Inspection Contingency Plan

Dear Members of the PCO Community,

We hope that you and yours are all staying safe and healthy. We want to thank you for the patience you've shown as PCO has been sorting through the repercussions of COVID-19 on organic inspection and certification activities. PCO has made some updates to our inspection contingency plan.

At this time, onsite inspections will be limited to situations in which the inspector and client agree that risks of COVID-19 can be sufficiently mitigated through social distancing and other site-specific approaches (such as modifying the inspection process to minimize time spent face to face in close proximity). In the meantime, we will be conducting most annual renewal inspections as a remote (virtual) inspection (performed using web meetings, teleconferencing or other electronic verification processes). Later in the season, for operations where onsite inspection and remote (virtual) inspections are not possible, we may conduct a desk audit (records review only). We do intend to follow up with an on-site inspection for every operation that we inspect remotely or via desk audit when it is safe to do so.

Please note that if an onsite inspection is scheduled, and the inspector or client feels that the other party is not respecting social distancing guidelines, the inspection process may be ended at any time. Inspectors who do not adhere to social distancing and other agreed-upon risk mitigation strategies may see limitations on future inspection assignments. Clients who do not adhere to the same strategies may be considered to have refused inspection and may be subject to a notice of compliance.

We are identifying and organizing operations into three priority areas for remote inspections:

• Priority 1: to be conducted by July 1, 2020
• Priority 2: to be conducted by September 1, 2020
• Priority 3: TBD

Once this prioritization has been completed by our review staff, we will communicate this out to you as well as to your assigned inspector, after which you can expect to hear directly from your inspector to discuss scheduling your virtual inspection.

For PCO to prioritize an inspection of your operation, we need to have received your Annual Update paperwork. If you have not submitted your annual update paperwork, please do so immediately and contact the PCO office to let us know it is on the way.

For operations that are requesting an OSP addition (e.g. new field, scope, product line, etc), these are being evaluated to determine if these requests can be met based on an in-house review of paperwork. This assessment will occur simultaneously with the prioritization of your operation for remote inspection.

For new 2020 applicants, PCO is considering each operation and situation on a case-by-case basis as we must be able to do some portion of the inspection as an on-site inspection in order to grant certification. We will evaluate the timeline of the operation; federal, state and local stay at home orders; the operations and inspectors comfortability for conducting a portion of the inspection on-site in the safest way possible; and the operations and inspectors’ capacity for conducting a portion of the inspection remotely. Depending on these factors, PCO will move forward with conducting a hybrid inspection (comprising both an on-site and remote component) or we may determine that we are unable to move forward with an inspection at this time and will need to postpone the inspection until it is safe to do so.

Please don’t hesitate to reach out to PCO for any questions you may have:

• Inspections questions: Jenny Cruse, Inspections Program Manager (jenny@paorganic.org or 814-422-0251 x250)
• Certification questions: your assigned Certification Specialist

Additionally, we know this is an unprecedented time and every operation is impacted differently. In order to support possible financial implications you may be experiencing, PCO is responding in a couple of ways:

1. Waived finance fees on past due invoices for April, May, and June. This means you will not incur a finance charge for paying late but you will still owe the payment for the invoice by the due date. If unpaid, the operation will continue to the non-compliance proceedings.
2. Payment plan options will be available upon request. We are prepared to work with you on any financial strain you might be experiencing and can discuss which of our payment plan options might work for you. Please contact the PCO office to speak with Shawnee Matis (x218) or Elizabeth Leah (x217) regarding your specific operation.
3. Late Annual Update paperwork fee: New this year, PCO planned to charge a flat fee for late Annual Update paperwork due by April 1. We are now altering this to only apply to clients who have not submitted by May 15.

With these changes, our intention is to offer you flexibility while at the same time continuing to provide our high-quality organic certification services. In addition, you may wish to reach out for financial support through the recent legislation for the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Visit our website for resources (also listed below) or call your local bank for options that may be available to you.

On behalf of PCO, thank you for being a valued member of our community and for your patience and understanding as we navigate this situation. Please continue to keep yourself, your family and companions safe during this time.

In partnership,

Katherine DiMatteo

Interim Executive Director