Training Course in the Evaluation of Internal Control Systems (ICS) for Smallholder Group Certification © IFOAM, October 2004 Authors: Florentine Lechleitner (IMO) & Ute Eisenlohr (IMO) Supported by Nabs Suma (Twin Trading), Bo van Elzakker (Agro Eco) and Gerald A. Herrmann (Organic Services)

Harmonization in Smallholder Group Certification For many years smallholder groups have been certified organic on basis of an ICS, but according to different requirements. Also, the EU has published a guidance document for all EU import authorities in which the certification of smallholder grower groups in developing countries is regulated and minimum external re-inspection rates be defined. A new harmonized IFOAM ICS Guidance Manual has therefore been developed to harmonize ICS requirements.

IFOAM ICS Projects Harmonization: - three smallholder harmonization workshops since 2000 - lobbying for an EU guidance document on smallholder group certification Project 1: a) revised ICS Guidance Manual for producer groups b) Training manual for setting up and harmonizing ICS (with 3 pilot trainings) Project 2: a) Protocol for ICS inspection & evaluation b) Training manual for ICS inspection and evaluation (for inspectors and certification staff) Project coordination (both projects): IMO Switzerland

Principles of Smallholder Group Certification A central body within the farmers group ensures the compliance of all smallholder farmers with an organic standard. The Group has a formal internal control system (ICS). One certification for the group (not for individual farmers).

Definition of an ICS IFOAM Definition: An internal control system (ICS) is a documented quality assurance system that allows the external certification body to delegate the annual inspection of individual group members to an identified body/unit within the certified operator.

Basic Types of Smallholder Projects A processor, exporter, or an NGO operates the ICS Contract Production A cooperative or a farmers association operates the ICS

Overview of Certification Requirements An Internal Control System (ICS) (1&2) has written procedures & forms (ICS Manual). (3) is aware of risks and critical control points. (4) has an internal organic standard. (5) has documented effective procedures for internal farm inspection, internal approval, and dealing with non-compliances. (6) has qualified personnel and a clear structure. (7) ensures training of farmers as well as of ICS staff. (8) handles/supervises organic product flow control. Farmers in the organic grower group (Numbering refers to chapters in the IFOAM ICS Guidance Manual)

(1&2) ICS Manual and Description of Activities The ICS must have documented and standardized policies, procedures, and forms, i.e., an ICS manual. See the IFOAM ICS Guidance Manual for an example. Can also be organized as separate documents. Many organizations already have an ‘internal regulation’ that could be considered a basic ‘ICS Manual’ in the sense of the new IFOAM ICS approach as presented in this course. The ICS operator has to present (e.g., in the ICS Manual) a brief overview of its organization and registered farms, as well as on buying and handling procedures.

(3) Risk Assessment and Risk Management Risks that may jeopardize organic quality must be known and taken into account in all internal procedures. Therefore, the ICS must do an initial risk assessment. All necessary measures must be taken by the ICS to minimize risks. The external inspector has to do an overall risk assessment to determine the minimum re-inspection rate and to be aware of critical control points.

(4) Internal Organic Standard The internal organic standard outlines the farm production requirements in a way that can be understood by farmers and ICS staff. takes account of all applicable standards as far as these requirements are important and relevant for the operation. Prepare compost No chemical fertilizer No synthetic pesticides Control soil erosion

(5) Internal Control and Approval Procedures 5.1 Registration of new farmers: basic farm data, contract, map 5.2 Internal inspection effective inspections, detailed internal inspection checklist 5.3 Yield estimates 5.4 & 5.5 Internal approval & sanction procedures approval procedures; sanctions must be appropriate & effective 5.6 ICS documentation for each farmer and summarizing farmers lists

(6) Organization and ICS Personnel One person is responsible for the overall ICS implementation but may delegate responsibilities so that, for each ICS procedure or task, one person is in charge. All personnel must be qualified and aware of their responsibilities Conflicts of interest must be avoided. BOARD OF DIRECTORS MANAGING DIRECTOR (Ali Muheza) EXPORT MANAGER (Charles Mulogo) PRODUCTION MANAGER/ COORDINATOR (Edward Mulagwe) FINANCE MANAGER (Thomas Tutu) PROCESSING/ OPERATIONS MANAGER Kitende (Mwatima Juh) Zanzibar (Betty Banja) Morogoro (Sebastian Shanga )

(7) Training Farmers have to be trained in organic farming methods and the rules for organic farming : - field advice - and/or farmers trainings ICS personnel must be continuously trained in order to be aware of organic farming practices, certification requirements and important internal procedures.

ICS Inspection Protocol The following documents are available as a basis for ICS inspection & certification. This course is based on the requirements and procedures as outlined in these documents. ICS Inspection Procedures Procedures covering application for certification, inspection planning, inspection and certification. New rules for determining the minimum re-inspection rate ICS Inspection Report Description of the activities of the group Evaluation by verification of compliance criteria. Compliance criteria are numbered according to their order in the report ICS Compliance Criteria with Comments for Inspector Lists again all compliance criteria (as in report), but with more details The order of presentation follows the actual workflow during inspection: preparation, ICS-office, farm re-inspection Offers comments/interpretation guidance for the inspector regarding certain criteria

Structure of this Training Course All numbers of the compliance criteria in this course refer to the numbers of the criteria in the new IFOAM ICS inspection report / ICS compliance criteria document and no longer to a chapter of the ICS Guidance Manual! How to verify? ICS documents Interviews Field visits Structure: 1. Introduction 2. Overview of inspection procedures 3. Inspection schedule & risk assessment 4. Inspection of the ICS (office) 5. External re-inspections 6. Inspection of product flow 7. Reporting, evaluation, & certification

Important Terms Organic: CERTIFIED according to a certain organic standard Conventional = not organic = not certified ICS Operator: Body that organizes the ICS; this is usually the farmers cooperative or the contracting processor ICS Manual: compilation of all documents regulating the ICS: policies, procedures, forms, etc. Non-compliance: a standard requirement is not met. A non-compliance always refers to a certain organic standard, e.g. spraying Ambush is a non-compliance because not in standard, but spraying copper is allowed because it is allowed in standard. Prohibited: not permitted according to certain standard Approval : internal ‘certification’ by ICS according to the internal organic standard and procedures Certification : certification by the (external) organic certifier according to regulations, public or private organic standards