Follow the National Organic Standards Board Meeting in St. Paul, MN #NOSB

October 24th, 2018

Join The Cornucopia Institute as we keep you informed via live tweet and web updates from the National Organic Standards Board (NOSB) meeting in St. Paul, MN October 24-26.

We will be sharing the play by play both below and with our Twitter followers, at #NOSB or by simply following our stream.

For background on issues up for discussion at the meeting, see:

Friday, October 27, 2018

5:21 PM CT: Behar adjourns the fall 2018 NOSB meeting.

The next meeting of the NOSB will be April 24-26, 2019 in Seattle, WA. Check the meeting page for information, agenda, and workplan.

National Organic Standards Board, Fall 2018

5:20 PM CT: Dr. Jennifer Tucker (NOP, acting Deputy Administrator) awarded Tom Chapman two “kudos” for his two years of service as NOSB Chair.

5:17 PM CT: The NOSB holds their annual election of officers.

  • Harriet Behar (NOSB, environmentalists/resource conservationists member) is elected Board Chair.
  • Steve Ela (NOSB, organic farmer member) is elected Board Vice Chair.
  • Scott Rice (NOSB, certifier member) is elected Board Secretary.

5:05 PM CT: NOSB board chair Tom Chapman (handler/processor member; Clif Bar) states the spring 2019 NOSB work agenda will be published online after their executive call.

[Cornucopia will update this feed when it is posted.]

5:02 PM CT: Crops Subcommittee (CS) moves to review the discussion document on paper pots as petitioned for use in organics.

Behar (NOSB, environmentalists/resource conservationists member) says we heard many public comments on this, and that she was impressed by the number of personal letters regarding the importance of this material. Numerous certifiers who have not allowed this material were in favor of extending the grace period for use until it can be reviewed. Behar offered a resolution (see photos below).

Oakley (NOSB, organic farmer member) encouraged stakeholders to send letters of support for paper pots to the Secretary and Undersecretary of the USDA. Ela (NOSB, organic farmer member) reiterated the importance of letters. Ela added that we cannot approve a product, only materials. We may look at the broader use of paper as a planting aid as well. I am concerned about adhesives added after paper is made. Stakeholder feedback is encouraged. We are seeking to avoid a broad allowance that would surely have unintended consequences.

Motion for the resolution passed unanimously.

4:55 PM CT: Crops Subcommittee (CS) moves to review the discussion document on aAmmonium citrate and ammonium glycinate as petitioned for use in organics.

Mortensen (NOSB, scientist member) states that these two compounds were submitted for consideration as agents to help deliver micronutrients to the soil for plant uptake. He adds that the comments noted that the board did not understand the chemistry and suggested that language was being misused. A technical review was requested to help sort out the chemistry. Mortensen says that ambiguous language needs to be clarified around chelating agents.

Crops Subcommittee moves to review the discussion document on calcium acetate as petitioned for use in organics.

Ela (NOSB, organic farmer member) says the comments suggested annotation and also suggested that it is problematic to apply this synthetic material to deal with the ill effects of plastic use.

4:42 PM CT: Crops Subcommittee (CS) moves to discuss the proposal on strengthening the organic seed guidance.

Behar (NOSB, environmentalists/resource conservationists member) notes that there was not public agreement on parts of the proposal, and they are being removed. As soon as the docket opens again, the public should make comments on this issue. Oakley (NOSB, organic farmer member) says that variety selection is an important tool for farmers. Many vegetable farmers perform seed trials, and rely on varieties found to work well over the years. Ela (NOSB, organic farmer member) adds that there is very little organic perennial material out there, specifically due to nursery stock issues.

Motion to amend the organic seed guidance proposal as noted passed unanimously.

Motion to accept all additions as described in the proposal to the NOP Regulations passed unanimously.

4:29 PM CT: Crops Subcommittee (CS) moves to discuss the proposal on natamycin as petitioned for use in organics.

Behar (NOSB, environmentalists/resource conservationists member) says there is agreement that this is a nonsynthetic, but also some concerns regarding human health. There is some resistance possible in candida.  She noted that most commenters want it to be listed on the prohibited nonsynthetic list and that some mushroom growers find it useful in dry bubble disease.

Slide: Natamycin

Behar shares that former NOSB member Tina Ehlers expressed that this is used on the conventional side, but it is not needed for organic mushroom production. She believes good management and exclusion are the front line defenses. Oakley (NOSB, organic farmer member) states that mushroom growers she knows had never heard of this use. Swaffar (NOSB, organic farmer member) asks what the precedence is for receiving a petition and then putting the material on the prohibited list. Chapman (NOSB, handlers/processors member; Clif Bar representative) responds that this one is unique in that once they vote that it is nonsynthetic, it is out of their purview.  This is the reason for taking this step. He asks if MOM’s allows this material in food products. de Lima (NOSB, retailer member) responds no, but she is not sure why not. Behar says that if approved for use there would be no way for retailers to know when it was used. Ela (NOSB, organic farmer member) notes that it would be very useful in his operation, but the human use issue is a problem. Chapman says it is unclear where pickle producers would use it in the supply chain.

Motion to classify natamycin as a nonsynthetic substance passes unanimously.

Motion to add natamycin as a nonsynthetic substance prohibited for use in organic crop production passes unanimously.

4:20 PM CT: Crops Subcommittee (CS) moves to discuss the proposal on sodium citrate as petitioned for use in organics.

Behar (NOSB, environmentalists/resource conservationists member) states that sodium citrate is already on the National List for processing, but this petition is for its use as an anticoagulant in blood meal.  She adds that they do not normally review processing aids for crop inputs, and that many comments inquired about the irregularity in this petition yet the NOP encouraged us to move forward to give due diligence. Behar suggests that, if approved, this opens the door to removing other materials from the list or to not be approved by certifiers because other processing aids have not been reviewed. Also, it is unclear how this would be classified.  She says that some have warned against approving this as it sets a precedent for reviewing other materials. Behar will likely ask the NOP to determine how to proceed here. It is not really a processing aid, but it is unclear what else to call it. Ela (NOSB, organic farmer member) says that he thinks they should act on petitions before them and that the NOP can determine how to act on the recommendation. Chapman (NOSB, handlers/processors member; Clif Bar) supports the petition, but has noted the concerns.

Motion to classify sodium citrate as synthetic passed unanimously.

Motion to add sodium citrate as an anticoagulant in the production of blood meal to the National List passed unanimously.

3:54 PM CT: Crops Subcommittee (CS) moves to discuss the proposal on allyl isothiocyanate (AITC) as petitioned for use in organics.

Buie (NOSB, organic farmer member) states he would like to send this back to subcommittee after reviewing the addendum, citing issues with the technical review comparison of AITC to MITC. Bradman (NOSB, environmentalists/resource conservationists member) agrees. Oakley (NOSB, organic farmer member) says she relies on the technical review more than information from the petitioner who has a vested interest. The concerns she originally had are not changed and she would like to vote. Chapman (NOSB, handlers/processors member; Clif Bar) moves to review this as a substance used to treat nursery stock. He adds that he, too, would like to send this back to subcommittee. Rice (NOSB, certifier member) would like to see whether it could be useful for nursery stock as well. Ela (NOSB, organic farmer member) agrees that we need a phytosanitary material for nursery stock; he doesn’t want to use a broad-spectrum spray and believes that broad-spectrum materials harm the ecosystem. He states that this is not organic.

Bradman asks, if this was used for nursery stock, is that still soil application? If not, perhaps this material can help us move forward on the issues of lack of organic nursery stock. Mortensen (NOSB, scientist member) states that he would like to move toward a systems approach to management rather than chemical solutions. Oakley adds that there are other ways to treat the issues addressed by AITC. Behar (NOSB, environmentalists/resource conservationists member) says she thinks we should at least explore this for nursery stock. Conventional nursery stock has been treated with fumigants and pesticides. She states that perhaps they will still vote it down, but we would give nursery stock industry due diligence. Bradman says he would vote no as this is written, but does want to find out how this material would be used in nursery stock.

Proposal to send AITC back to subcommittee passed: Vote – Yes: 10; No: 5.

3:40 PM CT: Crops Subcommittee (CS) continues discussions on the 2020 Sunset substances review.

Microcrystalline cheesewax:

Baird (NOSB, consumer/public interest advocates member) claims smaller shiitake mushroom growers do still use this, although some studies suggested it is not widely used. She adds that soy-based wax is available but comes from a prohibited source. Behar (NOSB, environmentalists/resource conservationists member) mentions a producer she knows who sells on average four tons of microcrystalline cheesewax annually. She says she disagrees with the technical review regarding its biodegradability, and has seen it on the forest floor four years after use, when the logs are gone. Oakley (NOSB, organic farmer member) states that perhaps it’s time to ask for a new technical review on soy-based hydrogenated (synthetic) oil wax.

Motion to remove microcrystalline cheesewax from National List of materials approved for organics failed unanimously.

Potassium chloride:

Motion to remove potassium chloride from the National List of materials approved for organics failed unanimously.

3:28 PM CT: Crops Subcommittee (CS) continues discussions on the 2020 Sunset substances review.

Liquid fish products:

Bradman (NOSB, environmentalists/resource conservationists member) cites vast support in comments for relisting, but also concern regarding use of wild fish stocks as source materials. He would like a work agenda item to look at this issue. Ela (NOSB, organic farmer member) responds that this item has been added to the work agenda. Behar (NOSB, environmentalists/resource conservationists member) brings up discussion regarding the pH requirement. Ela responds that the takeaway from the spring meeting was to have a final pH of 3.5 to assist with pest management.

The motion to remove liquid fish products from the National List of materials approved for organics failed unanimously.

Sulfurous acid:

Ela shares that this material has made a difference in iron chlorosis for some growers.

The motion to remove sulfurous acid from the National list of materials approved for organics failed unanimously.

Ethylene:

Oakley (NOSB, organic farmer member) states that this is being applied for economic purposes, but that we have heard comments saying uniform flower induction reduces pest pressures. Behar notes that the comments regarding pest pressure were important, and she has some concern regarding monoculture in this crop, though it appears they are doing good cover cropping. She adds, for long-term sustainability, she hopes they consider more crop rotation.

Motion to remove ethylene gas from the National List of materials approved for organics failed unanimously.

3:09 PM CT: Crops Subcommittee (CS) continues discussions on the 2020 Sunset substances review.

Elemental sulfur:

Bradman (NOSB, environmentalists/resource conservationists member) notes that there are three listings here for its use as plant disease control and a plant nutrient. He adds that this material has respiratory and ocular health concerns, and that many growers have purchased special equipment to limit the dangers of drift. Respiratory protection is a major concern, particularly with dusting rather than liquid. Behar (NOSB, environmentalists/resource conservationists member) asks if there is any resistance reported. Bradman replies that it is primarily used as a fungicide, and he is not aware of any resistance as it is not a systemic poison. Ela (NOSB, organic farmer member) adds that it uses multiple pathways, and resistance is not a concern.

The motion to remove elemental sulfur, all three listings, from the National List of materials approved for organics failed unanimously.

NOSB Members Eric Schwartz and
A-dae Romero-Briones

Lime sulfur:

Motion to remove lime sulfur from the National List of materials approved for organics failed unanimously.

Sucrose octanoate esters:

Baird (NOSB, consumer/public interest advocates member) says there are no comments regarding its use this time. She adds that there were four comments this spring saying it is used effectively in rotation. Behar notes that this product is no longer registered with the EPA. Also, that it is not known whether it is being used internationally, but it isn’t on the EU list. She doesn’t know about Canada. Bradman asks if we can have this on our list since it is no longer registered. Ela responds that he doesn’t think we can have a material on our list that has no use. Behar adds that, having used this, “it is completely miserable”.

Motion to remove sucrose octanoate esters from the National List of materials approved for organics passed: Vote – Yes: 11; No: 4.

Hydrated lime:

Mortensen (NOSB, scientist member) states these are widely used, safe products with wide support in the public comments.

Motion to remove hydrated lime from the National List of materials approved for organics failed unanimously.

2:48 PM CT: Crops Subcommittee (CS) continues discussions on the 2020 Sunset substances review.

Plastic mulch and covers:

Behar (NOSB, environmentalists/resource conservationists member) notes good support for this material because it warms the soil and provides a weed barrier but also that several comments pushed for moving toward biodegradable, plant-based materials. Oakley (NOSB, organic farmer member) recused herself as a farmer representative. She has reservations about the waste issue and growing with plastic, but there is widespread use and she is presently growing strawberries with it. Chapman (NOSB, handlers/processors member; Clif Bar) states that the alternative is bio-based mulch, and that there has been new research we should look over. Tucker (NOP, acting Deputy Administrator) adds that they will be looking at bio-based mulch in the coming months and that this will become a work agenda item. Rice (NOSB, certifier member) says that the current materials being used do not fit the criteria for bio-based mulch. Bradman (NOSB, environmentalists/resource conservationists member) notes that this is a challenging issue; it is a toxic waste material from organic production and cannot easily be recycled due to soil contamination.

Motion to remove plastic mulch and covers from the National List of materials approved for organics failed with 14 no votes and one abstention.

Aqueous potassium silicate:

Mortensen (NOSB, scientist member) says it is used for mite and spider suppression in vegetable crops in California and the Pacific NW. It is a replacement for other disease managers like copper sulfate. However, he states that the data regarding the mechanism of action is contradictory and thin. It is also unclear whether animals eating the plants would experience health effects.

Behar points out that they received much feedback regarding efficacy and essentiality, including from two former NOSB members who support its inclusion on the National List. She does not see much of an environmental issue. Bradman is concerned that it acts as a systemic, putting it into another category. It’s not like a systemic pesticide, but the mechanism is still concerning philosophically.

Mortensen states he is concerned about health effects to humans and animals.

Ela notes that public comments really matter. Based on reports of use, he is changing his vote from the subcommittee vote.

Motion to remove APS from the National List for use in organics failed: Vote – Yes: 5; No: 10.

Aqueous potassium silicate:

This listing is a separate listing for the same material, sourced from naturally occurring sand.

The motion to remove APS from naturally occurring sand from the National List of materials approved for organics failed: Vote – Yes: 4; No: 11.

2:33 PM CT: Crops Subcommittee (CS) continues discussions on the 2020 Sunset substances review.

Alcohols: ethanol, isopropanol:

Buie (NOSB, organic farmer member) notes that the public comments were largely in favor of re-listing.

Motions to remove both alcohols from the National List of materials approved for organics failed unanimously.

Sodium carbonate peroxyhydrate:

It was noted that CCOF has 49 operations using this; rice growers. Also, that this was added in hopes of replacing copper sulfate, which has not happened. Behar (NOSB, environmentalists/resource conservationists member) says it is used in rotation with other things and not very heavily. Oakley (NOSB, organic farmer member) adds that it is generally used in irrigation lines as an algicide. Ela (NOSB, organic farmer member) doesn’t believe a strong case was made for it to be removed. Oakley followed that “we want to avidly encourage innovation”.

Motion to remove SCP from the National List of approved materials for organics failed unanimously.

Newspaper or other recycled paper:

Behar mentions they’ve gotten a new technical review on this, and that the public was universally in support except for one public interest group; “which suggested we should encourage more plant-based mulches”, she adds. Oakley encourages people to read the supplemental technical review as it reveals higher toxicity than the original review. She adds that we cannot easily address that issue, but it bears consideration.

Motion to remove newspaper from the National List of approved materials for organics  failed unanimously.

2:25 PM CT: The NOSB meeting in St. Paul, MN reconvenes. Board chair Tom Chapman hands meeting over to Steve Ela (NOSB, organic farmer member) as chairperson of Crops Subcommittee (CS).

CS moves to discuss the 2020 Sunset substances review of the following:

  • Alcohols: ethanol, isopropanol
  • Sodium carbonate peroxyhydrate
  • Newspaper or other recycled paper
  • Plastic mulch and covers
  • Aqueous potassium silicate
  • Elemental sulfur
  • Lime sulfur
  • Sucrose octanoate esters
  • Hydrated lime
  • Liquid fish products
  • Sulfurous acid
  • Ethylene
  • Microcrystalline cheesewax
  • Potassium chloride

2:20 PM CT: The NOSB meeting in St. Paul, MN reconvenes.

1:28 PM CT: The board has finished with the Handling Subcommittee. It will resume with the Crops Subcommittee (CS) and work on the rest of its agenda at 2:15 PM CT following a lunch break.

1:17 PM CT: Handling Subcommittee (HS) moves to discuss the proposal on tamarind seed gum – petitioned for use in organics.

First motion is regarding classification (agricultural): All vote yes.

Second motion is regarding adding the material to the National List for use in organics: Vote – Yes: 11; No: 4. Petition to add to the National List for use in organics is rejected.

HS moves to discuss the proposal on pullulan – petitioned for use in organics.

de Lima (NOSB, retailer member) states they just got the technical review back and that the petition was submitted by OTA. She will be bringing forward this petition in the spring meeting.

HS moves to discuss the proposal on collagen gel – petitioned for use in organics.

Bradman (NOSB, environmentalists/resource conservationists member) states that this would be coming from animals not raised organically as, according to the petitioners, the scale of the market is such that organic source materials are not available.

12:55 PM CT: Handling Subcommittee (HS) moves to discuss the proposal on Ethiopian peppers – petitioned for use in organics.

Chapman (NOSB, handlers/processors member; Clif Bar) states he is unconvinced by this petition. Ela (NOSB, organic farmer member) adds that it is a poorly-supported petition.

First motion is regarding classification (agricultural): All vote yes.

Second motion is regarding adding the material to the National List for use in organics: All vote no.

12:48 PM CT: Handling Subcommittee (HS) moves to discuss the proposal on Japones peppers – petitioned for use in organics.

Slide: Japones pepper

Oakley (NOSB, organic farmer member) believes this can easily be grown organically and domestically. Chapman (NOSB, handlers/processors; Clif Bar) does not think the petitioner did due-diligence to support listing this. Oakley thinks the petition is inadequate. Rice (NOSB, certifier member) notes that they did not hear from the petitioner during the public comment process. Seitz (NOSB, consumer/public interest advocates member) states there should always be a high threshold for approving new materials for organics. de Lima says she voted for adding it, but is changing her vote.

First motion is regarding classification (agricultural): All vote yes.

Second motion is regarding adding the material to the National List for use in organics: All vote no.

12:33 PM CT: Handling Subcommittee (HS) moves to discuss the proposal on silver dihydrogen citrate – petitioned for use in organics.

Chapman (NOSB, handlers/processors member) summarizes comments: there is debate over if this is nano-material and concerns about the environmental toxicity of silver as well as concerns about its use in field applications, in water and residuals on food. There are additional concerns about resistance to silver. He says he is going to recommend it be sent back to subcommittee for further review.

Slide: Silver dihydrogen citrate

Mortensen (NOSB, scientist member) expresses concerns that were raised in public comments, believing that “there is ample evidence that silver, when in solution, will precipitate to form larger-sized molecules that approach a range we are worried about”. He said he also has concerns about introducing silver into the water stream and that they need to consider the fate of silver in waste water. Oakley (NOSB, organic farmer member) echoes Dave’s comments.

Chapman notes that the nano subject is complex. Mortensen states he is concerned with nano-particles introduced into cells and water streams. He adds that the fate of silver ions in water is a major concern and adding metals is not consistent with organic systems or organic management. Chapman asks if he has studies he can refer to about contamination. Mortensen responds yes, but “even just on the face of it this appears to be a major problem”. Chapman states the need to conduct research, to which Mortensen replies that “we need to use common sense here. Silver concentration will not be lower after we introduce waste stream”. Chapman follows that the dilution issue is “a question of math”.

Oakley clarifies that there are two different issues, one being when its diverted through municipal systems and one when it’s diverted into septic systems and groundwater.

Chapman state that this needs to go back to subcommittee. All vote yes to send back to handling subcommittee.

12:04 PM CT: Handling Subcommittee (HS) moves to discuss the proposal on sodium chlorite for the generation of chlorine dioxide gas – petitioned for use in organics.

Bradman (NOSB, environmentalists/resource conservationists member) notes health effects, including causing asthma, and that this is a harsh material as are many of the chlorine compounds. He would vote this petition down. There hasn’t been adequate monitoring of chlorine compounds and how affects workers. Mortensen (NOSB, scientist member) echoes these concerns and states the idea that field workers and processors are potentially exposed to gaseous formulas is very worrying.

Oakley (NOSB, organic farmer member) says she doesn’t support this.

Behar (NOSB, environmentalists/resource conservationists member) reminds the board they will be looking at sanitizers, so if vote they this down they might find a specific need.  She is going to vote against it and keep her mind open during the sanitizer review.

Swaffar (NOSB, organic farmer member) encourages members on the subcommittee to state their opinion for public record.

Slide: Sodium chlorite

Ela (NOSB, organic farmer member) states that he “wrestles with this”. He adds that he voted for it in subcommittee, but personally reacts to chlorine. It was his “go-to” sanitizer.  Looking at packing fruit and now with FSMA compliance for small processors, the attractiveness of a gas is strong. Ela says he is leaning towards voting for it, even though he has no love of chlorine materials.

de Lima (NOSB, retailer member) states she initially voted in favor, but will change his vote due to health concerns.

Schwartz (NOSB, handlers/processors member) voted to keep it, but empathizes with all the comments. He says that he spent time working with sanitizers and there are so few tools available; “if we  start taking those away, it’s a problem”. [Schwartz discussed this material from the assumption that the vote is to remove this material. This material is actually being petitioned and is not in the processor toolbox at present.]

Romero-Briones (NOSB, consumer/public interest advocates member) says she voted for it because it is used by a certified tribal operation; but she hears these concerns and is reconsidering her vote.

Rice (NOSB, certifier member) clarifies they would not be removing it, this is a petitioned material to be added to the National List of approved materials for organics.

Baird (NOSB, consumer/public interest advocates member) says she is taken by Steve’s comment that this helps small farms, as “small farms are where my heart is”. She asks if they could add a time lapse annotation, as to when the product dissipates.  Behar responds that it would be a rush to put this on. She encourages the board to wait as more information becomes available.

de Lima asks Ela what he does currently on his farm. Ela responds that he uses a chlorine wash but has spent a lot of time “scratching his head” about what to do.  He adds that, “at some point we have to offer growers a choice. FSMA is a whole different ball game than what it used to be like.  It’s a real challenge.” Right now, he uses chlorine and water. Rice asks Ela about ozone. Ela responds that he is exploring that, and his is a work in progress like many small farms. His spouse is his food safety officer and sometimes its hard to get answers, but “we want to do it right”.

Mortensen adds that farmer behavior is a distribution curve;  some are super careful and some are less careful. He points out that there isn’t a static farm community and we’re dealing with different behaviors. However, he says the substance is unforgiving in terms of human exposure and this is a concern.

Greenwood (NOSB, environmentalists/resource conservationists member) says there are about 900 major food outbreaks a year and 3,000 deaths and feels the best way to prevent this is sanitation. Gases work very well to get in places liquids can’t. He understands the comments about organics being more susceptible to disease. He states he is going to vote for it to be approved.

Behar clarifies that the actual material is chlorine dioxide gas.

Rice mentions that if they want to continue to vote on this, continued listing of chlorine dioxide gas would need to go back to subcommittee.

Chapman (NOSB, handlers/processors member; Clif Bar) asks if this can be handled by the NOP. Clarissa Mathews (NOP, National List Manager) responds that if it came through in the board’s recommendation, they would take it into consideration.

Vote – Yes: 6; No: 9. Petition to add to the National List for use in organics is rejected.

11:38 AM CT: Handling Subcommittee (HS) continues discussions on the 2020 Sunset substances review.

Fructooligosaccharides (FOS):

This is used in almost every infant formula on the market. Behar (NOSB, environmentalists/resource conservationists member) says this is a useful product and Chapman (NOSB, handler/processor member and Clif Bar) mentions the American Medical Association (AMA) says it is acceptable. Mortensen (NOSB, scientist member) says sugar beets in U.S. are almost entirely GM these days, and asks if this is from GM sugar beets. Chapman doesn’t believe the source is organic and is unaware if organic exists, but the source would be conventional, non-GMO. Rice (NOSB, certifier member) confirms that a certifier would verify through an affidavit it came from an operation that sourced from non-GMO source. Seitz (NOSB, consumer/public interest advocates member) asks if this is still essential for processed foods. Chapman responds that it’s a pre-biotic and still essential in some applications.

Vote – Yes: 1; No: 14. Substance is retained on the National List for use in organics.

Gums: Arabic, Carob bean, Guar, Locust bean:

de Lima (NOSB, retailer member) has questions around the availability of organic options. Chapman says he sources organic and supports the retaining of this listing, adding that commercial availability exceptions are working out well. He notes that some gums come from Africa and availability is dependent on political climate and weather. Behar (NOSB, environmentalists/resource conservationists member) wonders if other areas in the world can produce this as well. Chapman is hesitant to pull cash crops out of a developing country and is aware of guar grown in different climates.

Motion to remove these from the National List fails unanimously.

Lecithin – de-oiled:

Romero-Briones (NOSB, consumer/public interest advocates member) states she will vote to remove it. Baird (NOSB, consumer/public interest advocates member) asks if commenters have submitted documentation that alternatives work the same. Romero-Briones responds that it is a question of supply. Chapman (NOSB, handlers/processors member; Clif Bar) says “soy de-oiled lecithin is widely available, but the issue is non-allergenic forms of lecithin. Sunflower is the primary non-allergenic form and it is not consistently available.  Organic sunflower oil mostly comes out of the Ukraine.”  He says he is aware of domestic manufacturers working on it and will vote to re-list at this time but encourages we take a critical eye in the future. Swaffar (NOSB, organic farmer member) notes that getting a harvest out of sunflower is inconsistent and likes keeping it on the list because there are availability issues. Behar (NOSB, environmentalists/resource conservationists member) has seen some manufacturers talk about stable production and wonders if, in the future, they could split out lecithins in their work agenda so they could remove soy lecithin and retain sunflower. Ela (NOSB, organic farmer member) states that before sending a material to NOP for de-listing, they need a solid case and not speculation. He agrees to re-list now, but to give a critical eye next time. Rice (NOSB, certifier member) says that part of the process in reviewing would be that the manufacturer tried to source organic.

Vote – Yes: 3; No: 12. Substance is retained on the National List for use in organics.

Tragacanth gum:

Noted that this is prepared from the sap of some legumes and is effective at lowering pH with the percentage used in the final product usually low. Behar asks about mitigation steps to reduce microbial load and if there is any discussion about growing it organically. de Lima (NOSB, retailer member) states that there was no public comment on it being processed organically.

Motion to remove this from the National List fails unanimously.

NOSB Members Harriet Behar and Tom Chapman

10:56 AM CT: Handling Subcommittee (HS) continues discussions on the 2020 Sunset substances review.

Xanthan gum:

de Lima (NOSB, retailer member) notes this is used in numerous food products; that it disperses water and gives a thickening effect particularly effective in chilled products and often used in gluten-free baking. She adds that it is allowed internationally. She points out that in 2016 the subcommittee found this can be produced either non-synthetically or synthetically and decided not to move forward with re-classification. Mortensen (NOSB, scientist member) points out that the EU doesn’t grow GM crops so would be less of a concern there.

Vote – Yes: 1; No: 14. Substance is retained on the National List for use in organics.

10:52 AM CT: Handling Subcommittee (HS) continues discussions on the 2020 Sunset substances review.

Glycerides (mono and di):

Motion to remove these from the National List fails unanimously.

Magnesium stearate:

Noted that the dominant use is as a binding agent for nutritional supplements. Motion to remove this from the National List fails unanimously.

Phosphoric Acid:

Motion to remove this from the National List fails unanimously.

Bradman (NOSB, environmentalists/resource conservationists member) notes there should be concerns about phosphates in waterways, but votes no.

Potassium carbonate:

Motion to remove this from the National List fails unanimously.

Sulfur dioxide:

Ela (NOSB, organic farmer member) notes this is used in wine making and that he saw “basically no negative comments”. Behar (NOSB, environmentalists/resource conservationists member) adds that two sunsets ago this was controversial and there were wine makers that wanted it to come off because they could make wine without it. They have been able to distinguish themselves in the marketplace as organic wine [wine containing sulfur dioxide must use the “made with organic” label]. She feels that the listing as it stands is working. Motion to remove this from the National List fails unanimously.

10:37 AM CT: Handling Subcommittee (HS) continues discussions on the 2020 Sunset substances review.

Oxygen: 

Baird (NOSB, consumer/public interest advocates member) is glad to see support from producers in order to have more information on specific uses. Motion to remove oxygen from the National List fails unanimously.

Potassium chloride:

Noted that public comments were overwhelmingly supportive. Motion to remove potassium chloride from the National list failed unanimously.

Alginates:

Ela (NOSB, organic farmer member) notes that the main objections come back to the marine materials issue and the sustainability of harvest. Oakley (NOSB, organic farmer member) would like to see more information from stakeholders regarding the source of alginates and that they should use the open docket to do so. Mortensen (NOSB, scientist member) says they are going into more detail regarding marine materials as fertilizer than for this use. Motion to remove alginates from the National List fails unanimously.

Calcium Hydroxide:

Motion to remove calcium hydroxide from the National List fails unanimously.

Ethylene:

Mortensen expresses concern about use of growth regulators. Motion to remove ethylene from the National List fails unanimously.

10:29 AM CT: Handling Subcommittee (HS) continues discussions on the 2020 Sunset substances review.

Calcium carbonate:

Rice (NOSB, certifier member) notes that calcium carbonate was widely supported in public comments and that two certifier comments expressed concern regarding precipitated calcium carbonate (PCC). He heard comments regarding PCC not truly being a synthetic material. Motion to remove calcium carbonate from the National List fails unanimously.

NOSB Farmer Member Steve Ela

Flavors:

Chapman (NOSB, handlers/processors member; Clif Bar) notes a large amount of support for flavors from processors and their trade groups. Behar mentions that flavoring is impacted by the fermentation processes. Motion to remove non-organic flavors from the National List fails unanimously.

Gellan gum:

Baird (NOSB, consumer/public interest advocates member) says that a number of manufacturers wrote that they use it as a vegetarian option and also as a substitute for carrageenan. Retailers gave reports from consumers of adverse reactions. Swaffar (NOSB, organic farmer member) says she voted to remove carrageenan with the understanding that the gums would remain on the National List and that we should protect this material because the dairy industry worked hard to make this substitution.

[Cornucopia Note: Despite the NOSB voting to remove carrageenan from use in organics, corporate pressure on the Secretary of Agriculture led him to reject that vote by the NOSB.]

Mortensen (NOSB, scientist member) expresses concern with the lack of information about which materials undergo a fermentation process and asks if it is arising from GMO sources. He points out that knowing what is in an ingredient is especially important when consuming it, as compared to using it for sanitation. Chapman follows that this concern applies to every material that could be a product of fermentation. Swaffar responds that a  supplier of gellan gum testified yesterday that they do not use GMO sources for their product.

Behar (NOSB, environmentalists/resource conservationists member) says, as with carrageenan, the consumers influence the market.

Chapman says that allergen concerns should be addressed by the FDA.

Motion to remove gellan gum from the National List fails 14-1.

10:18 AM CT: Chapman hands meeting over to Lisa de Lima (NOSB, retailer member) as chairperson of Handling Subcommittee (HS).

HS moves to discuss the 2020 Sunset substances review of the following:

  • Calcium carbonate
  • Flavors
  • Gellan gum
  • Oxygen
  • Potassium chloride
  • Alginates
  • Calcium hydroxide
  • Ethylene
  • Glycerides (mono and di)
  • Magnesium stearate
  • Phosphoric acid
  • Potassium carbonate
  • Sulfur dioxide
  • Xanthan gum
  • Fructooligosaccharides (FOS)
  • Gums: Arabic, Carob bean, Guar, Locust bean
  • Lecithin – de-oiled
  • Tragacanth gum

10:08 AM CT: Livestock Subcommittee (LS) moves to discuss the Origin of Livestock resolution.

Behar (NOSB, environmentalists/resource conservationists member) and Oakley (NOSB, organic farmer member) both state they enthusiastically support this resolution. Oakley asks if it would be effective or possible to send this directly to USDA Secretary Perdue. Tucker (NOP, acting Deputy Administrator) says that in past, it has gone through the NOP and will best be received in that fashion. Behar notes that this is a great hardship on organic farms, and it is also about the integrity of the label. She asks Tucker to please bring it forward. Tucker responds that the administration will start to consider items elevated from the programs in January 2019. The regulatory approach remains the 2-for-1 approach [The Trump Administration has said two regulations removed for every new one in], and this will be considered across the program.

Chapman (NOSB, handlers/processors member; Clif Bar) states that he hopes the USDA hears the organic community here so that clarity can be brought to this standard.

Seitz (NOSB, consumer/public interest advocates) says he understands but disagrees with the 2-for-1 approach and that this is a regulations-based process. He asks if the USDA see the organic program as structurally different than other programs. Tucker responds that within AMS, a number of programs want to be regulated. With respect to Origin of Livestock, the regulations need to tie back into OFPA. She says this will be taken into account by the administration and that this is a challenge with this rule. The primary focus is in enforcing existing regulations and not in creating more.

Oakley states the board has done what it can do and encourages all stakeholders to write letters to the Secretary.

Mortensen (NOSB, scientist member) adds that case studies, including financial repercussions, are useful for politicians.

The resolution passed unanimously.

 

9:51 AM CT: Livestock Subcommittee (LS) moves to review the discussion document for oxalic acid dihydrate (OAD) – petitioned for use in organics.

OAD is used for treatment of Varroa mites.

Behar (NOSB, environmentalists/resource conservationists member) notes they received no detailed comments on this material, likely in part due to the small number of honey producers in the U.S. She adds that it can be put in a sugar syrup and sprayed on packaged bees, and that there is no other material she is aware of that can be used in this way. She says there is concern that the material is classified by the EPA as very hazardous. It is used for bleaching wood in a different formulation of the product. She says she will seek further information on this material.

Mortensen (NOSB, scientist member) says that this compound is useful for Varroa mite control, but the protective equipment required is concerning.

Swaffar (NOSB, organic farmer member) expresses concern with making decisions for agriculture without standards.

9:30 AM CT: Livestock Subcommittee (LS) continues discussions on the 2020 Sunset substances review.

Lime, hydrated:

Motion to remove this from the National List fails unanimously.

Mineral oil:

Behar (NOSB, environmentalists/resource conservationists member) notes that even though the NOSB voted to allow it for  release of constipation, the FDA wouldn’t allow it for that. Devon Patillo (NOP, Materials Specialist) says mineral oil is in the proposed rule now and notes that off-label uses are allowed under certain circumstances (with veterinary approval).

Motion to remove this from the National List fails unanimously.

Sucrose octanoate esters:

Behar states she would like to remove this product, continuing that she has used this product. When we were voting on it, we didn’t have certain information and had questions about effectiveness. She notes that even if the product is benign no one can use it in U.S. because the EPA doesn’t have it registered, and asks why it is taking up space on the National List.  She asked inspectors about use in other countries and also spoke with a Brazilian honey-seller.  If product is ineffective, she thinks it will stop being used, and there are much better products.

Mortensen (NOSB, scientist member) says he has researched this and that there are products that are less hard on bees; he is left with impression that this should be taken off.

Baird (NOSB, consumer/public interest advocates) notes that a review said it was benign to bees and hesitates to take something out of the tool box. She adds that it is registered by EPA, though not a specific product that is registered.

Oakley (NOSB, organic farmer member) thinks this is a great example of the sunset process and that, should it become more widespread, it can be revisited, but feels there is a compelling reason to remove.

Rice (NOSB, certifier member) asks if there is any reason to believe efficacy would be different on bees outside the U.S. (ie, Brazil) and whether it is working elsewhere.

Chapman (NOSB, handlers/processors member; Clif Bar representative) responds that there is an efficacy argument and use argument.  It has been pointed out that it is difficult to get opinions from small farmers, and honey produced in Brazil is produced far out in the Amazon, very rural places. He warns against weighing the lack of comments because the 16 day comment period may not have gotten out to rural Brazil.

Behar notes that, having used the product, it is extremely sticky, and would be sticky in tropical climate.

Mortensen adds that they did not get any comments at all, and this implies no support for relisting this material.

Swaffar (NOSB, organic farmer member) Struggling with this because we don’t have bee standards and have few organic honey producers in the U.S. as most of it comes from Brazil. It sounds like they do have other options. She concludes she will change her vote to de-list.

Behar notes that Hawaiian honey producers showed no support for this material.

Vote – Yes: 10; No: 5. Substance is removed from use in organics.

9:19 AM CT: Livestock Subcommittee (LS) continues discussions on the 2020 Sunset substances review.

Biologics – vaccines:

Behar (NOSB, environmentalists/resource conservationists member) asks for an agenda item to deal with inconsistent implementation of whether GM vaccines are allowed.  She states that some certifiers allow this and some do not. Comments universally supported retaining on National List. Dr. Clarissa Mathews (NOP, National List Manager) says she anticipates a response on whether or not this will be added to the work agenda relatively soon. Behar follows that this work agenda item aims for consistency and notes that some operations cannot access GM vaccines. Swaffar (NOSB, organic farmer member) says these are made from excluded methods, not GM. Chapman (NOSB, handlers/processors member; Clif Bar) moves for a vote. No vote is to retain. Yes is to remove. All vote “no.”  Retained on National List.

[Cornucopia Note:  One of the power grabs by the USDA under former director McEvoy was to take away the NOSB’s ability to set their own agenda and work plans.  Thus, you see requests from members, such as above, asking for the ability to look at items they view as important to organic integrity.]

Electrolytes:

Behar says that these are used extensively to replace vitamins and minerals.

Motion to remove this from the National List fails unanimously.

Glycerin:

Motion to remove this from the National List fails unanimously.

Phosphoric acid:

This is allowed as an equipment cleaner, as long as it does not come in contact with organically managed livestock and/or land. It was considered by all commenters to be essential, with some noting inconsistency between certifiers whether a rinse is required after it is used.

Motion to remove this from the National List fails unanimously.

9:05 AM CT: Livestock Subcommittee (LS) continues discussions on the 2020 Sunset substances review.

Alcohols – Ethanol:

Chapman (NOSB, handlers/processors member; Clif Bar) moves to remove ethanol based products from the National List and notes that this is sunset voting – with a yes to remove and a no to keep.

Motion to remove this from the National List fails unanimously.

Alcohols – Isopropanol

For  use as a disinfectant only. Chapman clarifies that a no vote is to retain for use in organics, a yes to remove.

Motion to remove this from the National List fails unanimously.

Aspirin:

Motion to remove this from the National List fails unanimously.

8:51 AM CT: Chapman hands meeting over to Ashley Swaffar (NOSB, organic farmer member) as chairperson of Livestock Subcommittee (LS).

LS moves to discuss the 2020 Sunset substances review of the following:

  • Alcohols: ethanol, isopropanol
  • Aspirin
  • Biologics—vaccines
  • Electrolytes
  • Glycerin
  • Phosphoric acid
  • Lime, hydrated
  • Mineral oil
  • Sucrose octanoate esters

8:48 AM CT: Dr. Jennifer Tucker (NOP, acting Deputy Administrator) begins with a brief report on enforcement. She revisits the four key NOP priorities for FY 2019:

  1. strong organic control systems
  2. farm to market traceability
  3. robust enforcement
  4. strict standards
Slide: Volume of Organic Corn Imports 

Tucker discusses specific actions on imports, with the Black Sea Region an area of focus. Multiple investigations are currently in progress, in partnership with OIG (Office of Inspector General) and APHIS (Animal and Plant Health Inspection Service). She says that the NOP is doing a better job of building relationships with APHIS and communicating more with the Foreign Agricultural Service (FAS). Of 1,175 operations in the Black Sea area that were formerly certified as organic, about 700 remain certified.  Many have been suspended, revoked, or have surrendered their organic certification. There is a 95% drop in volume in organic corn from Turkey since highest imported rate recorded in January 2016. NOP has also focused oversight on surrendered operations to make sure they don’t certifier shop. In the U.S., the organic sector is now fully integrated with the marketplace and they’re introducing new approaches to manage growth.

[Cornucopia Note: See Cornucopia’s June 2018 White Paper and report on import fraud for more details on this scandal.]

Mortensen (NOSB, scientist member) asks what it was that resulted in their organic certification being revoked. Tucker responds that there are different suspensions and revocation reasons, and a lot was done at the certifier level.  She adds, that we don’t always know. The certifiers are our point of contact on the ground and are issuing noncompliances.

Mortensen notes that there are hot spots of noncompliance and cold spots of good behavior, and says we should mine data to determine collective qualities of operations. He asks if  this is possible with the data. Tucker is not sure they have that kind of data and feels that there are enough problems out there that she would rather take a broad approach in hot spots.

Mortensen brings up the spike in the Serbian grain trade and if this sets off risk-based triggers. Tucker answers yes, and they they have deployed the FAS. She added that it is true that their government is investing in organics as a growth area, but we have a good indicator of what that government is doing to foster that growth responsibility. We didn’t have this capability a year and half ago, adding that the early warning system is new.

8:35 AM CT: The fall meeting of the National Organic Standards Board has resumed.

Board chair Tom Chapman (NOSB, handlers/processors; Clif Bar) calls meeting to order.

Thursday, October 26, 2018

5:27 PM CT: With the conclusion of discussion from the CACS Subcommittee, the board adjourns. The NOSB fall meeting will resume at 8:30 AM CT tomorrow.

5:20 PM CT: Board Chair Tom Chapman (NOSB, handlers/processors member; Clif Bar) comments regarding an update on analysis of feedback from the spring 2018 import panel that this has been touched on already and will be revisited at the spring 2019 NOSB meeting.

4:50 PM CT: CACS Subcommittee moves to discuss the proposal for Training and oversight of inspector and certification reviewer personnel.

Swaffar (NOSB, organic farmer member) notes that inspectors should be chosen by certifiers to inspect areas they specialize in.

Baird (NOSB, consumer/public interest advocates member) adds that team inspections are beneficial for very complex handling inspections, for example. Brief inspections are not long enough to perform a Mass Balance, necessary to find fraud.

Behar (NOSB, environmentalists/resource conservationists member) says mentoring inspectors is an important part of teaching, however, there is very little funding for this process.

Board approves the proposal on training and oversight of of inspector and certification reviewer personnel unanimously.

4:20 PM CT: Chapman hands meeting over to Scott Rice (NOSB, certifier member) as chairperson of Compliance, Accreditation, & Certification Subcommittee (CACS).

CACS Subcommittee moves to discuss the proposal for Developing criteria for risk-based accreditation oversight.

Rice shares that this proposal seeks to establish criteria for assessing risk factors when engaging in the oversight of USDA-accredited certifiers. These criteria proposed by the NOSB are not meant to trigger audits, but rather serve as a tool to evaluate risk. Stakeholders offered numerous potential risk factors for subcommittee consideration.

Tucker (NOP, acting Deputy Administrator) noted that personnel are always at the core of risk-based oversight; we are already introducing unannounced visits with operations and certifiers.

Chapman suggests the NOP should take the committee’s suggestions, consider them, and share their feedback regarding feasibility and potential impacts. The board should also consider general risk factors for clients.

Behar (NOSB, environmentalists/resource conservationists member) states the need for a robust baseline, including enforcement, and not just risk-based approach. She is glad to hear from Dr. Tucker that the staff and the new Accreditation Management System are exemplary.

Mortensen (NOSB, scientist member) asks, can we encourage producers to be eyes-on-the-ground to assist with this issue? Swaffar (NOSB, organic farmer member) believes that can help with fraud protection, but it is not part of this proposal. She adds that certifiers would do well to tell their clients how to file complaints.

Ela (NOSB, organic farmer member) asks, are you seeing any differences between state, nonprofit, and private certifiers regarding fraud? Tucker replies that the presence of satellite offices is a risk, but she cannot characterize further than that. She notes that you can access a certifier’s most recent audits on the NOP website.

[Cornucopia Note: To access an organic certifier’s accreditation certificates and audit reports, visit the Organic Integrity Database and click on any certifier’s name to open its certifier profile. On the right side of the screen, look for a link to the certifier’s most recent accreditation certificate and accreditation documents.]

Board approves the proposal on Developing Criteria for Risk-based Accreditation Oversight unanimously.

NOSB Members and NOP Deputy Administrator Jennifer Tucker

3:54 PM CT: Materials Subcommittee (MS) continues consideration of the discussion document for Marine Materials in Organic Crop Production.

Bradman (NOSB, environmentalists/resource conservationists member) notes the issue must be dealt with. He is concerned about wild harvesting criteria and notes that they have to come up with a standard. He would rather not allow this practice than adopt a position that would compromise marine environments.

Ela (NOSB, organic farmer member) asks how the EU is handling this and Oakley notes they are looking into that.

Romero-Briones (NOSB, consumer/public interest advocates member) says this issue is close to heart because she comes from a community that has been harvesting and eating seaweed and that this perspective has not been articulated at all in this discussion; there are tribal seaweed gatherers using this as traditional foods not as fertilizer or feed, and food insecurity in tribal communities is a problem particularly in winter months. She is opposed to moving forward with anything until we get these perspectives on the table.

Greenwood (NOSB, environmentalists/resource conservationists member) calls for a wide range of harvester perspectives, as some practices may be incompatible with what we’re looking for.

Paul Lewis (NOP, Standards Division director) shares that the program’s perspective is that we need to take into account NOA’s perspective.

Baird (NOSB, consumer/public interest advocates member) likes the idea of moving into wild crops harvest.  She says that “having done inspections of wild crop harvesting, some do a better job of protecting natural culture. Fair Wild standards meet our standards and this is based on risk assessment.  We have to do something to address sustainability of natural habitats.  This doesn’t fit in crop production. It fits in wild crops.”

Oakley (NOSB, organic farmer member) wants to include tribal communities in this discussion moving forward.

Mortensen (NOSB, scientist member) brings up declining fisheries in the northern Atlantic, and that when we start taking things out of depleted ecosystems we have to consider the impact.

Behar (NOSB, environmentalists/resource conservationists member) notes that the terrestrial world and marine world are very connected.

Materials subcommittee comes to a close.

Board chair Tom Chapman (NOSB, handlers/processors member; Clif Bar) notes Compliance, Accreditation, & Certification Subcommittee (CACS) is up next.

3:37 PM CT: Materials Subcommittee (MS) moves to consider the discussion document for Marine Materials in Organic Crop Production.

Emily Oakley (NOSB, organic farmer member) recognizes this has been ongoing, and the reason they are still working on the marine materials issue is concern over its environmental impact. In absence of third party certification, NOSB looked at wild crops standard for seaweed.  She noted that marine macro algae are different from a lot of crop inputs and is harvested from a natural ecosystem, and that the wild crop standard is loose and vague, needing more clarification.  Some certifiers are applying the wild crop standard and, moving forward, we will need more input from a wide group of stakeholders.

Oakley summarizes public comments:

Some felt there shouldn’t harvesting of seaweed at all because the ecosystem is so fragile, others that there is already enough oversight by governmental bodies. All recognized a need to address environmental impact, with two main areas of concern: (1) the domino effect of increased scrutiny on other natural crop inputs and, (2) difficulty for certifiers and that certifying fertilizers is out of their purview. Oakley clarifies that they are not looking to certify it as a fertilizer, but still considering it an agricultural crop. Concern exist about whether this definition passes legal muster.  Oakley adds that some products on the list do contain certified seaweed material, and if we treat this ingredient as a certified input then it reduces burden. There is also concern that certifiers don’t have the skills needed to certify this, and if that is the case we already have them doing that work so would need to address this anyway. Some certifiers would like to see more guidance for harvesting seaweed.  There were also suggestions for third party certification but these aren’t universally agreed upon. People asked for a phase-in period, and that is a definite given according to Oakley.

Oakley noted there is widespread support for the creation of an informal working group.

3:26 PM CT: Materials Subcommittee (MS) continues discussions on the proposal for Excluded Methods Determinations

Harriet Behar (NOSB environmentalists/resource conservationists member) notes a repeat of terminology passed in the fall of 2016 and the various criteria by which we determine if a method of production is considered an excluded method, meaning GE or GM. This will be updated to keep all excluded methods in one place so you won’t have to keep going back to look at previous dockets. Noted there were quite a few comments on transposons, and that transposons produced through in vitro manipulation would be an excluded method. She would like to take back the transposon topic and bring it back in spring to separate out the three different methods.

Behar would like to bring forward a vote on embryo rescue in plants as non-excluded, whether it be through in vitro, through chemical, or through radiation. She notes that we are trying to dig a little deeper into how those vaccines are made. She asks for work agenda item on livestock vaccines produced through excluded methods as well as items to consider at the spring 2019 meeting, including induced mutagenesis. She encourages the public to bring materials to their attention if they have opinions on what should and shouldn’t be excluded.

Behar motions to amend to remove transposon information from the document and only include as a proposal to add embryo rescue in plants. Should be listed and not an excluded method. Vote on motion to amend proposal (which means delete transposon section from proposal). All in favor.

3:15 PM CT: Materials Subcommittee (MS) continues discussions on the proposal Genetic Integrity Transparency of Seed Grown on Organic Land:

Harriet Behar (NOSB environmentalists/resource conservationists member) says this will be an open document, though Chapman points out that the date of when the document is going to be open is unclear as it might not be December 7. Comments must be provided within two weeks after docket opens.

Behar notes they didn’t hear comments from that many grain farmers and Chapman asks members of the public having contact with grain farmers to please solicit their comments. There were a few comments about zero tolerance, but our regulation does not have that. You can have the presence of GM and still sell certified seed.  You are not allowed to use GM seed intentionally in the production of organic crops, but if it is there unintentionally, you are not in violation.

Behar motions to refer genetic integrity transparency of seed grown on organic land proposal back to subcommittee.  All in favor.

3:00 PM CT: Materials Subcommittee (MS) continues discussions on the proposal Genetic Integrity Transparency of Seed Grown on Organic Land:

Harriet Behar (NOSB, environmentalists/resource conservationists member) opens for discussion.

Sue Baird (NOSB, consumer/public interest advocates member) is concerned about direction; if we implement this we are moving into a testing of product certification and not process certification. It’s a good idea, but has concerns about required testing which isn’t part of regulation.

Dave Mortensen (NOSB, scientist member) commented that the spirit of the draft is to help farmers know what they are starting with, meaning seed out of the bag, and admits there are problems on the back end.  This is not meant to come down on the farmer, but to enable the farmer to take remedial steps.

Tom Chapman (NOSB, handlers/processors member; Clif Bar) asks what do farmer members think about the cost.

Steve Ela (NOSB, organic farmer member) mentions that the testing requirement could add up when you are planting numerous smaller areas.

Asa Bradman (NOSB, environmentalists/resource conservationists member) asks how did you see this proposal for testing different from pesticide testing for residue? Baird replies that there are no requirements for producers to test for pesticides.

Jessie Buie (NOSB, organic farmer member) states that as a small farmer, I’m 100% organic so it wouldn’t be factor for me and I believe you said it would be $35?  Per batch? Per test?

Emily Oakley (NOSB, organic farmer member) says the question comes down to how many lots a producer has in a given year and that there aren’t many vegetable crops at risk that would require additional testing. At most, a couple hundred dollars.

Ashley Swaffar (NOSB, organic farmer member) feels that we need to spell that out; if we have to test all varieties of tomatoes we grow then it can add up.

Behar says this is for at-risk crops under this proposal. “At-risk” would include things cross-pollinated easily, so tomatoes wouldn’t be heavily at risk.

Oakley notes that the proposal says each seed lot, not “field.”

2:45 PM CT: Materials Subcommittee (MS) moves to discuss the proposal Genetic Integrity Transparency of Seed Grown on Organic Land:

Harriet Behar (NOSB, environmentalists/resource conservationists member) will be bringing this document back to subcommittee, giving additional time to give comments on the document as it currently exists. The board will then bring something forward at the spring meeting in 2019.

She shares that there is almost universal support for the proposal and that it’s a difficult issue. The proposal is meant to aid farmers in their choice of seed. All organic seed producers would be required to test for genetic contamination, with different levels of purity. If you use non-organic seed on organic land, you could ask the seed supplier to provide that information. If the seed supplier chooses not to, then the farmer is required to do testing and provide it in their OSP to a certifier. Testing is available; farmers could mail samples to a laboratory with baseline cost of $35. Farmers in a region where organic seed isn’t as available could share costs. Nobody likes to add cost, she added, but you need to know the information because after the crop is grown there will be testing and you need to know what your starting out with or risk being rejected once grown.

As far as level of purity, the seed tester could provide the exact level or be within categories. Regarding retaining of seed samples, she agrees farmers should save samples and NOSB could give some direction on how easy and how much. This is meant to protect farmers, she says, and that farmers would have a secondary check because they could check their own sample.

Behar adds that the purpose of the database was to start gaining information about the pervasive nature of genetic contamination in the field corn seed supply. Since organic farmers do use a fair amount of non-organic seed where there aren’t suppliers, we felt it was important to see hot spots and areas where there was a good chance they could grow seed corn and not have GM contamination. She said that she knows one seed grower who is growing out organic seed corn for sale in the U.S. and he is doing it in France.

Behar concludes that there remains a question as to who would manage this database. It could potentially be the NOP, but this remains to be determined. She says that it is important to know who grew and who planted the seed, and the only thing certifiers are passing on is the level of purity.

2:35 PM CT: Board chair Tom Chapman (NOSB, handlers/processors member; Clif Bar) hands meeting over to Harriet Behar (environmentalists/resource conservationists member) as chairperson of Materials Subcommittee (MS).

MS moves to discuss the proposal 2018 Research Priorities:

Emily Oakley (NOSB, organic farmer member) reviews research priorities, a portion of NOSB tasks that have been going on since 2012.  Livestock, crops, and handling subcommittees have worked on prioritizing previous years topics and taking off less significant items and addressing those most significantly commented upon. Integrity of breeding lines got a lot of comments as did GMO contamination. Comments also addressed:  soil health, climate change, pathogen prevention, alternatives to fatty alcohols.

Move to Vote:  Motion to adopt document 2018 research priorities. All in favor.

2:20 PM CT: The NOSB meeting in St. Paul, MN reconvenes.

1:00 PM CT: The board has finished taking public comments and will resume work on the rest of its agenda at 2:15 PM CT following a lunch break.

12:55 PM CT: Emily Oakley (NOSB, organic farmer member) extends thanks to all stakeholders for their work in staying apprised of the issues.

12:52 PM CT: Marty Mesh (Bellview Gardens Organic Farm) echoes comments on the National List regarding keeping ethylene and fatty alcohol in the toolbox. These materials allow substantial acreage for crops like tobacco and pineapples. He says that seaweed is a problem. Destroying habitat leads to lowered salinity in the ocean and harms the entire ecosystem.

12:43 PM CT: Dolana Blount (PURE Bioscience, Inc) urges the addition of silver dihydrogen citrate (SDC) as she believes it is not nanotechnology, thus does not meet current definitions of same.

Board chair Tom Chapman (NOSB handlers/processors member; Clif Bar) asks her to clarify the nanotechnology assertion and whether it is because of size. Blount responds that this is ionic silver, a silver salt. Not a nanoparticle. Tom asks what happens if this is used where there is no municipal water facilities. She states that it is a post-harvest processing aid, used only in processing facilities.

Steve Ela (NOSB, organic farmer member) states that he did not see the annotation regarding only for use in processing plants with an approved municipal water treatment system. What about cases where it would go into a septic system where there is no municipal system? We need much more annotation. Blount responds that the EPA and FDA have determined the silver that would be released is not of concern. Ela asks about septic systems, and she replies that the silver would be rendered inert when coming into contact with the organic matter. Ela follows with another question, asking if you have to let the EPA know when the septic system is pumped. Blount does not know.

Chapman asks what she thinks about the comments regarding microbial resistance. Blount replies that it is different than an antibiotic you would ingest. The citrate prevents the cell from recognizing the silver until it has killed the microbes inside.

12:30 PM CT: Laura Batcha (Organic Trade Association, lobbying group) says it is a revelation to the organization that some dairy producers are moving an animal off farm to conventional production and re-transitioning back to organic. OTA was not aware of this and does not approve. There are real challenges around taking clarifying action given the lack of clarity around the Origin of Livestock Rule. Requests NOSB pass a resolution urging the Secretary to take action on this rule. She mentions that OTA petitioned several years ago to change the natural flavors listing to an annotation requiring organic be used when available. It was approved by the board, USDA received comments, but the annotation is not final yet.

Paul Lewis (NOP, Director of Standards) stated that clearance goes through many levels, and it is being actively worked on now.
Natalie Krout, CDFA

12:22 PM CT: Natalie Krout (California Department of Food and Agriculture) testifies that California accounts for more than 40% of all organic products sold in the U.S. and enforcement of the organic dairy pasture rule is a priority. She says they want to partner with the federal government to address fraud concerns with grain coming into California. The challenges include visibility into ports, as California has 11 different ports of entry. They have worked closely with the USDA and FDA; having a view into database systems was one of the biggest challenges. She adds that they are working with NOP and the state’s feed program to increase oversight.

12:11 PM CT: Jose Quirce (Costa Rican Trade Representative for North American Affairs) urges the NOSB to vote against exclusion of ethylene gas. He says Costa Rica is the number one producer of pineapples in the world and the main supplier to the U.S. market.

12:04 PM CT: Terry Shistar (Beyond Pesticides) calls for no more additions to 606 [nonorganically produced agricultural products used as ingredients]. She says that antimicrobials used in medicine should not be used in agriculture, and the NOSB should not allow SDC (Silver dihydrogen citrate) or natamycin. She believes that fumigants are not compatible with organic production. Organic production creates healthy soil food webs and fumigants are counterproductive in the extreme. She continues that organic production must protect marine ecosystems.

Steve Ela (NOSB, organic farmer member) states that natamycin could reduce rot in fruits which would have human consequences. Shistar replies that any time you use antimicrobials, you are increasing resistance. There are other options for rot available and the risks are too high.

Asa Bradman (NOSB, environmentalists/resource conservationists member) states Allyl isothiocyanate (AITC) used in nursery stock could reduce use of conventional pesticides. Shistar replies that we have no control over what happens in the non-organic sector. Adding something to the National List only increases the risk in organic. It is not compatible to the way we do things in organic.

A-dae Romero-Briones (NOSB, consumer/public interest advocates member) asks Shistar to elaborate on her online comment on hops. Shistar states that as long as you allow the non-organic product, there is no incentive to grow the organic product. If you approve the petition now, it will take at least a few years to be allowed to grow. There could easily be organic producers who fill the hole in the market during that time.

Rick Greenwood (NOSB, environmentalists/resource conservationists member) asks Shistar if she believes that one should not use antibiotics on infected animals. Shistar says organic farmers are directed to administer antibiotics to sick animals.

[Cornucopia Note:  Any sick animal administered antibiotics cannot be brought back into organic production and must be removed from the herd or flock.]

Ashley Swaffar (NOSB, organic farmer member) asks for her thoughts on adhesives in paper pots and why they should have an extension. Shistar states that they’ve lobbied for a Technical Review on newspaper, hoping the new paper would be less toxic. But there are so many things that can be in paper. When she read about the paper pot issue, she considered the additives in these peanuts compared to paper’s technical review.

11:54 AM CT: Nathan Hecht (University of Minnesota, Department of Horticultural Science) shares the organic research priorities identified by the university. Agroecology and farmscaping practices: managing pests by farming for natural predators and pollinators. Covered agriculture and season extension; important for northern climates, but needs appropriate soil mixes and cultivars. Interdisciplinary studies and public engagement: aims to collaborate across traditional disciplines and involves stakeholders in all steps of the research process.

Jose Hernandez (consumer) supports the use of ethylene, believing it to be necessary with no current alternatives.

11:38 AM CT: David Hiltz (Acadian Seaplants Limited) is concerned about the language in various discussion documents, particularly the most recent NOSB document that suggests widespread over-harvesting is occurring. He said this is not consistent with many other comments and research on record. He says that his company is interested in harvesting sustainably and consults with scientists. Emily Oakley (NOSB, organic farmer member) asks about certification to wild crop standard. Hiltz replies that the rules are ambiguous and up to certifier interpretation. There is a need for more concrete rules.

Trudy Bialic (PCC Natural Markets) is speaking as a retailer and a consumer. She supports setting a deadline to sunset non-organic flavors, saying organic consumers do not want mysterious flavors in their foods and that only organic-produced flavors should be in organic foods. She believes xanthan gum should be sunset, and that it was illegally and improperly listed. She adds that gellan gum is also a product of bacterial fermentation and that there are reports from consumers regarding digestive issues. It is not listed as GRAS [Generally Accepted As Safe]. She asks the NOSB to add to their work agenda a consideration of gums created through bacterial fermentation. She said she had no objection to locust bean gum or guar gum.

Dan Seitz (NOSB, consumer/public interest advocates member) comments that he gets a lot of questions about flavors, and asks if Bialic could elaborate further. Bialic responds that consumers hope flavors come from major ingredients themselves and expect foods inherently flavorful not needing an additive. We haven’t done enough to get industry to comply with the 20-year requirement for organic flavors. Furthermore, manufacturers should be required to show how the flavors are produced so that a certifier can verify that the flavor was not produced by a prohibited process.

11:18 AM CT: Sandra Mays (of lobbyists Wolf, Dimatteo, & Associates) asks that pullulan be permitted for use as a non-agricultural substance allowed for “made with organic” products, to retain options for vegetarian capsules while meeting consumer demand. She adds that a kelp/seaweed working group should include international operators to understand harvesting styles and sustainability methods.

Kelly Monaghan (International Organic Inspectors’ Association) is pleased to see a proposal that focuses on reviewers and inspectors. She notes that we need a structure that allows inspectors to develop their skills, and that team inspections are under-utilized tools.

Melody Morrell, Cornucopia 

11:11 AM CT: Melody Morrell (The Cornucopia Institute, data analyst and research specialist) testimony below;

I have studied shipping logs, following the importation of “organic” corn and soy from suspect countries. I have seen loads whose consignee, shipper, and notifying party are all listed as FedEx—no transparency. Cheap, often fake, organic feed props up organic factory farm operations and has spread all over the marketplace. Cheap feed means cheaper meat, milk, and eggs.

In reality, these are conventional products sold at depressed organic prices.

Your continued attention to tracking organic products through the supply chain is critical to the integrity of the program and consumer trust. I am pleased to hear of the NOP’s present efforts and hope you can move quickly.

The natural evolution of organic farming is subverted when regulations are bent to fit the conventional model.  Rather than leaving room for the improvement of organic practices, we are ushering in a “kinder, gentler conventional agriculture.” Real organic farmers are being forced out of business.

Organic farmers who grow produce in soil now compete with hydroponic factories using organic inputs. Even during tomato season, “organic” hydroponic tomatoes dominate my rural Minnesota grocery store and our local organic buying club. They are cheap, sometimes even reaching conventional tomato prices.

Hydroponic operations require an enormous amount of energy-expensive infrastructure and do nothing to “improve or maintain the soil,” as the Organic Foods Production Act directs. Beginning in 1995, the NOSB studied, discussed, and took public comments on whether soil-less systems could be certified. In 2010, the board determined that “systems of crop production that eliminate soil from the system, such as hydroponics or aeroponics, cannot be considered as examples of acceptable organic farming practices.”

But here we are.

This spring, the European Union revised its organic standards to prohibit hydroponic production under their organic label. The E.U. will no longer import produce labeled “organic” if it was grown hydroponically, beginning in 2021.  I made copies of the pertinent parts of that new regulation, if you haven’t seen it yet. It includes a clear definition of organic soil-bound production. What will it mean for the U.S.-E.U. Organic Equivalency Arrangement when our labels do not mean the same thing?

Factory farm and hydroponic products dominate the market because they have been allowed to bear a seal they have not earned.  Thank you for your continued and complicated efforts to protect a true marketplace alternative. Thanks especially to Jennifer Tucker for her efforts at improved transparency at the NOP.

11:07 AM CT: Stephen Walker (MOSA Certified Organic) asserts that organic won’t meet consumer purity expectations unless there is more support for the USDA and not just the NOP. He says we need genetic integrity and transparency.

Michael Menes (True Organic Products) says they are a family-owned fertilizer company. He supports continued use of liquid fish. He supports the work and agenda to answer questions about its environmental impact.

11:02 AM CT: The board reconvenes.

10:30 AM CT: Break

Costa Rican delegation

10:23 AM CT: Wendy Jiminez (Central American Produce Association) supports the continued listing of ethylene.

Emily Musgrave (Driscoll’s, Inc) supports the continued use of elemental sulfur, which she believes is critical for strawberry growers, and that removing it would cause significant challenges and damage to crops. She also supports the continued allowance of sulfurous acid and liquid fish products. She says Driscoll’s supports sustainable sourcing. Emily Oakley (NOSB, organic farmer member) asks if they use kelp or seaweed products. Musgrave answers that a lot of growers use algae and marine products, and agrees with certifiers that it would be getting the regulation right.

Arturo Solorzano Arroyo (Government Authority, Costa Rica) testifies that he supports the continued use of ethylene in organic pineapple production. He says that climate change has increased a lot and is making undesirable fruit without uniformity, yet they need uniformity to manage pests. Harriet Behar (NOSB, environmentalists/resource conservationists member) summarizes what he said – when a field has different flowering times and ethylene is not used, you will have pests; so the reason for the use of ethylene is not just getting pineapples to market, but also in pest control through uniformity.

Ashley Swaffar (NOSB, organic farmer member) thanks all growers from Costa Rica for coming.

10:11 AM CT: Olman Briceno Fallas (National Chamber of Producers and Exporters of Pineapples of Costa Rica) says what keeps him up at night is the big issue of elimination of ethylene and fraud. If ethylene is eliminated, livelihoods will be over,  many workers will be laid off, and consumers in the U.S. would be affected by a lack of pineapples, bananas, and other crops.

10:06 AM CT: Luis Carlos Gonzalez Miranda (Pinas Orgnicas SOGA SA) tells the board through a translator that he is a Costa Rican farmer that uses ethylene and supports the continued use of ethylene.

Christian Herra Leon (Cooperagro) emphasizes that pineapple production puts biomass back into the soil. He says that cover crops are used. Dan Seitz (NOSB, consumer/public interest advocates member) asks if they use plastic mulch more than once. Carlos replies that they need plastic mulch, and use a slightly thicker plastic because pineapple takes 32 months to produce, then they send it to the recycling industry. Humidity and heat are a problem

Oscar Salas Porras (National Chamber of Organic Agriculture of Costa Rica) says organic production of growers established an organic agriculture chapter to help the government implement rules to improve the integrity of and implement the strictest rules for the industry.

Oscar Salas Porras, National Chamber of Organic Agriculture Costa Rica

 

9:39 AM CT: Rolando Soto Soto (Association De Productores bio ecological del norte) is a producer of organic pineapples in Costa Rica. He says the absence of ethylene for flowering will result in the disappearance of organic pineapple production and that ethylene should remain an approved product. Emily Oakley (NOSB, organic farmer member) asks where the increase in organic production is coming from. Soto says more people are consuming organic products so he believes conventional will convert to organic. Most of their pineapples are going to the U.S. but some are shipped to Europe.

9:35 AM CT: Nestor Ramirez (organic pineapple farmer from Costa Rica) addresses the use of ethylene and says he has worked with researchers and will share the results. Dave Mortensen (NOSB, scientist member) asks Ramirez to explain the pineapple fruit maturation process if they don’t spray ethylene. Ramirez said they can’t schedule when fruit will be harvested and it is impossible to operate when you don’t know when the fruit is coming.

9:31 AM CT: Laura Gomez (Organic Pineapple Cooperative) opposes banning ethylene in organic pineapple production. She runs a family farm in Costa Rica and uses a low cost ethylene spraying system. She asks for the continued allowance of ethylene in organic and mentions the need for certainty in producing organic pineapples. Sue Baird (NOSB, consumer/public interest advocates membre) asks how often they spray ethylene gas. Gomez says once a year and that there is nothing better to use.

9:20 AM CT: Orlando Rojas Esquivel (organic pineapple farmer from Costa Rica) tells the board that he has been an organic farmer for 10 years (through a translator). He says his family farm uses an ethylene system with all safety handling and that his family and employees depend on organic production. Responding to a question, he says the pineapple production cycle takes 30 months.

9:11 AM CT: Casey Hughes (National Organic Coalition) speaks to the use of antibiotics in day-old chicks. They support the need to completely eliminate antibiotics including in day-old chicks. She adds that the packaging-lining material BPA causes serious hazards and they support a technical review. Harriet Behar (NOSB, environmentalists/resource conservationists member) asks how BPA affects her food purchases. Casey responds, saying “I avoid BPA.”

9:08 AM CT: Shelly Connor (Wild Farm Alliance) thanks the NOSB for passing the recommendation regarding converting native ecosystems to crop land and urges the NOSB to create a working group to address marine materials. She says the group should include a diverse set of voices. Kelp and seaweed are key in ecosystems, and unsustainable harvesting, as well as climate change, could threaten them. The organic label can’t be complicit in destroying these ecosystems.

9:03 AM CT: Jamie Welch (EnviroLogix) says the company is a global leader in GMO diagnostics. He says GMO contamination can occur at a number of points and that a foundational requirement of organics is GMO-free seed. The standard cost for GMO testing of corn is $450 and takes five days to get results. He says farmers performing testing in-house need training.

8:50 AM CT: Michael Sligh (Rural Advancement Foundation International) strongly supports strengthening oversight of import fraud both domestically and internationally, with a need to focus on high-risk locations as well as developing greater rewards for those who remain in compliance. He urges all present to oppose the weakening of the Organic Food Production Act (OFPA) and says that fatty alcohols are needed for organic tobacco until alternatives are developed.

8:37 AM CT: Marisol Oviedo (Northwest Horticultural Council) focuses her comments on elemental sulfur and says it is critical for orchards, used for treatment of powdery mildew and adjusting soil pH.

8:35 AM CT: The Fall meeting of the National Organic Standards Board has resumed with public comments.

Board Chair Tom Chapman (NOSB, handlers/processors member; Clif Bar) calls meeting to order.

Wednesday, October 25, 2018

5:58 PM CT: With the conclusion of public comments, the board adjourns until 8:30 AM CT tomorrow morning.

5:53 PM CT: Doug Currier (Organic Materials Review Institute) testifies that they support the creation of a working group to consider aquatic plants.

5:47 PM CT: Bjarne Pedersen (Ellepot A/S) speaks for the Danish paper pot company. He supports a petition for paper pots. They have a “virgin” paper pot, as newspaper and recycled paper will not work. They use a special additive suggested by the Soil Association as a soil conditioner and do not need to use prohibited materials. This product is approved for use in the UK.

Harriet Behar (NOSB, environmentalists/resource conservationists member) asks if these are available in the U.S. Pedersen answers, yes. Steve Ela (NOSB, organic farmer member) asks if they can develop paper chain pots. Pedersen says they could, but their machines are meant to work on single pots taken from trays.

5:41 PM CT: Dave Colson (Maine Organic Farmers and Growers Association) testified on marine materials, saying it would be difficult to accomplish certifying marine materials to the organic wild crop standard. He said using a land-based standard for a sea-based product allowed for continued use of kelp, and now we are facing questions of sustainability of marine ecosystems. History, he says, has shown we aren’t always good stewards of the ocean. He notes that shrimp hasn’t been harvested from the Gulf of Maine in three years and the lobster abundance is in response to the decline of its predators. We, as an organic community, must step back and look at safeguarding natural resources.

5:30 PM CT: Albert Straus (Straus Family Creamery) testified that certifiers need tools to create a baseline for farms and displayed a hunting app that shows who owns the land and attendant acreage. He notes this could be used to help create the baseline for stocking densities, for example. He says they are the first dairy to have a carbon farm plan, working with a NASA scientist to quantify biomass on acreage. It saves money to grow feed on-farm. The 10% surplus of organic milk plus the operations doing continuous transition of conventional livestock onto organic dairies is causing a price depression for all organic farmers. He also mentions that they do not use much gum in products; a small amount of organic gum in softserve and it is found in chocolate chips they buy. Innovation, away from such additives, he says, is driven by necessity.

Jay Feldman, Beyond Pesticides

5:25 PM CT: Jay Feldman (Beyond Pesticides Executive Director and former NOSB chair) calls for a transparent review process for National List materials. We need to create a record which includes rigorous, robust, and reported review of all stakeholders and the release of detailed notes. Feldman says the board should reinstate the practice of documenting minority positions on policy and materials. When a proposed work plan item is rejected or removed, this needs to be in subcommittee notes.

Emily Oakley (NOSB, organic farmer member) responds that she will give the need for more detail and for documenting positions more thought and they will explore it as a group.

5:18 PM CT: Alan Lewis (Natural Grocers) says “organic is meaningless” is something he hears everyday and finds infuriating. Typically this is someone in their 20s saying this. The new science of soil biome, human health and global health, and climate change are tied up in the ethic of organic and it’s anything but meaningless. Lewis says it is illegal for exempt or excluded operations to use the seal, yet many retailers are using this seal and representing themselves as organic operations.

Emily Oakley (NOSB, organic farmer member) asks for an example of a retailer misusing the seal. Lewis says that ALDI is using a modified version of the seal as motif in their produce department. He calls for making the retailers comply with the verified organic systems plan. 

5:10 PM CT: Patrick Kerrigan (Organic Consumers Association) referenced an editorial regarding the unlikeliness of produce farmers continuing to farm as climate change unfolds. He says that climate change is the elephant in the room and can no longer be ignored. He added that the regenerative agriculture movement is gaining ground and can regenerate soil health; “We need to take a stand for soil”.

5:00 PM CT: Kiki Hubbard (Organic Seed Alliance) believes the organic seed proposal should move forward. She is glad to see it on the agenda and pleased to see stronger language regarding on-farm trials. She says issues remain in the genetic integrity proposal that must be addressed and is concerned with references to “seed purity” because there is not an industry standard for this and it cannot then be enforced.

4:58 PM CT: Nicole Dehne (Vermont Organic Farmers, Certification Administrator) says paper pots have been a game charger for operators and that these materials have already been considered. She also asks how do we regulate the purity of non-organic seed regarding genetic contamination?

4:49 PM CT: Anne Ross (The Cornucopia Institute, food and farm policy analyst and attorney) testimony below:

Not long ago, I received an anonymous tip that a certified organic grain operation located in Eastern Europe hired an individual away from their certifier to manage the certified operation’s organic division.

According to the  tips, this individual was scheming, with his former colleagues, who are still employed by the certifier, to fraudulently label conventional grain as organic.

Anonymous tips providing such limited information can be a dead end or can take time to sort out.  But there is a lesson here.

When a certifier’s employees, consultants, or board members are subsequently hired or retained by an operation that the certifier certifies, there is a potential conflict of interest.

This is also true when employees or consultants change employment in the opposite direction–from a certified operation to certifier, or even between the NOP and these entities.

To be fair, the “revolving door” can function in a positive way in that it allows different sectors of the organic community to make good use of the knowledge and expertise of individuals who have dedicated their work to this area.

But only if we frame rules and policies around a conflict of interest that could arise.

Why? Because, potential conflicts of interests are, in fact, conflicts of interest, only they are effectively managed.

So, let’s manage these conflicts of interest by (1) formally recognizing they exist and are a risk factor for certifier fraud; and (2) manage them through disclosure requirements.

The NOP should recognize:

  • If a certified operation hires an individual previously employed by its certifier, there is a conflict to manage
  • If a certifier hires a former NOP employee as an employee or consultant, there is a conflict to manage

The NOP should require that the nature of these relationships be made publicly available.

Requiring public disclosure would be consistent with other industries, professions, and governing bodies that require disclosure in potential conflict situations.

These industries recognize that this is NOT a hypothetical problem, but circumstances faced by good people by virtue of their positions and capitalized upon by a few crooked opportunists.

Adding this risk factor and disclosure requirement:

  • Helps in fraud detection
  • Protects all of the ethical certifiers and their employees from the appearance of bias
  • Increases public confidence in the organic label.

Addressing the revolving door scenario allows us to focus on productive conflicts—conflicts of ideas—and not on repairing breaches of trust that, all too often, accompany unmanaged conflicts of interest.

I’ve also submitted a written comment on this topic which includes more detailed recommendations.

Emily Oakley (NOSB, organic farmer member) asks Ross how the NOP should approach this issue. Is this NOP-level? Ross says that employees are already listed as a risk factor in documents the committee has put forth; adding former employees would be a good first step.

4:42 PM CT: Molly Schaus (Minnesota Food Association) requested the board consider how their decisions impact beginning farmers of color and immigrant farmers. With less capital and credit, land purchase is difficult. How can regulations address the land access issues suffered by so many?

Asa Bradman (NOSB, environmentalists/resource conservationists member) asked if she had suggestions for how we can help. Schaus said a barrier is the high cost of certification. Even though cost-share programs reimburse, the money is needed up front. In addition, institutional barriers to land access often make farmers unable to farm the same piece of land for more than one season.

Participants listen to public testimony

4:30 PM CT: Kyla Smith (Pennsylvania Certified Organic) says that they support the concept of continuous improvement in organic seed. The current language in the seed proposal does not give enough flexibility to both support operation improvement and oversee the operation. She asks for the proposal to return to subcommittee to clarify who is responsible for these tasks.

4:28 PM CT: Abby Youngblood (National Organic Coalition) says that they oppose the petition for allowed use of Silver Dihydrogen Citrate (SDC) in organics. It appears that the petitioned material may be nanosilver. There remains no clear prohibition of nanotech.

[Cornucopia Note: One of the recommendations from the NOSB that the USDA has refused to move forward on is a prohibition on nanotechnology in organics.]

Youngblood also says that GMO vaccines are being used in organic production, but should be reviewed first and placed on the National List of prohibited and allowed substances.

4:21 PM CT: Zak Wiegand (Oregon Tilth) says that allyl isothiocyanate (AITC) would provide a solution for organic growers in need of nematode reduction. Without these tools, some farmers are looking at giving up farming or converting to conventional farming.

Steve Ela (NOSB, organic farmer member) mentions that broad spectrum pesticides are troubling. Wiegand says that AITC leaves more non-pathogen communities intact than other comparable pesticides. It appears to break down into food for specific microbes in the soil. Cover crops cannot provide the same amount of AITC as the spray itself.

Emily Oakley (NOSB, organic farmer member) says that over time, cover crops can provide much help.

4:11 PM CT: Nathaniel Lewis (of lobbyists Wolf, Dimatteo, & Associates) encourages the NOSB to take another look at polyethylene film for mulch. He adds that liquid fish products should be finalized via the sunset process. He also urged prohibition of sodium nitrate on crops. [Most of the world bans the use of this fertilizer.]

Steve Ela (NOSB, organic farmer member) asks the NOP’s Director of Standards Paul Lewis about sodium nitrate, noting that it was removed from the National List of approved and prohibited substances because it needs to be dealt with by the NOP. It now remains in use without being reviewed.

Board chair, Tom Chapman (NOSB, handlers/processors member; Clif Bar) says petitioning sodium nitrate for removal could get it back on the NOSB agenda.

3:59 PM CT: John Hendrickson (Small Farm Works/Stone Circle Farm) wants to get paper approved for paper pots. The technical reviews are clear that paper and paper products contain many additional ingredients, largely unknown. But the small amount of paper in pots pales in comparison to the miles of plastic mulch used on organic farms.

Steve Ela (NOSB, organic farmer member) observes that the subcommittee is hung up on the problematic addition of adhesive after the paper is made.

3:56 PM CT: Jenny Cruse (Accredited Certifiers Association) says that paper pots should be allowed so as to reduce reliance on plastics; it seems comparable to mulch. She adds that the final language in the genetic source of seed proposal should allow for more flexibility and allow operations to show improvement over time, not just year-to-year. A comprehensive seed database would be helpful and could be funded and established by the USDA.

Richard Matthews, WODPA

3:50 PM CT: Richard Matthews (Western Organic Dairy Producers Alliance, executive director) says two certifiers are allowing operations to continuously transition conventional calves into organic dairy production. This is, he states, a violation of the organic regulations at 201(a)(5) and 236 (b)(1).

Harriet Behar (NOSB, environmentalists/resource conservationists member) asks him about the economic impact of that decision on WODPA members. Matthews says it is cheaper to raise calves conventionally than organically. They save about $1000 per animal. It allows them to disregard the feed provisions, livestock healthcare and living provisions, and the pasture provisions. He adds that those who have trouble raising animals do this. The good farmers don’t do this, and they are placed at an economic disadvantage.

Board chair Tom Chapman (NOSB, handlers/processors member; Clif Bar) asks NOP’s Tucker to provide context for what they’ve heard. She replies that when NOP gets a complaint, they look at what would happen if they propose an adverse action, and then how would lawyers appeal it. Is the lawyer’s appeal believable? If so, the lawyers win. She notes that a lawyer, upon appeal, would document conflicts of interpretation on Origin of Livestock, and that “we have to have full confidence that it would win to take an issue on.” NOP will not take an adverse action since there is uncertainty in Origin of Livestock rules. The pasture compliance project that the NOP is working on right now does clarify all aspects of pasture, grazing seasons, antibiotics, etc. She adds that we have to be pragmatic in how we deal with these complaints as it is very dangerous for the NOP to lose this type of appeal. An industry analysis of Origin of Livestock could be a future way to handle this, but it is not on the agenda at present.

3:31 PM CT: Rudy Amador (Dole) discusses the importance of ethylene for production of bananas and pineapple as it induces flowering and controls pests effectively. He maintains there would be none without ethylene. It also ripens bananas uniformly, necessary for organic banana production. Amador says growers would convert back to conventional if prohibited.

Harriet Behar (NOSB, environmentalists/resource conservationists member) asks if there is a rotation crop with pineapples. Amador says they use green manure between crops, but no rotation crop really. Fallow time depends on weather. A lot of rain makes it longer, with 6-12 week fallow periods. Dave Mortensen (NOSB, scientist member) asks why organic bananas are always more green in the store. Does that have to do with the amount of ethylene used? Amador says buyers request the level of ripeness.

3:23 PM CT: Jackie DeMinter (MOSA Certified Organic) has submitted a petition on paper pots. All paper pots will have to be discontinued next session, including newspaper and recycled cardboard. MOSA, she says, allowed them because the paper is used elsewhere and the adhesives are also used elsewhere in organic production. It will have a financial impact on MOSA. Many farmers have said if they have to choose between the paper pots and their certification, they will stay with the paper pots. They make their operation possible.

Steve Ela (NOSB, organic farmer member) asks how should we approach this to limit the adhesives allowed and to keep things concise?

DeMinter suggests they follow the process used with feedstock and mulch. There is a lack of consistency. If you can put the same products between the rows, how can they tell farmers not to plant the pots?

Charlotte Vallaeys,
Consumer Reports

3:11 PM CT: Charlotte Vallaeys (Consumer Reports) testifies that the organic label has fallen short regarding prohibiting the routine use of antibiotics in animals that aren’t sick. Day-old poultry continue to receive antibiotics. Even Tyson and Perdue have entirely stopped using antiobiotics in day-old chicks.

Ashley Swaffer (NOSB, organic farmer member) thanks Vallaeys for her work on this. How can we move forward, Swaffer asks. Vallaeys says that organic law, in OFPA, exempts day-old poultry from organic management. Consumer Reports is not asking for a change in OFPA, just asking for a singular prohibition in the regulations. Swaffer says we need to elevate this to the level of the USDA Secretary.

2:49 PM CT:  Robin Hadlock Seeley (biologist) states that rockweed (commonly referred to incorrectly as “kelp”) harvesting damages the environment for fish and other marine life. Kelp grows very quickly and can be farmed, but rockweed grows very slowly and cannot be farmed.

Jessica Walden (Quality Assurance International) says the 2018 technical review refers to precipitated calcium carbonate as synthetic. It is unclear why this is so. The starting material is the same as the ending material, after purification. The TR should not advise the industry, particularly certifiers, on the classification of the material. That is for the NOSB to do. It is not a new material created through a chemical reaction, although it undergoes a chemical reaction. The final recommendation needs to encompass the forms of the material being used to clarify for certifiers.

Alexis Randolph (Quality Assurance International) asserts QAI has robust risk assessment, including scoring methodology, that she shared with the board. She says prior suspension of operation, for example, increases the risk of an operation. High-risk operators are subject to higher inspection frequency, unannounced inspections, and sampling. Certifiers who certify internationally often have a risk assessment tool because the EU requires it, but they are not all the same. She is in favor of the NOP working toward a framework for risk assessment.

2:35 PM CT:  Wanda Jurlina (CP Kelco, ingredient supplier) says each gum is unique in its uses. High acyl and low acyl gellan gums each have different properties as well. These gums offer an alternative to other prohibited ingredients.

Harriet Behar (NOSB, environmentalists/resource conservationists member) asks why high acyl was the only gellan gum originally allowed for use in organics? Jurlina is unsure. Steve Ela (NOSB, organic farmer member) asks about other gums, like tamarind seed gum. Jurlina says they are challenging to use. It is difficult to make an organic product appear like a conventional product, she acknowledges.

2:25 PM CT: Public testimony resumes at the NOSB meeting in St. Paul.

Mark Kastel, Cornucopia 

Cornucopia’s executive director, Mark Kastel, asks the board;

Who owns the organic label? We all do.

We wish Dr. Tucker well. She inherits a troubled program.

When we founded the commercial organic movement, in the 1980s, and asked Congress to pass the Organic Foods Production Act. It was viewed as a social and economic justice vehicle for family farmers.

At $50 billion, how is the organic movement working?

  • Farmgate prices for milk are down 30-50%. Some farmers are selling out.
  • Some fresh market fresh vegetable producers tell us CSA and market sales are down 30%. They can’t compete with pseudo-industrial organics and hydroponics.
  • Row crop producers can’t compete with phony imports from China and former Soviet bloc countries, countries with histories of endemic commercial fraud in many sectors.

While the NOP and this board focuses on important micro issues, organic farmers are losing their livelihoods

Conflicts of interest – closing the revolving door

What if a former certifier becomes head of the NOP?

Congress charged the USDA with oversight of the certification process, yet past audits by the Office of Inspector General has been damning in their criticism of the NOP accreditation program.

What if a former certifier becomes the cheerleader in chief, on behalf of certifiers, at the ACA meetings? The certifiers he is charged to aggressively oversee.

What if secret behind-the-scene deals are made benefiting certifiers to the tune of millions?

What if, based on documents we have obtained under the Freedom of Information Act, some of the largest certifiers had been found guilty of major illegalities … And let off the hook?

And then, what if that official leaves the USDA and receives lucrative consulting contracts from the same certifiers they were just overseeing?

How would that look to the public?

And what if a different former NOP leader overrules a certifier ordering them to allow an operator to substitute a small porch, accommodating maybe 3-5% the birds in the henhouse, instead of allowing them to go outdoors?

According to the law: All organic livestock must have access to the outdoors.  What if the same NOP official, after retiring from the USDA, immediately becomes a consultant and lobbyist for the same egg producer?

NOSB members: Please close that revolving door.

Why should the organic regulatory structure be different than anything else that happens in Washington? … Because we said so!

Dan Seitz (NOSB, consumer/public interest advocates member) asks Kastel what are the main areas where certain dairy farms are not in compliance?

Kastel responds, noting that his criticism is not directed at new NOP director Tucker. Farmers are on suicide watch, Kastel says. Farmers can’t sell their cows. There is no market for organic cows. The NOP accreditation programs have allowed certification of some [CAFO] dairies that have 10 cows per acre. But the average organic farm has about one cow per acre. Some CAFOs are cutting hay off the same pasture cows are grazing. What’s the tie-in here with conflict of interest? Certifiers not doing their job. If you go to Cornucopia’s FOIA Reading Room, you can see that Shamrock – with thousands of cows in the desert outside Phoenix – was found guilty. Nothing happened to its certifier QAI. Nothing happened to Aurora after the Washington Post story in 2017. The result is farmers are losing their livelihood.

12:57 PM CT: Kate Mendenhall (Organic Farmers Association) indicates their opposition to hydroponics. She says the NOP should issue a guidance on the controversial livestock rule rejected earlier by the Trump Administration. As for imports, she says the NOP needs to act more swiftly to protect farmers.

Michelle Smolarski (International Food Additives Council) calls for re-approval for organic use of xanthan gum and gellan gum. She also supports retaining gum arabic and guar gum.

12:51 PM CT: Peter Nell (CCOF) says that they do not support certification of marine materials to wild crop standards. The NOSB should establish a working group of integrative fishery certification and all ocean-source inputs.

12:48 PM CT: Glenn Kern (Carolina Farm Stewardship Alliance) testifies that part of their work is helping farmers transitioning to organic. He says that CAFOs and chemical-dependent farms are unacceptable risks to human health and, in the context of changing climate, that flooding will become more common. Kern adds that organic tobacco may soon be lost to farmers in the Carolinas, as without the use of fatty alcohols many organic tobacco farmers will have to abandon production.

David Wallinga, NRDC

12:48 PM CT: David Wallinga, MD, (Natural Resources Defense Council) testifies about human antibiotics in livestock and associated increases of antibiotic resistant bacteria. The NRDC urges prohibition of antibiotics in organic agriculture without exception; including injecting gentamicin in eggs just before hatching. He says that particular antibiotics are injected into very sick humans when other drugs don’t work; used for systemic infections only. Wallinga is concerned that gentamicin is routinely used in organic chicken production, and says that this would surprise most consumers.

12:42 PM CT: Zea Sonnabend (CCOF, and former NOSB member) supports the seed proposal and the retaining of a sample of seed, but would like it to be for 18 months instead of 12. She mentions that CCOF does not have a position on paper pots but also has never allowed them.

Phil LaRocca (CCOF, board president) says organics is one of the rare bodies that ask for regulations. Dairy producers that are following the rules want to make sure that all livestock standards are being followed. The same is true for poultry production. LaRocca says certified organic producers need to be protected from pesticide drift. And that we are going to have areas affected by flood and hurricanes that will be dusted for mosquitoes – this may impact organic farms.

Harriet Behar (NOSB, environmentalists/resource conservationists member) asks the NOP if there is guidance on drift being worked on. NOP’s Tucker says that there was a draft on drift distributed within USDA, but it has not moved forward because of enormous complexity and is not active on their work agenda.

12:27 PM CT:  Beth Unger (CROPP Cooperative/Organic Valley) speaks to the proposal on genetic transparency of seed. She supports requiring improvement on sourcing of organic seed and urges passage of the proposal at this meeting.

Sam Welsch, OneCert

Sam Welsch (OneCert, Inc) supports removing microcrystalline cheese wax from use in organics. He also supports removal of sucrose from use. As to the qualifications of organic inspectors, Welsch supports high quality but opposes licensing, stating that certifiers are already required to have qualified staff. Asked about paper pots, he says OneCert never approved them.

12:13 PM CT:  Johanna Mirenda (Organic Trade Association) supports the use of paper in organics. She supports a technical review of adhesives added after paper manufacture and taking a broad view. If it only addresses “pots”, it might be limiting and require additional review. OTA wanted an extension of the 2018 phase-out. She says synthetic paper is already being used in organic systems. The OTA’s Mirenda also supports using the wild crop standard for the harvest of seaweed.

11:59 AM CT:  Gwendolyn Wyard (Organic Trade Association) calls for allowing continued use of pullulan in the manufacture of vegetarian supplement capsules.  She says  it should be classified as non-agricultural and appear on the National List. Wyard also discussed guidance on the use of organic seed.  She says the subcommittee working on it needs to continue revisions.

11:32 AM CT:  Christie Badger (National Organic Coalition)

Christie Badger, NOC

Tucker said that she thinks we could use open document to provide two-way communication.

Badger says this could be used for questions and praises Tucker for collaboration.

Harriet Behar (NOSB, environmentalists/resource conservationists member) asks question about energy infrastructure; point of providing information to aid producers and certifiers during the activities of energy infrastructure moving through organic land. Is it a best practice or should we consider banning? Answer: Prohibited substances can be identified when energy infrastructures are undertaken on organic farms.  Board could issue guidance for certifiers so everybody isn’t winging it.

11:08 AM CT: Public comment at the fall NOSB meeting begins with Lynn Coody (Organic Produce Wholesalers Coalition). She calls for the allowed use of ethylene gas for pineapple ripening. As for paper pots, she supports a request for technical review and urges the board to prioritize action.

11:00 AM CT: Dr. Tucker continues to field questions from NOSB members.

Both Asa Bradman (NOSB, environmentalists/resource conservationists member) and Lisa de Lima (NOSB, retailer member) ask Tucker to clarify why the NOP is putting removal of BPA from packaging on hold. Tucker says they would need to consider limits of statutory authority and that for now, BPA is not a priority given other challenges.

Rick Greenwood (NOSB, environmentalists/resource conservationists member) asks a question on residue testing and says that he thinks it is an important part of enforcement activity. Tucker mentions it is a great tool for surveillance and enforcement, telling certifiers the importance of risk-based oversight. She says they are updating residue testing guidance because detection limits are dropping as technology evolves.

Steve Ela (NOSB, organic farmer member asks Tucker how can we get more time for stakeholders to comment. Tucker says they will be re-initiating posting subcommittee notes. NOP is one program of many in the agency and we post the most on the website. She says they sometimes get complaints that there is too much on the website. In terms of comment periods, she says they could possibly post interim drafts of discussion documents and there may be some room to yet modify their process.

10:29 AM CT: Tucker concludes and takes questions from the board.

Emily Oakley (NOSB, organic farmer member) relays concerns on paper pots, with the decision leading to a loss of smaller-scale growers. Oakley is interested in seeing large numbers of growers engaging on the paper pots issue. Tucker replies that the decision was not made lightly, and the first fidelity is to USDA organic regulations and OFPA. She wishes the product had been petitioned earlier and believes certifiers who decided not to allow paper pots were correct. Tucker says they haven’t gotten a lot of communication about this until the current meeting and adds that letter writing is important; the best way is to write to the Secretary of Agriculture. Every correspondence gets assigned a number and is tracked. Writing to both the undersecretary and secretary is important and should include economic impacts that are being experienced. She adds that she can always be written to as well.

Harriet Behar (NOSB, environmentalists/resource conservationists member) asks Tucker if NOP will ask certifiers information on fields that are not directly adjoining the home farm. She believes it would be useful to watch this for drift as well as for crop insurance. Tucker responds that they are seeing instances where operations that are not close to each other should be separately certified. She says they have some challenges with addresses. Not all certifiers provide both parcel addresses and not all are doing thorough address checking.

Dave Mortensen (NOSB, scientist member) also asks about paper pots. He says that in his view not allowing paper pots for 2019 is disproportionately severe and impacts are large. Other than hydroponics, he has heard more comments about this than any other issue. Small growers are much less likely to have an organized voice at this meeting and large growers also have paid reps that can commit three days to being here. Small farms are widely dispersed, profit margins are usually thin as is their time, and to ask them to keep up with all of this rule-making and writing is difficult. Many don’t know they can write-in or think that they need to, and this kind of issue doesn’t get a fair shake because the system is broken given their lack of voice in DC on this issue. Tucker replies that she appreciates this feedback.

10:10 AM CT: Tucker mentions an NOP agreement with certifiers to not allow paper pots as they are not made out of newspaper or recycled paper.

Slide: ANSI Peer Review

Last fall, Tucker reported on the peer review but NOP has changed their approach. Reviews had gotten too detailed. ANSI was asked to take a systems level review and to review through a risk-based lens. Tucker says they have lacked a sufficient number of auditors for the USDA’s review of certification agencies, but that increased funding is helping them hire more staff. She also shares that procedures for residue testing on international operations aren’t well understood. There is a need, Tucker adds, to continue to train staff in investigative methods.

10:01 AM CT: Dr. Tucker comments on efforts for strong organic control systems. NOP is collaborating with APHIS on fumigation issues. There are a high number of fumigation offenses, although it turns out the hits are much lower than had initially been thought and allows the NOP to do more specific follow-up. They are developing new models for risk-based oversight using diverse data sources and information in the NOP database to identify high risk areas as well as ongoing certifier audits worldwide and a recent NOP negotiation to suspend one international certifier.

On strengthening organic enforcement rule making, Tucker says there will be a public formal comment period for the proposed rule anticipated in spring 2019. Also, an Organic Integrity Learning Center is going to be designed for certifiers and inspectors to receive continuing education and training. She shares that the NOP is building a new complaint management system, bringing up the latest shocking report of domestic grain fraud and that they have done a comprehensive review. Open cases are being worked on or referred to another partner, noting that building strong cases is vital. Tucker believes that fraudulent organic food sales are the exception and not the rule and that the NOP wants to ensure the organic seal remains the gold standard.

[Cornucopia Note: Full electronic traceback is essential as is certification of every entity in the international supply chain.  Until these goals are accomplished, fraudulent actors have ample room to penetrate the supply chain.]

Turns to an imports case study regarding corn imported from Serbia, with many people speculating it was fraudulent.

Slide: USDA Imports Investigations

The NOP has confirmed, through the certifier, that that Serbian producer had enough land to produce corn. Tucker uses this as a rapid response to show the system is working, and says that they are developing a risk-based system where accurate and timely data is critical with currently focus on certifiers in the Black Sea region.

[Cornucopia Note: As revealed in our June 2018 white paper, the Black Sea region is particularly troubling as it is a region of documented fraud. Enhanced focus on certifiers operating in this high-risk area is overdue and desperately needed.]

Tucker shared the complaint submittal process. Must include who, what, when, and where as well as the specific regulatory rule violation. Complaints are an important tool and the U.S. government has a unique ability to enforce these.  She encourages organic buyers to research supply chains.

Slide: Dairy Compliance

9:51 AM CT: Dr. Tucker discusses farm to market traceability. NOP published reports on collaboration and technology needs in response to 2017 OIG report, working with customs and border protection to scope organic “message sets” project and launch an electronic export certificate system. She says they have initiated visioning for the Global Organic Oversight and Traceability System, with a goal of full supply chain traceability and to allow government entities to quickly access and approve certificates and transactions. The vision is Connected Data Streams, with lots of different ways to look at a problem and explore ideas such as this.

Tucker says they are working toward robust enforcement. NOP is highlighting the Dairy Compliance Project, previously called Pasture Surveillance Project. There are problems that are being investigated and enforced, through unannounced inspections and monitoring, and it is one of their top priorities. The project will be continuing into 2019.

[Cornucopia Note: After years of stonewalling by the former NOP director, and failure to apply penalties to operators and certifiers when formal complaints were proven meritorious, the plans for extra scrutiny of giant dairies are welcome.  To date, there are no known results.]

9:38 AM CT: Tom Chapman (NOSB, handlers/processors member; Clif Bar) offers his 4th report as NOSB chair, noting there is a full leadership team in place at NOP. Recognizes and praises Tucker, hired under former Director McEvoy. Chapman also recognizes the board and their dedication.

Tucker gives her NOP report.

Displays map of 966 certified operations in MN, from an internal mapping system of the NOP database. They are invested in data visualization tools to help with audit planning, also helping with county and state level recording of acreage. Tucker highlights four key priorities for FY 2019:

  1. strong organic control systems
  2. farm to market traceability
  3. robust enforcement
  4. support the standards and collaborate with community

9:28 AM CT: Chapman introduces Dave Fredrickson, Commissioner Minnesota Department of Agriculture.

Fredrickson remarks:

Dave Fredrickson

Was a schoolteacher and then a farmer for 20 years before selling the farm to his cousin and running for a state senate seat in 1986. Served two terms in senate before becoming president of the Minnesota Farmers Union from 1991-2001  and then president of the National Farmers Union for another four. Currently serving his second term as Commissioner of Agriculture in Minnesota.

Was concerned about NAFTA negotiations and about tariffs, with agriculture becoming collateral damage as “farmers are not price setters, but price takers”.

Believes there is new interest in organic farming and a new generation of farmers stepping up who view agriculture differently from urban warehouses in different climates. Cites efforts to promote organic agriculture including grants, loans, certification cost-shares and organic conferences. A few years ago he traveled to Cuba to understand organic agriculture there. When the Soviet Union resources dried up for Cuba, the island entered a period of rapid growth in organic agriculture. Looking forward to returning in November to see recent changes.

Minnesota has presently more than 130,000 organic acres in the state, ranking 7th nationally. Organic sales “are strong in Minnesota at $106 million”. Cites a strong partnership with the organic industry and recognizes longtime MN organic advocate (and former NOSB chair) Jim Riddle. He concludes, noting he is looking forward to the meeting this week and thanks everyone for attending.

Chapman introduces Dr. Julie Grossman, a soil scientist and researcher at the University of Minnesota.

Grossman remarks:

Dr. Julie Grossman

Makes personal reflections on organic agriculture in higher education; argues that by way of training students they will be carrying out organic production. Recalls 20-30 years ago, organic agriculture was mostly being studied at fringe institutions. She decided to study farming while at Simmons College in Boston, doing her research at Drumlin Farm. Sustainable agriculture started to boom in the 90s, and now has been integrated into most land grant universities. Currently working at the University of Minnesota on the school’s six acre organic farm, looking at invasives and pests as well as the use of high tunnels as many farmers who currently use them struggling with soil health. Also working with organic farmers to understand organic price premiums. University of Minnesota Dairy Program helping with current “economic storm”, focusing on grazing research and building a more robust cow with more nutritious milk. She concludes, noting the University of Minnesota is preparing students in organic and sustainable agriculture and, though not all will be farmers, most will be working with farmers and continue to support organic programs such as this.

9:20 AM CT: Dr. Tucker provides quick overview of three-day agenda and introduces board chair Tom Chapman (NOSB, handlers/processors member), an ingredient sourcer from Clif Bar, who will chair his 4th meeting.

Chapman takes over.

Remaining NOSB members introduce themselves:

  • A-dae Romero-Briones (Consumer/Public Interest Advocates)
  • Lisa de Lima (Retailer)
  • Asa Bradman (Environmentalists/Resource Conservationists)
  • Steve Ela (Organic Producer)
  • Dave Mortensen (Scientist – Toxicology, Ecology, or Biochemistry)
  • Dan Seitz (Consumer/Public Interest Advocates)
  • Harriet Behar (Environmentalists/Resource Conservationists)
  • Scott Rice (USDA Accredited Certifying Agent)
  • Ashley Swaffar (Organic Producer)
  • Jessie Buie (Organic Producer)
  • Sue Baird (Consumer/Public Interest Advocates)
  • Emily Oakley (Organic Producer)
  • Tom Chapman (Handlers/Processors)

8:50 AM CT: Tucker will be presenting the new learning system NOP is implementing and welcomes two new members to the NOSB; Dr. James Greenwood, who sits on the environmentalists and resource conservationists seat, and Eric Schwartz, who sits on the organic handlers and processors seat.

Dr. Greenwood introduces himself: faculty at UCLA in Epidemiology and organic avocado grower in California.

Eric Schwartz introduces himself: currently works for a vegetable co-op that represents 50 growers and produces about 70% of the leafy greens grown on the west coast. Previously has worked for DOLE and KRAFT.

Dr. Tucker presents letters signed by USDA Secretary Sonny Perdue to the new board members.

8:32 AM CT: Official opening of the National Organic Standards Board Meeting in St. Paul, MN by Dr. Jennifer (Jenny) Tucker, acting Deputy Administrator of the Agriculture Marketing Service (AMS) National Organic Program (NOP).

She thanks everyone for coming and introduces the NOP staff, including Dr. Paul Lewis (Standards Director), Dr. Clarissa Mathews (National List Manager), Devon Pattillo (Materials Specialist), Betsy Rakola (Compliance & Enforcement Director).

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