Internal Control Systems for organic smallholder farmers
There has been a lot of work in recent years on standardising the rules for internal controls systems (ICS) for organic smallholder farmers. This is a short summary of the requirements, which have been developed by the International Federation of Organic Agriculture Movements (IFOAM) after extensive consultation with the major international certifiers. Thanks, too, to Naturland, a German certifying organisation that has done a great deal of work on this issue.
The rationale for an ICS is to bring down the cost of organic certification to smallholders by establishing a group that can do much of the monitoring itself. Then the certifierís job is just to see that the group processes and data collection are working well, and to check a small number of the farms. The objective is not to provide "easy" certification Ė the organic rules must still be followed because consumers have a right to know that the products they buy have been produced with organic methods. But by carefully setting up the group and its rules, the regulations can be simplified to such an extent that even illiterate farmers are clear on the rules they must follow, and the data that must be kept, and by whom.
It will be clear from the brief listing of requirements below that small-scale farmersí groups will not be able to set themselves up without help. If an NGO works with a group to establish it properly, it must be clear that this is a commitment of several yearsí work with the group. Alternatively, a model that works well in other countries is where the exporting company runs the system, with extension officers collecting the data from some farmers in the group and advising others (an example is a cotton growing group of 5000 farmers in Uganda).
IFOAM points out the following normal requirements for group certification:
∑A central body responsible for marketing and the groupís compliance to applicable standards (buyer, processor, or self organized cooperative or association).
∑One single certification for all individual production as well as processing and handling activities registered within the group. Individual operators within the group may not use the certification independently.
∑Group members operate under contractual or binding membership requirements specifying the commitment to comply with applicable organic standards and permit inspection, etc.
∑Presence of an internal control system (ICS), operated by the responsible central body or an external body contracted by the central body. The ICS normally maintains files on all members of the group and inspects each memberís operation at least once a year.
∑A list of all individual member producers.
∑Through the ICS mechanism the group decides on membersí compliance to applicable standards. Non-compliances are dealt with within the group according to set procedures and sanctions.
∑Measures to handle appeals and complaints.
When is a group a smallholder group?
The IFOAM consultation decided on the following criteria:
The cost of (individual) certification is disproportionally high in relation to the sales value of the product sold.
The farm units are mainly managed by family labour
There is homogeneity of members in terms of
osize of the holdings and
ocommon marketing system.
No maximum amount of hectares per farmer is set.
Minimum size of the group must be large enough to sustain a viable ICS. Practical guideline is a minimum of 30 to 50 smallholders but do not fix the minimum numbers, it depends on the situation
Maximum size of the group is the groupís own concern. It depends on structure, capacity, and communication, and is an element in the risk assessment
The basic elements of an ICS
∑A documented description of the ICS
∑A documented management structure
∑One person responsible
∑An internal regulation (production standard, conversion rules, sanctions etc.)
∑Conversion rules, i.e. traditional farming/virgin land/known field history
∑A contract between the group and the certification body
∑Identified internal inspectors
∑Training of personnel: manager, internal inspectors, producers and handlers
∑Some form of formal commitment of growers
∑Field records, maps for each farm
∑Annual inspection protocols
∑A farm inspection report/form, filled in per farm
∑An approval committee that decides to enter the producer on the Growers List
∑Use of internal sanctions
∑Regularly updated Growers List
∑Use of risk assessment to address risks, threats to integrity of organic production
∑Use of social control/community surveillance (depending on culture)
∑Documented post harvest procedures, including product flow and quantities
Setting up a small-scale farmersí group with an ICS
So, if you are working with a group of organic small-scale farmers who are producing one or two crops (or livestock or honey or whatever) that they would like to sell as organic, these are our recommendations:
1. Work first on the organic procedures. Farmers must be clear that they need to build the soil, and if they do not, they will not be able to produce reasonable crops without using agricultural chemicals.
2. Approach AFRISCO to start building up a relationship, and to obtain more literature on group certification. The certifier may also recommend a training organisation to assist you. The certifier cannot do any training itself (because then we would inspect our own work).
3. Then work on group processes. With the farmers, develop and record the methods that they must use. This must include the conversion rules, the rules for incorporating new farmers, and their minimum requirements (e.g., not too far away, and must be producing these crops).
4. With the farmers, develop the contract they will each enter into with the group.
5. With the farmers, develop an appropriate internal inspection form. (We can let you have a sample from which to work.) This will include a map and field history sheet (for at last three years for each field) for the farm of each participating member. Ask us for a guideline for what needs to be on the maps. They donít have to be complicated, and are best done on A4 (for faxing).
6. Elect or designate the internal controllers, who will do the internal inspections at least once a year. They will need training. Sometimes they are extension officers who are also likely to be involved in ongoing training of the farmers. In that case, they should never inspect farmers they have recently trained.
7. Elect or designate an Internal Review Committee, probably with some of the officer-bearers of the association.
8. Develop, with AFRISCO, the contract that the group will formally enter into.
9. Start regular, recorded monitoring of field activities and processing and marketing.
Then on an annual basis:
1. As a part of the normal round of monitoring, start a round of internal inspections some months before the external controller (i.e., the inspector from AFRISCO) will arrive. The farm of EVERY member will be inspected, and maps and records will be checked (probably not for the first time in the year).
2. Have each inspection form reviewed by the Internal Review Committee. From this, they will draw up the annual Growers List of approved farms. Until this is done, you are not ready for the external inspector.
3. For the external inspector, try also to have ready (but we accept that this may take a few years to perfect!) for the first external inspection:
ŁA documented description of the ICS, for which the farm and association records will be attachments
ŁA documented management structure
ŁA copy of the associationís regulations
ŁA file with all the membersí contracts
ŁThe sanctions file, including the agreed rules, and what was done about all problems encountered over the past year
ŁThe training programme over the past year
The other documents can be developed over time. The external inspector will review the inspection forms and processes, and all other records. S/he will also do a second inspection of a randomly selected sample of the farms to check the inspection reports. S/he will fill in gaps in the required information for the certification report, but will show you where the group could have done these themselves, and should plan to in the future. The more that the group does each year, the less will the external inspector need to do, and the more the certifying body will get confidence in your methods. All this will reduce costs each year.