OCIA has created an Emergency Remote Inspection Policy and Procedures document. This summary explains the main points of the policy and procedure.
- It is recommended that operators stay inspection-ready at all times. As on-site inspections are preferred and there may be pockets of time for inspections to be conducted, inspectors and operators must be ready to take advantage of these windows. At such times new applications, high-risk operations, and operations requiring on-site follow-up inspections will be prioritized.
- Additional surveillance, such as unannounced inspections and sample collecting, will be paused unless they can be conducted off-site. Remote surveillance may be possible in the case of unannounced inspections.
- Remote Inspection is an inspection completed remotely but in their entirety, covering opening meeting, records review, facility and/or field verification, and exit interview. This is an inspection that may be performed via web meetings, teleconferencing, or other electronic verification of processes. This type of inspection can also be known as an e-inspection or virtual inspection, and follows the same guidelines as an on-site inspection, but uses electronic or alternative means to collect objective evidence. This type of inspection includes a virtual live interaction between the operation and the inspector, and visual verification of on-site processes.
- Remote Desk Audit: A records audit is performed based on documents and information requested from the operator. Records audits consist of requesting a set of records, reviewing that set of records, and then where at all possible, discussing any questions or concerns with the operation – with the ability to both look at the relevant records at the same time. Operations subject to a records audit will be prioritized for on-site inspection upon availability.
OCIA inspectors will conduct a remote inspection or remote desk audit in these rare cases where conditions are such that an in-person on-site inspection cannot be conducted due to unsafe conditions or travel restrictions. The inspector must follow all protocols of the inspection process whenever possible.
For operators without video conferencing capabilities, we encourage them to partner with a friend or neighbor that can provide this service for the duration of the inspection if this is possible and safe.
- Authorization is received from OCIA
- Inspector receives and reviews operator file from OCIA
- Initial contact with operator, which will include additional records request and discussion of technology to be used
- The inspector will review the additional documentation and create the inspection schedule
- The inspector will schedule the remote inspection
- Exit Interview, including details of what could not be verified and any on-site follow-up recommended.
- OCIA may conduct follow up on-site visits once emergency conditions return to normal. These will be determined by a combination of factors including risk assessment of the operation and numbers of remote inspections conducted. These follow-up visits may be announced or unannounced, may be full or limited in scope, may include sample taking at the operation or at retail, and are intended to ensure compliance to the organic standards that OCIA is accredited to.
- Even when all possible aforementioned technological means of on-site verification are available for an remote inspection, the inspector may decide that they were unable to fully audit and inspect the operation in question, and may recommend follow-up inspections in the Exit Interview. The inspector should detail what parts of the Organic System Plan and/or operation were not fully verified. OCIA will take these inspector recommendations into account when determining which operators will require follow-up inspections.
- If follow-up is required the operator and inspector will be notified. General guidelines indicating a follow-up will be needed:
- If it is a new application or transfer for COR
- For all programs: there is a new location, new scope, or new field being added, a follow-up inspection onsite will be needed. If fields or other physical OSP elements cannot be verified.
Where programs have specific requirements, OCIA will follow them. Some special information has been indicated for these programs:
- NOP: Inspections may be conducted remotely for renewing applications, but an on-site inspections is required before certification can be granted to new applicants.
- EU Equivalency: Remote inspections can be conducted until June 1, 2020. This may be extended.
- Bio Suisse: Remote inspections may be conducted if allowed by EU.
- LPO: Update coming soon.
- JAS: Inspections may be conducted remotely.
Required On-Site Inspections
Where on-site inspections must occur, the operation must sign an addendum to the Operator Licensing Agreement. Additionally the ON-SITE PRECAUTIONS FOR INSPECTORS DUE TO COVID-19 (below) will be followed.
The time on-site will be limited as much as possible, so the inspector will complete a robust remote inspection and/or records audit. The inspector then will conduct a brief and socially distanced on-site inspection (in which the operator is still verifying compliance, in accordance with all relevant social distancing norms, recommendations, and orders). This will keep inspectors and operations safe by limiting exposure, and will support new operations entering the market.
ON-SITE PRECAUTIONS FOR INSPECTORS DUE TO COVID-19:
As on-site inspections are required in certain cases without exception (e.g. new applicants), inspection can occur upon mutual agreement of the operation and inspector provided that the following measures are followed. Inspections in high-risk areas (with 20 or more confirmed cases) will be suspended immediately.
For all inspections to be performed, we ask inspectors and customers to follow the minimum precautions as established by the World Health Organization. We recommend these precautions be put in motion during any inspection:
- If the inspector or operator, or anyone participating in the inspection on behalf of the operator, is displaying any symptoms (e.g. fever, ill), the inspection must be postponed. If, during the inspection, an inspection participate begins to display any symptom, the inspection should be terminated immediately.
- Inspectors who are in a higher risk category need to assess their ability to conduct in-person inspections. If an inspector is unable to conduct on-site inspections, they should inform OCIA. Doing so will not impact the inspector’s future inspection assignments from OCIA.
- Reject greetings with physical contact, no handshakes or elbow taps.
- Only essential personnel participate in the audits, limit non-essential participants. This means that spouses, children, or non-operation employees be present for the inspection.
- Incorporate social distancing whenever possible and increase the space and decrease the frequency of contact between individuals.
- Conduct audits in areas that allow individuals to remain two meters (6 feet) apart from each other and keep people as separate as practical.
- Inspectors must ride separately from the operator when visiting fields.
- When handling documents, frequently practice hand hygiene, use hand sanitizer, and do not touch your face. Gloves are advised when handling documents.
- Masks should be worn by all those present for the inspection.
- The inspector is encouraged to walk around the operation on their own, and may consider talking to the operator on the phone even while on-site to maximize separation. If possible, any file audit or paperwork review should be conducted outdoors or outside of the living area/home of the operator. Ideally, such review can be conducted remotely prior to or after the on-site portion of the inspection.
- Inspectors should not enter an operators home or living area unless absolutely necessary.
See the CDC website and your local health department website for further information on prevention.