Organic CB Workshop Opportunity
To better equip you for these transitions, we are contemplating a comprehensive CB workshop this upcoming fall on November 7 & 8. Your participation will facilitate an in-depth review of potential options and approaches. We are considering bringing our expert product managers and specialists to this event, including at our corporate headquarters in Santa Cruz, CA. The cost structure will be based on a per-attendee basis, covering travel and time. This workshop will delve into the aforementioned areas and highlight additional aspects of Intact functionality that could benefit you. Your proactive engagement will be invaluable in shaping the workshop’s content and structure.
Data Reporting to the Organic Integrity Database
Intact supports the National Organic Program Organic Integrity Database and believes it is an asset to the organic community and a leading system globally. OID becomes an even more important system as increased reporting comes into effect, certificates are generated from the system by both domestic and foreign certifiers, and the import certificates module is finalized to support SOE requirements.
We believe the NOP is committed to this system and will continue to improve it over time. Intact is working diligently within the existing framework and available tools to support your needs.
Specifically, SOE includes the requirement to update the OID system within 72 hours of a certification status change and, as a practical matter, more immediate updates for new certifications to support the issuance of the federated certificate. This poses several challenges to NOP CBs, who must either update manually frequently or may need to maintain many internal logins for staff to process day-to-day certifications. Similarly, the NOP has stated that previously optional fields in the OID data dictionary will become mandatory in the future. These include elements such as acreage and operation type. It is unclear how taxonomy will be handled in the future and whether continued reporting under “other” will be supported. Intact fundamentally supports alignment with and utilization of the NOP taxonomy and assists you in devising an appropriate approach.
Oh my, why? Can’t we do this with an API?
Maybe. The NOP has identified APIs as a solution to reduce the impact of the standard in the published rule (here and here, too). The OID database has available documentation regarding an inbound directory update API that has been available for some time. Intact is actively investigating this API functionality and requirements and plans to implement any development or customization in Q1 2024. We hope to have an available solution soon and welcome early adopters to participate. We hope to have a functioning system to support immediate data delivery to NOP on an ongoing basis to support your operations. We expect an API system to have some complexities and ongoing maintenance; therefore, it will be offered as a subscription product after we invest in the base functionality.
Possible API Challenges: To support a viable generic API, particularly with many required data elements, a high degree of consistency is needed. Therefore, with early adopters, Intact is defining a standard approach of using locked custom fields for gathering and maintaining new unique data for NOP reporting. We will seek ways to standardize other data elements as various existing OID exports differ between customers.
Additional challenges remain with the high degree of variability and preference in how organizations structure their systems and data. We are actively investigating whether a standardized system with data transformation or some more malleable approach is appropriate.
APIs, in general, require maintenance and careful testing. The NOP inbound API is likely well built, but it has not been tested under load or frequency of use, and it is unclear how it will work as data requirements change (such as making optional fields mandatory). There may be technical, operational, or other challenges. We have extensive API experience and daily move data into and out of the Intact Platform. However, until fully built and tested, it is not confirmed whether the existing untried API will meet your needs.
Bottom line: Data reporting is changing. Work with Intact to review your current data and reporting to ensure you are ready for SOE. Intact is working on an API solution, but it is not guaranteed. Customers must ensure their base data is sound and work with a common structure to be successful and reduce costs.
What do I need to do? NOP access requires you to identify your interest and request access credentials from NOP. Any customer who hopes to have API access or to explore the option should contact NOP and request credentials in a timely manner. Sign up to be part of our API early adopters. Be prepared to upload OID data manually via spreadsheets.
Certification and Certificates
Certificates: The NOP SOE requires certificates to be generated from the OID system. This poses new challenges and workload for NOP CBs, and Intact is sympathetic to this issue. Not, however, that this requirement and structure are not unique, and a centralized certificate is common in a variety of standards.
Certificate APIs TBD: Many customers desire an automated certificate generation, extraction, and upload functionality between the OID and Intact systems. This is not possible at the moment. Currently, no such API or functionality exists within OID; certificates can only be generated by an authenticated CB user you have authorized via your admin login to OID. NOP understands the concern but is focused on the import certificate module. There is no current plan to our knowledge to provide such an API/functionality in the immediate term. Therefore, certificates will need to be generated by CB staff after updating a new record, extracted, and uploaded/sent to customers directly. Intact’s Manual Certificates functionality will provide a method to upload certificates with the properties and role of a certificate in the Intact Platform. Addenda/Profiles will remain.
We encourage CBs to work with NOP, express their needs, and support funding for such developments where appropriate. Intact will also remain in communication with NOP, but your voice is critical to supporting NOP’s decision-making and priorities.
Certificates Bottom Line: CBs should prepare themselves operationally to generate and extract certificates from the NOP system via a centralized function or individual logins for reviewers. Intact will support NOP certificate uploads to our “Manual Certificates” add-on module functionality, allowing an uploaded document to take the form and function of a system-generated certificate.
We recommend working with the new system and testing all functions before March 1, 2024 and planning for an early transition so you can work out any issues before the required compliance date.
Bottom line: Certificate generation is changing dramatically and will likely be an operational challenge. We recommend practicing and preparing your organization for this as soon as practical. Contact NOP and ask them to prioritize this area of operational inefficiency through APIs, etc.
Profiles and Certificate changes: Existing addenda documents must be modified to include the NOP’s SOE specified language and may benefit from direct links to OID before March 19, 2024. Where CBs have developed a single report to generate the certificate and addenda document together, this must be adjusted.
SOE includes the requirement to manage customer risk and utilize this for decision-making. Intact’s Risk Rating system can be easily configured to give you a clean, organized, integrated process. Intact will not be programming a risk analysis or rating generation system but does provide a risk rating functionality where risk can be set on contract/service level and modified during audit and review.
This functionality ensures that you have a clear rating. It can be according to whatever scale you prefer and is managed during the audit and review so you not only ensure risk is considered, but you can also demonstrate compliance and competent management of this element during accreditation. Implementation requires minor configuration and administration.
SOE includes specific requirements for the performance and management of witness audits. Several Intact customers use the Performance Review Audits module add-on to succeed in this area. The Intact Platform will help you perform quality, organized, and effective witness audits.
This functionality allows you to create audits against the auditor, perform them, and raise findings/areas of improvement for the auditor to address. These witness audits can then run through review and are organized, efficient, perfectly documented, and available for accreditation.
When coupled with Intact’s Track and Solve Auditee Portal, the auditor can respond online and learn how to teach customers to use the same portal.
Intact strongly recommends using this module and the creation of all required witness audits at the outset of the year, as this will help you avoid missing these difficult-to-schedule and perform audits.
SOE requires specific auditor and reviewer qualification, training and experience criteria, and tracking. The Intact Platform has highly flexible qualification, training, and experience recording standard functionality under auditors and reviewers. Several CBs already require reviewers to record training and other elements in this area. Intact is working to transition this functionality to the web to support online addition by staff members complementary to the use of the desktop client application. We currently do not plan to pre-populate this area with standard drop downs or other values, but it is easily administrated to fit your needs.
Intact has produced an Advance Qualification Module that supports entering detailed data and other criteria to support qualification decisions. It can be deployed to larger CBs or as a centralized system at a national or regional level.
Supply Chain, Suppliers and Investigations
We have received differing feedback in this area. Some CBs would prefer various large-scale data integrations; others see no substantive change to existing operations beyond additional clarity of expectations. We have received feedback from some CBs that they would like a complete supplier and ingredient tracking functionality. This would be an investment that would require some CB teamwork and investment. We do encourage you to submit these elements as feature requests, however.
Intact has developed a robust industry-level Feedback Functionality within our International Aerospace Quality Group (IAQG) deployment (see https://knowledgebase.intact-systems.com/display/public/FEED/Feedback). This toolset supports straightforward inquiries, follow-ups, and information sharing utilizing existing data. NOP, ACA, or others could adopt this solution, and Intact would welcome an exploration of the topic.
Annual audits, updates, and season rollovers: SOE includes the modification allowing for minor, simpler updates from operations and a significant change in audit timing requirements. Annual audits must be performed in the calendar year but are not tied to a renewal, expiration, or previous audit date. Similarly, Intact is focused on reducing the role and necessity of the season functionality and season rollover in our software. While useful in many aspects, such as search performance and oversight, it is also a source of confusion.
As a result, annual audits may be created at the outset and managed for maximum compliance and organizational capacity optimization. For instance, as a practical matter, an initial audit can occur in October and a subsequent annual monitoring audit the following January or February if it is in your interest from a compliance or operational perspective.
What does this mean for you and Intact? Moving forward, we encourage you to roll over your season late in each year or very early in the year and create ALL annual audits at that time to support your allocation planning. If operations fail to renew, you may simply remove the audit. This will help ensure that no operation is accidentally not audited and will help you manage workload and capacity over the year.
International CBs and Import Certificates
GLOBAL, the International OID: SOE includes a highly proactive and ambitious goal of requiring all entities importing to the US to be listed in the OID database. Similarly, all shipments to the US of organic goods, including overland trucking, must carry import certificates. These certificates will be tied into the larger US trade systems. These systems are a significant development and area of technology and operational focus to the NOP. With you, we are awaiting more details about the requirements and functionality. It is not known if existing APIs for OID will work for the GLOBAL system.
Intact does not expect that import certificates will carry API functionality. We can provide the existing Intact Transaction Certificate functionality at an essential level to support import certificates by providing a clear, simple, and organized repository for adding, tracking, and making import certificates available for your internal staff, inspectors, and customers. This creates a strong tracking mechanism and a way to track basic volume and other data associated with certificates you import. We expect this to support your compliance tracking, such as the ability for an inspector to review an import certificate and track its origins and audit trail back.
Intact has improved file handling and provides a download and upload functionality for local PDF and Document editing using the web interface. See Jake Lewin’s Upgrade Your Game presentation from the 2023 Intact Summit for more information. Details coming soon.