Inspector is a ACT staff. Inspector is trained both theoretically and practically before registered as ACT inspector.
Inspector’s job is to inspect the farm and operating site and verify that the information in application and other documents (production plan) is correct. He/she also checks whether the production activities and management comply with applicable organic standards.
All inspection expenses are to be paid by ACT. Inspector has no right to demand for any extra expenses from the operator. Also, inspector is not allowed to receive any valuable gift or present from the operator.
If operator encounters any inspector having inappropriate behavior, please lodge a written complaint to ACT manger.
8.2 Type of Inspection
Inspection can be divided into 3 types.
(1) Initial inspection
This is an important inspection where all farm unit and relevant operation units are inspected. This inspection and assessment is served as a guidance for the operator to understand and adjust its management to comply with applicable organic standards. It also serves as a basis for future inspection.
(2) Annual inspection
This is a normal inspection which must be performed annually at least once a year. Annual inspection is an announced inspection where the operator is informed of the inspection schedule in advance.
(3) Extraordinary inspection
This inspection is in addition to annual inspection. It is organized based on the need from various reasons such as the applicant’s request for extension of scope, a corrective action of certification decision, a complaint, suspicion or risk of non-compliance, appeal, or the ACT internal quality assessment. This inspection may
be announced or un-announced.
8.3 Inspection methodologies
Normally, inspection will take place after ACT has received completed production plan (as part of application document or annual renewal document) and certification fee is paid. ACT will inform the operator in advance who is the assigned inspector to do the inspection.
The operator has the right to object the assigned inspector. The objection must accompany with proper reason, e.g. the assigned inspector has direct conflict of interest with the operator and his/her inspection may not be objective. The operator must submit the objection in writing to the ACT manager. However, ACT reserves the right to decide whether to accept the objection and to assign who will do the inspection.
The inspector will contact the operator for making an appointment directly. On the date of inspection, the operator must be present at the farm or operating site during inspection visit. If there is an urgent need, the operator may contact the inspector for re-scheduling the appointment.
The operator must cooperate with the inspector during the inspection whether announced or unannounced. For the announced inspection, the operator and responsible staff for the production and/or processing must be at the production site to provide information to inspector.
If the operator causes a delay in the inspection, resulting in the increase of inspection costs. In this case, ACT may invoice additional inspection fee.
In general, organic inspection is done with the following steps:
(1) Opening, introduction, inspection planning and interview of operator and responsible staffs involved in the organic production;
(2) inspecting farm and operation sites, both organic and conventional;
(3) separation of organic product throughout the production process;
(4) inspecting production documents, e.g. purchase records, farm input application records farm activities records;
(5) inspecting processing records such as certificate of ingredient, ingredient purchase order, ingredient receipt, ingredient stock, processing/packing record, finished product stock, sale/delivery record, cleaning record, processing plant’s pest control record, complaint record, and other relevant documents;
(6) inspecting the product labeling, traceability, and input-output conciliation;
(7) inspecting the labour policy and interview workers (only for applicant of IFOAM Programme)
(8) exit meeting
When the inspector completes the inspection work, the inspector must summarize and inform the operator of the non-conformities found during inspection. Around within 30 days after the inspection, the inspector will send the inspection report to the operator to review whether the report accurately reflect what has happened during the inspection and to sign off the report.
If the operator disagree with part of the report, the operator can submit his/her comment in writing to ACT. ACT will take the operator’s comment into consideration for certification decision.
8.4 Sampling for Residue Testing
Normally, ACT does not have policy to use the laboratory analysis (chemical residue) for certification decision. This is because residue testing does not indicate how the organic production take place. Besides, residue analysis is also quite expensive and takes a long time.
However, in case where farms, storage, or operation unit has high risk or evidence of contamination, the inspector may take sampling of water, soil or produce for chemical residue analysis at a laboratory. When a sample is collected, the operator must sign off sampling form.
In addition, in case where ingredients or additive intended to be used for organic processing are suspected or having risk of GMOs contamination, ACT may take sampling for GMO analysis.
The cost for laboratory analysis shall be responsible by the operator, except when the testing is done as part of the ACT internal quality control system.