 Page 23

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Among the required actions listed in Table 1 0 interview responses revealed variation in the relative ease with which certain actions are carried out. One challenge that regularly arose during the interviews was interpretation of terms such as sufficient expertise While many certifiers interpreted this to mean intimate familiarity with relevant organic agricultural practices, others questioned the need for agriculturespecific experience and advocated for educational experience in areas such as environmental policy. One respondent held that while there exists wide variation among certifiers in terms of staff expertise, as far as the respondent knew, no certifier has ever been cited or had their accreditation threatened or revoked for not meeting that standard. During interviews, certifiers shared a variety of implementation experiences. Many experiences were positive but some were less than ideal. For example, while virtually all respondents recognized and appreciated the burdens and constraints placed on NOP staff, a common certifier concern was difficulty in getting answers from the NOP when inquiries were made about the appropriateness of specific practices under organic certification. A related challenge was the introd uction of new products or practices to the organic industry, and a lack of guidance on the standards that should be applied to new entrants into the industry. For instance, at the time of the interviews at least half of the respondents reported that their organization did not certify apiculture due to a dearth of regulations that applied to the practice. From the interview responses, the research team developed a list of implementation activities that may pose challenges to certification organizations. R espondents were asked to rank each activity as Not Difficult (0) a Minor Difficulty (+1) or a Major Difficulty (+2) There was also an option for the respondent to indicate the activity is not conducted by their organization. Concurrent with the interv iew responses, Table 1 1 illustrates the most difficulty is experienced by certifiers Waiting for clarification on questions posed to the NOP Also indicated to be minor or major challenges for many certifiers were Applying the NOP Penalty M atrix and Spreading of organic practices to products not explicitly addressed by NOP regulations. Although the NOP audits of certification organizations did not appear to be a major difficulty according to the responses to the question above, the research team received quite a bit of feedback from the interview participants and in the comments section of the survey. Commonly discontent was raised over the cost of the audits, particularly the apparent inequity of the cost relative to organization size. One respon dent said : The small agencies like us seem to pay the same as big agencies without the client base to spread it over. S everal interview respondents conveyed that auditors do not understand how certification organizations operate and that the auditors d ecisions are inconsistent from year to year. As one interview respondent stated: Somehow the NOP needs to work with ACA Report October 2013 Page 24

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their auditors to come to some kind of agreement over what level of recordkeeping is enough. Table 1 1 Implementation c hallenges (n= 3637) Not difficult (0) Minor difficulty ( + 1) Major difficulty ( + 2) Do not complete (NA) Mean Waiting for clarification on questions posed to the NOP. 8.1 % 37.8 % 54.1 % 0 1.6 Applying the NOP Penalty matrix. 5.6 % 50 % 30.6 % 13.9 % 1.1 Testing products periodically for pesticide residue. 21.6 % 45.9 % 32.4 % 0 1.1 Preparing for NOP monitoring audits of accredited certifiers in addition to the required accreditation audit that occurs every five years. 21.6 % 51.4 % 27 % 0 1. 1 Spreading of organic practices to products not explicitly addressed by NOP regulations. 5.4 % 51.4 % 24.3 % 18.9 % 1 .0 Identifying genetically engineered organisms via product tests. 19.4 % 33.3 % 22.2 % 25 % 0.8 Responding to NOP investigation of clients of your organization. 29.7 % 51.4 % 13.5 % 5.4 % 0.8 Conducting unannounced inspections of organic operations in addition to annual certification inspections. 40.5 % 43.2 % 16.7 % 0 0. 8 Adhering consistently to the National List of Allowed and Prohibited Substances. 41.7 % 44.4% 13.9 % 0 0.7 Responding to growth of the US organic market to include imported internationally produced products. 29.7 % 29.7 % 10.8 % 29.7 % 0.5 ACA Report October 2013 Page 25

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Objective 3: To understand interactions within the community of organic certifiers, between the organic certifiers and the USDA, as well as among the ACA and its members. To meet this objective, the research team posed several questions about the interactions among certification organizations, their clients, and NOP personnel. Respondents answered a series of questions about their interactions with each of the following groups: other certification organizations, NOP personnel, and their own clients. For each group the respondents revealed how often interactions occur, the purpose of those interactions, and finally the tone of the interaction (positive or negative). Results show the most frequent interaction occurs between the certification organizations and their clients although many reported daily interaction with other certification organizations as well. Figure 3 below illustrates the frequent of interactions report on the survey. Figure 3 Frequency of i nteractions (n = 3436) 0 5 10 15 20 25 30 Certifying organization NOP (n=36) Certifying organization Other certifying organizations (n=34) Certifying organization Clients (n=34) Number of Respondents Daily Weekly Monthly Annually To further understand the interactions among certifiers, their clients, and the NOP, the study included questions about the nature or purpose of the communication. Respondents ACA Report October 2013 Page 26

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revealed two main reasons for interacting with NOP personnel: To resolve questi ons not addressed in the NOP regulation (92%) and To issue a notice of noncompliance (92% ). A bout 39% of the respondents indicated their organization contacts NOP personnel To seek clarifications on specific ingredients and about 33% do so To report fraud Thirty six total survey responses were recorded. Other reasons listed for certification organizations to interact with the NOP include: To seek guidance on interpretation of the NOP regulation (2) To express concern about NOP administrative decisions (2) To discuss accreditation issues (2) To communicate changes within the certification organization To work through investigations with NOP compliance and enforcement Interview responses generally reflected the reasons for interacting with the NOP consistent with survey results. Interview respondents from larger certification organizations consistently reported higher interaction frequency than those from smaller organizations, while also noting that the high interaction frequency was not reflective of certifiers as a population. Respondents from several small certifiers noted that communication with the NOP was generally one sided, and that the NOP rarely initiates interaction with them. Similarly, one survey respondent observed that their organizations interactions with the NOP were too few to facilitate effective issue management saying, Too often we are not aware of the direction of ongoing work, until we see the output, and then the certification community feedback leads to NOP retracting documents. Another offered, I believe the NOP has a distant relationship with its certifiers. Survey respondents provided answers to a similar question about the purpose for their contact with other certification organizations There was less agr eement among the 34 responses to this question as compared to the interaction with the NOP. The two most common responses chosen for this question include: To contribute to or respond to Listserv posts (71%) and To consult on specific products or scopes (68%). Another popular explanation for certifiers interactions (41%) was To discuss a shared client Several other responses were offered centering around three main topics: T o gain feedback on interpretation of NOP regulation (3), To discuss industry issues (2), and To casually visit Of the 35 individuals who responded to the question about the nature of interaction between certification organizations and their clients, 100% agreed the purpose was To respond to client inquiry Thirty four respondents (97%) answered To schedule a site visit and 71% indicated To make an unannounced site visit Other interactions described include the following: To seek remittance of application and inspection fees (3) ACA Report October 2013 Page 27

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To follow up on the submission of updated Organic System Plan (OSP) To share information about regulatory issues Finally, to round out this objective, survey respondents were asked to characterize the typical nature of the exchanges For each group of interactions, respondents selected from a scale of Always positive to Always negative to describe the overall tone of the communication. In Figure 4 below, the bar chart illustrates a comparison of the interactions among certification organizations and the NOP, other certification organizations, and clients all of which show a majority of Always positive or Usually positive answers. Figure 4 Tone of i nteractions (n = 34 36) 0 5 10 15 20 25 30 35 Certifying organization NOP (n=36) Certifying organization Other certifying organizations (n=34) Certifying organization Clients (n=35) Number of Respondents Always Positive Usually Positive Neutral Usually Negative Always Negative Interview responses indicated a variety of characterizations of the relationship and interactions between certifiers and the NOP. Despite the concerns of limited interactions with the NOP, the interactions that did occur were consistently reported to be almost always positive in nature and practically constructive. Overall, certifier perception of NOP staff was very positive, particularly in reference to recent years and the direction of Deputy Administrator Miles McEvoy. This positive perception was ref lected in statements such as [NOP staff] have made vast improvements in the quality of work and their transparency and their ability to maintain consistent guidance to certifiers. The Program has grown ACA Report October 2013 Page 28

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leaps and bounds since Miles has taken over running it and We have the utmost respect with the current [NOP] staff that is in place and we work really well with them. Objective 4: To identify the benefits of the ACA for member organizations, as well as opportunities for better services to the organic certifier community. This study included a series of questions intended to further the goals of the Accredited Certifiers Association (ACA) by providing feedback about the organizations activities. These questions also contribute to the overall project by highlighting the role of this organization within the industry. Membership participation First, respondents were asked about their orga nizations membership in the Accredited Certifiers Association (ACA). Of the 35 respondents to this question, 77% are active members of the ACA, 23% are not. Respondents who indicated their organizations are not members of the ACA were further asked abou t the reasons why they choose not to participate. The most common reason listed for not joining the ACA was the location of the respondents organization outside of the United States. A couple of respondents were unsure of the value of the ACA to their o rganization and another respondent reported the inability to attend meetings as a limiting factor. Interactions with ACA Respondents were asked to consider their interactions with the ACA while answering a series of questions about the frequency, tone, and nature of the engagements. The largest portion of respondents (37%) interacts with the ACA on an annual basis but some indicated daily interaction (13%). The results of this question are illustrated in the bar chart in Figure 5 ACA Report October 2013 Page 29

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Figure 5 Frequency of i nteraction with ACA (n=30) 0 2 4 6 8 10 12 Daily Weekly Monthly Annually Number of Respondents When asked about the purposes for the interaction between their organization and the ACA, respondents most common answer was Training (77%). Table 1 2 shown below, includes the number of respondents and percent of the total respondents for each purpose. The table also contains a short list of reasons for interaction provided in the Other category. Table 1 2 Purpose of ACA i nteraction (n=30) Purpose Respondents Percent of Total Respondents Training 23 77% During participation in working groups 20 67 % Serving on ACA Board 10 33 % Other 6 20 % Other purposes for interacting with Accredited Certifiers Association: Listserv and email questions (2) Casual chatting Never interacted Conference calls Surveys ACA Report October 2013 Page 30

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Respondents were asked to consider the nature or tone of the interactions and assess those exchanges on a scale ranging from 1 ( Always positive) to 5 ( Always negative) A large majority of the 30 respondents to this question indicated the interactions were either Always positive or Usually positive. The answers are illustrated here in Figure 6 Figure 6. Tone of i nteractions with ACA (n=30) 0 5 10 15 Always negative Usually negative Neither positive nor negative Usually positive Always positive Number of Respondents Effectiveness To measure perceptions of the ACAs effectiveness among the certification organizations, respondents were asked to evaluate the Associations performance given a list of functions. The five point scale ranged from Very ineffective ( 2) to Very effective (+2) The responses, including the mean score, are shown in Table 1 3 According to the survey results, the ACA is most effective in providing a forum for networking and discussions. ACA Report October 2013 Page 31

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Table 1 3 Evaluation of ACA p erformance (n=31) Very in effective ( 2) Ine ffective ( 1) Neither ineffective nor effective (0) E ffective ( + 1) Very effective ( + 2) Mean Providing a forum for discussion of issues impacting organic certification. 0 3.2% 3.2% 29% 64.5% 1. 6 Providing networking opportunities for certification organizations. 0 3.2% 3.2% 35.5% 58% 1. 5 Offering training for certifiers regarding NOP regulations. 0 0 9.7% 45.2% 45.2% 1. 4 Developing uniform criteria for implementation of the USDA National Organic Program. 0 3.2% 19.4% 48.4% 29% 1.0 Ensuring the integrity of organic certification in the U.S. 0 3.2% 22.6% 51.6% 22.6% 0.9 Interview responses indicated similarly positive assessments of the ACA. The ACA list serve was consistently cited as a productive mechanism for posing questions, sharing information, and building consensus among certifiers that supports consistency in certifier practices. As one interviewer commented, the ACA list serve helps to level the playing field, encourage transparency, and reduce widely divergent practices that encourage certifier shopping. Working groups and the ability to present unified c ertifier positions on a variety of the topic to the NOP were also cited as important services that the ACA provides certifiers. In a statement reflective of the leverage the ACA provides certifiers, one respondent said by going through the ACA and presenting to the NOPi f theres five or six certifiers our size or larger, that absolutely is going to carry some weight. Another ACA Report October 2013 Page 32

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commented Its a pretty powerful group that if something comes out of that group, the NOP tends to listen. Finally, the research team asked survey respondents to describe how the ACA might be more effective in meeting the needs of organic certifiers. Respondents were allowed to enter free form text detailing their ideas. Twenty (20) respondents offered suggestions centered on a few recurring themes listed below including sample comments by survey respondents: Internationalization Given the globalization of the organic food supply, the ACA is predominantly domestic with limited engagement from foreign certifiers. It would be good to have international representation. If the ACA could delve into the other programs outside of just the NOP (i.e. Canada and EU) to discuss certification, implementation, and interpretation issues, it would be helpful as a certifier and also to ai d in consistency of implementation of those programs. Representation for international certifiers. Communication Summarize the Listserv discussion including outcome or resolution. Provide a quarterly spreadsheet of the summary. It would be helpfu l to encapsulate the general agreement of topics on the Listserv rather than having to search the threads. Training Resources Provide resources to assist new certifiers, and their employees, such as best practice manuals for the certification process (input review, label review, etc.) I would like ACA guidelines or instructions on Material Review. More training. Certifiers interviewed for this project expressed clear appreciation for the ACA and the opportunity the organization provides for networking. Many survey respondents affirmed the actions and efforts of the ACA with their comments as well. The following comments represent the positive support for benefits the ACA provides: ACA Report October 2013 Page 33

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Considering the diversity of the group, [the ACA] does an exce llent job and provides a much needed service. I cannot imagine not having the ACA. I enjoy the conference calls associated with State agencies and unique issues with them versus private certifiers. I think [the ACA] has b ecome more diverse and stronger The services they provide there are great I dont know what else they could really do. I see no areas where they could improve. It is a very valuable resource for certifiers trying to consistently interpret the NOP rule. ACA Report October 2013 Page 34

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Section 3: Summa ry of Results Objective 1: To understand the strengths and weaknesses of the NOP, including the alignment of rules and actual practices of organic producers, handlers and certifiers, from the perspective of organic certifiers. All respondents agree the NOP is necessary to maintain consistency in organic food production (strength) According to results, some feel the NOP does not address the concerns of organic producers (weakness) 92% believe their organizations goals either Completely align or Mostly align with the goals of the NOP (strength) Small percentage of respondents (16%) helped develop the NOP but larger percentage regularly communicates with the NOP to discuss the regulation (68%). Objective 2 : To understand the emerging and evolving challenges organic certifiers face implementing the NOP rules and the strategies employed to overcome these challenges Most organizations manage a website to disseminate information and provide resources Paying accreditation fees and preparing for the USDA audit are the most difficult accreditation tasks for certification organizations Most understand what mandated accreditation tasks as required Biggest implementation challenge for certifiers is waiting for clarification on questions posed to the NOP Objective 3 : To understand interactions within the community of organic certifiers, between the organic certifiers and the USDA, as well as among the ACA and its members. Certifiers interact more frequently with their clients compared to their interactions with the USDA or other certifiers Certifiers interact with the NOP most often to resolve questions not addressed in the NOP regulation; few do so to report fraud Certification organizations interact among other certifiers on the ACA Listserv o r directly consult directly on specific products or scopes Respondents report mostly positive interactions among the with clients, the USDA, the ACA, and other certifiers Objective 4 : To identify the benefits of the ACA for member organizations, as well as opportunities for better services to the organic certifier community. Almost 80% of the respondents represent ACA member organizations Several nonmember respondents indicate they are located outside of the U.S. The most popular reason for interacting with the ACA was for t raining Interaction is characterized as a lways or u sually p ositive by 94% of the respondents ACA Report October 2013 Page 35

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ACA is most effective in providing a forum for networking and discussion among its members Could be more effective by: o Incorporating issues r elated to the globalization of the organic industry o Finding ways to summarize useful Listserv discussions o Offering more training Respondents appreciate the work and benefits of the ACA ACA Report October 2013 Page 36

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Section 4: Conclusions This study, part of a larger research project funded by the NSF ( (#1124541) entitled Assessing Policy Designs and Improving Outcomes: An Institutional and Behavioral Analysis of the U.S. National Organic Pr ogram was undertaken with the Accredited Certifiers Association to investigate the im plementation of the NOP regulation from the perspective of certification organizations. A specific objective of this research included an examination of the benefits offered by membership in the ACA and opportunities for enhanced services. The interview and survey responses reveal challenges faced by certification organizations, both in pursuing and maintaining accreditation and implementing the NOP regulations. Specifically, preparing for USDA audits and paying the accreditation fee present obstacles to certifiers in the accreditation process. Many certification organizations indicated implementation challenges are the result of interpretation Waiting for clarification on questions posed to the NOP and Applying the NOP penalty matrix. Overall, the report shows most certification organizations understand the mandated requirements of the NOP regulation, interact with one another in positive ways, and appreciate the services provided by the ACA. Many certification organizations are diversifying th e services they offer to their clients and believe the ACA can aid the efforts of certifiers by extending training events beyond the NOP regulations. The expanding global market for organic products may present opportunities for growth for the ACA. Several survey responses were received from organizations operating outside of the United States. Respondents expressed interest in joining the ACA. Finally, certification organizations expressed desire for a convenient way to review the ACA Listserv discussions. Some would like a summary of the exchange while others requested an archive that could be searched via keywords. ACA Report October 2013 Page 37

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Appendix A: Interview Que stion Guide Organizational Background 1. What are your responsibilities within your organization? Probe: What activities do these responsibilities entail? Probe: How do you responsibilities and activities relate to the NOP regulations? 2. What products does your organization certify? 3. How many organic operations does your organization currently certify and how long does a typical organic operation stay certified? 4. What are the different positions in your organizations, and what are the responsibil ities associated with those roles? Probe: Are certification tasks specified in the NOP regulations handled by different people/divisions within your organization? 5. Do you contract out any services (e.g., organic operation inspection)? 6. How are your personn el (in house and/or contracted) trained about to NOP procedures? 7. [IF the organization is not a public state organization] Is your organization a private, for profit organization, or a nonprofit, 501(c)(3) organization? Objective s 1 and 2 : To understand the implementation of and compliance with the NOP. 8. From our examination of the NOP regulations, there appears to be a sequence of activities associated with the continued accreditation process. We have simplified this sequence into five step s: (1) Conducting an annual performance evaluation and program review; (2) Submission of an annual report including an update of required information and the results of the most recent performance evaluations and annual program review; (3) Payment of accreditation fees; (4) A USDA audit once every five years, at a minimum; (5) And, ongoing record keeping of required certification information. How is this sequence of activities similar or dissimilar to how you perceive continuing accreditation for your organization? ACA Report October 2013 Page 38

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I am go ing to ask you about specific statements taken directly from the NOP about accreditation. Can you tell me about the extent that each statement is reflective of your actual practices, and how your practices may differ from each statement? Certifying agents (for continued accreditation) a. .must submit a description of any training that the certifying agent 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. b. must submit a description of the qualifications, including experience, training, and education in agriculture, organic production, and organic handling, for each inspector to be used by the applicant c. must conduct an annual performance evaluation of all persons who review applications for certification, perform onsite inspections, review certification documents, evaluate qualifications for certification, make recommendations concerning certification, or make certification decisions d. must have an annual program review of its certification activities conducted by the certifying agent's staff, an outside auditor, or a consultant who has expertise to conduct such reviews Certifying agents (during certification) a. must submit to the administrator any notice of denial of certification issued pursuant to 205.405, notification of noncompliance, notification of noncompliance correction, notification of proposed suspension or revocation, and notification of suspension or revocation sent pursuant to 205.662 simultaneously with its issuance. b. must notify the inspector of its decision regarding certification of the production or handling operation site inspected by the inspector and of any requirements for the correction of minor noncompliances. c. must charge applicants for certification and certified production and handling operations only those fees and charges for certification activities that it has filed with the Administrator d. may conduct additional onsite inspections of applicants for certification and certified operations to determine compliance with the Act and the regulations in this part. e. must ensure that its responsibly connected persons, employees, and contractors with inspection, analysis, and decisionmaking responsibilities have sufficient expertise in organic production or handling techniques to successfully perform the duties assigned. ACA Report October 2013 Page 39

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f. must ensure that the decision to certify an operation is made by a person different from those who conducted the review of documents and onsite inspection 9. Wh at aspects of the NOP Rule have been the most difficult to implement and how have you overcome these difficulties? 10. To what extent do certifiers strictly adhere to the NOP Rule? Objective 3 : To understand the relationship between 1) certifiers and the USDA ; 2) certifiers with other certifiers; and 2) certifiers and organic operations. 11. How often do you (or members of your organization) interact with USDA personnel? 12. For what purposes do you (or members of your organization) interact with USDA personnel? 13. To what extent are these interactions positive or negative? 14. In reference to your more recent interactions, what extent have USDA enforcement personnel been effective in administering and assessing certifier compliance with the NOP rule? Probe: Are enforc ement personnel knowledgeable about organic farming processes, regulations, certification processes, the organic farming industry, etc.? 15. How often do you (or members of your organization) interact with other certifiers? 16. For what purposes do you (or members of your organization) interact with other certifiers? 17. To what extent are these interactions positive or negative? Probe: To what extent do certifiers cooperate/compete with one another? 18. How often do you (or members of your organization) interact with org anic operations? 19. For what purposes do you (or members of your organization) interact with organic operations? 20. To what extent are these interactions positive or negative? Objective 4: To identify the benefits of the Accredited Certifiers Association for member organizations, as well as opportunities for better services to the organic certifier community. 21. What activities/actions does the Accredited Certifiers Association perform that prove valuable to organic certifiers? ACA Report October 2013 Page 40

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Probe: How, if at all, have th e services provided by the Accredited Certifiers Association changed over time? 22. What activities/actions not currently performed by the Accredited Certifiers Association would be helpful to organic certifiers? 23. What lessons have you learned over time relativ e to organic policy and organic certification? 24. Are there any questions regarding organic certification and the NOP that I have not asked you that you think I should have? ACA Report October 2013 Page 41

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Appendix B: Survey Questionnaire Accredited Organic Certifier Survey This survey seeks to understand national organic policy and certification in the United States, including: National Organic Program (NOP) implementation and program administration; Certifier interpretation of, and action related to, the NOP regulatio n; Interactions between the NOP, accredited certifiers, and certified operations, and; The benefits and possible opportunities for improvement of the Accredited Certifiers Association. If you have questions about this survey please contact Sara Miller Chonaiew via email at schonaie@iupui.edu. Please click the Next button below to begin the survey. 1 How many operations does your organization currently certify as USDA organic? Fewer than 50 50 200 201 400 401 600 601 1000 More than 1000 2 How many employees does your organization currently employ? ______ Full time ______ Part time ______ Contract or Seasonal 3 For how many years has your organization been operating? Less than 1 year 1 5 years 6 10 years 11 15 years More than 15 years ACA Report October 2013 Page 42

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4 Which of the following business structures best describes your organization? Check all that apply. Private Non profit Other, please describe: ____________________ Public Part of university extension 5 Please indicate the categories of organic commodities produced by the operations you certify as USDA Organic. Check all that apply. Vegetable c rops Herb crops Nursery, fl oriculture, greenhouse crops Apiculture Brambles, berries Tree or vine fruit, nut crops Grains, alfalfa, mixed hay, other field crops Other, please list: ____________________ Beef Poultry Dairy products Lamb Pork Honey Eggs 6 Does your organization provide certification services for operations in countries other than the U.S.? Yes No Answer If Does your organization provide certification services for... Yes Is Selected 6a Please list countries outside of the U.S. for which your organization provides certification services. ACA Report October 2013 Page 43

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7 Does your organization provide certification for labeling standards other than the USDA organic program? Yes No Answer If Does your organization provide certification for eco labe... Yes Is Selected 7a Please list the labeling standards for which your organization provides certification. ACA Report October 2013 Page 44

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8 In addition to certifying responsibilities included in the NOP regulation, please indicate which of the following activities your organization performs. Check all that apply. Offer training or workshops to help clients understand the content and requir ements in the NOP r egulation Regularly send a newsletter or other document to clients containing informatio n relating to NOP regulation Manage a website that contains informational resources relating to the NOP regulation Host venues for clients to meet and exchange information regarding NOP regulation and the organic certification process Engage in informal discussions with clients regarding the NOP regulation or the o rganic certification process Other, please describe: ____________________ 9 The NOP regulation lists general activities required for continued accreditation. Please indicate the level of difficulty associated with the following activities: Not difficult Minor difficulty Major difficulty Do not complete Conducting an annual performance ev aluation and pr ogram review. Submitting an annual report including an update of required information, results of the most recent performance evaluation s and annual program review. Paying accreditation fees. Preparing for USDA audit once every five years. Maintaining records of require d certification information. ACA Report October 2013 Page 45

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10 In consideration of your organization's practices and preparations for submitting the annual report to the NOP, please indicate which practices listed below you consider Required, Optional, or Not allowed. Required Optional Not allowed ...notify the inspector of its decision regarding certification of the production or handling operation site inspected by the inspector and of any requirements for the correction of minor noncompliance. ...charge applicants for certification and certified production and handling operations only those fees and charges for certification activities that it has f iled with the Administrator. ...conduct additional on site inspecti ons of applicants for certification and certified operations to determine compliance with the Act and t he regulations in this part. ...ensure that its responsibly connected persons, employees, and contractors with inspection, analysis, and decision ma king responsibilities have sufficient expertise in organic production or handling techniques to successfully perform the duties assigned. ...ensure that the decision to certify an operation is made by a person different from those who conducted the review of docum ents and on site inspection. ...submit to the administrator any notice of denial of certification issued pursuant to 205.405, notification of noncompliance, notification of noncompliance correction, notification of proposed suspension or revocation, and notification of suspension or revocation sent pursuant to 205.662 simul taneously with its issuance. ACA Report October 2013 Page 46

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11 Some certifying organizations have indicated challenges with the following implementation activities. Please indicate the l evel of difficulty associated with the following activities for your organization: Not difficult Minor difficulty Major difficulty Do not complete Appl ying the NOP Penalty matrix. Conducting unannounced inspections of organic operations in addition to annua l certification inspections. Testing products periodi cally for pesticide residue. Identifying genetically engineered organisms via product tests. Preparing for NOP monitoring audits of accredited certifiers in addition to the required accreditation audit t hat occurs every five years. Responding to NOP investigation of c lients of your organization. Adhering consistently to the National List of Allowed and Prohibited Subs tances. Waiting for clarification on questions posed to the NOP. Spreading of organic practices to products not explicitly addressed by NOP regulations. Responding to growth of the US organic market to include imported interna tionally produced products. ACA Report October 2013 Page 47

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12 Please specify your role in the development of the NOP regulation. Check all that apply. In the last five years, I have been a regular participant in public meetings r egarding the NOP regulation. In the last five years, I have regularly communicated with USDA representatives to discuss the NOP regulation. In the last five years, I have served on at least one advisory committee or participated in processes that provided recommendations to the USDA about the NOP regulation. I contributed to the initial develo pm ent of the NOP regulation. I have not participated in the develo pment of the NOP regulation. 13 Please indicate your level of agreement with each of the following statements relating to the NOP regulation. The NOP regulation... Strongly agree Agree Ne ither agree nor disagree Disagree Strongly disagree is necessary to maintain consistency in organic food productio n among different producers. addresses the co ncerns of organic producers. addresses public concerns about the integ rity of organic commodities. maintains the ecological h ealth of agricultural lands. protects t he health of farm employees. protects the health of consumers. supports economic development by creatin g highly valued commodities. provides predictable monitoring and enforcement mechanisms in organic food production. ACA Report October 2013 Page 48

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14 To what extent do the goals of your organization align with the goals of the NOP? Completely align Mostly align Somewhat align Do not align at all 15 How often do you (or members of your organization) interact with NOP personnel? Daily Weekly Monthly Annually 16 For what purposes do you (or members of your organization) interact with NOP personnel? Seek clarifications on specific ingredients Resolve questions not add ressed in the NOP regulation Report fraud Iss ue a notice of noncompliance Other, please list: ____________________ 17 Are your (or members of your organization) interactions with NOP personnel generally positive or negative? Always positive Usually positive N either positive nor negative Usually negative Always negative 18 How often do you (or members of your organization) interact with other certifying organizations? Daily Weekly Monthly Annually 19 For what purpos es do you (or members of your organization) interact with other certifying organizations? Discuss a shared client Consult on specific products or scopes Contribute to or respond to Listserv posts Other, please list: ____________________ ACA Report October 2013 Page 49

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20 Are your ( or members of your organization) interactions with other certifying organizations generally positive or negative? Always positive Usually positive N either positive nor negative Usually negative Always negative 21 How often do you (or members of your organization) interact with your clients? Daily Weekly Monthly Annually 22 For what purposes do you (or members of your organization) interact with your clients? Respond to client inquiry Visit site unannounced Visit site scheduled Other, please li st: ____________________ 23 Are your (or members of your organization) interactions with your clients generally positive or negative? Always positive Usually positive N either positive nor negative Usually negative Always negative 24 Are you currently a member of the Accredited Certifiers Association? Yes No Answer If Are you currently a member of the Accredited Certifiers A... No Is Selected 24a Please describe why you are not a member of the Accredited Certifiers Association. ACA Report October 2013 Page 50

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25 Please indicate how effective the Accredited Certifiers Association has been in performing the following functions: Very effective Effective Neith er effective nor ineffective Ineffective Very ineffective Ensuring the integrity of organic certification in the U.S. Developing uniform criteria for implementation of the US DA National Organic Program. Offering training for certifier s regarding NOP regulations. Providing networking opportunities f or certifying organizations. Providing a forum for discussion of issues impa cting organic certification. 26 How often do you (or members of your organization) interact with Accredited Certifiers Association personnel? Daily Weekly Monthly Annually 27 For what purposes do you (or members of your organization) interact with Accredited Certifiers Association personnel? Training During par ticipation in working groups Serving on ACA Board Other, please list: ____________________ 28 Are your (or members of your organization) interactions with the Accredited Certifiers Association personnel generally positive or negative? Always positive Usually positive N either positive nor negative Usually negative Always negative 29 Please describe how you think the Accredited Certifers Association can be more effective in meeting the needs of organic certifiers. ACA Report October 2013 Page 51

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30 Please indicate your professional role(s) within your organization. Check all that apply. Owner or Manager Ad ministrative assistant Inspector Accountant Marketing specialist Compl iance officer Human resources manager Other, please describe: ____________________ 31 What is your age? Under 25 26 35 36 45 46 55 Over 55 32 Are you female or male? Female Male 33 Is there anything else you would like to share with us related to organic accreditation, certification, and the NOP? 34 Would you like to receive a copy of the survey results? Yes No Please click the Submit button below to complete the survey. ACA Report October 2013 Page 52