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NOFA-NY Certified Organic, LLC 2007 Policy Manual
Introduction
We believe it is important for farmers, processors and consumers to understand the process we use to certify farms and processing operations. Consequently, we have provided a road map of how we conduct the process here. The National Organic Program's (NOP's) rules provide a framework for how we can structure the process. In addition, we are following the general requirements of the International Organization for Standardization (ISO) for "Bodies Operating Product Certification Systems" and have also obtained conformity recognition through the "Conseil des Appellations Agroalimentaires du Québec". These requirements are referred to as ISO 65 and CAAQ. You will see that our certification review process still relies heavily on volunteers who have the expertise to review farm files and determine if farm practices are in compliance with the rules for organic production. If there is something about the process that you do not understand, please let us know. This will allow us to improve our Policy Manual in the future, as well as answer your questions. In order to create a logical progression of topics, we have created our own numbering system in this section, even though a great many of the provisions, such as the inspection process for farms or what we must do if we deny certification, are from the federal rules on certification. We have provided the number for the federal rule next to the topic heading wherever the requirement is from the federal rule and the language is theirs.
Staff - Carol King, Lisa Engelbert, Sherrie Hastings, Marilyn Murray, Amie Paulo, Linda Sharpe, Heather Swa and Bethany Mrva
Table of Contents
1. Organizational Structure, Authority and Policies NOFA-NY Certified Organic is a Limited Liability Company (LLC) engaged in certification activities for agricultural producers and handlers of organic products. NOFA-NY Certified Organic, LLC is owned by the Northeast Organic Farming Association of New York, Inc., a non-profit, tax-exempt educational organization. NOFA-NY Certified Organic, LLC is operated in the same non-profit manner as the Northeast Organic Farming Association of New York, Inc. NOFA-NY Certified Organic LLC has received accreditation from the USDA as of April 29, 2002 to certify the following: Crops, Livestock, Wild Crops and Processing/Handling. The agency is also ISO65 accredited and recognized by the "Conseil des Appellations Agroalimentaires du Quebec".
1.4 Authority of the Management Committee A Management Committee, appointed by the Northeast Organic Farming Association of NY, Inc., has all powers to control and manage NOFA-NY Certified Organic, LLC, as stated in the Operating Agreement between the Northeast Organic Farming Association of NY, Inc. and NOFA-NY Certified Organic LLC. The Management Committee sets policies for NOFA-NY Certified Organic LLC, based upon recommendations from Final Reviewers, office staff and inspectors. 1.5 Authority of Final Reviewers The Management Committee appoints Final Reviewers to review and determine whether applicants are in compliance with the Certification Standards of the National Organic Program. The Management Committee may appoint additional ad hoc committees as necessary to complete the work of the NOFA-NY Certified Organic LLC. Members of the Management Committee, Final Reviewers, staff, inspectors and any other personnel shall maintain strict confidentiality with respect to the clients certified by NOFA-NY Certified Organic LLC. No business-related information pertaining to clients, obtained during the certification process, can be disclosed to third parties (with the exception of the Secretary of the USDA or the applicable State officials or their authorized representatives) unless permitted in writing by the certified producer or handler. An annual declaration adhering to this policy will be required of all final reviewers, staff and inspectors. 1.7 Conflict of Interest Policy (§205.501(a)(11)(i-vi)) The NOFA-NY Certified Organic LLC shall prevent conflicts of interest by: 1.7.a. Not certifying a production or handling operation if the Management Committee or a responsibly connected party of such committee member or staff has or has held a commercial interest in the production or handling operation, including an immediate family interest or the provision of consulting services, within the 12-month period prior to the application for certification; 1.7.b. Excluding any person, including contractors, with conflicts of interest from work, discussions, and decisions in all stages of the certification process and the monitoring of certified production or handling operations for all entities in which such person has or has held a commercial interest, including an immediate family interest or the provision of consulting services, within the 12-month period prior to the application for certification; 1.7.c. Not permitting any employee, inspector, contractor or other personnel to accept payment, gifts, or favors of any kind, other than prescribed fees, from any operation inspected; 1.7.d. Not giving advice or providing consultancy services, to certification applicants or certified operations, for overcoming identified barriers to certification; 1.7.e. Requiring all persons who review applications for certification, perform on-site inspections, review certification documents, evaluate qualifications for certification, make recommendations concerning certification, or make certification decisions and all parties responsibly connected to the certifying agent to complete an annual conflict of interest disclosure report; and 1.7.f. Ensuring that the decision to certify an operation is made by a person different from those who conducted the review of documents and on-site inspection; 1.7.g. Reconsidering a certified operation's application for certification and, if necessary, perform a new onsite inspection when it is determined, within 12 months of certifying the operation, that any person participating in the certification process and covered under 205.501 (a)(11)(ii) has or had a conflict of interest involving the applicant. All costs associated with a reconsideration of application, including on-site inspection costs, shall be borne by the certifying agent; 1.7.h. Referring a certified operation to a different accredited certifying agent for re-certification and reimburse the operation for the cost of the Re-certification when it is determined that any person covered under 205.501 (a)(11)(i) at the time of certification of the applicant had a conflict of interest involving the applicant. Any person (farm or handler) marketing organic products may apply for Certification through NOFA-NY Certified Organic LLC. NOFA-NY Certified Organic LLC shall not exclude from participation in, or deny the benefits of the National Organic Program to any person due to discrimination because of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, or marital or family status. No form of discrimination will be practiced in receiving and reviewing applications, although the Program may refuse the application of any farm or handler that fails to meet the criteria or make a serious commitment to organic practices. Application is made by submitting the completed application forms with the appropriate fee within the application period. 1.9 Reciprocity with other certifying agents Since accreditation of the NOFA-NY Certified Organic LLC certification program by the USDA, we accept the certification decisions of other USDA accredited certification programs. If an operation has been inspected by another USDA accredited agency within 9 months of application with NOFA-NY Certified Organic, LLC; the program will accept that report in place of another inspection visit. 1.10 NOFA-NY Certified Organic LLC Program Administration 1.10.a. The Management Committee The Management Committee has all powers to control and manage NOFA-NY Certified Organic, LLC, as stated in the Operating Agreement between the Northeast Organic Farming Association of NY, Inc. and NOFA-NY Certified Organic LLC, with the exception of granting certification. The Management Committee sets policies for NOFA-NY Certified Organic LLC, based upon recommendations from personnel. 1.10.b. Final Certification Review Final Reviewers are responsible for evaluating applications and inspection reports for compliance with the standards and deciding which operations qualify for certification. Additional Final Reviewers may be added as needed. Final Reviewers may be clients certified by NOFA-NY Certified Organic LLC, staff or from the general public. Final Reviewers will knowledgeable in the organic production type that they are reviewing and making decisions in. A final certification decision will be made by one final reviewer. The final reviewer can not be the same person who conducted the initial file review or onsite inspection within the current certification year. The program reserves the right to utilize two or more reviewers for new applicants or repeat applicants with non-compliances. If two or more final reviewers are involved in a certification decision, consultation between the reviewers may take place via phone, e-mail or in person. A Program Administrator and other office staff are responsible for conducting the day to day work of the Certification Program. Inspectors, who are either employees or independent contractors, conduct the on-site inspections of farms and handling operations and submit inspection reports to the Final Reviewers.
Certification under NOFA-NY Certified Organic LLC is an annual process consisting of: An application and inspection are required annually. Any person (farm or handler) marketing organic products may apply for Certification through NOFA-NY Certified Organic LLC. NOFA-NY Certified Organic LLC shall not exclude from participation in or deny the benefits of the National Organic Program to any person due to discrimination because of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, or marital or family status. No form of discrimination will be practiced in receiving and reviewing applications, although the Final Reviewers may refuse the application of any farm or handler that fails to meet the criteria required for organic certification. Application is made by submitting the completed application forms with the appropriate fee within the application period. The NOFA-NY Certified Organic LLC operates a certification program that certifies: The National Organic Program's National Organic Standards are the basis for certification of the above types of production. All clients are provided with a copy of the Federal Rule. Any exempt/excluded operations that purchase the NOFA-NY Certified Organic, LLC Guidence & Policy Manual also receive the Federal Rule, so that they may fully comply. 2.3 Certification Process for New Applicants 2.3.a. Obtain Current Version of Certification Standards and Application Packet New applicants must obtain the current version of the National Organic Program's National Organic Standards and the application packet. These can be obtained through the Certification Program Office. 2.3.b. Attend Orientation Session All new applicants are strongly encouraged to attend an Orientation Meeting before submission of the application packet. The Orientation Meetings are designed to provide information on the specific requirements for certification, and also provide the applicant an opportunity to ask questions about the process or the application itself. There is no fee for the Orientation Session. These sessions reduce the overall time it takes applicants to fill out applications and the time it takes reviewers to review files, keeping overall certification costs down. Orientation Meetings are scheduled in advance and are held at the Certification Program Office and/or locations around the state. Orientation Meeting attendees must pre-register. A list of the available dates is sent with the Application Packet. Attendees should purchase the Standards Manual and application packet prior to the Orientation. The Orientation Meeting covers the requirements for: The Orientation Meetings are not designed to permit the applicant to complete the Application for certification. They are designed to provide information on the entire certification process from application to the completion of the process. If the applicant has questions while completing the application they are encouraged to call the office for clarification. 2.3.c. Submission of Complete New Application Applications for certification must be complete. Incomplete applications will be returned for completion prior to inspection and review. Applications must be completed in pen. In addition to the complete application (and as required by §205.401(c)) the applicant must also supply information regarding the name(s) of any organic certifying agent(s) to which application has previously been made; the year(s) of application; the outcome of the application(s) submission, including, a copy of any notification of noncompliance or denial of certification issued to the applicant for certification; and a description of the actions taken by the applicant to correct the non-compliances noted in the notification of non-compliance, including evidence of such correction. Based upon a review of the application, other information necessary to determine compliance with the National Organic Program's National Organic Standards may be requested. 2.3.d. Due Dates for New Applications Due Dates for Submission of Vegetable Crop/Field Crop /Specialty Crop /General Livestock and Poultry Applications Initial applications for Certification of Vegetable Crop/Field Crop/Specialty Crop/General Livestock and Poultry are due at the end of March. Additional deadlines for new applicants are also provided, with the assessment of late fees to reflect delays in scheduling. The deadlines are established annually and included in all information brochures and the application packet. Due Dates for Submission of Dairy Applications Initial applications for Certification of Dairy may be submitted at any time during the year. Due Dates for Submission of Handler Applications Initial application for Certification of Handler operations may be submitted at any time throughout the year. 2.4 Certification Process for Continuing Applicants: Annual Information Update All certified operations are required to submit an Annual Information Update. Update applications are supplied in the following manner: Vegetable/Field Crops/Livestock/Poultry/Specialty Crop Updates Update applications will be mailed to all continuing operations in January of each year. The application will include an addition of production form for the producer to return, if necessary. Dairy Updates Update applications will be mailed to all continuing dairy operations in January of each year. Handler Updates Handler clients are notified 2 months prior to the due date of their annual information update. Applicants are asked to respond within two weeks. 2.4.b. Due Dates for Submission of Annual Information Updates Due Dates for Submission of Vegetable Crop/Field Crop /Specialty Crop/General Livestock and Poultry Information Updates Vegetable Crop/Field Crop/Specialty Crop/General Livestock and Poultry annual update information have a due date at the end of February. The exact date is determined annually and included in the application packet. Applications postmarked after the initial established date are assessed a late fee of $125.00. If the application is not received by the end of March, a notice of non-compliance will be issued. If the notice of non-compliance is not responded to by the designated due date, a notice of proposed suspension will be issued to the operation. A $50.00 early bird discount will apply to any complete application submitted with full payment and postmarked by the second Friday in February. The exact date each year will be included with the application. Due Dates for Submission of Dairy Information Updates Dairy annual update information has a due date at the end of February. The exact date is determined annually and included in the application packet. Applications postmarked after the initial established date are assessed a late fee of $125.00. If the application is not received by the end of March, a notice of non-compliance will be issued. If the notice of non-compliance is not responded to by the designated due date, a notice of proposed suspension will be issued to the operation. A $50.00 early bird discount will apply to any complete application submitted with full payment and postmarked by the second Friday in February. The exact date each year will be included with the application. Due Dates for Submission of Handler Information Updates Annual Information updates for Handlers must be postmarked by the due date established in the annual information update packet. The exact date is provided to the applicant at the time the application is sent. 2.4.c. Submission of Complete Updated Organic System Plans Applications for certification must be complete. Incomplete applications will be returned for completion prior to review and inspection. 2.5 Review of New and Annual Information Updates Once the application for certification or the annual information update, with applicable fees, is received, the office staff reviews this for completeness. If all information for the application is complete, a determination is made whether the applicant appears to comply, is able to comply with the standards or is unable to do so. If the application is incomplete, any requests for additional information must be complied with by the due date. If the applicant does not supply the requested information, the certification process is suspended. Staff communicates the findings to the applicant in the Review Letter. The applicant is sent the Inspection Letter, which details the types of additional information the applicant must have available for the inspector to review. The inspector schedules the on-site inspection. The applicant must be present for the inspection. Additional details on the Inspection Visit are found in Section 3, The Inspection Process. New and repeat applicants may withdraw their application at any time. An applicant who withdraws an application shall be liable for the costs of services provided up to the time of withdrawal of the application. An applicant that voluntarily withdraws an application prior to the issuance of a notice of noncompliance will not be issued a notice of noncompliance. Similarly, an applicant that voluntarily withdraws its application prior to the issuance of a notice of certification denial will not be issued a notice of certification denial. Upon completion of the Inspection and return of the Inspection Report, the Final Reviewer evaluates the application and inspection report for compliance with the standards and decides to certify or not certify the operation. The Certification Determination Letter is sent to the applicant. This letter identifies: Detailed information pertaining to the process of Notification of Non-compliance, denial, suspension or revocation of certification can be found in the section titled Violations, Sanctions, Suspensions, Denials & Appeals. 2.6 The Certification Certificate The Certification Certificate contains, as required by §205.404(b)(1-4), the following information: If the certifying agent determines that the certified operation is complying with the Act and the Regulations in this part and that any of the information specified on that certificate of organic operation has changed, the certifying agent must issue an updated certificate of organic operation pursuant to 205.404 (b). Once certified, a production or handling operation's organic certification continues in effect until surrendered by the organic operation or suspended or revoked by the certifying agent, or the USDA AMS Administrator (§205.404(c )). To continue certification, a certified operation must annually: If the above information is not received within the application period, a proposal to suspend or revoke certification will be issued. If a certified operation decides not to continue certification, they must provide written notification and voluntarily surrender their certification certificate to the certification office. Failure to do so by the end of the designated application period will result in a proposal to suspend the operation's certification. This will be completed by the certification office. 2.8 Extension of Certification to Cover New Products Requests for extension of certification to cover new products will be handled on a case by case basis. In all cases complete information regarding the new product production must be supplied. The Final Reviewer(s) will decide whether an additional on-site inspection visit is necessary, or if the new product(s) production is similar to products already certified, therefore no additional on site inspection is required. 2.9 Sourcing Agricultural Inputs and Ingredients for Processed Products When management practices are insufficient to prevent or control pests and diseases, a biological or botanical substance or a substance included on the National List of synthetic substances allowed for use in organic crop production, Section 205.601 through 205.607, may be used by operations certified by NOFA-NY Certified Organic LLC. Ingredients used in processed products must be produced in accordance with these Standards. Nonagricultural (non-organic) substances and non-organically produced agricultural products must be used according to Sections 205.605 and 205.606 of the NOFA-NY Certified Organic LLC Certification Standards Manual. 2.10 Monitoring Continued Compliance Compliance with Final Reviewer requests for issues such as additional information, changes in farm plan, etc., is monitored by assigning a due date for submission and/or completion of a task. Tracking is done through a computer database. Office staff will follow-up as necessary to obtain the information. Monitoring compliance at the farm shall include random unannounced inspection visits or by short notice (overnight) visits. The unannounced and short notice inspection is limited in scope, with pre-determined areas for review. Areas for review would include, but would not be limited to, any follow-up conditions placed by the Final Reviewer(s). 2.11 Testing for Residues (§205.670) 2.11.a. All agricultural products that are to be sold, labeled, or represented as "100 percent organic," "organic," or "made with organic" (specified ingredients or food group(s)) must be made accessible by certified organic production or handling operations for examination by the USDA AMS Administrator, the applicable State organic program's governing State official, or NOFA-NY Certified Organic LLC. 2.11.b. The USDA AMS Administrator, applicable State organic program's governing State official, or the certifying agent may require pre-harvest or post-harvest testing of any agricultural input used or agricultural product to be sold, labeled, or represented as "100 percent organic," "organic," or "made with organic (specified ingredients or food group(s))" when there is reason to believe that the agricultural input or product has come into contact with a prohibited substance or has been produced using excluded methods. Such tests must be conducted by the State organic program's governing State official at their own expense, or the NOFA-NY Certified Organic LLC Program at our expense. 2.11.c. The pre-harvest or post-harvest tissue test sample collection pursuant to paragraph (b) of this section must be performed by an inspector representing the USDA AMS Administrator, applicable State organic program's governing State official, or NOFA-NY Certified Organic LLC. Sample integrity must be maintained throughout the chain of custody, and residue testing must be performed in an accredited laboratory. The specific sampling techniques used are dependent upon the testing requirements. Inspectors will work with the testing laboratory to meet their sampling requirements. Chemical analysis must be made in accordance with the methods described in the most current edition of the Official Methods of Analysis of the AOAC International or other current applicable validated methodology determining the presence of contaminants in agricultural products. 2.11.d. Results of all analyses and tests performed under this section: 2.12 Exclusion from Organic Sale (§205.671) When residue testing detects prohibited substances at levels that are greater than 5 percent of the Environmental Protection Agency's tolerance for the specific residue detected or unavailable residual environmental contamination, the agricultural product must not be sold, labeled, or represented as organically produced. The Administrator, the applicable State organic program's governing State official, or the certifying agent may conduct an investigation of the certified operation to determine the cause of the prohibited substance. NOFA-NY Certified Organic LLC inspectors play a key role in the Organic Certification Program, they are the connecting link between the applicant and the Certification Program. They are the "eyes" of the Certification Program. The inspector does not play a role in the actual decision making of whether or not an applicant is certified. In the NOFA-NY Certification Program the inspector's role is one of observer & verifier that the practices used on the farm or in the facility are reflected in the application submitted. The Inspector must also identify practices, materials, or production processes that are not in compliance with the Standards of the NOFA-NY Certified Organic LLC. These areas of non-compliance must be communicated to the applicant and the Certification Program. The Inspector is responsible for scheduling and completing all inspection visit. The inspector is responsible for the scheduling of visits to new applicants as early in the season as possible, bearing in mind the economics of this visit. The Inspector is responsible for visiting all fields and facilities enrolled in the Certification Program and for the completion of all inspection forms associated with the farm or facility visit. The Inspector is responsible for returning the applicants file and completed inspection report to the Program office within 14 days of the inspection visit. 3.2 Qualifications of the Inspector The inspector should have a good background of organic and conventional agriculture, and of handling and manufacturing practices, if conducting processing inspections. The Inspector is required to be familiar with the National Organic Program's National Organic Standards, the NOFA-NY Certified Organic, LLC Policy Manual and Guidance Manual. Inspectors hired by the NOFA-NY Certified Organic LLC Certification Program, either as employees or independent contractors, must attend and complete the Independent Organic Inspectors Association Basic Training Program. Inspectors hired by NOFA-NY Certified Organic LLC may also be certified by NOFA-NY Certified Organic LLC. The scheduling of the inspection is never easy and relies on the cooperation of both the inspector and applicant. In order to keep inspection travel costs low, farm inspections will be grouped by geographical areas. Each applicant will be contacted to arrange an inspection visit in a timely manner by the inspector assigned to the operation. The length of inspection visits can vary depending on the size and complexity of the operation. Vegetable operations may take from 2 - 4 hours, while dairy farms or processing facilities may take 6 - 8 hours. The applicant is required to be present for the inspection. Cancellation of an inspection appointment is very costly to the Certification Program. Producers should keep in mind that the inspector is not working with just one farm when scheduling this appointment, as many as three or four other operations in the area are more than likely involved in planning the inspection visit schedule. Should a cancellation occur, it affects the rest of the inspection appointments. A cancellation of an inspection visit one week prior to the inspection visit will be without penalty. Applicants canceling within one week of the inspection visit will be billed for the inspection costs of the re-schedule visit. Farm certification fees include the cost of one inspection visit. Should additional inspections be required, the applicant will be billed for these on a cost basis. Applicants certifying various seasonal operations, such as maple syrup production as well as vegetable production, are required to have an inspection for each operation during the production season. Handling/Processing operations are billed for the actual costs of the inspection visit. Non-payment of inspection fees can lead to suspension of certification. Additional information pertaining to Inspection fees is found in the Fees section. 3.6 Inspection of a Crop Production Operation 3.6.a. Documentation Provided to Inspector The Certification Program office supplies the Inspectors with the client's complete application, the previous year's inspection report and the review letter completed by the office. 3.6.b. The Inspection Visit will encompass the following: Initial discussion with the applicant regarding the process to be used to complete the inspection. Explanation to the applicant that the inspector is only an observer, and does not make the final certification decision. Review of Equipment being used. Review of crop input materials and pest control materials for both use and appropriate storage. Inspection of all fields to be certified to verify: Review of processing areas (if applicable). Review of crop/product storage areas. Review of all audit trail records including, but not limited to: Summary of Inspection Visit including: Submission of completed Inspection Report, billing for inspection, any samples taken and return of applicant's file within 14 days if possible. 3.7 Inspection of a Dairy or General Livestock Production Operation 3.7.a. Documentation Provided to Inspector The Certification Program office supplies the Inspectors with the client's complete application, the previous year's inspection report and the review letter completed by the office. 3.7.b. The Inspection Visit will encompass the following: Initial discussion with the applicant regarding the process to be used to complete the inspection. Explanation to the applicant that the inspector is only an observer, and does not make the final certification decision. Review of Equipment being used. Review of crop input materials and pest control materials for both use and appropriate storage. Inspection of all fields to be certified to verify: Review of processing areas (if applicable). Review of crop storage areas. Review of livestock housing areas and conditions. Review of animal identification system. Review of health remedies, medications and cleaning materials on hand. Review of feed supplies on hand. Review of milk handling practices, including cleaning materials. Inspection of slaughter facility. Review of all audit trail records including, but not limited to: Summary of Inspection Visit including: Submission of completed Inspection Report, billing for inspection, any samples taken and return of applicant's file within 14 days, if possible. 3.8 Inspection of a Poultry Production Operation 3.8.a. Documentation Provided to Inspector The Certification Program office supplies the Inspectors with the client's complete application, the previous year's inspection report and the review letter completed by the office. 3.8.b. The Inspection Visit will encompass the following: Initial discussion with the applicant regarding the process to be used to complete the inspection. Explanation to the applicant that the inspector is only an observer, and does not make the final certification decision. Review of Equipment being used. Review of land uses adjoining facility. Review of processing areas (if applicable). Review of feed storage area. Review of poultry housing areas and conditions; including outdoor access. Review of health remedies and medications on hand. Review of all audit trail records including, but not limited to: Summary of Inspection Visit including: Submission of completed Inspection Report, billing for inspection, any samples taken and return of applicant's file within 14 days, if possible. 3.9 Inspection of a Handling Operation 3.9.a. Documentation Provided to Inspector The Certification Program office supplies the Inspectors with the client's complete application, the previous year's inspection report and the review letter completed by the office. 3.9.b. The Inspection Visit will encompass the following: Initial discussion with the applicant regarding the process to be used to complete the inspection. Explanation to the applicant that the inspector is only an observer, and does not make the final certification decision. Review production area. Review of equipment being used. Review of sanitation logs. Review of certification verification for ingredients. Review of processing aids used, certification verification or allowability. Review of product storage areas including: Review of pest control practices used. Review of all audit trail records including, but not limited to: Summary of Inspection Visit including: Submission of completed Inspection Report, billing for inspection, any samples taken and return of applicant's file within 14 days, if possible. Additional inspections will be necessary if the applicant does not have all the necessary information available for the inspector to review or if a conditional certification is granted by the Final Reviewers. The applicant will be billed for the actual costs of the additional inspection(s). 3.11 Unannounced Inspection Visits The NOFA-NY Certified Organic LLC Certification Program monitors compliance by conducting random unannounced inspections visits or by short notice (overnight) visits. The unannounced & short notice inspection is limited in scope, with pre-determined areas for review. Areas for review could include, but would not be limited to, any follow-up conditions placed by the Certification Review Committee, along with review of the following areas: Record Keeping Practices including a review of: Progress on Compliance with Final Reviewer(s) requests/condition. Record Keeping Practices include a review of: |