SGS Verification Of USDA-Natural Resources Conservation .

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SGS Verification of USDA-Natural Resources Conservation Service Audits of U.S. SoySustainability Assurance ProtocolthDate issued: December 18 , 2015Issued to: U.S Soybean Export Council16305 Swingley Ridge Road, Suite 200Chesterfield, Missouri 63017ISO 17021 Equivalency ReportIn accordance with instructions received from U.S. Soybean Export Council (USSEC), SGS conducted a review of the USDANatural Resource Conservation Service (NRCS) audit process, as described in U.S. Soy Sustainability Assurance ProtocolAudit Procedures, for the purpose of assessing compliance to ISO 17021-1:2015 specifically in regard to inspectors, theirtraining and the overview of the program.There are eight specific areas of compliance that SGS reviewed for equivalency. The process SGS utilized was to take eachcriteria, review the requirement of ISO 17021-1:12015, and compare with what the NRCS has documented and is currentlyperforming. All information reviewed was provided by the NRCS at SGS’s request.This assessment was performed using ISO 17021-1:2015 requirements and was completed without undue bias based on theinformation provided by the auditing party. Based upon document reviews including, manuals, organizational charts, maps,and compliance processes during the audit, it is the opinion of this auditor that based on the information provided, NRCS hasmet the requirements of ISO 17021:2015 in regards to the eight standards listed below.1.The verification body is independent and has no interest in the outcome of the audit:a.ISO 17021-1:2015 Requirement: (5.2.2) the certification body shall have top management commitment toimpartiality in management system certification activities. The certification body shall have a policy that itunderstands the importance of impartiality in carrying out its management system certification activities managesconflict of interest and ensures the objectivity of its management system certification activities.b.Objective Evidence:i. National Food Security Act Manual – 5.18.2 Section D: Review to Determine Conflict of Interest.1.There is a process in place where the district conservationist reviews the completedcompliance review to determine if there might be a potential conflict between the NRCSemployee and the assignment they were given. Stated conflicts could consist of tracts ownedby the employee, family members, friends, conservation officials or any other individual thatcould conflict.2.Where a potential or actual conflict is to be found, contact is made to the next level line officerto arrange for assistance in completing those reviews.ii. HEL WC Compliance Guidance Document1.This states that status reviews may not be completed by personnel within the field office butwill be completed by assignment from the Area Conservationist.iii. National Food Security Act Manual – 5.18.0 Section A: Preparation for Conduction Compliance Reviews1.The above stated that tracts for reviewing will be selected randomly by criteria that are listed insection 5.18.1.2.When staffing the review the State Conservationist will utilize either of the followingapproaches:a. The state or area assigned compliance review teamsPage 1 of 6

b.c.2.3.Employee’s from adjacent countiesA combo of (a) and (b)The verification body has the financial and material resources to adequately monitor a representative sample offarmers:a.ISO 17021-1:2015 Requirement: (5.3.2) the certification body shall evaluate its finances and sources ofincome and demonstrate that initially and on an ongoing basis, commercial, financial or other pressures do notcompromise its impartiality.b.Objective Evidence:i. The NRCS is a large organization that is organized by state and by counties. The following areexamples of their operations in Iowa and Missouri.1. Iowa NRCS organizational Map: The state is divided into 5 areas with 90 field offices. TheNRCS leadership team for Iowa contains 29 listed personnel on the document NRCSLeadership Team and Key State Office Contacts.2. NRCS Missouri State Conservation Organizational Chart has 52 listed contacts. Fieldoperations in Missouri are divided into 4 areas with the following employees available in each:a. Area 1 - 86b. Area 2 – 88c. Area 3 – 50d. Area 4 – 51ii. The NRCS is a government body bound and financially held by numerous legislative authorities andpolicy’s including:1. The Food Security Act of 19852. The Food, Agriculture, Conservation and Trade Act of 19903. The Federal Agriculture Improvement and Reform Act of 19964. The Farm Security and Rural Investment Act of 20025. The Food Conservation and Energy Act of 2008The verification body follows well documented procedures and has implemented a quality system making sureall audits are executed in a standardized manner:a.ISO 17021-1:2015 Requirement: (10.2.1) the certification body shall establish, document, implement andmaintain a management system that is capable of supporting and demonstrating the consistent achievement ofthe requirements of this part of ISO/IEC 17021.b.Objective Evidence:i. NRCS has FSA Compliance Status Review Policy that is currently under version control (2.3)1. The above covers the process on how to conduct and complete a review. It also provides thedirection on how to report findings.ii. The NRCS uses an IAS application online where they complete the Compliance Tract Reviews. Allemployees completing the reviews use the same database. Access and control requirements andinstructions are listed in the FSA Compliance Status Review Policy.iii. The NRCS utilizes dated memos to provide further information and work instructions prior to the reviewseason. The following are examples of what was sent in 2015.1. May 11, 2015 – Provided guidance for completion of the FSA status review includinginstruction for managing the compliance database, sending notification letters, and assemblinginformation for the assigned reviewer. Specific dates were provided in the memo for whenactivities should be completed.2. May 11, 2015 (Attachment 2) – Gives detailed instructions for the letters being sent tolandowners along with how to assemble the case file.3. May 20, 2015 – Letter provided guidance on completing preliminary FSA compliance statusreview determinations and information on where the reviewers can find their work lists.Page 2 of 6

4.iv.4.May 20, 2015 (Attachment 1) – Provides instruction and detail on finalizing reviews andsending out the determination letters. Included were specific dates for when all should becompleted.The National Food Security Act Manual also details the procedures for conducting reviews.There is a clear distinction between auditing and advising:a.ISO 17021-1:2015 Requirement: (4.2.3) to obtain and maintain confidence, it is essential that a certificationbody’s decisions be based on objective evidence of conformity (or nonconformity) obtained by the certificationbody, and that its decisions are not influenced by other interests or by other parties.b.Objective Evidence:i. In the National Food Security Act Manual, Fifth Edition Part 519 – Quality Assurance the following isaddressed on how to conduct the reviews:1. Conduct complete and comprehensive reviews2. Coordinate the review with all parties3. Randomly select the field offices and tracts for review4. Conduct entrance and exit conferences5. Outline all findings and recommendations needed for corrective action6. Ensure all corrective actions are implemented to address the deficiencies found7. Provide copies of all quality reviews completed to the appropriate division directorsii. The NRCS also has a Quality Control Review process in place as stated in Part 519 of the abovemanual. It covers 13 specific items that will be covered during the Quality Control Review.iii. In the National Food Security Act Manual – Subpart B – Compliance Reviews 5.18.10 there is thefollowing statement:1. Assumptions of past or future year plantings used to determine compliance with the HELCprovisions are not appropriate. The actual conservation system, including the croppingrotation, cultural practices, and conservation practices installed and maintained, shall be thebasis for the compliance review determination to be made. Where the evidence of compliance,including a USDA participant’s records, is inconclusive, do not assume compliance or noncompliance.iv.5.The FSA Compliance Status Review System is a web-based database that strictly controls theinformation that is allowed into the review. The information below is just a sampling of what is input intothe database:1. Tract Information2. Local Customer Information3. Tract Validity4. Wetlands Review5. Non-compliant Tract Report6. Compliance Determination Detail ReportThe verification body is transparent about the procedures, roles and responsibilities as defined in the qualitysystem:a.ISO 17021-1:2015 Requirement: (4.5.1) a certification body needs to provide public access to, or disclosure of,appropriate and timely information about its audit process and certification process, and about the certificationstatus of any organization, in order to gain confidence in the integrity and credibility of certification. Openness isa principle of access to, or disclosure of appropriate information.b.Objective Evidence:Page 3 of 6

i. There were numerous outreach efforts conducted in Missouri to inform producers about the compliancethprocess. A total of 75 events were held between October 16th, 2014 and May 14 , 2015. A total of over1900 people attended these events. Listed below are just a few examples:th1.St. Peters, Mo – 110 Attendees - November 20 , 20142.Popular Bluff, MO – 250 Attendees – December 4 , 20143.Springfield, MO – 500 Attendees – February 5 , 20154.Hillsboro, MO – 250 Attendees – April 9 , 2015thththii. Title 180 – National Food Security Act Manual which is available online has the following sectionsrelated to the audit process and quality system including:1.Part 510 – Responsibilities2.Subpart A – Appeals Process3.Part 518 – Audit Process4.Subpart B – Compliance Review Codes5.Part 519 – Quality Assuranceiii. The NRCS has a public National Head Quarters Directory that clearly identifies their mission, vision,priorities, and process. Also included is their organizational structure and links to various guidancedocuments.iv.In the National Food Security Act Manual - Part 518 – Subpart A – Section C the following is stated:1.Notification to the USDA Participanta.6.The NRCS employee shall notify, in writing, the USDA participant when a tract underhis or her control has been selected for a compliance review. Notification shall not bemore than 30 days prior to the review, or less than 15 days prior to the compliancereview.The verification body makes sure the auditors do not monitor the same farmer more than three times in a rowand make sure the auditors have no personnel relations with the farmers they visit:a.b.ISO 17021-1:2015 Requirement: (4.2.1) being impartial, and being perceived to be impartial, is necessary for acertification body to deliver certification that provides confidence. It is important that all internal and externalpersonnel are aware of the need for impartiality.Objective Evidence:thi. Memo dated May 20 , 2015 on Attachment One States: That the person conducting the audit isselected by the state or area conservationist. They cannot conduct any reviews in the county of theirduty station and they must be an employee of NRCS.ii. National Food Security Act Manual – 5.18.01.Section A: The tact will be selected randomly2.The State Conservationist will utilize either of the following approaches for staffing compliancereviewsa.The state or area assigned compliance review teamsPage 4 of 6

b.Employees from adjacent countiesc.A combination of (a) and (b).iii. Compliance reviews are based on a national sample of tracts with a combination of random selectionwithin full producer group and specific sub-group deemed at greater risk or higher participation inconservation programs. A minimum of 5% tracts will be reviewed annually. In 2014, 22,127 reviewswere conducted totaling 3,179,686 acres.7.The verification body makes sure auditors are trained in a proper manner, allowing them to execute their jobsproperly:a.ISO 17021-1:2015 Requirement: (7.2.5) the certification body shall have a process to achieve and demonstrateeffective auditing, including the use of auditors and audit team leaders possessing generic auditing skills andknowledge, as well as skills and knowledge appropriate for auditing in specific technical areas.b.Objective Evidence:i. National Food Security Act Manual – Part 518 Audit Processii.Compliance Review Assignments1.The State Conservationist shall determine who will conduct compliance reviews within eachState, as set forth in the following paragraphs:a.(i) All employees responsible for conducting Compliance Reviews shall have therequired knowledge, skills, and abilities to assess the status of both HELC and WCcompliance. If there are currently no employees in a county with the requisite trainingand knowledge, skills, and abilities to perform Compliance Reviews, the AreaConservationist or STC shall assign another employee the responsibility for thatspecific county.b.(ii) The State Conservationist and the Directors of the Caribbean Areas and PacificIslands are responsible for assigning staff to conduct Status Reviews within eachState using methods that comply with this policy, Part 518, and the regulatoryprovisions of 7 CFR Section 12. The State Conservationist may utilize either of thefollowing approaches for staffing compliance reviews:i. (iii) State or Area-Assigned Compliance Review Teams.ii. (iv) Employees from adjacent counties.iii. (v) A combination of (i) and (ii).c.(vi) The State Conservationist or designee shall ensure Compliance Reviewprocedures are consistent with Parts 518 and 519, and the Quality Control Manual.iii. The NRCS utilizes a detailed process available in the document – FSA Compliance Status Reviews(version 2.3)iv.8.Detailed memos are sent to the NRCS reviewers prior to the season reminding them of the process andthe requirements that need to be met during the review period.The verification body reports back the results to the farmer have implemented a complaint mechanism and isaccessible for explanation of the audit results.a.ISO 17021-1:2015 Requirement: (9.7.1) the certification body shall have a documented process to receive,evaluate and make decisions on appeals.Page 5 of 6

b.Objective Evidence:thi. Memo dated September 18 , 2015 – Provides step by step guidance and instructions on the appealsprocess of a report.ii. National Food Security Act Manual – Subpart A – NRCS Administration of Appeals states the following:a.The employees designated or appointed as the NRCS representatives for an appealare responsible for:-----Ensuring NRCS’s interests in the appeal are properly and adequatelyrepresented.Protecting the integrity of NRCS’s programs in all administrative appealproceedings.Preparing and assembling NRCS’s agency record by making sure that allrelevant and pertinent documents, program operating guidelines, and applicableregulations are included.Ensuring all appeal administrative actions and deadlines are met as provided inFederal regulations and policy or as directed by NAD.Submitting documents as requested to a USDA agency (for example, the FarmService Agency), mediator or NAD hearing officer; reviewing and providingcopies to the agency representative, appellant, and third parties, as applicable.Preparing for the informal or formal hearing including the evaluation of theadverse decision being appealed. Representatives should be prepared tocompetently defend any adverse decision appealed by a program participant orapplicant and cite the statutory and regulatory authority.Communicating the basis (factual basis and policy and regulation basis) for eachadverse decision.Communicating the procedure by which a program applicant or participant canobtain their USDA administrative appeal rights.Understanding the uses of mediation as a tool for potentially resolving anadverse decision (limits and benefits).Knowing when and how to use the waivers, exemptions, variances, and equitablerelief provisions of the various programs.Appearing at the NAD in-person hearing as agency’s authorized representativeor participating in a teleconference hearing.Reviewing the agency or NAD determinations for appropriate action.Coordinating appeal activities with SAC.Working with SAC in consulting with NHQ on program issues relating to aspecific case, including guidance on national policy and procedure, and, asappropriate, authority to resolve a case.Ensuring NAD determinations are properly and timely implemented.iii. National Food Security Act Manual – Subpart B – General Information – 5.10.10: The informationprovided here details out what the appeals process is, who can appeal and then steps that need to betaken to appeal.Documents reviewed as part of this verification:National Food Security Act ManualNRCS Organizational Chart and DirectoryIowa Organizational ChartIowa NRCS Leadership Team and Key Contacts ChartFSA Compliance Status Reviews (Version 2.3)Missouri NRCS Organizational ChartBulletin 180-15-2 (Memo Dated May 11th) (3 attachments)Bulletin 180-15-3 (Memo Dated May 20th) (two attachments)Bulletin 180-15-4 (Memo Dated June 21st) (one attachment)Bulletin 180-15-7 (Memo Dated Sept 2nd)(one attachment)Compliance Review Separation of DutiesHEL Determination Separation of DutiesVerified By: Reviewed By:Billie RilesUSAGRI Quality Assurance LeadTheresa AlmonteUSAGRI Audit & Certification ManagerPage 6 of 6

Chesterfield, Missouri 63017 ISO 17021 Equivalency Report . There is a process in place where the district conservationist reviews the completed . April 9th, 2015 ii. Title 180 – National Food Security Act Manual which is available online has the following sections

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