OECD Users Guide Section D - Accreditation Program

Overview: Accreditation Program
In 1996, the Organization for Economic Cooperation and Development (OECD) conducted experiments to determine the effectiveness of accreditation for Seed Schemes Program activities. The first experiment was for activities related to field inspection and later broadened to include testing and sampling. This accreditation allowed third parties to perform certain activities necessary for OECD on behalf of the Designated Authority. Owing to the success of these experiments, OECD has authorized accreditation for field inspection, sampling (including labeling and sealing), and testing activities.
As the U.S. Designated Authority, the Agricultural Marketing Service (AMS) has the responsibility for developing accreditation guidelines for implementing this program.
Entities desiring accreditation have the option of participating in all levels of accreditation or participating in just certain components. For accreditation for field inspections and/or sampling, authorization can be by the state seed certifying agency or through participation in, respectively, the Accredited Field Inspection Program (AFIP) or the Accredited Seed Sampling Program (ASSP). Testing for OECD requires the seed laboratory be accredited under either the Accredited Seed Laboratory (ASL) Program or ISTA. Applications should be submitted to the appropriate entity. For accreditation through the Process Verified Programs for Seed that would be the Grading and Verification Division of AMS.
Once the entity passes initial assessment, an on-site audit may be conducted. The accredited entity is evaluated annually by the SCA and also a comprehensive audit is conducted every three years by an AMS-approved auditor.
A List of US OECD Authorized and/or Official Entities is maintained by AMS and includes pertinent information about each accredited entity. This list is available on the US OECD website at the following link: Authorized List
All instructions within this guide pertain to the OECD Program procedures. Confidentiality of the information obtained in the course of accreditation activities, at all levels, will be maintained.
More information about the OECD Seed Schemes can be obtained from the following link: OECD Seed Schemes Rules and Regulations – link to page in new site once developed.
 
Contact Information

Steve Malone, Ph.D., CCA/CPAg
US OECD Seed Schemes Program Manager
USDA-AMS-LPS-SRTD
801 Summit Crossing Place, Suite C
Gastonia, NC 28054
704-810-8888
Email: Stephen.Malone@ams.usda.gov

Overview of Accreditation Process
Step 1
Entity applies to appropriate authority to be accredited for one or more of the follow:
Field Inspection      Sampling (including labeling and sealing)     Testing 

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Step 2 
An AMS approved auditor conducts initial assessment 
 
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STEP 3
An on-site audit may be conducted by AMS approved auditor. 
 
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STEP 4
Once the audit is passed, the applying entity is accredited for the specific program. Entity is added to List of US OECD Authorized and/or Official Entities and, if applicable, to the Official Listing of Accredited USDA Process Verified Programs for Seed. 
 
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STEP 5
Entity performs the functions for which they are approved. 
 
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STEP 6
Entity completes all functions and requests certificate/tag to ship seed internationally.
 
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STEP 7
Post accreditation activities are performed: Annual evaluation by SCAs and on-site audit conducted once every 3 years by an AMS approved auditor. 
 
Section D-1: Application Procedures 
1.1 Who May Apply 
1.2 Procedures 
1.3 Initial Assessment
 
 
1.1 Who May Apply 
Any seed company, organization, or individual that operates within the United States and under an approved Quality Management System may apply to become accredited. 
 
1.2 Procedures 
Request for accreditation. Those entities wishing to be accredited for the OECD Program must submit a completed application to the appropriate accrediting body. Entities must indicate on this application which component(s) they would like to become accredited for (field inspection, sampling [including labeling and sealing], and/or testing). 
 
Submitting applications. Applications for accreditation should be submitted well in advance of an anticipated need for accreditation. After accreditation has been granted, notification or requests should be submitted to the relevant state seed certifying agency at least 90 days prior to the date on which services are needed. It is suggested that notifications/requests concerning field inspections for summer crops be received by the SCA no later than February 1, and for sampling (including labeling and sealing) and testing, be received no later than July 1. 
 
Adding new locations. Accredited entities who wish to add new locations to the program do not need to go through the application process again, but should notify the SCA/OECD Program Manager of such changes. Such additions will be subject to the auditing process before accredited work can be undertaken. 
 
Withdrawal from participation. Accredited entities who decide to no longer participate or significantly change their level of participation, must give at least 90 days notice in advance to the appropriate SCA.
 
1.3 Initial Assessment 
An AMS approved auditor will conduct an initial assessment to evaluate the application for completeness and ISO-based quality assurance documentation. In order for the application to be processed, it must be signed by the entity’s management representative. 
 
If accreditation is sought through one of the Accredited Seed Programs, the assessment will be based upon the requirements of that Program and the applicant’s ability to comply with OECD Seed Schemes, state seed certification regulations, and U.S. accreditation protocols. The auditor may arrange an on-site visit at the entity’s designated location(s) and shall use a prepared checklist (example in Appendix) to conduct the visit and record all responses on the checklist. The auditor is not limited to questions on the checklist and can add additional questions appropriate to the applicant. 
 
Incomplete application/non-conformances. If the application is found to be incomplete or any non-compliances are identified during the on-site visit, accreditation may be denied until such time as additional information has been supplied or the non-conformances corrected.
 
Section D-2: Evaluation Procedures 
 
Upon successful completion of an initial assessment by the AMS-approved auditor, an on-site audit is conducted by an appropriate auditor, as determined by AMS. The auditor will conduct on-site evaluations using a checklist appropriate for the component(s) for which the applicant is applying. The auditor is not limited to questions on the checklists and can add additional questions appropriate to the applicant and within the scope of the component. The auditor shall inform the applicant of any problems encountered. 
 
Notification of results. If accreditation is granted upon completion of the assessment the applicant, the OECD Program Manager, and (where applicable) the SCA are notified. 
 
Audit requirements for components of accreditation. Each component of accreditation (field inspection, sampling, testing, and labeling/sealing) has specific accreditation requirements. These requirements are outlined in Sections 3-5 of this document. Post accreditation activities for all components of accreditation are outlined in Section 6 of this document. 
 
Time frame for on-site audits. On-site audits will be completed and reports issued to entity in a timely manner. 
 
If approved, the entity will be added to the List of US OECD Authorized and/or Official Entities. This list will be maintained by AMS and available on the US OECD website at the following link: OECD List  
 
The List of US OECD Authorized and/or Official Entities will contain the following: 
  • Entity name 
  • Management representative at entity 
  • Locations approved for accreditation 
  • Components for which the entity is approved (field inspection, sampling, testing, labeling) 
 
Also, SCAs will maintain a list of accredited individuals who are authorized to perform OECD work on their behalf.
 
Section D-3: Components of Accreditation—Field Inspection 
 
 
Entities desiring to inspect fields for the OECD Program may do so through participation in the Accredited Field Inspection Program (AFIP) and/or in cooperation with state certifying agencies (SCA). 
 
As part of the process for field inspection entities may submit to the SCA a Uniform Agency Field Application Form for all fields eligible for certification (available from the SCA) that will be included in the Accreditation Program. If requested by the SCA, the accredited entity will provide a list of any production fields that will not be in the accreditation program in each state to the SCA. Information may include the field number, hybrid name, pedigree, acres, and reason why the field will not be included for certification. This list may be shared between certifying agencies as needed. 
 
The SCA will evaluate the field application to determine adherence to applicable certification scheme and program standards. If approved, inspection by the approved entities will be carried out according to inspection guidelines and standards established by the appropriate SCA. The approved entity will carry out inspections for every field in the Accreditation Program. The SCA has the option to reject any or all fields not meeting inspection criteria under the OECD Accreditation Program. The SCA also has the discretion to deny accreditation to a particular location and require normal certification due to concerns over the ability of the location to satisfactorily meet the accreditation requirements. 
 
Accredited entities must identify their production acreage for each selected crop kind eligible for certification in each state under the program; however, it will be the responsibility of the SCA to ensure that each location meets the requirements of the Program. This Program is intended for certified seed class only and does not include foundation seed. 
 
In order to protect the integrity of the program the agency will have the right to request additional information from the accredited entity regarding the status and disposition of any production fields whether accredited or not. 
 
The U.S. Designated Authority recognizes the Accredited Field Inspection Program as a valid alternative for OECD field inspecting accreditation, provided that the entity incorporates the check-inspecting guidelines stated in section 3.3 and that accredited personnel have sufficient knowledge of OECD Seed Certifying Schemes. For further information on the AFIP, contact the OECD Program Manager or select the following link: Accredited Seed Programs – link to page in new site once completed
 
If the entity is an accredited field inspector under the AFIP, the certification agency will still have access to all records and relevant documents needed to maintain traceability.
 
The following basic criteria will apply: 
 
  • Every field in the Accreditation Program will be inspected by the accredited entity. 
  • In order to develop uniform protocols for all crop kinds, a panel of SCA representatives familiar with specific crop kinds will be appointed by the Program Manager to develop appropriate protocols. 
  • Field inspectors should also verify the inbreds/cultivars for the phenotypic characteristics with the latest description provided by the seed company. 
 
  • SCAs will determine that all OECD work was performed by authorized entities. 
 
Inspection. An SCA representative will inspect a minimum of 5% of total acreage for all species in the usual manner for that SCA. During the inspection of these “control” fields, an attempt shall be made by SCA representative(s) and representative(s) of accredited entity to jointly monitor and resolve major differences or areas for improvement. If an irregularity that would compromise certification eligibility is discovered by the SCA, the approved entity will be notified immediately. 
 
“Spot check” inspections. The SCA may randomly conduct “spot check” inspections for fields in the program outside of the control acreage. Spot checks may be single visits to check for specific information or may be complete inspections to obtain a “random” set of records for fields not in the control acreage. The SCA shall use spot-check inspection data to compare to the approved entity’s inspectors’ records. All inspection records may be used to evaluate the entity’s performance. These records shall be held in strict confidence by all parties. 
 
The SCA may check inspect a proportion of crops selected randomly from all authorized inspectors and additionally monitor inspectors with a risk of non-compliance at a higher frequency than normal. 
 
Official inspection records shall be compared to the “accredited” inspection records as they are completed. The SCA shall determine final eligibility for certification if differences exist. The approved accredited entity shall receive regular reports during the season for all control fields. The SCA and the approved accredited entity will provide immediate feedback to each other on fields which fail to meet the certification criteria at the time of discovery. 
 
Access to field reports. The OECD Program Manager and appropriate SCA shall have access to the field reports from the approved entity’s field inspectors for all fields during the season. The approved entity will provide to the SCA a field disposition report indicating that the field passed, passed with exceptions, or was rejected. The approved entity will also provide information about the physical disposition of production from fields not fully passing field inspection.
 
As an integral part of the field inspection process, it is required that the approved entity has a documented quality-assurance plan for the field inspection program. This plan must: 
 
  • Have written field inspection standards and protocols, which at a minimum are to be equivalent to the State SCA field inspection standards and protocols. 
  • Designate a key contact person within the entity who will be responsible for timely compliance with all auditing protocols. 
  • Conduct annual training that ensures inspectors are qualified to perform and document field inspections that comply with company and certification standards. 
 
As a minimum, the entity’s annual training program must: 
 
  • Provide a current version of training reference materials to the SCA. 
  • Address both technical competencies and procedural performance expectations in the training/reference materials. 
  • Develop or update a training program syllabus. 
  • Provide inspector training. 
  • Maintain cumulative individualized training records for inspectors. 
  • In advance of training, provide appropriate notification and invitation to SCAs. 
  • Where applicable, fulfill the requirements of the Accredited Field Inspection Program. 
 
Audit of training program. An auditor shall evaluate the entity’s training program for training inspection personnel. The auditor may accomplish this review by auditing the training program, by attending the program, or both. The approved accredited entity will maintain records showing who has been successfully trained and is therefore qualified to perform field inspections. These training records will also be available for review by the auditor.
 
Section D-4: Components of Accreditation—Sampling (including Sealing and Labeling) 
 
SCAs will verify that the approved entity has the necessary equipment and will determine that individuals are qualified to perform seed sampling, sealing, and labeling in accordance with the Program. Entities desiring to sample seed for the OECD Program may do so in cooperation with state seed certifying agencies (SCA) or through participation in the Accredited Seed Sampling Program (ASSP). In either event, the accredited entity should cooperate closely with the SCA in fulfilling the requirements for this component. 
 
The U.S. Designated Authority recognizes the Accredited Seed Sampling Program as a valid alternative for OECD sampling accreditation, provided that the entity incorporates the check-sampling guidelines stated in section 4.7 and that accredited personnel have sufficient knowledge of OECD Seed Certifying Schemes. For further information on the ASSP, contact the OECD Program Manager or select the following hyperlink: Accredited Seed Programs 
 
The SCA will review the company-specific sampling plan that was approved during the initial assessment and verify that the minimum requirements are being met. 
The minimum requirements for the sampling plan must include: 
  • Minimum sample size and frequency appropriate for testing and certification requirements (Note: OECD and state requirements for minimum sample size may vary. More stringent requirements will take precedence.) 
  • Listing of designated sampling points 
  • Sample containers
  • Minimum sample identification criteria 
 
The minimum requirements for the sealing/labeling plan must include: 
  • List of printing equipment 
  • Company documentation for tracking labels 
  • Name of person(s) responsible for labeling at central or specific location 
  • Procedures consistent with the SCA specific requirements 
 
All samples for OECD certified seed inspection shall be taken in accordance with the sampling procedures prescribed in the current Association of Official Seed Certifying Agencies (AOSCA) Operating Procedures and practices as specified in the Association of American Seed Control Officials’ (AASCO) Handbook on Seed Sampling. Samples must also be taken by accredited or official seed samplers 
 
Minimum sample size. The cooperating seed company will supply representative samples of each product to be included in the Program in a container approved by the SCA. The minimum size of the sample will be determined by the International Seed Testing Association (ISTA) rules or contact the SCA. For example, the minimum submitted sample size for corn and sunflower seeds is 1000 grams. 
 
Maximum lot size. To qualify for Certified Seed (blue label), the maximum lot size must conform to OECD regulations (for maximum lot size, see ISTA Rules). For gray label “not finally certified seed,” no maximum lot size applies. 
 
Identification required. Each sample must be clearly and securely labeled (per Sampling Procedure) with the following information: 
 
  • Company name (Producer/Applicant) 
  • Material or product name 
  • Status of sample (finished, sheller, bulk, etc.) 
  • Unique identifying number (i.e. lot or batch number which must match the OECD reference number printed on the tag) 
  • Year of production 
  • Origin of sample (agency applicant) 
  • Conditioner number or name (if applicable) 
  • Seed size designation (if applicable) 
  • Treatment identification (if applicable) 
 
The SCA will accept certification seed samples from approved accredited entities according to agency-specific protocols. 
 
The SCA may issue a receipt of samples to the accredited sampler and will record the information in a manner customary for their business. Seed companies may request a status report on the disposition of samples. As an option, the SCA may enter the information into a sample status log that records receipt of samples (including date of receipt). The accredited entity will maintain a similar sample status log. A copy of the sample status log will be made available to the accredited entity by the most appropriate method. 
 
When submitting samples, the accredited entity will supply appropriate seed details, as well as shipping documents. The SCA may retain samples for later use in post-control grow-out testing. 
 
At least 5% of the labeled seed lots should have post control testing. Sub-samples from the certification seed samples may be used for these post control growout tests. Growouts will be conducted in the SCA’s customary manner and at a location selected by the SCA. If a failure rate of greater than 3% occurs for a company, the percentage of labeled seed lots that must be tested for post control the next year will increase to 25%. 
 
In addition to post accreditation evaluations that should be conducted for all components, at least 5% of the seed lots sampled by accredited seed samplers are check-sampled by SCA samplers for testing comparison. Seed lots that have been sampled by approved automatic samplers (approved by Seed Certifying Agencies) are exempt from this requirement. 
 
The cooperating seed company must provide documentation for seed that has moved from its production origin before final certification of seed will be issued by the SCA. For movement of unconditioned seed entering the United States from other countries, a gray OECD “not finally certified seed” label should be used. 
 
The accredited entity will project the number of blank labels needed. The SCA will then hold in inventory the blank labels until requested by entity. 
 
Printing labels. As an alternative, the entity may manufacture blank labels according to OECD specifications (available from SCA) and provide documentation of how many blank labels were manufactured. If blank labels are ordered by the accredited entity, the 
SCA will record the shipment in their customary manner, which may include recording label serial numbers. The accredited entity is then authorized to print and attach labels to seed lots. The accredited entity submits the printed label, a certification seed sample, and associated documentation to the SCA. 
 
Labeling and sealing report. A labeling and sealing report must be submitted to the SCA (in the customary manner) on or before date of seed shipment and must include the following information: 
  • Cultivar name 
  • Number of pounds and number of units of seed being shipped 
  • Serial numbers used
  • Lot number 
 
Additionally, when the entity is manufacturing their own labels, the labeling report must include the following: 
  • Number of labels manufactured by entity 
  • Number of labels printed 
  • Number of labels attached to bags 
  • Number of labels destroyed 
  • Number of labels in inventory 
 
If the entity has requested labels from the Agency, the report must include the following: 
  • Number of labels printed 
  • Number of labels attached to bags 
  • Number of labels destroyed 
  • Number of labels returned to Agency 
 
Each OECD label must have the following information: 
  • Name and address of SCA 
  • Species and cultivar name 
  • Hybrid/Inbred 
  • Type of cross (i.e. single or double) 
  • Certified Seed (1st, 2nd or other generation) 
  • Reference number 
  • Country of production (if the seed has been previously labeled as “not finally certified seed” 
  • Statement of re-labeling, if required 
  • Lot numbers and origin of Basic Seedstock (for gray tag only) 
  • Net weight (of bag or container) or seed count 
  • Date of sealing (month and year) 
  • Any additional information required by the SCA (i.e. seed treatment). 
 
Additional wording requirements for blue OECD labels for seed exported to European Common Market Countries: 
Statement “Meets EC norms and standards” Sampled and analyzed according to AOSA rules. 
 
It is the responsibility of SCA’s and seed companies to ensure tests are performed which substantiate the above statement. 
 
Note: for purposes of identifying cultivar name, the seed company should provide the SCA with a list of experimental names and their subsequent final cultivar names. This list will be held in confidence by the SCA. 
 
Gray “not finally certified seed” labels should be used when seed lots have not been finally conditioned. Conversely, if a seed lot has been finally conditioned, a blue OECD label should be used. 
 
The cooperating seed company can be accredited for re-labeling seed that has moved from its production origin, but must provide the SCA with the appropriate documentation. 
 
Once all requirements for OECD certification are met for an accredited seed lot, the approved entity will notify the SCA and request an OECD shipping certificate. When the SCA agrees that all requirements have been met, they may issue an OECD shipping certificate (“Certificate Issued Under the OECD Schemes for the Varietal Certification of Seed Moving in International Trade”).
 
Section D-5: Components of Accreditation—Testing 
In some cases, the accredited entity may choose not to become accredited for testing and in that event may utilize the services of a SCA Lab or private or public lab approved by the OECD Program Manager. A list of laboratories which are approved to test for OECD can be found at the following link: OECD Authorized Entities.
 
 
Upon application, auditors will verify that the approved entity meets the requirements of the program. The auditor will also determine whether individuals are qualified to perform seed testing through proficiency testing and training records. Entities desiring to test seed for the OECD Program may do so through participation in the Accredited Seed Laboratory (ASL) Program. 
 
The U.S. Designated Authority recognizes the Accredited Seed Laboratory Program as a valid alternative for OECD testing accreditation, provided that the entity incorporates the check-testing guidelines stated in section 5.4 and that accredited personnel have sufficient knowledge of OECD Seed Certifying Schemes. For further information on the ASL Program, contact the OECD Program Manager or select the following hyperlink: Accredited Seed Programs 
 
The AMS auditor will review the company-specific testing plan that was approved during the initial assessment and verify that the minimum requirements are being met. The minimum requirements for the testing plan must consist of: 
  • List of authorized test types by crop species. 
  • Minimum sample sizes. 
  • Name of Registered Seed Technologist (RST) or equivalent. 
 
The accredited entity’s Lab Manager or equivalent shall oversee the tests in accordance with applicable Association of Official Seed Analysts (AOSA) rules or applicable OECD Seed Scheme requirements. The Registered Seed Technologist (RST) or equivalent shall oversee all OECD testing activities at the accredited entity’s lab relative to AOSA rules.
 
Tests are based on OECD Seed Scheme requirements, which may include: 
  • Purity testing (physical and/or varietal) 
  • Germination 
  • Biochemical testing (calorimetric, electrophoresis, etc.) 
 
A portion of OECD certification seed samples tested at an accredited entity’s location(s) must be check-tested in a SCA laboratory or an official laboratory approved by the OECD Program Manager. The proportion must be at least 5%. The SCA will compare test results submitted by the seed company against official test results for previously submitted samples. 
The SCA and approved laboratories will also be responsible for ensuring that samples were taken by authorized samplers. 
 
The accredited entity’s Lab Manager shall generate and submit a test report detailing the findings for each seed lot that will be labeled for certification. The format for this report shall be in accordance with SCA’s specific requirements. The lab report shall be submitted to the SCA and recorded as received on the sample status log. Test results are required for all seed samples that are submitted as part of the Program. 
 
Identification required. To facilitate matching test results with submitted samples, each test report must be clearly labeled with same information submitted with samples: 
  • Company name (Producer/Applicant) 
  • Material or product name 
  • Unique identifying number (i.e. lot or batch number which must match the OECD reference number printed on the tag) 
  • Year of production 
  • Seed size designation (if applicable) 
  • Treatment identification (if applicable) 
  • Test types that were conducted 
  • Additional information as required by the SCA 
 
Minimum levels. For equivalency arrangements with the European Union, the levels of germination and purity differ for some crops. More information concerning EU requirements is available at the following links: for cereals, Council Directive on cereals ; for fodder plant seed, Council directive on fodder plant seeds ; and for oil and fiber plant seed, Council Directive on oil and fiber seeds . For example, for corn and sunflowers, the levels of purity and germination are: 
 
 SunflowerCorn
Germination minimum:90%84%
Physical Purity minimum:98%98%
If a testing quality concern arises or if the sample(s) or result(s) do not conform to requirements (such as EU Norms and Standards, OECD, country-specific requirements, etc.) the accredited entity shall be allowed to re-sample and re-submit the certification seed samples for more testing at the discretion of the SCA. If a second sample is submitted, the sample must be labeled as a “second sample” along with the original identifiers. 
Samples must be maintained and stored by the SCA and the accredited entity in accordance with the Federal Seed Act. 
 
Section D-6: Post Accreditation Procedures 
 
SCA responsibilities. Annually, the SCAs will evaluate accredited entities for compliance with the program. An evaluation form will be distributed to the SCAs by the OECD Program Manager each year and should be completed and returned. SCAs should obtain, prior to the annual evaluation, any new or revised Standard Operating Procedures (SOPs) or work instructions. SCAs will also provide the OECD Program Manager with previous reports and summaries for the accredited entity prior to, or at the time when, annual evaluations are submitted. 
 
In addition, the SCA will be responsible for specific requirements of the individual components of accreditation as indicated in sections D-3 through D-5. 
 
Those entities that have successfully fulfilled the requirements of the annual evaluation by the SCA and remain accredited, if applicable, under the relevant Process Verified Program will be noted on the List of US OECD Authorized and/or Official Entities. 
 
Areas for improvement. If the annual evaluation reveals areas for improvement, the entity shall be given the opportunity to take corrective actions. The OECD Program Manager will determine the appropriate steps based on the annual evaluation and any corrective actions taken. 
 
Monitoring. SCAs will assist the OECD Program Manager in monitoring compliance with program requirements. If non-compliances are discovered, the OECD Program Manager will contact the accredited entity and request updated information relative to the non-compliance or particular areas under review. 
 
A review of the accredited entity’s facilities, procedures, and records will be conducted to (1) determine conformance with the program, and (2) verify the accredited entity’s ability to meet all of the requirements of the program. These surveillance audits will be performed no less frequently than once every 3 years
 
Section D-7: Seed Certification 
Certificates are issued when program requirements are met and requested by the seed company. 
 
When all requirements for OECD certification are met for an accredited seed lot, the approved entity will notify the SCA and request an OECD shipping certificate. When the SCA agrees that all requirements are met, they will issue an OECD shipping certificate. If approval is not granted, the SCA will notify the accredited entity immediately.
 
The certificate shall contain the text: 
“Certificate Issued Under the OECD Schemes for the Varietal Certification of Seed Moving in International Trade” 
 
Note: All certified lots are subject to post-control testing with protocols established by the SCA and the U.S. Designated Authority for OECD Seed Schemes. 
 
Section D-8: Appeals, Removal from Program, Re-Instatement 
Appeals. Appeals of adverse decisions under this Program may be made in writing to the Chief, Seed Regulatory and Testing Division, 801 Summit Crossing Place, Suite C, Gastonia, NC 28054-2193. Appeals must be made within 30 days of receipt of adverse decision. 
The appeal must include reasons and facts as to why the decision should be reversed. A 3-person review committee, comprised of the Division Director, the OECD Program Manager, and an SCA representative (appointed by the OECD Program Manager), will be convened to review the appeal. Following review of the appeal, the Division Director will grant or deny the appeal in writing within 30 days, stating the reason for his or her decision. 
 
Removal from program. Entities or locations that have failed to meet accreditation requirements, are no longer participating in the Process Verified Programs for Seed (where applicable), and have exhausted the appeals process will be removed from the List of US OECD Authorized and/or Official Entities by order of the OECD Program Manager, thus terminating the entity’s accreditation with the program. 
 
Re-Instatement. If an entity chooses not to participate in the Accreditation program for two consecutive years and is not being audited on an annual basis by a designated auditor then the entire program or locations not participating should be re-evaluated prior to re-instatement in the Program.