Almost every citizen who grocery shops in the United States will see the United States Department of Agriculture’s (USDA) organic label on some food products.  The organic label is the result of the USDA’s 1990 Organic Foods Production Act that sought to unify organic foods productions standards and establish a consistent organic labeling system through the creation of the National Organic Program (NOP).  Since its inception, the content of the NOP has challenged practitioners and researchers alike in its multiple levels of regulatory action including state, local government, and private sector actors.  Additional challenges emerge from the hundreds of institutional statements within the NOP that specify what is permitted, required, and forbidden for certain actors under certain conditions.  Regulations such as the NOP pose distinct difficulties for anyone attempting to understand the architecture of policy designs and the intended action in their implementation. An approach to comprehending such regulations is found in the institutional grammar tool (IGT), initially developed by Drs Sue Crawford and Elinor Ostrom in 1995.  The IGT provides guidelines for systematically analyzing institutions, especially those rules, norms, and strategies written into policy designs.  In this paper, we apply the IGT to provide clarity to the actions depicted across levels of government in the NOP.  The IGT-driven content analysis clarifies the multiple actor categories identified within the NOP, the authority that is deferred to actor categories, and the levels of interaction where such authority is exercised.  There are four contributions to the study of policy design from this paper.  The first is a clarification of IGT coding guidelines for complex regulation such as the NOP.  The second is offering guidelines for categorizing and analyzing nested institutional statements.  The third is the incorporation of action levels into the grammar analysis of policy.  And the fourth is providing recommendations for descriptive and explanatory approaches for understanding and improving policy designs toward improved implementation outputs and outcomes.