Annex 5: The group’s internal sanction matrix (sample document)
This sample document is a guide for groups to develop their own specific sanction matrix. It should be adapted to the group’s ICS and OSP requirements. Examples are provided in
order to facilitate better understanding of non-compliance characteristics, corrective action and related sanction. However there are no binding requirements on how groups
should draft their internal sanction matrix. Groups therefore should coordinate with the responsible certifier and seek approval for their specific sanction matrix to avoid problems.
2: ICS imposes corrective action and sets a
deadline for implementation
1: ICS imposes corrective action
Sanction
level*
minor
non-compliance characteristics
Non-compliance examples
Decision, corrective action examples and sanctions
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Non-compliances may be related to
 recordkeeping, documentation, e.g.:
- poor documentation
- outdated group member information
- late notification of changes (e.g. change of the
production area)
 and organic practices, e.g.:
- weak farm management
- failure to meet the OSP monitoring requirements
(e.g. pest management)
The group member is notified about the non-compliance.
A corrective action is imposed, e.g.:
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no indication of systemic failure
group member still demonstrates ability to
comply with OSP and applicable organic
standard
can be easily corrected and compliance can
be ensured
corrective action can be implemented immediately
There is no indication of systemic failure
group member still is able to demonstrate
ability to comply with OSP and applicable
organic standard
more complex than level 1
requests time for implementation of corrective action (and possibly a corrective action
plan)
may require implementation of corrective
action to be monitored by the ICS
- Create documents that meet the ICS requirements
- Notify changes without undue delay
- Solidify communications with ICS personnel
- Improve farming practices
Group member is verified organic and the group member
list is updated accordingly.
Non-compliances may be related to documentation and The group member is notified about the non-compliance.
organic practices:
A corrective action is imposed and possibly a deadline for
implementation set, e.g.:
 recordkeeping, documentation, e.g.:
- complete or update farm documentation in line
- lack of list of crops produced for the (past) year
with OSP requirements
- incomplete sales receipts
- ensure cleaning of equipment before use
 and organic practices, e.g.:
- meet with the field advisor (or any other ICS per- not cleaning equipment when moving from consonnel) to present buffer zones and boundaries in
ventional to organic production
line with OSP requirements.
- lack of buffer zones
- provide evidence for the safe disposal of the pro- unclear boundaries
hibited substance immediately
- storage of a prohibited substance
Group member is verified organic and the group member
list is updated accordingly. ICS monitors implementation
of corrective action.
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4**: ICS imposes exclusion
3**: ICS imposes temporary suspension
major
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failure to successfully implement a corrective
action that has been imposed before
repeated or multiple violations indicating
that the group member is unable to comply
with OSP and applicable organic regulations
accidental violation of organic standard
violation puts organic integrity at risk
violation requires immediate action
non-compliance is uncorrectable
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repeated or multiple violations indicating
that the group member is unable to comply
with OSP and applicable organic regulations
willful or deliberate violation
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repeated incomplete sales receipts
repeated storage of a prohibited substance
unclear or no separation of products
unintentional use of prohibited substances
use of GMO and/or treated seeds or planting stock
use of synthetic fertilizers or growing medium
use of treated lumber for fencing
misuse of compost or composted materials
misuse of manure
use of chemicals in produce wash water
storage (full-time or temporary) of organic products
at un-approved site or warehouse
re-use of packaging that previously contained conventional product
falsification of e.g. sales receipts
group member tries to sell products from fields not
registered
- from conventional fields
- from neighbors
group member acted fraudulently, violating OSP
(used prohibited substances)
internal inspection denied
The group member is notified about the non-compliance;
a suspension is imposed. The suspension may involve only
portions of land but can also concern the group member
verification as a whole, e.g.:
-
suspension of the group member for one year
products may not be marketed as organic during
that time
fields concerned are downgraded and must again
undergo conversion requirements
group member remains under internal control
surveillance
group member to undergo (additional) organic
training to better understand rules and regulations
Group member and group member’s products that are
non-compliant are listed as sanctioned.
The group member is notified about the non-compliance;
exclusion is imposed:
- group member contract is cancelled
- products may not be marketed as organic
Group member is listed as sanctioned and crops/ products
are excluded from group harvest and sales.
*In case of repeated non-compliance, sanctions according to the next sanction level must be imposed
** Sanctions of level 3 and 4 must be reported to the certifier
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