Cornucopia staff members attended the National Organic Standards Board (NOSB) pre-meeting webinar today, where the NOSB heard comments from the public. Cornucopia’s notes from this meeting are below.

You can also view our notes from the Tuesday webinar.

Eleven NOSB members present
(2 missing, environmentalist and handler NOSB positions have not been filled)

Source: gdsteam

Edward Field, Natural Merchants, Inc.

Elimination of Sulphur dioxide would be detrimental for business and for organic wine producers.
In Europe all of our wine would be considered organic.  Since ruling on sulphites in 2012, we have followed guidelines to the letter.   Organic wine sales continue to grow between 10-20% by volume.  Sulphites are a key part of that production.   Majority of our portfolio must continue to have sulphites.  No viable alternative.  Use does not threaten integrity of organic label and should retain Sulphur dioxide on the National List.

Katharina Schlegel, BASF Corporation

Another representative from BASF spoke instead.

Addressed biodegradability of bio-based plastic mulches in soil.  In Europe new standard was created to allow for these to be used.

Harriet:  Can you tell me if there was any part in studies that if continual use in same area resulted in any spike in nutrients or differences in soil bio?

Asa:  Is there any update on the proportion that is petroleum derived?

Answer:  No change since last meeting.

Angela Anandappa, Alliance for Advanced Sanitation 

Alliance is public/private partnership w/ Univ. of Nebraska; goal to improve sanitation practices; research involves cleaning products/sanitary agents for food.

Experts need to evaluate microbials and proper use and suitability for particular operations.

Mary Agnes Rawlings, Farm Owner

Not on call

Angela Wartes-Kahl, Independent Organic Services, Inc.

Organic inspector; topic of uncertified operations in the supply chain; certified operations are selling to uncertified handlers and this is a threat to organics.  Handler must be certified.     Because inspectors not physically present all the time, reviewing product labels and supplier invoices, there is plenty of room for fraud if certification isn’t required throughout the entire supply chain.   Dried fruits, spices, chocolate are problematic.   Imperative that the NOP close the loophole and require all handlers in the chain be certified.  Supports comments of OTA and Oregon Tilth.

Britt Lundgren, Stonyfield

Sympathetic to ecosystem proposal, however concerned that the definition of native ecosystems describes most forest land in New England region.   If a farm needs to expand to meet nutritional needs of cattle/might need to clear land within walking distance to the milking parlor.  These farmers are not choosing to log land because conversion is faster.  This is the only land to expand their operation.  Developments are the problem, not organic farms.  Proposal should focus on eliminated high conservation value ecosystems.  If NOP adopts proposal, many organic dairies won’t be able to expand operations and would damage transfer to next generation.  Revise proposal to high value, rather than native ecosystems.

Emily:  We’ve discussed your comment on subcommittee calls.  You have been heard.  Some of land farmers might be looking to convert would not fall under the definition of native ecosystems.  Good amount of land in New England has been converted back to forest.  Want to express we are trying to achieve consumer expectation as well.  Do you have sense of what percentage of Stonyfield farmers are converting forestland into farmland?

Answer: Informal survey, identified 10 farms out of 30 that are in direct milk supply who had cleared land to convert to pasture.  It’s a common practice in New England region.   It’s routine for any operation that is expanding to cut down some trees.  A lot open to interpretation in applying native ecosystems definition.  Sensitive to consumer expectations because we want to meet expectations of consumers and also spent a lot of time on consumer expectations on pasture standards.  They need pasture to meet expectations.

Emily:   Not an outright prohibition.  Do you have a sense of those 10 operations (out of 30), the amount of acres that had to be converted from woodlands to pasture?

Answer:  It was an informal survey so I wouldn’t characterize it as a large amount, but don’t have the number.

Ashley:   On the definition of native ecosystems, if we cut out the last sentence, would that alleviate your concern?

Answer:   Yes, that would help.  Depends on who is doing the evaluation and some people would define based solely on plant species and not historic use.  If classic mix, might conclude it’s native whether or not land was previously disturbed.

Katherine DiMatteo, Wolf, DiMatteo & Associates

During sunset reviews please ask if material could be useful in the future.  It is very difficult to put something back on the list.  To put back a National List material is a long and arduous process.  Please don’t limit the toolbox unnecessarily.  Sodium nitrate Sunsetted in Oct. 2012, but the NOP never acted on this – shouldn’t it be considered for another sunset review now? NL should be based upon the review of criteria, not to keep the list small.

Francis Thicke, Organic Farmers Association

Recent developments in EU for hydroponics.  EU just confirmed ban on hydroponic production and prohibits importation of hydroponics from US;  EU does not allow organic production of hydroponics.   All organic production will have to be in soil.   New EU regulation will require US to comply with their rules on hydro. and will not be able to ship hydroponically grown products to EU as organic.

Urge NOP to put container and greenhouse standards back on agenda.   OFA opposes hydroponic production under the organic label.

Tom:   A lot of differences between EU and US standards.   Why do you view this different from other differences?

Answer:   Regulation passed by European parliament—my impression is regulation may be broader for hydroponics than other issues.

Tom:   Why is this different than other differences with EU?

Answer:  This new regulation will modify equivalency agreement. EU is going to prohibit importation of US hydroponically grown produce.

Tom:   Why does this change way US regulates products?

Answer:   Exporters will not be able to get hydroponic products into EU.   If it came into EU and was discovered to be hydroponic, it’s possible certifier would lose license.

Tom:    How is this different from US and Canada equivalency?

Answer:  Canadians will also have to conform to EU regulations as well.

Emily:    What issues should we address for container growing?

Answer:    Don’t have any greenhouse standards.  Do not have standards for hydroponics.  If going to certify, then need standards for lights, what to do with plastic containers, disposal of media, energy use.

Harriet: My understanding is that EU hydroponic operations using approved inputs can then import products into US as organic (can’t sell in EU but can export into US).

Answer:  Yes, hydroponically produced EU product can be imported into US as organic, but not sold as organic in the EU

Tom:   A lot of difference between EU and US standards.

Catherine McDonnell-Forney

Not on call 

Aviva Glaser,  National Wildlife Federation

Not on call

Thomas Braun, N2E + for Life 

Pharmacist and health advocate; need nutrient-rich diet;  in our labeling regulations, trace toxins are included under “natural flavors”; majority of disease states are inflammatory caused by trace toxins;  consumers have the right to know; food producers and FDA don’t recognize that these trace toxins cause disease states;  food industry must reduce impact of chemicals consumed by the American consumer; need food definition of “organic” that is without man-made chemicals; growers must reduce chemicals in food supply; need a healthy America.

Megan DeBates, Organic Trade Association 

Import Fraud–Faso introduced legislation to increase funding to track products through supply chain; entire bill included in Farm Bill; provision that requires the USDA to complete rule making and limit types of operations that are excluded from certification; NOSB needs to provide thorough definitions.

Elise George, OEFFA Certification  

Must require importers and brokers to be certified; would be minimal impact on industry; import certificates are helpful; lot numbers should be included on import certificates; import certificates should be required for all imports; a risk-based system would be an excellent tool to detect and deter fraud.

Tom:  How would cross-checks work?

Answer:  Select certifiers to initiate cross-checks for high risk operators throughout process linking all the way back to the farm; look at different tools to ensure record keeping. 

Carol Goland, Ohio Ecological Food & Farm Association

Executive Director
NOSB is essential; NOSB should have authority to set own work plan; hope will return to publishing subcommittee notes online; deeply concerned by USDA’s disregard of NOSB’s recommendation;  urge NOSB to support and lead organic community; ask NOP to prohibit certification when no applicable standards exist; structure and function are related

Noelle Weber Strauss, general public

Wisconsin mother, uses USDA organic label as a guide; recently brought to her attention that USDA label isn’t gold standard anymore; food plays large rule in health crisis; can’t use natural or synthetic flavors in organics; carrageenan should not be allowed in our foods; food is medicine if food is real; without integrity of USDA organic label, we will be lost.

Dave Shively, Shively Farms; President of OEFFA Grain Growers Chapter

Organic farmer in Ohio, grows corn, soybean, wheats, oats, rye, cover crops;

Addressing fraudulent imports—huge impact on farmers; fraudulent imports have tarnished organic name; everything for US growers is traced and just yesterday came to my attention that we are holding another ship with about a million bushels of corns from Turkey and further investigations found from Russia and other countries; these countries importing grain under these conditions should be stripped of their organic certification;  some companies playing a shell game; millions can be made by this and we call it the organic grain mafia; urge the USDA to continue to take hold on this and be diligent about keeping integrity.

Harriet:   We don’t have enough domestic production to supply livestock.   Can you address this?

Answer:  Year ago our markets started dropping and could feel effects for everyone.  Instead of $10-12 for corn, getting $9, if even that.  That has a tremendous impact.  We can compete if we’re on the same playing field.  We can eventually meet domestic needs with level playing field.

David Marchant, Certified Organic Farmer in Vermont- River Berry Farm

Addressing biodegradable mulches; plastic waste is major issue; NOSB and NOP need to encourage development of biodegradable mulch; need to set realistic goals to decrease use of plastic mulch over time.

Suzanne McMillian, ASPCA

Condemn USDA for withdrawing livestock and poultry rule; need meaningful animal welfare standards

Michael Jones, Sanctuary Farm

Located North Central, Ohio; produces soybeans, popcorns, field corns, hay, wheat;

Addressing fraudulent imports of soybeans and corn—cost to his small farm of 140 acres is $21,000 last year because of prices of imports;  that’s a 30 percent loss;  no problem competing as long as same playing field, but continues to see imports coming in with different standards; OIG found NOP couldn’t provide reasonable assurance that imports are from certified organic farms;  biggest concern is that fraudulent organics will destroy trust in organic label;  EU has a watch list of countries; we need to look at that.

Dave:  Board is thankful to hear about this issue, especially from growers about real world problems.

Answer:  Wants to pass farm on to next generation and has to be economically viable to do it.

Michael Stein, Organic Farming Research Foundation

Policy Associate
Addressing weed pest and disease pressures for organic farmers;  biggest challenge is the weed pest and disease pressures organic farmers are facing; several recommendations—look at soil health and conservation, cover crops, and building organic matter; NOSB puts out research recommendations and would encourage NOSB to keep putting these out; purpose in commenting is to request more research on organic soil health; need reliable protocols for farmers to be able to implement and predictable guidelines and testing methods to look at soil health and fertility; this is very regional or state to state; increased research needs on soil health.

Harriet:  Soil health has been getting a lot of attention. What are specific areas that focus on organic?

Answer:  More research on the role of soil and living root biomass; look at what happens in organic systems and looking at how organic systems can promote soil health.  Measurements of soil health are largely undefined and we need more research in this area.

John Schumacher, Hallcrest Vineyards & The Organic Wine Works

Not on call

Lois Christie, Christie Organic Consultants, Inc.

Sulfur burners/to produce sulfurous acid are beneficial to drought-prone areas with high soil pH; less problems with build-up of algae in irrigation lines; important for plant health; better for soil than granular sulfur

David Bell, Paul Bell and Sons, LLC

Member of OFA grain growers chapter; 450 acres of corn, beans, wheat, and other crops;  addressing imports—significant impact on operations, lost $189,000 in price reduction;  if public can’t be sure product is truly organic then they won’t spend extra money;  no one is verifying imports are organic; paperwork needs to be verified before shipment leaves foreign countries and at least when they get to our ports; rules of organic production must be enforced or will lose market and way of life.

Harriet:   I understand. I don’t hear anyone talking about the health consequences to livestock if animals aren’t being fed nutritious organic feed.  Complete supply chain problem.

Emily:  Echoing what Dave said earlier about appreciation for farmers’ presence in the comments.

Dave: My sense is something is going to change; the stars aligned for this issue to be addressed by NOSB.  Climate is right for something to happen and the testimonials help make compelling argument that it has to change quickly.

Emily Musgrave, Driscolls

Not on call

Andrew Tomes,  WISErg

Works for manufacturer of organic fertilizer; liquid fish fertilizers need to be reviewed again; quoted Cornucopia’s 2015 comments on concern for overharvesting of forage fish.

Emily:  Aware of specific example of fish being harvested specifically for fertilizer use?

Answer:  Overharvest of forage fish is having impact on fish populations, I will submit study.

Asa:  Did you submit written comments?

Answer:   No, but will send copy of verbal comments

Jeff Bogusz, Ferrara Candy Company

Flavors should remain on the list, but keep requirement to use organic when available.

Steve:   Speak more to Sulphur dioxide?

Answer:  Used as preservative in some of products we purchase; most cooked off in production process

Robert Rankin, International Food Additives Council

Support listing of several sunset review substances:

Gellan gum – used to stabilize and thicken;

Magnesium stearate – not aware of comparable organic alternatives

Lecithin (oiled and de-oiled) –  has unique functionality. Organic supply of de-oiled is sufficient.

Question:  How should we determine if substance is available in sufficient supply?

Answer:  Difficult to survey all supply and demand. Also evaluate if substance is essential.

Harriet:   What are barriers to having more of this product organically in the marketplace?

Answer:   Believes it’s a matter of having enough certified to supply entire market.  Finding adequate supplies that aren’t genetically engineered is challenging.   Will follow up with more information.

Ray DeVirgiliis, International Food Additives Council

Xanthan gum—produced from natural sources; production doesn’t harm environment; safe and aligns with organic principles; should relist and should be listed as non-synthetic

Phosphoric acid—should be relisted; does not negatively affect environment

Mono and diglycerides—should be relisted

Michelle Smolarski, International Food Additives Council

Alginates – should be allowed; produced from algae; safe for humans; used to provide structure in organic foods that consumers expect; NOSB should relist

Gums—should relist; demand is high; improve texture and mouthfeel and reduce calories; organic forms aren’t available in sufficient quantities; guar gum is extremely versatile; gum arabic and locust bean gum should be relisted and there are not technologically comparable ingredients

Emily:   Board might consider proposal requiring organic certification of marine materials.  How would this affect producers and manufacturers?

Answer:  Defer to experts

Steve:  How do we know if alginates being harvested in sustainable manner?

Answer:  Defer to member of organization; continue dialogue

Dave:  how do I find out more about IFAC organization; website requires password

Answer:  go to

Stephanie Rose

Supports potassium silicates; safe for humans and for aquatic systems;

Asa:  How does this change structure of plant?

Answer: foliar application; not sure about cellular changes or how different when applied as foliar application; will provide more information.

Steve:  How much is it being used?

Answer: Part of regular programs; selling in 20 different states; would be on regular rotation with other fungicides; benefits of applying as fertilizer but not allowed in organic farming; as far as she knows only using as a foliar application.

Aviva Glaser, National Wildlife Federation

Reducing Incentive to Convert Native Ecosystems proposal—believes concerns can be met through additional clarification; board should approve proposal; believes organic certification does not incentivize the conservation of natural ecosystems into agricultural production; supports proposal; a few concerns about grazing—guidance could address restoring habitat;

Emily:  impact of removing native ecosystems on wildlife

Answer:   lost habit, climate concerns, native ecosystems store carbon

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