Episode 4 of 18Chapter 2 · Building the ICS
ForFPO managers and ICS staffLevelBeginner

Under NPOP group certification, the Certification Body does not inspect every farmer. It checks the FPO's Internal Control System, then verifies a sample of farmers against its records. This episode sets out what the ICS must contain, who staffs it, and the records it must produce.

The short version

  1. The CB checks your ICS, then a sample of farmers against your records.
  2. Every farmer is inspected by the ICS twice a year.
  3. Inspectors must not approve their own inspections or inspect their own land.
  4. One source of farmer data; update the portal from it.
Test yourself

What an Internal Control System Must Contain

An ICS is a set of components — manual, farmer register, inspections, decisions, training, input approvals — each with evidence.

An ICS is not a single document. A certifying body expects a defined set of components, each with evidence that it operates in practice rather than on paper.

ComponentWhat it establishesEvidence required
ICS manualYour written procedureApproved, dated, version controlled
Farmer registerWho is in the groupLand details, survey numbers, plot areas
Internal inspection reportsThat you inspect your own membersTwo per farmer per year, signed
Approval and sanction recordsThat findings have consequencesDecisions on non-compliant farmers
Training recordsFarmers know the standardDates, attendance, subject covered
Input approval recordsOnly permitted inputs are usedInvoices and usage logs per farmer

The component most often missing is the fourth. Many FPOs inspect their farmers and record the findings, but never document what happened next. An inspection report noting a problem, with no corresponding decision, reads to an auditor as a system that detects issues and ignores them.

Did you know?NPOP requires at least one internal inspector for every 50 to 60 farmers.

Who Staffs the ICS, and the Conflict of Interest Rule

The ICS Manager, internal inspectors and a three-member approval committee, with no one approving their own inspection.

NPOP names several ICS roles; three of them carry the checks, and they cannot all be the same person.

  1. Internal inspectors visit farmers and record findings against the standard.
  2. The approval committee, of three members from within the group, reviews those findings and decides whether each farmer is approved, warned or suspended.
  3. The ICS manager maintains the records and is the auditor's point of contact.

An internal inspector cannot approve their own inspection. Where the same individual inspects a farmer and signs off the decision, the certifying body treats that approval as unsupported. In a small FPO this is usually solved by having the approval committee sit as a group, with any member declaring an interest excluded from that farmer's decision.

Inspectors should also not inspect their own land, or a close relative's. Rotating inspectors between villages each season removes the question entirely and is straightforward to evidence in your records.

Group certification means the group holds one certificate. A finding against one member's records is a finding against the group, and can suspend every farmer in it.

Running Internal Inspections That Hold Up

Inspect every farmer twice a year, recording plot, crops, inputs, buffers, storage and a yield estimate.

Every registered farmer must be internally inspected twice a year; the Certification Body inspects only after this is done. The inspection covers what the external auditor will check, so that nothing is discovered for the first time on audit day.

Each inspection record should establish:

  1. Plot identity. Survey number and area, matching the farmer register exactly.
  2. Crops in the ground against what the farmer declared for the season.
  3. Inputs used since the last visit, checked against purchase invoices.
  4. Buffer zones where a plot adjoins conventionally farmed land.
  5. Storage separation where organic and non-organic produce are handled together.
  6. Yield estimate for the plot, which is later checked against quantities sold.

The yield estimate matters more than most FPOs expect. If a farmer's declared plot area cannot plausibly produce the quantity sold as organic, that gap is the first thing a certifying body examines. Recording an estimate at inspection, before harvest, protects you from that question later.

Keeping the ICS Consistent With Tracenet

Keep one authoritative farmer register and update Tracenet from it, never the other way round.

Where produce is destined for export, farmer and plot data also sits on APEDA Tracenet. Two records of the same farmer, maintained separately, will drift. The mismatches that follow are found at inspection, when there is no time to reconcile them.

Three practices prevent this:

Check yourself

Tap an answer to see whether you are right, and why.

How often must the ICS inspect every farmer under NPOP?

  1. Once a year
  2. Twice a year
  3. Once every two years

NPOP 5.2 and 5.5 require 100% internal inspection twice a year.

An internal inspector also sits on the approval committee. What must happen?

  1. Nothing
  2. They are excluded from decisions on farmers they inspected
  3. They approve alone

Nobody approves their own inspection.

Remember these things

  • The CB checks the ICS, then a sample.
  • Inspect every farmer twice a year.
  • Record decisions next to findings.
  • Keep one source of farmer data.

An ICS whose records match the field is the one that passes inspection. KrushiFlow validates these fields and submits farmer records to the portal in bulk.

Up next · Episode 5FPO Organic Compliance: NPOP ICS Setup for CBBOs
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