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

Thirteen of 15 NOSB members present:

Source: Aaron Yoo

Ashley Swaffar
Jesse Buie 
Emily Oakley
Steve Ela
Harriet Behar
Asa Bradman
A-dae Romero-Briones 
Sue Baird 
Tom Chapman
Eric Schwartz
Lisa de Lima 
Dave Mortensen
Scott Rice

James R. “Rick” Greenwood was not present.
Dan Seitz may have joined late.

Michelle from NOP gives some housekeeping comments.
Paul Lewis gives opening comments
Tom Chapman (Chair of NOSB) also offers some oral comments.

[In Cornucopia staff notes on individual comments below, our staff has included the commenter’s name, affiliation, and topic(s) addressed in comments.]

Amalie Lipstreu, Policy Coordinator, Ohio Ecological Food and Farm Association, Comment Topic: General
Prohibited substances being used during energy infrastructure building. Add a study on energy infrastructure impacts.
Encourage looking at levels of contamination of seed, especially corn.
Genetic contamination testing methods are different, and equivalence between methods is not certain.
Burden should not be on organic farmers for genetic integrity.
Qs from Board: Any testing of water, etc? No, don’t foresee that need yet.
Impact of extraction – what would work plan product look like?
A: Ultimately want as many mitigation protections as possible.

Harold Austin, Organic consumer and former member of the NOSB, Comment Topic: Crops, general
Expresses support all of the crop subcommittee position except for allyl isothiocyanate, which could be very useful.
Materials subcommittee: marine materials discussion doc – this document is not ready for review; need to enhance environment and be sustainable. This document creates more questions:
Q: Difficult to find international definition of sustainability, how do we figure out scope?
A: Environmental concerns and folks who rely on these materials are serious. Ideally form committee to analyze this. Take your time. Environmental concerns, feasibility, and impact on stakeholders.
Q: Wild crops standards enough for marine issues?
A: Unknown.
Q: Allyl isothiocyanate, more detailed thoughts?
A: Compared to other materials on conventional agriculture side, this substance is less toxic. And phytosanitary standards we need to meet, especially for nurseries. We could use this material in a defined application technique, which is close to natural materials. Especially with rootstock and planting stock – could be good tool for organics.
Q: Would you be in favor of annotation restricting it to planting stocks?
A: I would not be opposed to that at all.

Percy W Hawkes, Protena Nicaragua, Comment Topic: Crops
Sodium citrate should be permitted for use. Commonly used as anti-coagulant, used in slaughterhouses (processing aid). Used for organic derivative fertilizers.
Q: Vast majority of dried blood meal has sodium citrate in it now?
A: yes, it is the anti-coagulant now.
Q: Did a certifier say that you couldn’t use blood meal fertilizer if this substance was used to create the fertilizer?
A: Yes.
Q: blood meal fertilizer has been allowed in the past w/o a review.
A: Some blood meal is processed from raw blood directly. Other international organizations need to have it approved too.

Ted Auch, PhD, Researcher and Staff Photographer, The FracTracker Alliance, Comment Topic: General
Soil scientist. Look at unconventional oil and gas industry; water, land, and waste impacts. It’s critical that you get an idea of the magnitude of unconventional oil and gas industry. It is everywhere and having dramatic impact. Fracking includes tremendous amount of infrastructure and moving stuff – trickled down to organic stakeholders. They have mapped the impact and it can be found at their website.

Julia Barton, Ohio Ecological Food and Farm Association, Comment Topic: General
Ongoing request to board regarding energy infrastructure to work agenda. This development has serious impact to organic farms. We need consistency and transparency on how to deal with this. Prohibited substances are used all the time in the infrastructure.
Inspectors have a difficult time. Guidance is really needed.

Doug Raubenolt, organic inspector, IOIA, Comment Topic: General
Oil and natural gas boom led to huge projects with organic farms in their path. Inspectors have been employed to ensure their farm maintains organic status in the light of pipelines and others going in. NOP regulations are unclear in the following areas concerning these issues:
Topsoil replacement
Rock formations (drilling and blasting by companies – once the substance has exploded, is it still prohibited?)
Concern for things buried deep, well below soil, is it still a concern?
Toxic products used during building need to be monitored.

Jo Ann Baumgartner, Wild Farm Alliance, Comment Topic: General
WFA is happy about the native ecosystems passage and is producing a draft guidance to help with the native ecosystem rulemaking.
Marine materials: any seaweed should be harvested regarding the wild crops standard (showing no environmental impact). Visual assessment alone is not enough, but assessment of all aspects before and after harvest is needed. Wildlife documentation should be required. Encourage working group with marine biologists, producers, folks affected, etc. to discuss the issue.

Corellia Johnson, General

Steve Etka, Policy Director, National Organic Coalition, Comment Topic: General
Policy updates: Farm bill officially expired; both versions include good and bad provisions. NOC strongly opposes changes to the NOSB authority. Concerned about the lack of reliable USDA organic data collection. Gaps in data are very bad; make it difficult to track fraud, etc. Urges AMS to hire statisticians.
Petitioner should show they have exhausted efforts to produce an ingredient organically, rather than just showing they haven’t been able to source an organic ingredient. We should be able to source all ingredients organically.
Q: Clarify what data had been collected prior to 2015 that is not being collected?
A: ERS did organic certifier survey, transferred to NASS later, and that survey would go out to each certifier to collect data, which led to higher compliance. AMS has taken over that function – and the survey process has been slow to get started and, with the complexity of what certifiers have to supply, there has not been good compliance data. We don’t know how much organic acreage there is anymore (last data in 2015).
Q: Sec. 606 issue, farmers not being able to find markets?
A: Hops example, big fight about whether that could come off 606 list. In general, the organic market can provide any certified organic crops, but you have to encourage farmers by showing them there is a market for those materials (like hops).

Ari Davis, The Soil Company, Comment Topic: CACS, Policy Development (PDS)

Nathan Brown, organic farmer, Comment Topic: Crops
Organic dairy, past chair of Montana Organic Assn.
Paper pot transplanter issue. Would like recommendation from NOSB to extend December 2018 expiration of its use until the topic can be discussed and voted on. The paper pot transplanter has been used for one year and it has transformed farm.
Q/comment: One of the issues is that recycled paper is allowed but not virgin paper (pots are usually composed of virgin paper). How do we extend a deadline for something that is synthetic without other approval? It may set a poor precedent.
A: The glue is in other paper products like cardboard and composting and other things being used.
Q: The materials are synthetics and the comparison of virgin vs. recycled paper. Probably the current situation (regarding the material needing to be reviewed and accepted before use in organics) deals with the adhesive.

Jessica Shade, The Organic Center, Comment Topic: Materials
Support creation of research priority framework.
Happy to see: Plant disease management, invasive insects, production of celery for powder, etc. because TOC is actively involved in conducting research on these topics.
Comparison of low and no-till production research. Reduced tillage of crops increases carbon storage. Reduced tillage is also associated with reduced yield of final product. More research is needed!
Three additional beneficial research priorities: soil health, climate change (mitigation/best practices, and adaptation to changing climate), and pathogen protection.

Amber Pool, CCOF, Comment Topic: Crops
Color requirements for printing on produce boxes are restrictive. Modifying section 205.311 to allow printing in any single color would reduce burden on farmers.

Jaydee Hanson, Sr. Policy Analyst, Center for Food Safety, Comment Topic: Materials
Silver dihydrogen citrate: NOSB should direct the petition. Even with recommended annotation, there are substantial concerns regarding nanoparticles and human/environmental health impacts.
Q: Any evidence of contaminated soils?
A: Silver is very toxic, even more so when combined with citrate.
Q: How do you deal with contaminated foods then?
A: Should be reserved for medical uses and not sprayed around farms or cutting boards, etc. Research shows certain plants are prone to uptake silver ions. The EPA had a belief rather than science-based policy regarding this substance.

Ronald Gonzalez, Dole Tropical Products, Comment Topic: Crops
Skipped at first but then returned to. (Difficult to hear)
Ethelyne gas is a necessary material for pineapples to control flowering, cannot find any alternatives.

Jaime Barron, Vision Produce Co., Comment Topic: CACS, Handling

Timothy Opiela, Researcher, Alpha Gal Allergy (Red Meat Allergy)

Tonda Fernando

Harold Lyles

Jean Marie N Gore Traore, Wari Di

Inita Patton

Kestrel,Burcham, The Cornucopia Institute, Comment Topic: Material petitions, livestock research priorities
Supports Beyond Pesticides’ written comments, including opposition to the listing of silver dihydrogen citrate, allyl isothiocyanate, and natamycin. Supports livestock research priorities (especially for methionine), cautionary principle with marine materials.

Suzanne McMillan, Content Director, American Society for the Prevention of Cruelty to Animals (ASPCA), Comment Topic: Livestock
Reforms to policies are needed to ensure welfare of animals in organics. Genetics inform behavior and physical issues; mast majority of farm animals are bred for high production which has severe animal welfare implications. Breeding programs only emphasize production traits, and the other functions of the animal suffer as a result. Environmental stressors also add to the problem. These unbalanced genetics now dominate the U.S., and many organic lines are sourced from the same genetic lines with the same faults.

Heidy Lopez- Rodriguez, Van Drunen Farms

Joseph Smilanick, Consulting plant pathologist

Michael Forrest, Youngstown Grape Distributors

Frankie Thorn, Green Mother Zen Farms

Linley Dixon, Associate Director, Real Organic Project, Comment Topic: General
Farmer-driven effort to get organic standards back in line with the law. There are major differences in how certifiers interpret the law, encouraging shopping. Farms that have the ROP add-on label are fostering soil fertility and outdoor access. Urges the NOSB to make the ROP obsolete and to enforce strong animal welfare standards, soil-fertility. ROP published provisional standards online. ROP has many farms in pilot project – farmer interview available as well. Complete transparency is in line with organic law.

Brian Bates, Bear Creek Organic Farm in northern Michigan
Potential ban of paper pot transplant paper. Black plastic mulch is used and is 100% synthetic, but that is allowed. The paper pot system changed everything from efficiency in greenhouse and field and environmental standpoints. Has allowed them to lower their prices and become cash positive when they were not previously. Supports a proper review, but the notice that it is not allowed was too short. They will have to lay off staff.
Q: The NOP has not been hearing a lot about the need for paper pots, so your comment is appreciated. Your comparison with the plastic is useful.
A: The paper pot system is only used by small farms and is very beneficial for small farms. Not widely scale-able. Feels like a particular attack on small growers. The annoyance over virgin vs. recycled paper is also an issue (pots are virgin paper).

Miraj Patel

Rodrigo Cifuentes, affiliated with Pace International

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