Fall 2019 NOSB Meeting – Webinars: October 15 & 17

October 18th, 2019
Source: Mariah Dietzler, Flickr

Cornucopia’s director of domestic policy, Marie Burcham, JD, attended the National Organic Standards Board (NOSB) pre-meeting webinars on October 15 and 17, where the NOSB heard comments from the public.

Our notes from this meeting are below.

Tuesday, October 15

NOSB members present:

Harriet Behar (January 2016 – January 2020) – NOSB Chair
Steve Ela (January 2017 – January 2022) – Vice Chair
Scott Rice (January 2016 – January 2021)
Sue Baird (January 2017 – January 2022)
Jesse Buie (January 2016 – January 2021) (joined late)
Tom Chapman (January 2015 – January 2020)
Lisa de Lima (January 2015 – January 2020)
James R. “Rick” Greenwood (May 2018 – January 2023)
Dan Seitz (January 2016 – January 2021)
Ashley Swaffar (January 2015 – January 2020)
Emily Oakley (January 2016 – January 2021)
Asa Bradman (January 2017 – January 2022)
Dave Mortensen (January 2017 – January 2022)

Not in attendance:
A-dae Romero-Briones (January 2016 – January 2021)

Introductions from Michelle Arsenault. She notes that the ZOOM webinar is being recorded and there will be a transcript provided as well.

Paul Lewis, Director of Standards Division from the National Organic Program (NOP), opens the meeting.

[In Cornucopia staff notes on individual comments below, our staff has included the commenter’s name and affiliation]

Maddie Kempner, NOFA-VT Policy Advisor

Comment on excluded methods from livestock and materials subcommittee. While not on the current work agenda, the current regulations prohibit use of gene editing, and we want NOSB and NOP to support the exclusion of gene editing.

Want to add in vitro methods of mutagenesis to be added to excluded methods.

Kempner supports adding embryo transfer to the list of not excluded methods, as long as hormones are not used. This is not something producers have found necessary.

Excluded methods vaccine proposal: vaccines are important; we support continued allowance of vaccines. We verify to the best we can that vaccines are not produced using excluded methods, including GE methods. We support the use of excluded methods vaccines when others are not available. We want to encourage the development of alternatives for those that don’t have non-GE equivalents.

Harriet: Does the livestock vaccine proposal show willingness to accept GE vaccines or help promote non-GMO vaccines to be available?

A: It provides the opportunity for more available info, hopefully to increase and encourage the development of vaccines from non-GE methods. If folks document that these vaccines are not available, that will be info that others can use to develop new vaccines.

Linley Dixon, Real Organic Project (ROP) Associate Director
Farmer-led grassroots effort with over 250 farms certified to date

Major failures of NOP to enforce basic foundations of what makes organic organic. The development of sustainability third-party labels is a direct result of the failures in the organic label.

There is a severe economic disadvantage and true farmers are facing unfair competition. There are examples in hydroponics and in dairies that truly graze compared to those cattle that fill their bellies with TMR and then turn them out on poor pasture (that is not real grazing).

The ROP shouldn’t know more about what is going on in the organic industry than the NOP.

NOP still has not clarified if the three-year transition is required for hydroponics. Soil health is vital: it’s what organic means to organic farmers.

Emily: Clarification on NOP memo on transition period is of concern with other stakeholders as well. I’m wondering if Paul or someone on the call is able to address that for us.

Paul: At next week’s NOSB meeting Tucker will be talking about the memo and determining clarification of that point of transition time.

Harriet: Thank you for working with so many passionate organic producers.

Andrew Dykstra, WODPA and organic dairyman in WA

As a dairy, we’ve been playing under two sets of rules and many have been losing big time. I am in favor of the origin of livestock rule, and pasture enforcement is needed.

Peyton McDaniel, Hickory Meadows Organic Farm

Farmer growing 600 acres of organic crops. Tobacco is a major part of this operation and I don’t feel like it can be done without the use of fatty alcohols for sucker controls. Labor costs will increase such that we can’t continue to grow the crop and increase the risk of green tobacco sickness to workers. Please add fatty alcohols to the list of allowed substances.

Emily: Have you grown tobacco without the use of fatty alcohols before?

A: Yes, we did for several years. It was very labor intensive and it wasn’t good for the crop.

Q: How many acres do you grow?

A: About 50 acres

Q: Do you sell it to a variety of buyers?

A: Two different buyers

Jennifer Daniels, Windy Creek Farms

Tobacco growers located in NC. We profit one leaf at a time. We’ve been certified organic since 2014; we grow sweet potatoes, cucumbers, peppers, etc. organically. Fortunately, tobacco is how we transitioned into the organic market. Currently we have 200 acres certified organic. Only 12 acres of organic tobacco this year. Tobacco is still very important to our farming effort and is a cash crop. Without fatty alcohols the amount of suckers would damage the rest of our operation because we usually spend the rest of our hand labor on picking other veggies and then that labor would need to go to tobacco. It would take three times as much money to take care of that tobacco if we did not have this O-TAC material.

Jane Iseley, Iseley Farms

Burlington, NC farmer. Been in family since 1790, and many of those years spent growing tobacco. Also have cattle, strawberries, etc. Farm has been certified organic for 22 years. We have tried other sources of sucker control, such as mineral oil. That failed.

Tobacco plants have 18-20 leaves, and each of those leaves has an opportunity to make suckers, so there are 18-20k suckers in just an acre of tobacco. If you get lots of suckers, the quality of the plant dissipates. There was a concern about suckers on tomatoes—rather than 6,000 plants an acre, tomatoes are grown about 2,000 plants per acre. When you sucker tomatoes, you break off the suckers one time (from the bloom down), so it is much less labor intensive. We are a small farm, about 30 acres of tobacco, and tobacco pays the bills and allows us to do other things. If you take the fatty alcohols away from us, you will put us out of business.

Harriet: What are the other crops you grow in rotation?

A: Fescue, hay, oats (cut for hay). 2-3 years of hay and then back to tobacco.

Alex Watkins, farmer from NC

The use of fatty alcohols is very important to us. We grow tobacco, wheat, soybeans, and now hemp. I have a lot of experience trying alternatives to fatty alcohols, such as different oils. It causes lots of leaf drop-off, and we get paid by the pound of leaves. This material is very crucial to our operations.

Being certified organic means a lot and it all comes from the opportunity to grow tobacco. Tobacco is rotated with grains and this increases yields. Yields are higher as organic than when I was a conventional farmer.

Mike Faucette, Faucette Farms

Long time farming family, growing organic tobacco since 2007. Also grow strawberries, sweet potatoes, and organic grain—but it was all started because of tobacco. I’ve used vegetable oil in the past and had big issues of leaf droppage. We need to keep O-TAC (brand name of a fatty alcohols material) to keep this farming operation alive. Growing around 50 acres of organic tobacco this year and O-TAC is a big part of success with tobacco. Without tobacco we won’t have enough to keep farming.

Emily: Clarification: I don’t know the history with the certifier allowing this material before it was approved by the NOP. This was a material that was used PRIOR to being approved; I’m sure that was done in good faith by farmers but did not understand the certifiers allowing it. It has been determined to be a synthetic material so now it needs to be reviewed before being added to the national list.

A: This chemical is a fatty alcohol which is nothing but a high concentrated soap, is my understanding.

Emily: Jesse is the lead on this material. It’s not a purely natural material.

Steve: It was determined that this is a synthetic.

A: If we get these products and then someone says we can’t use it anymore, it changes our operation and puts stress on a farm.

Mike Hocutt, Hocutt Farm

Skipped/not available

Kelvin Bass, Bass Plant Farm

In Nashville, NC and 3rd generation farmer. 350 acres certified organic, grow tobacco, sweet potatoes, soybeans, etc. Tobacco is one of the first we started with organically and the fatty alcohols are very important in our tobacco production. Alternatives add to labor costs and risk to workers. Tobacco is a part of overall crop rotation and one of the crops we count on for income.

Emily: Can you help me understand the history? Many of the speakers are from NC area and may be going for the same company. What’s the history of using fatty alcohols?

A: It’s been used on conventional side for years, but I am not sure how it originally got approved. I think O-TAC was developed for the organic market and I think it was developed using organic products, possibly coconut oil. I assume it’s now being called a synthetic because of the manufacturing process?

Richard Enoch, farmer at Enoch Farm

I raise around 20 acres of organic tobacco in NC rotated with around 40 acres certified organic  hay and wheat. Oils damage leaves, so when they let us use [fatty alcohols] it was pretty good. When conventional we used O-TAC for 20 or more years. If you do away with it, there will be more labor costs.

[Paul interjects with a sidebar: We recently opened public comment for proposed rule for Origin of livestock. This gives people a chance to make comments if they did not have a chance before. If you’ve already submitted a comment in 2015, you do not need to re-submit unless you have new information.]

Matthew Vann, North Carolina State University, tobacco extension specialist

Discuss a little of the research we conducted over two summer periods and comparisons with fatty alcohols and other organic substances that have been proposed as alternatives. Pelargonic acid, vegetable oil, canola oil, peppermint oil/spearmint oil, and fatty alcohols were tested. The organic acid was the next most effective but there was significant injury (about 75% sucker control). The oils effectiveness was only about 30%. Greatest yield was with fatty alcohols with least injury. All other treatments were significantly lower.

Steve: We had a presentation in Seattle that said they were in the process of creating a natural sucker control agent, but don’t recall what the product was. Do you have knowledge of that?

A: No I do not; the only thing I’ve had references is organic soybean oil. We found soybean oil was high injury and low control. We’ve also heard soybean oil and some surfactants, but I don’t think that’s registered in the U.S.

Emily: What’s the OMRI listed product you mentioned listed for use in tobacco?

Product: AXXE is the product name (Biosafe Systems possibly). Recommendations for their label were evaluated by my research and sucker control was limited and injury high.

Emily: What was the impetus for this study?

A: Started in 2018 specifically to look at alternatives in organics. But we have been doing these studies for several years. But O-TAC has been studied in non-organic trials.

Jeff Preddy, Preddy Farm

Manages 110 acres of organic land in NC with a lot of small fields and poor soil. Our main crop is organic tobacco (also grow sweet potatoes and small grain cover crops for hay). We made the transition to organic tobacco as a way to survive. We need fatty alcohols.

Shep Erhart, Maine Coast Sea Vegetables and Maine Coast Mariculture

I appreciate the NOSB’s concern about sustainability of seaweed harvest worldwide. I’ve been running a small company in the Bar Harbor region for four decades. I’ve been watching harvesters return to the same seaweed beds year after year. Don’t believe there is a sustainability issue for seaweed here in Maine. Engaging harvesters as stewards and not trying to regulate them is the right approach. They don’t want to jeopardize their livelihood. Other companies have been returning to the same beds for almost as long and have developed sustainability practices as well.

Is our amount of harvest having an impact? I’m sure it is. Is it destructive to the environment? I don’t believe it is. Rockweed harvest impact has been studied and detailed rockweed management plan has been developed. 13% harvest per sector was developed and they also set a cutting height.

Emily: What are your thoughts about requiring certification with crop inputs?

A: I don’t think it is necessary.

Emily: Are most or all of your products certified organic? And if so why don’t you think inputs need to be certified?

A: Yes, they are all certified organic. The metrics for sustainability are underdeveloped and unreliable. Going ahead to tie sustainability to organic certification—it’s too early and need more time to define the metrics of sustainability.

Emily: The board is not looking at adapting any sustainability metrics or standards. We are supposed to ensure that all organic materials do not cause environmental harm.

Amber Pool, CCOF

Paper pots—very supportive of paper products on-farm. Important for certifiers to have robust rules and clarification to review products.

Harriet: There are paper pots that have not been asked to be approved in organic and they are mostly 100% synthetic fibers that do not break down easily.  We have been struggling with something that will break down with little to no negative impact

A: That’s why certifiers would need very clear standards to review it–and what we can and can’t approve. But we definitely approve of farmers using less plastic.

Steve: Similar question. Should we allow any synthetic fibers or not? Should we apply an AMSI standard to biodegradation of those products?

A: It’s hard when our regulation notes another regulation because that might change. I wouldn’t want to see paper pots be allowed only if they are 100% not synthetic.

George Ibrahim, Society of Cosmetic Chemist (SCC), American Chemical Society (ACS)

Skipped/not available

Kendra Klein, Friends of the Earth

Comment on excluded methods and soil health. Friends of the Earth applauds the work of the NOSB. Induced mutagenesis that comes from in vitro techniques should be an excluded method. We also support adding embryo transfer to excluded methods list.

For soil health and climate change, there is interest in soil carbon sequestration. Many standard practices in organic cropping support carbon sequestration. Many of the pesticides allowed in conventional undermine soil health, disrupt soil communities and therefore undermine the goal of carbon sequestration. We recommend that the NSOB add an item on identifying and strengthening carbon sequestration, soil health, and climate change issues.

Amber Sciligo, The Organic Center, science program manager

Support subcommittees’ research priorities. We would like to suggest soil health, climate change, and pathogenic prevention be prioritized. Soil health: we are conducting a review of organic compliant methods for optimizing soil health. Needed to compare soil health on organic and conventional farms. We need to understand variation in soil health and the benchmarks used to qualify soil health.

Climate change will have serious consequences, especially to vulnerable food systems. The Organic Center is engaged in climate change research and the practices that cause and prevent climate insecurity. Synthetic nitrogen fertilizer is a huge driver of energy use and sustainability issues.

Pathogen prevention and protection is also an area we need better research in.

Sean Mallett, Harmony Organic Dairy LLC., Twin Falls, Idaho

Past leader in WODPA.

The proposed Origin of Livestock rule would have closed loopholes in 2015. 99% of comments were in favor of the proposed rule, but it wasn’t finalized. Hundreds of millions of dollars have been lost by actual organic dairies. In the last 4 years, the organic dairy market has been slack, so when there was an oversupply, milk process on-farm dropped 30% which is below cost of production. If you can’t raise cows and heifers as organic are you an actual organic dairy? Final rule will help maintain integrity of organic rule.

Enforcement of grazing requirements. This needs to be improved. Satellite tech can be used to monitor actual grazing. Training on how to measure meaningful grazing is needed. Organic law mandates and consumers expect grazing. Consistency of enforcement is also critical.

Animal welfare is a priority. Leave treatment options on list of approved substances. Certifier playing field is uneven here as well.

Harriet: Grazing animals organically, young animals, does that help the operation later?

A: As a young animal goes out to grass, that benefits them and their rumen in the future. Any cow about 6 months of age onward should be out grazing. The added movement and exercise the animals receive is good for them. We’ve seen that on our farm.

Asa: You mentioned there are certifiers that approve one treatment and others will not.

A: I know this has happened, but I don’t have examples in front of me. I know for us our certifier would not allow a product but Midwest certifiers would allow it.

Scott: We have a process for with the NOP when there is disagreement among certifiers on products. We encourage you to raise that issue when it happens with the certifier or the NOP if that does not work.

Jennifer Beretta, Dairywomen, Beretta Dairy, WODPA

Skipped/not available

Carmen Fernholz, OFARM

Skipped/not available

Martin Lydgate Driggs, NOFA/Mass

Skipped/not available

Jennie Landry, DSM Nutritional Products

Omega-3 DHA products. We strongly recommend re-listing of fish oil to National List. Organic fish oil is not available. Fish oil has fatty acids, EPA, and DHA which contribute to human health. Organic consumers recognize the benefit and should have access to value-added products. In public comments there was a concern about contamination, but fish oil is 100% safe. There are several refining steps for fish oil that make it safe.

Harriet: When there is an issue with fish oil and heavy metals or other contaminants, when we rely on another agency or other standard, those things can move around and change from when we first thought they were acceptable, so we don’t want to add a lot of layers of regulation. But we want to be sure we protect the organic label and seal and make sure what we are selling under that seal meets all the criteria. We are struggling with this.

A: Fish oil has to meet safety requirements like other foods. When used in a nutritional ingredient in food, it’s used at lower doses. Since that’s how it’s being used in organic foods, it gives extra assurances that its safe.

Marie Burcham, The Cornucopia Institute Director of Domestic Policy

Read Burcham’s complete comments.

Ashley: Thanks for support for OLPP. Asks questions about methionine (which was discussed in Cornucopia’s written comments). Specifically: The EU does not allow methionine but they allow 5% conventional products in feed. Also, I want elaboration on which farms you see that don’t use any methionine.

A: The products the EU uses to provide methionine in flocks should be investigated as alternatives here. The producers that don’t use methionine are smaller family-scale and use legitimate outdoor time. When these birds forage appropriately, they get all the methionine they need. This material should be removed from the list or given a date where it will expire to inspire alternatives.

Ryan Mensonides, Providence Farms, Mensonides LLC, VP of WODPA, Organic Valley member

Commenting on the origin of livestock issue. I would like this rule implemented as it is written currently, without changes. We worked hard with producers to get this rule how it is.

I am a mid-sized producer. Some groups have allowed the abuse of this rule as it stands and it has a marked effect on the industry. Putting hard working dairy farmers out of work.

It costs us significantly more to raise our heifers organically. Advantage of $800-1k per animal to get them to milking. The lack of enforcement has also led to the oversupply of milk.

We need this rule implemented immediately.

Thursday, October 17

NOSB members present:

Harriet Behar (January 2016 – January 2020) – NOSB Chair
Steve Ela (January 2017 – January 2022) – Vice Chair
Scott Rice (January 2016 – January 2021)
Sue Baird (January 2017 – January 2022)
Jesse Buie (January 2016 – January 2021)
Tom Chapman (January 2015 – January 2020) (joined late)
Lisa de Lima (January 2015 – January 2020)
James R. “Rick” Greenwood (May 2018 – January 2023)
Dan Seitz (January 2016 – January 2021) (joined late)
Ashley Swaffar (January 2015 – January 2020)
Emily Oakley (January 2016 – January 2021)
Asa Bradman (January 2017 – January 2022)
Dave Mortensen (January 2017 – January 2022) (joined late)

Not in attendance:
A-dae Romero-Briones (January 2016 – January 2021)

Paul Lewis makes some opening comments, welcoming participants. Sends thanks to Harriet, Lisa, Tom and Ashley for their tenure.

Harriet makes some opening comments describing the webinar process.

Edward Maltby, NODPA

Some recommendations of the NOSB do get put into force, and we urge the USDA to finalize the 2015 Origin of Livestock rule. It should be implemented immediately after the comment period. Require a one-time transition only, and then have cattle be from the last third of gestation.

The dairy pasture rule enforcement is gaining some traction and I wanted to congratulate the NOSB on their progress. Seems like certifiers are having to be taught what the regulations are all over again. The 2010 rule was a very long and transparent process, and there is no excuse for those certifying to not know how it should be done and recorded. When dairy enforcement falls short, large dairies will not provide meaningful pasture.

Gene editing: it’s absurd that we would think of adding this in any organic regulation. The NOSB has clearly determined this is excluded. Any future efforts to include gene editing will be met with the full force of the organic community opposing it. Gene editing isn’t wanted. Gene editing should remain excluded methods.

Vaccines in organic livestock production: they are an essential tool in the toolbox. We need every opportunity to use that. We support the change proposed by the subcommittee.

Harriet: Can you speak to the economic impact of certified organic dairy operations if the origin of livestock rule is not implemented in a speedy manner?

A: Organic dairy has gone through cuts in pay price, and this has forced many dairies out of business. One of the causes of this is the inconsistent enforcement of the origin of livestock. It has upset the basic nature of supply—without having hope that the rule will be implemented quickly, many more organic dairies will not be able to survive. Also consumers will doubt organic integrity if they find out a large amount of organic milk is coming from cattle that were conventional only the year before.

Ashley: Can you finish your statement on vaccines?

A: The NOP should have a list of which vaccines are produced without excluded methods, and given to all certifiers. This will help producers know where they stand and give more clarity to certifiers.

Steven Etka, National Organic Coalition

NOC asks the NOSB to continue to track and update everyone about organic import fraud. We want the establishment of an inter-agency working group between USDA and imports agencies. Need for more specific tariff codes; plans to update CDP tracking system, to add message prompts to the system; tracking of folks that have surrendered their certificate; tracking of products that are fumigated at the border; and better communication and tracking.

Mention of funding through the farm bill toward the NOP. The appropriations provision requires origin of livestock to be finalized. The 180-day target for this finalization is a moving target however. Regardless, it’s clear Congress intends that the origin of livestock be finalized as soon as possible.

Harriet: Do you think Congress is paying attention to the rulemaking, and how is the support overall?

A: There has been broad bipartisan support on origin of livestock and imports fraud rules in Congress, including in the Farm Bill. Also provisions in the appropriations process in House and Senate; supported by Republicans and Democrats.

Dick Atlee, general public

Skipped/not available

Linda Coleman, general public/consumer

Skipped/not available

Lisa Germo, general public

Thank you NOSB for having this webinar. I am a mother and consumer of organics. I oppose genetic engineering being added to the organic seal. We already have excluded methods, and that should include all new and old technologies. As a consumer I choose my food wisely. To throw GE under the organic label, consumers will likely choose not to buy any organics. GE being added to organics will be met with force; the trust of the consumer will be lost for the organic seal. The organic seal may be lost overall; it undermines the American people who choose to eat clean organic food.

I would love to be a supporter of the organic seal. Thank you.

Robert Morse, Atlantic Laboratories, Inc -dba- North American Kelp, Kelp cultivation, processing [Robert has an attached video.]

President and founder of this company. The video shows a bay that he has been harvesting for seaweed for 48 years.

Emily: I know North America kelp has kelp certified for livestock use. Are you aware that we are asking for certified organic requirements for crop use?

A: We are against the rules requiring being certified organic. The rules were done for Iceland, not a place with higher population. If all our fertilizer is put under that requirement, I’m not sure what it would do to our company. The sea is one big body of water; you can’t draw a line on one side and say another line is conventional. Our harvest is cultivation of the tips of the seaweed, and that grows back.

Emily: If half of your harvest is certified for livestock, what is the barrier for getting the rest of your harvest as organic?

A: It will be too costly to certify organic for crop inputs because the rules keep getting more and more restrictive. Carrying nets according to the organic regulation is very costly. We would like to stay in the program; I am not sure the market can afford. There are also a lot of imports coming in.

We are regulated here by our state of Maine Resources.

Emily: To clarify, we are not looking at this because of any individual testimony. It came up during the sunset review with various seaweeds. We received tremendous testimony along the spectrum of these products. There isn’t any single individual that is propelling this discussion.

Steve: We received a lot of testimony about the sustainability of the Maine system. There are a number of products coming from non-regulated fisheries and the organic program does use those non-regulated products. How could the NOSB protect the environment in those non-regulated areas?

A: I wouldn’t say they are non-regulated. I’ve spent lots of time putting in complaints into the NOP, with nothing being done.

Harriet: I sit in the environmentalist seat on the board. I should be able to get some feedback from the environmental panel in the in-person meeting. I am concerned about habitat for smaller feed-animals and the kelp itself, and the health of the fishery where there is significant kelp harvest in an area. Are there studies of this that I could look to?

A: On the coast of Maine, we have 70,000 acres of rockweed habitat. There is a turnover rate each year as the plant matures, storms pull kelp off the rock when there is a storm or ice. The amount we harvest compared to what naturally comes off. We also have the highest cutting height in the world (16 inches). It’s not a complete harvest, it’s a spot-harvest with plenty of the rockweed left behind. Found that we had more periwinkles where we harvest than not, because sunlight is able to filter down due to our harvest.

William Selkirk, Sterling Agriculture, Inc, Research Dept. VP

About a year ago we learned about synthetic fatty alcohols and we started researching organic methods with the same efficacy. During the case studies we found that we could do so, even with less cost. I am asking the committee to consider not allowing synthetic fatty acids to be used.

Every one of our ingredients on our formula is on the List. It’s made with organic product. Our ingredient list is already approved, using medium-chain triglycerides that are effective in sucker control. I ask the NOSB to allow the use of soap in sucker control (expanding the use of already-listed soaps), and this would allow the use of other effective products.

Steve: Can you list the ingredients again? We had a speaker that did efficacy trials in an extension, and from his trials, rosemary oil was not effective in suckering.

A: He is correct. We derived our soap from the inert side, and that’s where the triglycerides come from. The rosemary oil is in the product as a preservative. That in and of itself does not help reduce tobacco suckers.

Steve: Your process is a non-synthetic process to get to those triglycerides?

A: That is correct, we have a provisional patent. We use no synthetic approaches to this. The acid is derived from apples.

Jesse: Have comparative studies and fatty alcohols been published yet?

A: No, they have not been published yet, but our research will be published soon.

Steve: You said you received initial approval for this? Getting things on the market always takes more time than we think. What growing season would this would be available for?

A: 2020 market, March 1. Because this is a pesticide, even though the EPA sys we are waived because of the ingredients, we are asking the NOSB to consider putting this product (the soap) in the approved soap.

Harriet: We would need a petition for a new soap or another approved use. We want to learn more about the field trials you conducted. Can you send the ingredient list to Michele?

Jo Ann Baumgartner, Wild Farm Alliance

Biodiversity conservation issues are important. We recently had two biodiversity conservation trainings for certifiers that were successful.

Protecting native ecosystems: We want to underscore how critical it is for the NOP to adopt the NOSB recommendation to protect native ecosystems. This rulemaking will protect rainforest from being burned one day and planted in organic crops the next day. We are working with partners to develop guidance on this issue and will keep the NOSB updated.

We don’t support gene editing in organics.

We ask the NOSB to recommend a rule change requiring that all marine algae must be harvested according to wild harvest requirements. The NOP should also work on publishing marine materials guidance.

Emily: First a question for the NOP: is there any update on the rulemaking for native ecosystem protection?

Paul from the NOP: We are aware of these recommendations but don’t have any further response at this time.

Emily: There has been some concern about requiring organic certification for seaweed use in organic production. Could guidance be developed for this topic in a similar way it is for the native ecosystem proposal?

A: Yes, it would certainly help if we went in that direction. With birds declining at such a rapid rate, marine algae harvests are part of that problem. The NOP is complicit in that—so that is a problem for integrity of the label.

Steven Sprinkel, President, Ecological Farming Association; Certified Organic Farmer

Skipped/not available

Angela Schriver, Schriver Organics, Schriver Farms

Crop farm, split operation organic/conventional. We chose to transition to organic because there is a higher premium for grain. In the years we have been organic, it has changed us as consumers, farmers, etc. The organic standards need to be upheld; it’s a lifestyle change. When you make exceptions such as origin of livestock or GE content, it hurts the bottom line, consumers, etc.

It is okay if you can’t raise birds during the winter or have to pinch off tobacco. I want you to consider: they have affinity to what is familiar and don’t like change. If you can’t do something and still be organic, exceptions should not be made. You do not have to compromise the integrity of the label to ensure that is possible.

I expect a rule on the imports fraud on organic grain. This is a personal issue to us as grain farmers.

Danielle Quist, International Dairy Foods Association

The review of dairy cultures—the subcommittee would like to combine dairy cultures with microorganisms. These cultures are critically necessary for any kind of cultured dairy products: cultured butter, yogurt, cheese, etc. Our organic members oppose any combing cultures with microorganisms on the National List. They support keeping the listings separate.

Cultures are not a subset of microorganisms, they have a very specific functional use of other microorganisms. So we don’t feel there is redundancy there requiring this move. Combining them under the larger umbrella would be a problem. Our dairy members believe that customers know the term “dairy cultures” on products, and listing it as “microorganisms” would confuse consumers.

Steve: You could still say “dairy cultures” on a label, and yes, all microorganisms have different functions. If they were combined, what would be the negative?

A: If they are still allowed to put the word “cultures” on the label, consumers may assume it’s not organic and would have to find that under the microorganism umbrella. Dairy producers are worried it would appear they were not being transparent.

Tom: You can currently use the strains of dairy cultures on the labels. What wouldn’t be available today if we removed dairy cultures?

A: Feeling that it is a separate and unique organism; and here is a process issue. Concern that consumers would think that “cultures” was removed for some reason that would make consumers worried. Individual brands will be presenting about this in the in-person meeting.

Caleb Goossen, Crop Specialist at Maine Organic Farmers & Gardeners Association

Thank you for the crop subcommittee discussion on paper pots and paper. Paper pots should be allowed in organic production. While prior prohibition of virgin paper products was well thought of previously, that should change now. Though paper mulch lies elsewhere, virgin paper fiber should be considered. A 100% bio-based paper mulch film is in later production. But it would have similar production benefits to plastic mulch films.

Requiring sea vegetables to be certified organic rather than just having an annotation on them seems burdensome.

Emily: We have looked at organic certification for sea vegetables because it’s a tool we have available. We’ve looked for annotations as a possibility. We don’t know how that would be verified or enforced. It would have to be an affidavit situation.

A: I would defer to the NOSB and others on how to verify. My concern is more what else would be opened up with that listing; there are other inputs currently being used that possibly have greater impact to the environment and possibly we don’t want to open up that can of worms.

Harriet: We’ve learned that paper is not just cellulose based; there are multiple types of synthetic fibers. We are struggling on the type and number of synthetic fibers.

A: Hopefully the synthetics can be replaced with paper fibers.

Christy Kerbs, Stakeholder

Skipped/not available

Sam Welsch, OneCert, Inc.

Paper pots: paper is not just cellulose, and there are 100% synthetic papers on the market. We are seeing research now on micro-plastics on microorganisms. I would ask you only allow natural polymers and fibers in pots, and prohibit synthetic pots.

Ion exchange is a chemical process used for many things. When creating or refining products, it is a chemical process. A substance is often dissolved, remaining substance is removed, etc. Result is the remaining substance is not the same! Concerned about this as agricultural products are not being defined as organic, creating logical inconsistency. How can something required to be put on the National List to be included in a product also be certified organic? The FDA’s definition of “natural” does not match NOP definition of natural. Many things are so refined and extracted, the identity of the original product is unrecognizable. Flavor extracts are not agricultural.

Q: Paper pots cannot be made without some synthetic fibers currently. So we are wrestling with this. If they are synthetic in some small part, how would you approach that?

A: Even biodegradable plastics end up breaking down into microplastics; it does not bio-degrade on the molecular level. Still has effects on microorganisms. Annotation that synthetic fibers cannot be used unless not commercially available. I suspect someone innovative will be able to use hemp to replace synthetic products.

Tom: I didn’t understand your last point about flavors and other products that are non-agricultural.

A: I’m suggesting that when you start certifying non-agricultural products, you create a situation where the USDA is for agricultural products so there is no enforcement that can take place (when complaints are set up). Plenty of examples in cosmetics and soap. When you start certifying non-organic substances, you are creating complications. You are certifying molecules that don’t sound very organic. It’s very damaging to the organic brand; implies certain affinity to natural substances. Its opening the door to things that we don’t really want certified organic.

Emily: Paper pots issue: the crop subcommittee has spent tremendous amount of time discussing this topic. We don’t want a lot of synthetic fibers in this product. We are struggling with creating a listing that is more stringent than the current listings for papers.

A: Don’t use the other paper listing as a guide; use the law as it is to guide paper pot listing. If it is inconsistent with the other paper listing then maybe that one needs to be revisited as well. If you create a strict standard, people are innovative and will find solutions.

Harold Austin, Chair of the NHC’s Organic Subcommittee and Science Advisory Committees, organic consumer, former member and chair of NOSB

The Pacific Northwest farms 90% of all organic apples grown in the U.S., along with pears and cherries. I have provided comments on specific materials needed for this fruit growing; many of them are also useful in grapes and wine growing.

There is a need for these materials—that’s why these materials were added to the list in the first place.

Support NOSB changes to PPM. I support continued listing of DL-Methionine. On sanitizing materials: it’s important we maintain as many as possible. Pathogen control is a serious concern because the options we have are so few. The current system of sunset review is adequate for these materials.

Dave: Clarification on a point that has come up: sanitizers and resistance management. Can you give us an example of what organisms are arising as a threat?

A: Looking at crops perspective and handling side of the business, we are dealing with various pathogens (listeria, E.coli, powdery mildew, fireblight, etc.). We see resistance building up to a lot of the pesticides we use. Because we have so few tools in our use, we want to make sure we have the ability to rotate these materials so that resistance does not build up. Also these tools are used at different points of contact where pathogen control is of concern, so having different compounds is important to make sure we don’t have resistance management scenario.

Jane DeMarchi, American Sea Trade Association

We oppose a de-facto requirement for testing of seed. These issues are best resolved in the marketplace. Information sharing around testing is best solved in the market. Testing is not regularly done in some crops where there is low adoption of GE tech, such as squash and potatoes. We support the idea of forming a task force surrounding these issues.

Excluded methods determinations—we are worried some of the proposed methods are vital in current plant breeding. Concerned about intention to potentially include double haploid method as an excluded tech. Concerned about the induced mutagenesis process because these are indistinguishable from things that would happen in traditional plant breeding.

Harriet: We’ve heard from the farmer community: they want this transparency in the possible presence of genetic engineering in seeds because that transparency helps them make good choices for their businesses.

Dave: The reason that people are not asking for more information is that they are assuming there are no contamination issues with the seed that they are buying. This would just be providing more information in the way many larger seed companies would have this information available. It seems manageable to me.

A: There are some companies that are pro-actively marketing the levels they are selling.

Colehour Bondera, Kanalani Ohana Farm, former NOSB member

Concept of sunset: it means that things go away. Even though habits are hard to break. Non-organic celery should be removed from our list even though it’s been allowed for a decade. Organic and conventional are not the same.

Re-listing of synthetic methionine. If sunset no longer exists, then we need to put a date on methionine for going away.

The concept of GE being allowed in organics: I think the NOP needs to prioritize what advisors have said regarding this topic. GE papaya was allowed on the island, and it contaminated the wild papaya. You can’t get rid of it once it’s there.

We need to recognize farmers are not into compromising and getting rid of things. But we need to stay strong and not just make everything organic. All of you should recognize this foundation and stand firm with it together.

Steve: How do you deal with ringspot in papaya?

A: Organic papaya is easy: don’t monocrop, don’t only grow one variety. It is only monoculture that leads to pests you can’t eradicate. What we need in organic is not to replicate the path conventional has gone down.

Asa: Comments on celery powder, all of us have concerns about this. We voted not to remove it—can we develop an organic source? How do you feel about using organic celery? And also, what about the health impacts of nitrites from any source?

A: My understanding is organically grown celery does not have high enough levels of nitrate to cure meat. But we should stop doing things like the conventional industry. We should be using a different psychology. Maybe we shouldn’t have these things in organic!

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