DAY 1: October 17, 2023

Michele Arsenault take a roll call of National Organic Standards Board: all members are present except for Javier Zamora.

For more information about the NOSB members, check out the NOSB’s biographies.

NOSB Chair, Nate Powell-Palm, runs the webinar comment session.

Alan Lewis – Natural Grocers (General)

Part of many ag organizations. Invocation for the planet, workers, all living things on earth, maintain our sacred obligation to respect the rights of others. Alan has customers, don’t need the organic seal. When organic is not a leader for social justice, helping poor people, and environment, we are irrelevant. Internationally, we are not doing what we should for climate change and loss of soil quality and social justice. We need to get back to soil based organic, we need to more away from input-based agriculture and protect organic from falling into that only. Thanks to all of the NOP and NOSB.

Mindee: Do you think people recognize us as policy leaders and unique in America’s regulatory world?

Alan: No, we are driven by corporate interests. We will hear calls for gene editing and other things that really benefit corporate ag. If that is something that is good for big ag, then yes, we are leaders. If you are someone who does not benefit from those things, then no. In the small places that we have an impact – maintaining the National List – then perhaps. For everything else that is out of scope, then absolutely not.

Nate: Googling around, saw someone say that Natural Grocers has a regenerative egg now. Elated it said certified organic regenerative. That’s action right there.

Alan: We have built our entire business on the organic seal, which is why, when it’s threatened, we feel it so severely. Everything we do we try to start with the seal. That’s why we have a team that goes out with boots on the ground every year and checks out what all of these new certifications really are.

Nate: Can you follow up on the social groups that you feel we need to be working with to move the needle in the direction that we are working towards, I would appreciate it. And thank you for that invocation; a lovely way to start the day.

Mark Kastel – OrganicEye (General)

Executive Dir. of Organic Eye. What are we doing in this basket and where are we going? We built this movement which has morphed into an industry, environmental stewardship, economic justice for famers. It’s time for NOSB to take back regulatory reins from betrayal. Seeing large scale fraud, livestock factories squeezing out family farmers, losing family famers, loss of confidence, competing labels. These are bad signs for bad times for the true working definition of organics. You will hear from an Organic Eye farmer and a lawsuit recently filed regarding organic fraud. Our farmers can’t compete against international fraud. Not just about bananas and chocolate. Factory farms in the desert. We have hogs, chickens: none of them are outdoors. The current law requires natural behaviors. It’s a joke. Carcinogens in food are undercutting consumer confidence. Material review organizations with no oversight; a lot of funding comes from corporate entities they serve. Take back the ability to control your own agenda and work plan.

Logan: Question about imports: a lot of them come across the border, so in the SEO we compete with that. When you say that they can undercut the farmer – we see that a lot in labor cost, because labor costs are so cheap in other countries – and organic can be a labor-intensive practice. Do you think it is tailored to the labor side, or toward the products? What area are you trying to imply in that?

Marni: Engaging with producers, USDA, and frame in context of hearing what folks say. One of things hearing that are barriers for existing and transitioning is around duplicative paperwork requirements and if could just write down once, it would make it easier. Another piece is around how tough it can be for producers to navigate living in different places – phone numbers, people to talk to, etc. — we can think about centralized resource hub where folks can find things; wants to hear more from those on the ground.

Mark: I would say the answer to that is yes, in both regards and more. We have commodity crops like soybeans. We are the largest producer in the world for many of these crops. There is no reason that we cannot compete, except the system is stacked against us. Labor is a factor. Monetary exchange and fraud is a factor. Bruce will be talking about group certification, which started out as a good idea, but has morphed into a different system, so now we have corporate ag supervising their own suppliers. We have uninspected products coming into the country – some of which we can produce here, but some of which we cannot, so we have to rely on the organic process.

Amy: Thanks for extending invites to farmers to participate in this process. Similar to Logan’s questions: your written comment in response to residue testing. In the past you had a petition for rulemaking in this topic, can you send this our way? We have this as a discussion document so it would be helpful.

Mark: I’d be happy to. Some of these legal petitions – this is the lack of control that you folks have over your work agenda. One shipment, bulk freighter, from off-shore, equals the annual production of 40-50 US grain farms. The cost to test every shipment is inconsequential to what it’s worth. If you compare the cost of certifying 40-50 US farms versus the testing of the shipments, we could be nipping this in the bud. Also, the cost of inspecting farmers in good standing every year, but taking a look at that and possibly auditing these people every five years, and then taking the savings that we have from not doing this busy work every year and really ramping up the random testing, unannounced inspections, because right now, most inspections whether you have 20,000 cows or are mom-and-pop, these inspections are scheduled. Everyone knows when they are going to happen. Creative paperwork is all too easy to deceive people with lower levels of experience.

Kim: Thank you. You mentioned organic work production. Can you give us what you think would help to promote the organic work industry in the US?

Mark: The integrity of the label – pork and poultry, broilers and layers –

Kim: Let’s just look at pork from a growth perspective – what would be your thoughts on that?

Mark: Besides sausage, I do not see a lot of pork out there. There is an old axiom in marketing – Be Better – we have applied the industrial model to livestock production. If you look at someone who is truly raising pastured pork, it is great. They could say “pastured pork,” but if it’s not certified organic, it really isn’t. Depending on the breeds and production model, there is a tremendous difference in the taste of that product. If we cannot distinguish the taste of the products, no matter who it comes from, and we charge more for it, then we really are back to that input dynamic that Alan was talking about where “organic” is what we avoid instead of producing a better product that you can really taste, and pork is one of those products.

Elizabeth Bell – CROPP Cooperative (CACS; Crops (CS); Handling (HS); Livestock (LS))
Organic Valley. Thank you to NOSB. Previously worked in Organic Cert., and now work to consult with OV farmers and the certifiers they work with. CROPP likes the location identification, but we have concerns. Who will be responsible for geo-location, and how data is stored? It could have severe issues with the plain clothes community. Farmers do not want to share this information publicly. We support the use of geo-location or certifiers as a voluntary process, but not mandatory. We hope the NOP will establish best practices if this moves forward. We hope the organic transition will be supported, especially from a consumer demand aspect. Farmers need guidance driven by market demand. Demand-side growth develops opportunities. We encourage USDA to focus on market demand and consumer education. Transition is difficult and buying organic feed without getting the price premium dissuades people from transitioning. OV provides transition incentive to dairies in their 3rd year of transition (12-month funding).

Amy: Thanks for your time. Question about your written comments about residue testing in a global supply chain. Comment that your organization would have concerns if there was an increase in testing across the global supply chain. We’ve heard that people are pushing for increased testing of imports. Wanted to understand your comments better.

Elizabeth: Thank you. Mike Crotser will be talking more about this, so I will save this for him.

Amy: Thank you.

Allison: Thanks so much. You mentioned operating from a consumer-demand perspective. Can you talk about products that aren’t being addressed through the organic transition initiative? I would also like to hear about the 12-month funding that you provide and wonder if that could be something the NOP could do.

Elizabeth: We can follow-up on demand after sitting down with our marketing group. We are part of the puzzle, and we have a perspective, but other industry members have great perspective, as well. I envision a roundtable of those in industry talking about this and getting the ball rolling on those discussions. We would like to see this and have a seat at the table. As far as a 12-month incentive on a larger scale, we can certainly provide information on how we do it and offer insights on whether that is something that might be developed.

Nate: If I heard you right, you like the geo-location doc, but want to ensure the caveats are held.

Elizabeth: Yes, want to make sure that the NOP can provide some Best Practices guidance on that.

Nate: How hard of a burden was it as an inspector locking in these CMZ files?

Elizabeth: I was challenging, but I would say that the benefit outweighed the cumbersome aspect. Nate is referring to when I was drawing up Google Earth KMZ files. That was something we did to capture exact boundaries every year. Great confidential information to be had as part of the OSP.

Nate: You mentioned the organic marketing grant – how much support have you gotten for this work and for the celebration of value-added on farms.

Elizabeth: I will make a note for us to follow up with you on this, Nate.

John Foster – Wolf & Associates (General)
Consulting firm that specializes in everything organic. National List should be accommodating to as many producers as possible, including internationally. Concern about commercial availability, wants it to be applied more broadly, yeast, collagen gel. CA can drive innovation, what about ethyl acetate and benzaldehyde, naturally occurring in flavors and now available as organic, illustrates how commercial availability can drive innovation and growth in organic products. Citric, lactic acids, Malic acid, enzymes, ascorbic acid calcium citrate, carbon dioxide, tocopherols

Amy: Thanks for the inclusion of the list that you had in the written comments. I see in your written comments that you have a goal to generate a petition for the NOSB on this topic – do you have an idea on a timeline for this?

John: I consider low-hanging fruit be citric acid. I would rather see a blanket commercial availability over the whole of 605, but assuming that it’s not in the cards, I do not know how you would create something that would cover every item on 605, so I think you’d have to do it individually. The rub on citric acid is that it has to be ordered to be produced. This is something that could be in your hands to do by the Spring meeting, but definitely by Fall in Portland. Whether it’s citric acid or something else, I think there are a number of opportunities, that was just one example. Would you like to see that in the fall?

Amy: Anything that could help drive innovation and expand our markets, I think we are in favor of that.

Nate Lewis: Citric acid happens to be my sunset for next year. Duly noted for potential annotation there. It sort of makes sense to me why commercial availability is not on 605, since these are non-ag products, and these are anomalies that meet the processing requirements of organic. Absent a 605 blanket commercial availability clause, what kind of structure can we put into place so that at sunset a specific annotation could be put into place? I am trying to think about building in some mechanism on the sunset review to get this under control.

John: There we – back on my term in NOSB – it was the time when annotations were being added. Meetings went much longer, times were different. The takeaway – biodegradable mulch lit the time – I don’t think it makes sense to build annotations into the Sunset Review process due to the train wreck in 2012 or 2014. But if it was a straightforward petition, especially when it wouldn’t include an updated TR, because then it would make it easier.

Logan: I have flavors, and it’s good to hear that there are some that are increasing. The two that you talked about – you said that organic production has increased – do you know where they come from?

John: I am not privy to the source materials, but I know that they were certified about four weeks ago and immediately funneled to the OID, and within 3 days of posting on the OID, they had inquiries from much larger houses asking if they were sure that they had organic – it took 72 hours for others to recognize this and that now that it is available, they have to use it. The manufacturer was taken by surprise that global flavor houses monitor the OID so quickly. That says a lot of positive things about the role of OID in the marketplace and the power of it, and I think we ought to harness the heck out of it.

Michael Crotser – CROPP Coopertive/Organic Valley (Handling (HS))
Certification Director. Appreciate NOSB and NOP’s work. Harvest season is here. Gratitude to all organic community and especially farmers. Residue testing: expanding testing will be a small shift toward metric driven process. In general, we support residue testing. Targeting fumigants makes sense. The threshold for hexane and how it relates to testing must be thought out. Have to differentiate between incidental contamination and actual adulteration. Since a finalization of residue testing law actually reduced fraud. Would a TR about the benefits of residue testing assist? Would association with pesticide chemicals and trade name assist? We do support expanded testing for residues, our point is to convey to complexity of residue testing.

Amy: Thanks for the written comments and letting us know about concerns about the written materials we have provided. You stated that in general you would have concerns if this testing would increase global supply chain testing as a whole, especially in imports. It seems that your organization had concerns that were different from others – which were largely in support of more testing.

Mike: My concerns were mostly addressed today, but specifically for inputs. Sourcing ingredients can be a challenge. A good example that is not related to residue testing is organic sunflower lecithin. We have used that to ?? whey protein concentrate. And then the war in Ukraine broke out, where we get most of the sunflower lecithin. I do not want to imply that we are opposed to testing, but it could affect some of the availability of ingredients that we are looking for.

Nate Lewis: Want to acknowledge that I share your view that organic is a process-based standard. I’m looking at testing an effective verification and validate tool. If you see the proposal getting more toward a metric and outcome-based standard, let us know.

Mike: That’s why I kind of backed up… There are challenges when you get a positive test and what you do. It’s more so, before we bite off another chunk of residue testing, we should look at where we currently are with residue testing.

Bruce Kaser – Pratum Farm, LLC ‐ certified organic hazelnut farm (General)
Old lawyer who turned into an organic hazelnut farmer. The public perception is that organic farmers get higher prices for food that hasn’t been sprayed with chemicals. Shelling processors pass on their own organic premium for their work to get crops to market in the supply chain. He is surprised that imported Turkish organic hazelnuts are coming into the shellers at the same price as nonorganic. There was a direct link to grower group certification. Are these farmers not getting a premium.? Foreign interests have used grower groups to avoid the cost and trouble of organic farm inspections.

Nate Lewis: Hazelnuts or filberts? Serious question: residue testing and global supply chain. Are their compounds that could root out fraudulent imports. Glyphosate may be applied on the ground, then if you harvest from the ground? Curious what residue testing would be a practical deterrent?

Bruce: Old school people still call them filberts. The industry decided to rebrand them to hazelnuts, so we decided to go along with them. Residue Testing: I have absolutely no idea.

Allison: I tend to think of grower groups to help smaller producers stay in the organic world. I am curious if you think there is a role for grower groups generally and there is a more narrow way to get at the concerns you are raising, or if you think GGs certifications have to go completely?

Bruce: I think that there may be a narrow window for the concept of GG certification, if it is done the right way, but I think that the general concept of GG certification is 40-50 years out of date and it has morphed into something different than its original intent was. I do not think that the ideals of GG certification are being implemented by and large. In Turkey, you cannot get on the USDA OID and locate a single organic Turkish farmer, and that ought to tell you something.

Jerry: I spent 6 years in Turkey, and any concern that you might have about the false flagging of products is demonstrated to be legitimate. My one question – in terms of your lawsuit – is it the lack of a price premium on an organic product that is an underlying piece of that lawsuit?

Bruce: No, that was the thing that got my attention. I heard this. How could that possibly be happening? You folks wouldn’t understand what “shell out” means in the nut industry, but anyone that heard here in OR that processors are charging a 3% premium…….that was just the starting point, but the issue of the lawsuit is to follow the statute – we have a statute that says all farmers must be inspected every year.

Franklin: Given importance of group certification, how do you see it is being done right?

Bruce: It’s not going to work unless it’s cut down to a smaller number of farmers, can’t have grower groups of 1000 members. The original idea is a small group of growers where all their pots are next door to each other. Organic certification is looking at what’s going on the farm. When they are next to each other, it makes sense to certify them together and create fewer costs for the farmers. We can’t have thousands of growers in different towns.

Kyla: Did I hear you correctly – did you say in the OID that when you look up Turkey as a country, there are no certified operations, or were you speaking only about hazelnuts?

Bruce: The USDA has a database, OID, that enables the public to look up certified operations. You will not be able to use that database to find a Turkish organic hazelnut farm – they are all processors. You should look. It is quite fascinating when you look at the number of handlers that are certified versus what are solely crops operations – lots of handlers, not many farmers. That leapt out at me when I started looking at the database.

Kyla: For a long time certifiers were operating off an instruction in the handbook about GGs, and now these have been codified in the SOE final rule. Do you think that will help in certifying these types of groups in a more unified way?

Bruce: Absolutely not. I would ask that you read the complaint when it goes out. It outlines the history and the process. I do not think the new rule is going to make a difference.

Terry Shistar – Beyond Pesticides Crops (CS); Materials (MS); (General)
[NOTE: These comments correspond with PP slides. Their comments were provided to us in full.]
My name is Terry Shistar, and I’m on the board of directors of Beyond Pesticides. We have submitted comments on all the issues before the board. My comments today will address so-called “inert” ingredients. More details are in our written comments and in our 2017 report “Inert” Ingredients in Organic Production. :18

NOP has repeatedly tried to divert our attention from the crucial issue—one that has threatened the integrity of organic products for more than 20 years and continues to do so. The question that must be addressed is not whether these potentially toxic inputs should be individually evaluated, but how to do it. :21

To dispense with the false issue first, the evaluation of individual so-called “inert” synthetic ingredients in products used in organic production is not optional. It is required by law. NOP must allocate resources for this project. In addition… :18

Because of the NOSB’s intensive review of active ingredients and the lack of oversight over other ingredients, the so-called “inert” ingredients pose greater risks than the active ingredients. :16

“Inert” ingredients make up the largest part of most pesticide products. Here are some examples. :09

And “inert” ingredients are not generally listed on pesticide labels, so NOP and the NOSB have been allowing unknown toxic mixtures to be applied to organic crops and livestock. :15

On to the real issue… :04

We estimate that there are 137 synthetic “inerts” currently used in organic production that must be evaluated. NOP must immediately publish the known list with a request that registrants of products approved for use in organic production notify NOP of the “inert” ingredients contained in their products. :22

We propose that the NOSB first insist on the publication of that list. The NOSB has undisputed authority over allowed synthetics in organic production and should not shy away from taking a strong position. :18

Second, we have proposed substitute language for these substances on the National List. Here we list categories of substances as previously determined by the “Inerts” Working Group, but more details are in our written comments. The exact assignment of “inert” ingredients to the review groups can, of course, be adjusted to meet the convenience of the NOSB and contracted reviewers. This substitute listing should be approved at the Spring 2024 meeting. :28

The time to act is now. Thank you. :04

Allison: I think we all agree that we need to tackle this issue, and having specific suggestions will be helpful. One thing that stood out to me is that you were able to come up with #s. Can you talk more about how you came up with your list?

Terry: If you go back to that slide, it starts with the list of inert ingredients that are being used in products that are recognized by OMRI, WSDA, and PCO. Then we looked at the materials on that list that are on EPA’s 25b list that are used in pesticides that do not need to be registered, so we subtracted those. Then we subtracted off the natural ones, because they do not have to be evaluated. Then we came up with 137 – might be a little more or a little less, but nowhere near the 1000s that NOP was estimating.

Nate Lewis: Appreciate sharing your opinion about inerts being listed individually. Does that extend to other lists we have? Why are inerts unique in that they want all of those listed, but not excipients in livestock drugs?

Terry: If you look at the slide that addresses the toxicity of inerts versus the toxicity of the active ingredients – this is coming from a group that is focused on pesticides, so that’s why we are focused on it – and I think that this is a high priority because of the fact that we have so many toxic substances that are being used as pesticides. Maybe after we take care of the inerts, we will focus on the excipients, but it’s a priority for us.

Nate Lewis: Just want to see if there are inherent distinctions we need to make and whether it needs to be treated differently.

Terry: I think that the biggest problem is the secrecy, and I imagine that is the same with excipients, but I haven’t looked at them that closely yet.

Dilip: Subcommittee is brainstorming on inerts. I have a clarification or question about the toxicity you mentioned. Can you elaborate.

Terry: In our report that we produced in 2017, we used a number of sources to identify the characteristics, whether it is toxic, carcinogenic, or whatever, of those chemicals. That summary slide that I presented was a summary of ones we could identify the sources. You will find more information about where we went in that 2017 report. If you have any further questions, let me know and I will try to dig it up.

Sydni Arnone – The International Food Additives Council (Handling (HS))- Global association
Manager of gov’t relations. Represents manufactures of ingredients. Re-list non-synthetic substances and natural substances including alginates, gums, etc. These ingredients are safe and align with organic principles. Our written comments address the particulars, but also would like to address potassium chloride. It’s important to reduce sodium content in food. Addressing questions about Mono – diglycerides: these products are commonly used: 4.4% of organic products include mono or di-glycerides. They are used in organic food production including drum drying of food. We are not aware of any alternatives.

Ellie Hudson – Accredited Certifiers Association (CACS)
[This presenters comments were provided to us in full.]
Hello NOSB members, NOP, and members of the organic community. I’m Ellie Hudson, Executive Director of the Accredited Certifiers Association or ACA.

ACA is a non-profit that exists to benefit the accredited organic certifier community and the organic industry. Broadly, we look to develop certifier resources that can alleviate the pressure often germane to a regulatory environment, and we proactively seek ways to add, improve, and innovate the value of ACA membership. We envision an environment where barriers and implicit bias have been eliminated, and where everyone has the resources they need to live up to their full potential in all aspects of our work.

ACA has developed new certifier resources toward consistent implementation of the Strengthening Organic Enforcement final rule, or S-O-E. In pursuit of consistency, various collaborations and educational programs are available. Creating an environment of consistency among certifiers can generate a ripple effect that benefits everyone. These activities are provided free of charge to the certification community as part of a cooperative agreement between NOP and ACA.

Also funded through our Cooperative Agreement, we are partnering with the International Organic Inspectors Association or IOIA, around mentorship of aspiring organic inspectors. The data gathered in our 2023 mentor cohort will be analyzed and used to develop resources aimed at making mentoring more efficient, accessible, and enticing.

ACA is also a partner in a project led by Organic Farmers Association in pursuit of racial equity and justice in organic. This project aims to provide continuing diversity education and concrete tools for organic professionals through a cohort learning model, focusing on questions and challenges that are organizational in nature. Certifiers in the inaugural cohort have reported deep opportunities for growth and change in a supportive and constructive environment. Applications for the second Racial Equity Cohort for certifiers will open on November first.

The ACA Board also identified a strategic need to better understand our Supportive Membership category, available for those who are not accredited certifiers, but have an interest in supporting ACA’s mission. As a result of a steering committee’s survey of existing members, and soon prospective members, we are beginning to understand what you want from ACA and how we can deliver more value.

I must also mention that 2024 will mark ACA’s 20th anniversary. I am truly amazed and humbled that many of the founding certifiers who created ACA are still active in our community and many of you are here today. We have some special things planned to recognize and thank you throughout the year. I feel like I am standing on the shoulders of giants with this opportunity to offer these comments. Thank you for your work in getting us to this point, and thank you, NOSB.

Amy: Congrats on the anniversary of ACA. You highlighted some of the collaboration efforts. Through other written comments in regards to the Discussion Document on residue collecting. There were comments from inspectors that noted they were interested in helping to edit the materials that are currently out there. Is that something ACA would be interested in?

Ellie: We are trying to include staff inspectors, but other types as well. We are excited to find new ones and we are excited to take this up.

Nate Lewis: I noticed a comment from one of your members – OEFFA – talking about the cost of residue testing that must be borne by the certifier – have you approached NOP about a way to help cost share that testing financial burden and whether there are funds for SOE implementation that could go toward that?

Ellie: We haven’t had that conversation yet, but we can. There are some funds that are reserved for SOE support generally, and that’s a conversation that we can have. We meet with them monthly.

Nate Lewis: Let us know if a recommendation from the Board could help with that.

Nate Powell-Palm: What can you tell us about the party?

Ellie: You are invited to join ACA and a network of co-host organizations invite you to join us for a happy hour reception. You can e-mail if you want to register to attend.

Mark Lipson – Molino Creek Farm; Heartland Health Research Alliance (CACS; Materials (MS))
Member of Molino creek farming collective and consulting practice, doing work with CCOF, HHRA, and Wolfpack associates. Also working at UC Santa Cruz where starting an agroecology program. Commenting on inerts, climate smart verification, and status of organic policy advisor position. All inerts have to be declared and cannot remind hidden behind proprietary information, and have to be reviewed by the Board. Point you to comments of Dr. Charles Benbrook, Shistar’s comments, etc. Just a week ago EPA denied a petition from CFS asking for a review of all inerts. Made it clear they do not intend to hold up their end of regulating inerts. The NOP and USDA cannot be held up by the USDA’s failure to address the issue. Residue testing: a better system for the whole program is needed rather than just increasing residue testing. Create a common protocol. Have ability to distinguish hot spots of actual contamination from small hot spots of increased ability to detect ever smaller amounts. There is no one in the organic advisor position right now which is a big problem for climate smart, etc.

Brian: I was hoping that you could cover the rest of your topics?

Mark: TOPP – It is two orders of magnitude – more resources than we ever had ten years ago, but it doesn’t have a goal. USDA has chosen to launch this program without having a goal. I think that is problematic, and I think the NOSB could create a dialog that could help industry or community create a goal. Climate smart verification – problematic how that is being pursued. Need to get organic integrated directly, not as a secondary aspect of how Goldberg… Hoping the NOSB can help create a dialog that would help communicate that directly to the USDA.

Allison: Thank you for talking about inerts. Do you have any advice/suggestions for how to deal with this cumbersome topic and getting these materials reviewed. And what should we set as the goal.

Mark: TOPP Goal: I think there are a lot of different variables, and the market development part of it, which isn’t well-integrated with the partnerships program, is a key thing. I think there is important economic analysis that should be done. ERS should be part of this process to establish a realistic but ambitious goal that is differentiated throughout the supply chain. And the emphasis has to be on domestic production. Regarding inerts review: I think Terry’s suggestions are very constructive and totally plausible. I do think the number is no astronomical. To give the benefit of doubt to the program, I saw the AMPR as a cry for help to the community to do something at the legislative level that they cannot mention or suggest to get them off the obsolete EPA list.

Amy: You mentioned that we need a better system as a whole for residue testing and ability to distinguish hot spots of contamination. What are the best methods to do this?

Mark: We saw in 2018 maybe, Consumer Reports using the work of Dr. Benbrook and the dietary risk list that he compiles from the USDA residue testing of fruits and vegetables showing fungicides showing up on a lot of spinach, as an example. Did not appear to be a matter of fraud, but a systemic problem of something in the supply chain or handling chain. That is very different that I think most certifiers are doing with these sort of spot detection, where levels are constantly going down. We do not really have a way other than the analysis of USDA’s Market Sampling program that only includes a portion of the organic sector with it, we do not have a way of combining all of the results from all of the certifiers. I think this is part of what Michael Crotser was talking about – what are the patterns? We would be able to see that patterns if we had a combined program of all of the certifiers where all of the results were going into one common system. Right now they use different labs, different protocols, and they cannot be compared. That is the direction this needs to go in.

Dan Langager – Northwest Horticultural Council (CACS); Crops (CS); Handling (HS)

I’m with the Northwest Horticultural Council. We represent growers, packers, shippers of berries in PNW. Direct you to our written comments for the PNW tree fruit industry’s perspective. Highlight some materials under crops of importance:

Ethanol/alcohols- decontaminate irrigation systems. if not decontaminated, emitters can become clogged causing damage to system and unequal supply of nutrition

Used to clean pruners for fire blight so as to not spread.

Plastic mulch and covers- bird nets, wind screens, shade cloths, deterrent in cherry orchards for leaf hoppers. can transmit middle cherry disease-epidemic in Washington state. ground covers reflect light into canopy to reflect light, heat, and support maturity

Damage leaf tissue leading to less fruit or fewer …

Elemental sulfur, used to adjust soil ph- nutrient uptake, etc.

Lime sulfur, used by most- CA, sulfur, controls blight mildew, scab. Dormancy through bloom- to control insects or pathogens that overwintered.

Thank you for the opportunity.

Brian: Thanks, Dan. I know fruit growing is different in different regions. Curious about hydrated lime. IN the east, would just be used in Bordeaux mix. are there other pesticide formulations that use hydrated lime. with Bordeaux mix- other copper products are safer, why are people still using Bordeaux mix.

Dan- Yes, I believe there are other formulations that growers can use. I will defer to my colleague, Harold Austin who will know those better than I.

Amy: Dan, thank you for your time. Question about potassium sorbate. It was noted in your comments that the growers in your group decided that it would be beneficial to preventing disease. We’ve heard there are concerns with that substance and the use in this petitioned fashion. Questions on efficacy of trials listed in the petition. Wondering what pushes your growers to want this to be accepted. There is limited information used as petitioned.

Dan- the subcommittee talked about the need for more research. We’d like to see that as well. To see how it’s working and in what circumstances, climates, growing regions. We are fortunate with climate and soils in PNW. Helps in controlling post-harvest diseases. Very big issues. I would also say it fits into the tools in the toolbox our growers and packers have. If efficacious, we’d like to see it in the toolbox.

Jay Feldman – Beyond Pesticides (General)
Executive Dir. BP is bridging farmer and consumer needs. Believe deeply in Organic land management. The USDA needs to ensure integrity. The NOSB decisions this session are key in establishing organic integrity. Laws that have brought us to the brink of ecosystem collapse and organic is the solution. Yes organic is a small percentage of overall food. Decisions now before the NSOB are critical in this light. You’ve heard our position on inerts. OFPAS requires national listings by specific use or application. We must move away from petrochemical plastics and move toward intercropping and mulch. The NOSB hops decision nearly a decade ago is demonstrative. Certain materials are available now as organic but that has not been addressed. Liquid fish annotation is not being enforced by NOP. NOSB should not re-list until the recommendation is enforced.

Dan Langager – Northwest Horticultural Council (Crops (CS) (General)

Represent growers and packers of apples, pears cherries in the pacific northwest. Crops issues- ethanol and isopropyl alcohol, needed for disinfection of lines. Pest mites, brown rot need lime sulfur. Needed it to adjust soil pH too. Weed mats- plastic- need this for pest control, many different types of mites that spread disease, especially into cherries. Netting, shade cloth- hail and sunburn protection. Big investment to set it up and this needs to stay in place. Inert ingredients, importance cannot be overstated, this chemistry is part of all materials. Take a deliberative process in reviewing these essential inputs.

Amy: Want to confirm your organization’s stance on potassium sorbate – provided comments in the spring in support of this for disease control. Wanted to ask if anything has changed?

Dan: We left it out of our comments this round because after going back to our growers, it might not be the right time for that. We did not get a lot of input that it would provide a significant change, and in order to fully support and defend that, we’d need to do more extensive research on how that would benefit the industry.

Brian Baker – Belcairn Concerns LLC (Materials (MS))
Thank you to the NOSB and NOP. Opinions expressed are my own. Sunset and specifically on the request to comments on inert ingredients, a subject worked on since 1988. For any synthetic substance to be added to the national list OFPA requires it must be necessary and not harmful. The burden should be on the folks using the inerts to prove they meet the requirements. We should not proceed until there is a full disclosure of inerts that are being used. While formulants are necessary in some cases, how and why they are needed needs to be cleared. EPA allowance is not enough to put them on the National List. Many inerts have greater toxicity than the actives themselves; they often work through synergy and can increase persistence of active ingredients. Formulated products are more toxic than the active ingredients alone. The AMPR public comments showed that most of the ingredients are still needed. Full public disclosure is needed. Please consider my written comments and my comments to the AMPR.

Brian Caldwell: I am excited to address this issue – so difficult, but so important. Pleased to hear you strongly support the disclosure of inert ingredients – makes sense. Do you think that sort of disclosure needs to be tired to the actual product, or can a company put it on a blanket list and say that we disclose that we use this material, but not tie it to a specific product. I do not want companies to be disclosing a whole bunch of things that they would like to use but aren’t necessarily using right now.

Brian: You do not have to link the two, but some form of justification is needed. Like shampoo bottles – you do not need to know the %, but you need to know what is in there. For the purposes of evaluating under the 21-19 criteria, you need to be able to evaluate these materials regarding what effects there might be on non-target organisms. I think the process will be self-limiting, but I could be wrong. We greatly underestimated the petition process in the past and we may be overwhelmed by people that want to experiment and they may not end up in the final formulation. I will say that the manufacturers and formulators want a larger list of substances to work with, and they don’t want to go to the trouble of field testing and then realizing that it won’t work. The manufacturer needs to work with the NOSB – should be a collaborative process, open and transparent, and a lot of these are intended to reduce the amount of active that is used, and that needs to be weighed as well. It is a matter of getting the information and figuring out how to proceed from there.

Allison: Picking up on how many products are we dealing with question. Terry said the 100-200 range. Is that the ballpark? Would you recommend prioritizing to make it more manageable?

Brian: It’s not our job to figure out how many substances we are talking about: it’s the job of the people using the substances that need to come forward. I came up with a smaller list than Terry, perhaps due to overly optimistic view based on how USDA and EPA could collaborate. I think Terry is at the top end of what the list is, but I think we could get down to 20-30. We need to know what we are talking about first.

Nate Lewis: Is there anything unique about inerts in contrast with excipients that require their listing?

Brian: The beast is out! I was at CCOF in 1988, that’s when the dam burst. They are different. They are put in the statute for a unique way for a reason. We cant forget what was done since before there was an NOP of OFPA. OFPA was driven by the alar crisis. Echo what Mark Lipson said earlier: we are dealing with obsolete lists. The food quality protection act happened 6 years after OFPA, required EPA to review the materials. The EPA didn’t ban materials willingly. This is a long complicated issue with a lot of history. They are different from excipients and animal drugs – vets have a lot more info on excipients than you do with pesticide inert ingredients. Because of food safety issues there is a lot more access to information about additives. Other than helium and argon, all inerts have a function and are active and all need to be disclosed.

Julia Barton – Organic Farmers Association (OFA) (General)
[This presenters comments were provided to us in full.]
Good afternoon, my name is Julia Barton with the Organic Farmers Association. I’d like to share comments today on 3 topics.

First: Crop Insurance:
OFA appreciates the board’s work on this important topic. OFA farmer-members have a wide range of experiences with crop insurance and are eager to make crop insurance work better for organic farmers. Two points we want to highlight here include:

Farmers need a way to manage risk due to genetic and pesticide drift contamination. If these situations could be recognized as a qualifying event for crop insurance, farmers suffering from loss wouldn’t be required to identify a source, which isn’t always possible. More support from USDA to protect farmers from these types of contamination and to deter the practice of drift is necessary.

Secondly, OFA has identified a need for risk management within the organic dairy industry. For the past year, OFA has facilitated a national organic dairy farmer working group to identify farmer-driven solutions to the national organic dairy economic crisis. This farmer-led group has identified a strong need for the creation of a safety-net program specifically for organic dairy, based on organic-specific milk and input cost data.

OFA asks that USDA’s National Organic Program (NOP) increase enforcement of the organic standards (including access to pasture requirements and the updated Origin of Livestock rule) to ensure that all organic dairy farmers are following the same rules so that farmers are operating on an equal playing field.

Next: Residue Testing:
OFA agrees with the Board that residue testing is an important tool for fraud prevention. However, organic is a process-based standard, and so testing for residue must not be the standard for proving organic practices.

Here we would also like to mention that OFA supports efforts by state and federal agencies to help farms cope with contamination of soil and water by (PFAS) chemicals, including assistance with soil and water testing, technical assistance for determining whether farm operations can safely continue, and compensation for lost production and lost farm value due to contamination. MOFGA has provided outstanding guidance and support to the organic farmer community in this arena. We know that PFAS contamination exists across the country and urge the NOSB and NOP to get ahead of the problem with more proactive strategies and support for farmers dealing with contamination.

Finally: Oral Comments:
OFA members would like to see the Board return to allowing public stakeholders to give comments in person at NOSB meetings, starting with the Milwaukee NOSB Meeting in the Spring. The point of moving the meetings was to give each region an opportunity to speak directly to the NOSB. While the online testimony is important, and we want you to continue that mode of communication, OFA farmers also see value in in-person testimony. In short- we need both. More opportunities for communication are better.

Thank you for the opportunity to comment, for your time, and for your service.

Amy: Crop insurance – there have been some comments about plant dates and that organic farmers are interested in RMA extending plant dates – do you think this is a regional concern or a nationwide concern?

Julia: I would imagine that planting date requirements would have regional variation and therefore farmers that have noted that it is a problem for them have asked for a broader window to determine when planting makes the most sense for their organic crops. We have also had farmers note in the past that the delayed planting date that they used the year before is already factored into their calculations as it is part of the production. We are essentially double penalizing them. I think that if we were to check in nationally, we would find that what farmers would like to do is do more of the thought managed, rather than a one-size plug-and-chug model, which is what they are held to now.

Amy: If we could get a location area to understand if it is a national or regional need from OFA, that would be great.

Julia: We will be working on that this winter with OFA farmers as part of a working group format.

Harold Austin – Past NOSB member; Organic crop production (Crops (CS); General)
Lifelong member of tree fruit assn. In the PNW. Thank you for your service. Refer to my written comments and those of the NW Hort Council. Support continued listing of various substances for handling and crops, including alcohols, crop covers. Lime sulfur is especially important for tree fruit. Do not support a work agenda item for regulating rate and timing for application of lime sulfur. I’ve worked with this material for a long time and am familiar with its effect on beneficials. We see a slight knockdown effect, but it recovers quickly. Our beehives remain out in the field. The timing and rate is the job of the EPA, not the NOP. Also in subcommittee notes you raised concerns about on farm sulfur burners. We use those to treat our water and to protect our fruit from sunburning. It reduced the pH of the water. It’s a safe product and the only true alternative would be to use sulfurous acid and we don’t want to go there. I urge caution when moving ahead when looking at materials that are currently necessary for crop production.

Logan: About carbon dioxide for irrigation use – do you ever have an interest in using that product instead of sulfur burners.

Harold: The majority of our crop production is organic. We have used the sulfur burners for so long, we have a lot of confidence in it. It is a safe use and application, our workforce is comfortable with it, and it is the most effective product we have seen for keeping the calcium carbonate off our fruit – it is more than just the lines. We have to cool our fruit to keep it from getting burnt by the sun in the summer. The additional impact is we are reducing the pH of the water – getting it down to 7.2 and maybe low – and it is helping with the penetration of everything else. There are so many benefits – it’s not a narrow focus, but a pretty wide scope.

Jerry: Were I to characterize what I find to be the most consistent criticism of sulfur burners is that it could be used to mask poor soil.

Harold: We are working with poor soil – it is not the soil itself, but the irrigation water. It will start the beginning of the season of 8.2, and by the end of the season the pH is 8.5. It is not really poor soil, but soil that is being impacted by the pH of the water that we are putting on it. It is not masking anything. Maybe there are areas, but I used to be a crop consultant, and it is very beneficial to our crop production.

Tracey Dion – Yellowstone River Farm (General)
Raise certified organic lambs, cattle, oats, alfalfa, etc. Appreciate the virtual platform as it levels the playing field as it is equitable access to all. 10 years ago we took over the farm from my parents. In 2017 we achieved organic status and our soil has been miraculous. After all that work buyers will pay a premium: that is the miracle of the organic seal. We need help spreading the message to organic consumers. It’s a great system and a great product, but I can’t find a market for my lambs because of the confusion surrounding organic. Organic is the only federal standard and the most climate-smart production system. Most consumers would choose organic if they knew every dollar was cleaner and better for the environment. We need help from the USDA. We need the USDA’s AMS to educate consumers about what the organic seal means, explaining the attributes of organic.

Kim: Can you expand on what your outlets are for “harvesting” your animals and what are your current practices? Direct to consumer?

Tracey: At this moment we have a state inspected facility that is about 2.5 hours from me. The issue becomes finding the markets for organic lamb. When you do the math on it, you come back to the same kind of profit margin. It is something that I’d like to pursue more – I think there is an opportunity there – but at this point it’s getting the value of the organic label onto that lamb that is going to make all of the difference.

Allison: It sounds like you have access to processing that is reasonably workable, but it’s the market that is the challenge. Do you have a sense of whether your costs are higher and make your price point challenging, and are there practices that your competition uses that makes your product…

Tracey: I do not know that I got that far into antitrust issues. There are a lot of people that use direct marketing for their lamb…

Allison: Do you think there are practices that you are competing against that are not captured in the consumer price, whereas your costs are?

Tracey: I would say that anyone who is raising organic lamb has their hands full. The amount of recordkeeping involved in proving that something is organic, and sheep is not an easy product at all. I think that a higher price is warranted if someone is going to take on organic sheep production.

Nate: We have a document on CACS on geolocating and trying to make it consistent how farmers turn in how they are describing their fields. MT puts directly on the certificate the location of each field. How do you feel about that?

Tracey: I fully support that, and I would expect that on every organic certificate in the whole country.

Nate: Amen. Thank you.

Kestrel Burcham – The Cornucopia Institute (CACS; Policy Development (PDS); General)
[See Cornucopia’s oral comments from the Policy Director here.]
Amy: Referring to your written comments. You mentioned for residue testing for global supply chain, you really wanted to see testing conducted at the point of origin and arrival for bulk containers. Are you aware of any testing on the rapid analysis front? Sometimes there is a delay that might take 4-5 days and that can be a lot of time.

Kestrel: I do believe there are some new technologies for rapid testing. My colleague might be able to provide more information on this. This is an area that is expanding rapidly with SOE coming on, and I can get you more details, as needed.

Amy: I would love the follow up. Thanks.

Nate: Is there a way, in our communication, how we need to be shouting from the rooftops the benefits of organic. Is there a way that we can celebrate all that is good while still not losing sight of the points of improvement? Can we do both?

Kestrel: I would hope we could do both. I see that there are no black and whites in food production – all grays. Consumers often focus on the black and white because the nuances are so overwhelming. For me, I see that we need to show the benefits of organic on the nutrition end, environmental end, and the animal welfare end through fact-based and-science based information. There is a lot of information that is coming out that we need to help break down into more accessible ways for consumers to access that heavy science. The USDA, NOSB, and stakeholders like us should have a role in that. For the consumer side, I think that consumers lose faith when we talk about the problems that organic has. I think we need to make it known that continuous improvement is built into the system, and maintaining those systems of continuous improvement is essential. I think that comforts consumers; rightly so! As soon as you lose that piece of checks and balances, you lose consumer confidence.

Jerry: I am glad you got your extra minute or so, as I appreciate the way you ended your thoughts on how things might be gray. I think what I would add on how we find consensus and engage in continuous improvement, I find that as we go about staking out our opposing positions, we become our worst enemies. I do not think that anyone makes the organic consumer more confused than ourselves.

Nate: If you have any great one-liners for “why organic” or “what organic,” we would be eager to see them.

Joseph Brinkley – Bonterra Organic Estates (Materials (MS))
Speaking in support of maintaining sulfur dioxide for wine making in made-with organic category. We have seen incredible interest and growth in our wine at home and abroad as the interest in organic continues to grow. The use of SO2 acts as both a sterilant and antioxidant, serving two critical needs. No viable alternatives. We pride ourselves on selling wines at an approachable price point. We maintain our SO2 at the allowable amounts. Removing this material would be devastating to our brand and business. For sterilant, while there are other materials, they are all synthetic and cannot be used. As an antioxidant, there is no alternatives to SO2. Our organic handling would be critically impacted if the use of SO2 was no longer allowed. Our ask is that NOSB vote to relist SO2 for wine made with organic grapes.

Logan: Ethyl acetate – are you familiar with that, and are you able to source it organically?

Joseph: We do not necessarily need that. The magic of wine is that the fermentation of the sugar gets us to where we need to be on the alcohol side.

Allison: Thanks. Happy to see producers commenting on this. Curious if you have any comments on how “made with organic” annotation has affected Bonterra.

Joseph: One of the limiting factors is the lack of consumer awareness. There is a bit of confusion surrounding wine in organic wine vs. Made with organic grapes. Challenging, but we are still working in that direction. Depending on the demographic of the consumer. We are the only nation where there are two categories of wine consumers have to understand and deal with.

Nate Lewis: Do you have any opinions about the restrictions on SO2, particularly as it is only limited to grape wine, and then the issues with the 100 PPM.

Joseph: Cannot speak to other fruit wines, not our focus. As far as the PPM issue, I would continue to advocate for the levels to be maintained where they are. I’m not here to ask for a lowering of the standards, but I do find that the limited use in the made-with category is critical to us, to the point where if it was dropped, we would probably drop the certification.

Abby Youngblood – National Organic Coalition (General)
[This commenters comments were provided to us in full.]
Good afternoon. I’m Abby Youngblood, executive director at the National Organic Coalition or NOC.

I’d like to talk today about our work with Congress, in-person oral comments, and advancing racial equity in the USDA Transition to Organic Partnership Program.

We are in a tumultuous period in Congress right now, with an unclear path forward for a new House Speaker, action to avert a government shutdown before the November 17 deadline, and renewal of the 2018 Farm Bill after it expired on September 30. I want to highlight two issues that pose a particular threat to the organic community.

First, the Cost Share Program is especially vulnerable in an environment where Congress decides to extend the current Farm Bill. In the absence of a special provision, the Cost Share Program will expire, leaving thousands of organic farmers with a huge net increase in their annual certification costs.

Second, amendments to agriculture appropriations legislation have been introduced in both the House by Congressman Keith Self (R-TX) and in the Senate by Senator Roger Marshall (R-KS) that would block forward movement on the Organic Livestock and Poultry Standards rule.

We will need to fight in the coming weeks to secure funding for the Cost Share Program in the Farm Bill extension and to defend against these amendments to block the organic animal welfare rule from moving forward.

Together with many partners, NOC is also advancing seven marker bills with specific provisions related to organic Farm Bill priorities – certification cost share, continued transition support, organic integrity and continuous improvement, organic research, seeds and breeds, organic dairy, conservation priorities, and addressing Black farmer land loss. We refer you to our detailed written comments for additional information about these marker bills.

In-Person Oral Comments

We appreciate the discussion at the Atlanta Board Meeting. We are strongly advocating that the Board try in person comments for at least two meetings so that Board members have a comparison to a meeting with only virtual comments. We ask that the Board try in-person oral comments at the Spring 2024 meeting in Milwaukee.

Advancing Racial Equity in TOPP

In closing, I want to thank the Board for your work to build a more diverse, equitable, and inclusive organic movement. And I want to encourage us as an organic community to consider ways that we can leverage USDA’s Transition to Organic Partnership Program, TOPP, in that effort. NOC is a participant in one of the national TOPP projects and as a part of that work, organic organizations have the chance to participate in an 8-month racial equity learning cohort that is being offered free of charge. This is an incredible opportunity to work within our organizations to deepen our commitment to advancing racial equity.

Thank you for the opportunity to comment and for the Board’s work in service to the organic community.

Allison: Thanks. Your last point about the training you’ve done on racial equity – love to hear more. Your comment about how racial equity training for NOSB members: how could we best bring that training to the Board.

Abby: The learning cohort that Ellie and I both mentioned in our comments is a very deep dive type of training opportunity. I wanted to flag it. The first cohort was for certifiers and inspectors. The second will be for education and advocacy groups. There are two more. I think that between all of these, there will be dozens of organic organizations will be taking part. I think that many organizations have trainings that their staff do, and I think that something like that might be something beneficial to the NOSB, and I think that thinking about how to institutionalize the process would be a way to integrate it into the work that the Board does. I think that the Board has a fantastic opportunity through the in-person meetings and the speakers that you invite to continue to build equity.

Amy: General question for those that represent us on the Hill. In 2018, one of the top priorities was oversight and enforcement. Excited to have funding for that. I see that in current priorities, enforcement and oversight was absent. The ones that are on there are brilliant and wonderful, but wondering where it stacks up – oversight, improvement – continuous improvement.

Abby: In my mind, the biggest linkage is around additional funding for the NOP, and that funding keep pace. That is a conversation that we continue to have and hope there is a continued opportunity to increase the resources for NOP – going from $9M in 2017 up to over $20M today. I think that additional funding is important, but I will note that the actual funding for the NOP is through the appropriations process. We have to keep fighting there to get the funding increases. There are things that the administration has the ability to do and can do without legislation, but in the Farm Bill, we feel that we need that legislative tool to keep our goals achieved. If the Board is seeing that we need that legislative tool, then I hope we can be in conversation about it.

Franklin: Question regarding the cost-share program and how it affects organic producers.

Abby: We do know from a survey that OFRF did that cost is a barrier to many famers. Especially areas of the country where access to certification is expensive. Cost share needs to be improved. We have many people who use organic practices but are not certified. Taking away cost share will only exacerbate that problem. An extension is very likely in the farm bill, and we will be working to get the cost share as part of that. It is not automatically assumed that it will be included, so we will be working to ensure that we find money for it for 2024.

Scott Rice – Organic Trade Association (General)
Regulatory dir. Also a former NOSB member. OTA submitted written comments. Highlighting a few points: first we support CACS expanding testing protocols, making it risk-based. Logical step forward in supporting organic integrity. What else can be done to strengthen residue testing: consistency is needed. Responses to positive presence must mean consistent processes with the tests, analysis, and how it’ applied. Produce consistent data. That data can inform risk assessment and better efficacy in fraud detection. Sampling procedures and how to respond to fraud detection. If the industry is going to rely on it, then the NOP needs to update how we are to respond to fraud detection. We need tools to respond to the detection of organic fraud. Let’s take this opportunity to incorporate data from a consistent testing plan.

Nate Lewis: Appreciate residue sampling information. Do there need to be updates to the regulation in addition to the guidance? Where do we need to focus our work (regulation vs guidance).

Scott: having guidance codified in the regulations is the best case, but a hard lift. If we have solid guidance, it’s still just guidance. I think that continued attention to the handbook and where that lives – I know that also poses difficulties as updating that sometimes is seen as a regulatory action. I think that guidance still has its place. I think that the most important part is that the guidance gets out to all certifiers, both domestic and foreign. What is most important is that we are consistent and how it is consistently applied.

Kim: On consistency note: heard a suggestion about bulk lab testing. Consistency in testing procedure, is that in the form of companies allowed to do the testing? Or as long as testing procedures can be validated, how would you approach that?

Scott: I think it incorporates all of that. The way that samples are collected. In terms of the labs, we do have guidance from NOP on minimum requirements for labs that can conduct the testing. I think there is minimal guidance on the list of what is sampled for. I think the list of substances that NOP has in the handbook is dated and much smaller than what I think should be referenced and used. I think it is consistency across all of those areas.

Kim: I do know that working with labs, you might have an internal result, and then you might have a referee result. I think that’s where my mind is a little gray at the moment. Consistency is key, for sure. I appreciate your thoughts on this.

Nate: As a former WASDA’er – could you talk a bit about the burden and benefit of having exact coordinates for certifiers of fields. WASDA seems to do it without much challenge.

Scott: Echo Liz’s comments: with any new practice you brin in with a team it’s got headaches on front end with practices, training, consistency, etc. Once you get there the value of the data outweighs the front end heartburn.

Stephanie Jerger – Organic Trade Association (CACS; General)
Vice President of Operation. We have submitted comments. Our diveristy initiatives in regards to transtioning and BIPOC armers and growers. We decided to make a more intentional push toward making sure organic does not include historical inequities. There is opportubnity to transition. Barriers are: communication. There is acultural competancy communication lacking. Plain language is already heard enough if it’s not culturally competant; so having egulatiry language is a huge hurdle. The paperwork burden is huge to even get started. It can be a deterrent. Also, we want to better highlight what is expected of these producers so it’s not so daunting. Want to demystify our organic resources like the national list – what’s allowed. These things are not innate if you are not in this community. Learning curve: they don’t know what they don’t know. There needs to be a more holistic place to find the information they need. If TOPP is wildly successful, which we hope it will be, we will have created more issues. Please reach out directly.

Logan: Curious, for some of those educational things, you have a nonprofit for organic growers – has that become a resource, is it lacking information, if there is a need there for those local outreach programs, do you think that is a good way to get some of that information to farmers?

Stephanie: I do think that having more information coming down and trickled into those organizations and communities would be helpful. The communities already trust those organizations. I would say that better educating more local organizations would be helpful, but they have to be better educated themselves.

Allison: I appreciate your comments and the barriers that you named are the same things that I am hearing regarding organic transition. What do you see working so far in the early stages of TOPP? You especially mentioned cultural competency.

Stephanie: What I really see it is helpful to have more hand-holding. I know people don’t have time. I put on a webinar once a month saying “ask me anything” — it’s been successful. We’ve been able to get a number of people and one person certified through this process.

Franklin: Can you provide examples of the kind of language that puts people in the community off? Language that maybe sometimes for the person talking might sound like it is every-day language.

Stephanie: There are two words that I have to stop myself every time I say them, and they are “regulatory” and “compliance.” Those words mean different things in the communities that we are trying to penetrate. That is a part of cultural competent communication. Technical language is fine for understanding the words, but they won’t be able to if they cannot understand them. There are other words as well that do not translate well for the communities that we are trying to reach.

Nate: When we talk about hand holding – good way to put it. Farmers should focus on farmers. Having a deep regulatory knowledge isn’t something farmers can do. We have FSA offices who will do this sometimes. Do you have ideas for how we can pass that process along to ask these questions and get your hand held.

Stephanie: That is the experience they are not having in these places. Having an FSA office that can translate what the USDA has passed down to it is great, but often not happening. When a lot of folks that I work with go into the FSA office and talk about organic, they get a glazed look and the people do not know what they are talking about. I think we have to acknowledge that in places where organic is not a hotspot, we need more education at the federal level.

Nate: Would you say that resources are best deployed to go to those communities is better than higher up?

Stephanie: Resources in those areas will be better used at the local level rather than higher up.

Kyla: I say regulatory and compliance about 1000 times every day. I know OTA has resources: is a lexicon of better words one of those resources?

Stephanie: It is not yet, but it is coming as a part of our diversity resource library that is an ongoing library that we keep on our website that comes from our diversity counsel. This is something that we will be working on next year. Stay tuned.

Margaret Scoles – IOIA (General)

Phil LaRocca – CCOF (General)
LaRocca Vineyards & CCOF – long-time organic stakeholder. Vice-chair for Cal Org Product Advisory Board. Semi-retired mode as my farm took a pretty good burning in CA fire.

I wrote the rules for organic wine and wines made with organic grapes 22 years ago. Sulfur dioxide is actually outlawed in organic production. With that said, it would open the door to other preservatives. So, we came up with organic wine cannot have any synthetics, including sulfur dioxide. We knew that organic wine was growing and we needed to do something. We came up with the “made with organic” label. To pull that off, we did it with the help from 4 senators from two different states – let’s allow Sr citizens to buy drugs for half price, and by-the-way, let’s allow organic wine to be made with sulfur dioxide. Since that rule was passed, we’ve seen 1000s of organic wine produced. When we were producing, we were in the 10,000-12,000 case/year. To this day, we still have inventory that we are selling out of our tasting room that is 5-18 years old. You do not need sulfur dioxide to make good wine. But I’m not here to tell people how to make their wine. I am here to say that I endorse organic wine, and I endorse the “made with organic” label.

Allison: Curious with long-term perspective on the growth of the organic wine sector? Is the current law still working as written?

Phil: The industry is growing, there is no doubt about it. What we are experiencing in the organic wine production, and I’m talking with other organic wineries, we are seeing sales there, but they are not wanting to pay the premium for organic. We need a major marketing campaign that shows that organic is better and it is worth the price premium. Even some of our big palm growers in CA are saying that they are getting conventional prices. When we say that we get an organic premium, that premium is just the cost of doing business organically. We need that premium so it is worth it to the organic producer to make a profit.

Nate Powell-Palm: Through line from farmers that there is help needed with marketing and spreading the word of the program. What would be your dream plan for “why organic”?

Phil: First, I think we need to do a marketing campaign just like they did with the old raisin commercials – that boosted raisin production ten-fold. I know that USDA will have a hard time with this, but I think that we need to say that organic isn’t just better for the environment, but also for your diet. We like to say, “Pay the farmer, not the doctor.” You can see that organic crops actually have higher nutrient value. We need to promote that.

Nate: I’d love to follow up with you.

Margaret Scoles – IOIA (General)

Margaret Scoles – IOIA (General)

Comment is mostly on the organic transition document.

Sunset reviews keep materials on the National List. Vaccines are essential in organic livestock.

Standardized location – Listing of township coordinates for field was required suddenly for one area – I was astounded with how much time it took – the farmer shouldn’t need to be present for the inspector to locate the field.

Transition – You acknowledge that the formal comment processes have been limited. That lack of opportunity was a drawback. The synergy of funding is working well. Actual barriers to transition are not nearly as large as the perceived barriers. We must protect cost share. The way to successful transition is to stick with it. Inspectors have been key.

One of the most rewarding things as an inspector is to see producers improve over time. The NOP guidance document on technical assistance is important. Inspectors have always worked hand-in-hand with retailers.

Transition must include the development of OSP. I was last week in a meeting with Jenny Lester Moffit and farmers and talked about what has been helpful in MT. We now have funding for transition.

Amy: Thanks for reiterating position on standardized location information. Collaboration for risk assessment is awesome. Ask you: on the testing you mentioned that you would recommend all bulk ships are met for offloading. Can you elaborate?

Margaret: I think it is a matter of risk assessment. When you have really large volumes, the risk is so much higher if the load is not organic.

Allison: Appreciated your comments on transition. Do you have thoughts about how we can give really clear direction to inspectors? What more can we be doing to allow producers to get the benefits that inspectors bring without crossing the line?

Margaret: We have exercises and training – we focus on trying to get people to understand the difference. It’s easy for inspectors to say they cant help with something. Training is really important for inspectors and certifiers because both are bound by the same part of the regulation.

Nate Lewis: I appreciated IOIAs comments on the testing document and honing in on the dynamic that creates with inspectors as boots on the ground. I spent most of my certification time behind the desk. It was easy for me to send out the samples. I appreciate that you all offered some suggestions there. Wanted to acknowledge that I read that and appreciate it.

Margaret: I think almost every inspector would be excited if sampling wasn’t part of regular inspection, and if you just have a specific sampling inspector that you sent on a circuit. The oddest was when we had to do unannounced inspectors often ended up being really good inspections. Maybe residue sampling is one of those things that goes well with unannounced inspections too.

Nate: Could you speak to the DEI work that IOIA has been involved in?

Margaret: It has been one of the most fun projects. Two years ago with the Human Capital Initiative, we started a partnership with OFA, IFOAM, NOC, and that lead into the project that others have been talking about. What we learned on early on is that we did not spend enough time talking with potential partner organizations about what they would find helpful; we just assumed we knew. Over the past several months, I’ve participated in doing more of this. I have been able to sit in on some interviews with organizations and it was really good to hear what they had to say. I do not know where that will go, but for sure there are organizations that are needing resources and help, and they’re out there, but they don’t know they are available. We also did a project last year with an intern that was good.

Nate: It has been an amazing process to see after these efforts have been made when we put on IOIA trainings, there are now people in them that were not there before. Thank you for the work that has been going into that, it has been tangible effective.

Margaret: Everyone is thinking more about diversity and inclusion, which is great.

MonaRae Tuhy – General Public (General)
From Bigfoot, Montana. Sat on the Montana Organic Assn/ Board for 10 years. Working as an organic gardener for whole life, consumer of organic since late 80s. Worked with school gardens and teach kids about the soil, what soil is, and how to build that. That I love most about organics is the soil building. We have a lot of orchards in this area that are afraid to go organic because of the expense and paperwork. I would love a campaign that it’s not that difficult or expensive. Organic is the one stop shop for consumers to get the cleanest most environmentally friendly food with a benefit to producers. It’s going to take everything we’ve got to educe. AMS should launch a educational program to educate consumers. It would help consumers understand and help more people transition. As part of the TOP program: I hope it will continue for many years. I’d like to bill the farmer not the doctor.

Nate: As you think about the marketing campaign that would go into trying to inform folks as to what organic is, what are some of the most organic myths that you would like to see posted?

MonaRae: The cost, but also the dedication of the farmers regarding what they believe in and the dedication to the soil and land. The love of the planet and land that farmers have. I would love to see a Superbowl halftime commercial on organic!

Amy: What is your accessibility to organic products in the area you live.

MonaRae: Farmers markets, local CSAs. I get a lot of organic products in CostCo and Natural Grocers.

Alice Runde – National Organic Coalition (General)
[This commenter provided their comments in full.]
Good afternoon, my name is Alice Runde. I am the coalition manager for the National Organic Coalition. I’d like to start by thanking all of the board members for their important work.

There is increasing consensus among the organic community that racial equity needs to be centered in our movement: creating a more equitable food system is a core value for the organic community. We must create a more diverse, equitable, and inclusive movement to achieve our vision of transforming our food system to benefit people and the planet, and I am so excited to hear the topic of DEI coming up so much today.

More and more research shows that BIPOC farmers experience the same challenges as white farmers but at much higher rates – addressing these challenges would help all farmers.

We encourage the NOSB to interact with the USDA’s 2023 Equity Commission report, which includes 32 actionable recommendations to modify programs, policies, practices, culture, systems, and structures to reduce disparities and advance racial justice and equity for underserved communities. Many of these recommendations could be applicable to the NOSB.

We also recommend that the NOSB encourage the NOP to engage with and address the recommendations listed in the report, as many of these are applicable to the NOP. .

In previous comments, NOC has recommended that the NOSB include racial equity as part of the CACS subcommittee work. We understand that the NOSB may not have the capacity or resources for a standalone committee focused on racial equity. However, as Abby mentioned in response to Allison’s question, we encourage the NOSB to find other mechanisms to both embed racial equity into their processes, and help the NOSB stay accountable to these goals. We are excited to hear the board thinking about including equity training in the PPM.

One way to have racial equity be a part of the NOSB would be to include racial equity as a standing agenda item in NOSB meetings. At the Spring 2023 NOSB Meeting in Atlanta, Georgia Organics’ presentation on the legacy of structural racism in Georgia agriculture was extremely educational and very well received. We commend the NOSB and NOP for including this topic on the agenda, and are grateful for Georgia Organics for their work and presentation.

Building on this success, NOC recommends that the NOSB consider including a topic on “racial equity” as a standing agenda item for all their public meetings.

On Crop insurance & Transition. We appreciate the NOSB creating space for the organic community to discuss important topics like crop insurance and transition to organic.

On both of these topics, NOC emphasizes the importance of making sure that programs and resources are available, accessible, and relevant to all farmers, and the value of building on existing successful programs.

We also need to acknowledge and address the impact of historical discrimination on the access to, and trust of, government programs, and authentically partner with organizations who have served underserved communities to start rebuilding that trust.

Finally, on Residue testing: NOC applauds the CACS for opening the discussion on residue testing in handling. NOC supports the NOSB’s proposal to require residue testing for handling operations.

Thank you for your time.

Allison: Stands out to me: how much is happening in DEI in organic community right now. Several conscious efforts and trainings that are facilitating progress. Curious for your reflection on what more we as an organic community to be pushing change at USDA? Still bumping against the challenging and discriminatory USDA, and that progress isn’t being dispersed equitably across the country.

Alice: I do not know that I know personally what the call to action should be. I think that our first step has been a lot of education and understanding how we got to where we are today. I think we are approaching a time when we can begin to discuss how we dismantle it, rebuilding some trust, and how to repair some of the past hurts. I wish there was a 30-second elevator spiel on how we fix the system. I do not have it, but I think we are getting closer to it.

Doug Currier – The Organic Materials Review Institute (OMRI) (Materials (MS))
[Comments pending.]

Allison: Strong interest and consensus from stakeholders in looking at these materials. How many products/materials do you think we are looking at? How many materials would we need o review?

Doug: We did work with WSDA and PCO to put together a list of inerts that are used now. Within that is the subset of nonsynthetic materials that do not need reviewed. I’m thinking 140-150 range. The classification system – I think what Beyond Pesticides has put out there is helpful as a way of categorizing as a way to add to the National List.

Amy: We’ve talked about final products and fortification that could take place. We are reviewing potassium sorbate. The NOSB is not evaluating the final product. 55% of the final product is composted of inerts, including urea. Does OMRI have protocols regarding urea has an inert?

Doug: For a fertilizer that would be prohibited. Where Urea comes in, I believe it is a List 4 inert – it is a different standard pesticide vs. fertilizer. There are some pesticides that claim a dual use, so we would take a look at that, because it is a prohibited nitrogen source. We do look at humic acid fortification. It is a struggle to know when they are using too much, because there is nothing in the standard such as for liquid fish. Those are two examples that we do look at. Potassium sorbate is an interesting one because it is a prohibited plant nutrient source, so if you start claiming it as a fertilizer, then it’s not allowed.

Amy: The purpose is it’s petitioned as a pesticide and fungicide. I just questioned because of the label claims versus the stakeholder comments.

Doug: Tough because label claims come into play, too.

Nate Lewis: Curious if you had an opinion on hybrids inerts approach: where you’d list some EPA references with exceptions – allowance with some prohibitions. Something in-between.

Doug: There is a practicality element that has been at play for as long as we have been talking about this. I think that the thing with referencing those lists is that you bypass the OFPA criteria. So, while a subset of the OFPA criteria might have been met, you’re not going to get it all. Unless we have some kind of exception for inerts, which I do not think that we have right now, referencing bulk lists is in line with what we have right now, but I think we have an opportunity to do something different that raises the criteria and ensures that these materials are meeting the OFPA criteria.

Ty O’Connor – Organic Farmer/Rancher (General)
Family operates O’Connor crops and cattle in SE Montana. Certified since 2008. Organic farming allows us to raise corps and raise cattle for premium amounts. The cereal crops we get paid sometimes double but on beef side we never really exceed 10% of the conventional market. We’ve shipped to CA for several years, but during COVID supply chains were disrupted especially in CA market. We invested 5mil in organic slaughter facility in MT. It’s operational now and we’ve been working to sell widely. We’ve been encountering issues with getting this meat to consumers. Retailers opt to sell “natural” beef instead. Co-ops, restaurants, and retailers in Seattle refuse to sell our beef. It wasn’t because of price. For organic, especially in grassfed sector, we must get people to recognize the value of the organic seal. We need the USDA to increase public awareness campaigns about organic farming. And to continue to strengthen organic seal and make playing field level in organic beef sector.

Amy: Thank you for joining us. Wish I could help. I think this is the first step; letting us know of the challenges. Hopefully the organizations that work on the Hill can help with expanding markets.

Mindee: Want to be careful and not disparage anyone in particular, but what were the reasons retailers gave you for saying no?

Ty: Never had a great reason; a lot of running around. Told us that they didn’t think the grocery stores that they sold to would be interested in our products. We did go to a lot of co-op stores that were selling organic and they were selling “natural” beef and weren’t interested. Supply wasn’t an issue, because our herd is large enough to supply a big chunk of the market in Seattle.

Nate: Did the grocery stores that you were trying to work with, did they have any organic beef on shelf already?

Ty: Some did, but some did not. Some had local products, but not organic, and they weren’t interested in local & organic. Some had somewhat of a variety, but not a huge variety of organic products. We had targeted that area. The two biggest cities for buying organic meat on the west coat were Seattle and San Francisco. Right now we are targeting Seattle with an internet marketing approach. We are trying to pursue the angle that all of our products comes from our one ranch and all of the product comes from our ranch.

Nate Powell-Palm: How can we get retailers to be those story tellers on how to get people to choose organic?

Ty: One thing that we heard is that it takes 9 months to start a new product and basically it felt like they were saying we already have products, and why do we need another new product.

John Wicks – Organic Farmer (General)
Owner of Timber Ridge organic’s, dryland pulse and grain in MT. Multi-generational farm. Organic has been huge for his farm to run a profitable business. We need to focus on consumer demand, which is diectly linked to consumer education. There are a lot of myths surrounding organic. If we increased consumer awareness and education it would jump up demand. We need the AMS to launch an educational service. We need help describing the soil benefits and the benefits of growing without toxic pesticides to help drive the demand. Any dollars helping the education is a good investment in rural America, our environment, and our people.

Nate: I think the throughline that I have been seeing is how do we get the message out? There are all of these farmers, about to be a lot more transitioning farmers, who need a strong market. Telling your neighbor how great organic is, is a lift. What are the things that really stand out for you as the truth about organic?

John: I look at it more as a food product rather than a commodity. I see the importance of making a clean product for people to eat. Before I was just going through a process, but now that I care more and realize that this is food for people, it makes more of an impact. I don’t think my neighbors think about the fact that this is food when they spray pesticides and such.

Allison: One of the challenges I run into messaging the benefits, there is reluctance to raise organic up above of other farming systems. Do you have a perspective in getting people to say good things about organic without disparaging other types of farming.

John: I think the best thing to do is education, and teaching people that there are different ways to do things. It has been enjoyable to learn how to farm, and I enjoy sharing that with people. When you get people caught on the bug and get them interested, I think the thing is sharing positive perspectives. If you get them interested in these different practices, I think it steamrolls and they get caught up in it.

Nate: When we talk about educating consumers, it’s not about what is better, but that there are so many myths about organic. Would it be helpful to get USDA/AMS to explain the rules. To not even bring up that its better than conventional.

John: Definitely. A lot of the myths that you hear are not true. I think explaining that to consumers and getting that message out there would drive people… To know how much work and care go into producing the food.

Joseph Kibiwott – Organic Agronomist (General)
Timeless Seeds – Certified Crop Advisor – Professional training in soil science and organic cropping systems.

Timeless has been working with growers, sourcing, and contraction with about 4 dozen growers to product lentils, chick peas, and ancient grains for the past 30+ years. We have to acknowledge that the demand for organic food is increasing. That is evidenced by the amount of growth that has been shown. To maintain that momentum, we need to ensure that farmers are supported to transition more land and maintain certification. I think that the TOPP program is great, but feel there is still more to be done. From my own speaking with all of these farmers that I meet every day, some of the challenges that are impeding organic include crop insurance – Some of the crops that our farmers could grow, they cannot, because they are not insured. For those that grow pulse crops, they cannot maintain pulse crops in the rotations, because it takes 4 years. May need to have intercropping to ensure that there is continuity.

The other thing that we are seeing is pesticide contamination of some of the crops. When we experience this, the organic farmer is not at fault, but that crop has become decertified. Does not only affect the farmer, but Timeless, as well, because we cannot market that crop.

We need to bring in more growers to talk with each other so that established growers can teach young growers.

Nate Lewis: First, we love your black beluga lentils. You comment around pesticide drift and prices: do you know if crop insurance would cover that kind of loss? Like getting an indemnity from RMA for that kind of loss?

Joseph: To this point, there is none that we know of. Actually, we had a classic example because we had a grower that had pesticide drift and lost certification and we lost the potential for anything there. I think this is where USDA should come in either through RMA or another way for the grower to be compensated for the loss of the crop.

Allison: Curious to dig in on market development. I know Timeless has been successful in creating markets for crops that did not have much consumer interface. How much are you doing in house for new consumer uses for pulses? Or is there a collaboration? What resources would help market development?

Joseph: Thank you. I would say within Timeless alone, we try to connect with researchers who want to do value addition so that we can market the products through different channels. Lentil flour, noodles from chick peas, but we are limited because of the amount that is needed for that market and development. We want to do it within the country, rather than ship our products overseas and then importing it back into the country. Opportunities to teach our own marketing teams, go out on trade missions that are specifically focused on organic. For example, Europe, they do not allow pesticide contaminates in most of the products that they import, but I am yet to see a specialized focus on a mission to market organics.

Powell-Palm: Thank you as a handler for commenting.

Jess Alger – Organic Farmer (General)
Raise organic cattle, wheat, peas, black beluga lentils, etc. In Sterling MT. Commenting on the fact that we need to help consumers understand how wonderful organic is. Too often I hear people say there is no difference between conventional and organic. I can’t explain to everyone, but grass-fed organic has more omega 3s and is healthier. The USDA needs to educate and explain the value of organic products. The USDA is the only one that has the resources for this. I am a mentor to two new ranchers. We want more people to transition to organic, but the consumer demand is not high enough for more people to transition.

I recently learned that AMS spends $15M/year to help promote ham. Organic is a growing industry and we need USDA to allocate additional funds to educate consumers.

Nate Powell-Palm: That mentorship component is essential. Cool to see all the work you are doing. If you were to come up with a slogan or piece for organic that every consumer should know, what resounds most with you.

Jess: Most of organic production is more nutritious, more vitamins and minerals and is just better for you. I think a lot of people don’t understand that.

Nate Powell-Palm: Thank you so much for making the time to call in today. I know it’s easier to make a ten-minute call than it is to spend three days and a plane ticket.

Emily Moyer – International Fresh Produce Association (Crops (CS); Handling (HS); General)

VP of regulatory compliance and global food safety standards.

Thanks to the NOSB for your time and efforts.

IFPA represents over 2500 companies from every segment of the global fresh produce supply chain. Comments are represented of the IFPA committee. Each of the materials being reviewed this year are of utmost importance to organic producers. My comments will focus today on ethylene gas and alcohols.

IFPA supports the continued listing of ethylene gas for a plant growth regulator. Essential for pineapple products. Also critical for post-harvest ripening for de-greening of citrus. Allows farmers to harvest earlier in the growth cycle when product can be shipped without damage. We have not identified an alternative to this product for these uses.

IFPA supports continued listing of ethanol gas and alcohols. Critical that producers have most effective materials available to them to ensure safety. We know that the ethanol production is a challenge and wonder if it would be feasible to source it organically.

Amy: Cross referencing you comments in the Spring vs Fall: I didn’t see any acknowledgement about potassium sorbate for the fall comments where you were in support in the spring.

Emily: Similar position as a previous commenter. Since the Spring comments, we have decided to take those out of our fall comments.

Lisa Wade – Certified Organic Rancher (General)

Raise certified beef, pastures, and forages in Kyla, MT. First certified in 2004. Built business around organic label. We spend a lot of time educating customers around what it means to be organic. Including what it means to raise our food without hormones.

Also admin of MT organic producers cooperative (all gras fed and certified organic). While we all have high quality beef, a lack of consumers has slowed our growth. The demand is just isn’t strong enough. While everyone on the NOSB and on this call can educate, it will take a bigger microphone to spread the message to everyone in the USA. We need the USDA’s help to explain why it’s an exceptional label. Organic represents the most complete regenerative management. I hope that the AMS will launch a marketing campaign spread the word to all the consumers in the country. We need help. If we want more ranchers to transition. Consumers will definitely demand more organic if they understand why its so wonderful.

Logan: This is something we are hearing a lot, and more recently with cattle. I know cattle might have a competitor in the grassfed. Do you think having those other options hurts you on the demand side?

Lisa: In our specific case, we are all grassfed and certified organic. I think consumers could see that as the double whammy. I do not think that is a competing factor. I think people get confused about other standards.

Logan: Do you think people see grassfed and think that it means that it is organic on the shelf?

Lisa: I think that we need to let people know that organic is all of that – regenerative – all of that. I think that a little more simple, specific marketing assistance would be helpful to consumers and producers both.

Logan: When you said that growth has slowed – have you seen a decrease in demand, or no increase at all?

Lisa: Probably very specific to some farms and ranches. Some live where they can direct market where they can do that, where other live rurally and need to get plugged into larger distribution market. That’s where we’ve struggled.

Kim: Curious – do you have any support from the MT Beef Council?

Lisa: I am not aware of that with our co-op group. I don’t see that.

Kim: Good to know. I know that in Colorado, I work very closely with the Colorado Beef Council, and their lead nutritionist promotes that. I’m wondering if there wouldn’t at least be a voice to help promote that? It starts local, so wondering if there isn’t a potential resource there.

Nate Powell-Palm: Thank you so much for making the time to call in today. I know it’s easier to make a ten-minute call than it is to spend three days and a plane ticket.

Mark Smith – Organic Rancher (General)

Organic beef producer in Montana since 2007. We have been able to raise a family doing business in certified beef. I have found there is this gaping hole in people understanding what organic means. When my wife and I were delivering later we heard the term “better than organic” being used. In my mind there is nothing better than organic. Since we started all those years ago, we’ve seen the rules and requirements change – that has been a good thing. The thing as “natural” or “just as good as organic” makes things very difficult. Even non-organic ranchers have misconceptions about organic. Some people think we can’t vaccinate when actually health and welfare is one of the primary things we put in our plans. The USDA needs to educate the public in general. Our prospective consumers I need to constantly draw the comparison and clarify what organic vs. Natural is. Even as the market has grown for us it’s been a continuous challenge. Some of the misconceptions are outright lies about what organic is.

Nate: Really appreciate you taking the time today, Mark. Isn’t it incredible that we have this platform that allows you to call in and make your voice heard rather than get on a plane?

Mark: With the Beef Council – I was formerly the administrator for the MT Org Producer Coop. I am aware of zero effort on the MT Beef Council to promote organic at all. There is a checkoff for organic beef growers to be exempt from the $1/head contribution because of that reticence to promote organic.

Allison: Since you broke the ice, the organic checkoff is what comes to mind. A lot of checkoff programs haven’t worked well for organic producers. As an organic producer, would you be willing to have money going into a shared marketing pot.

Mark: The Beef Council has had some really egregious misuse of such funds, and for that reason I am reticent to institute any new checkoff. If there is a way for that sort of misuse of funds to not happen, I would be willing to consider it, but we would really have to put into place proper audit features, with responsibility, to allow that to go through.

Nate: Grateful that you called in today.

Becky Weed – Farmer/Rancher‐ Thirteen Mile Lamb and Wool (General)

Montana Farmer. You’ve been hearing from a lot of people with good suggestions. I have a dream: sometimes the left and right hands of the USDA wont be working at cross purposes. Seeking a unified vision: the north star of continuous improvement should be the goal of all agriculture. The USDA should promote the principles of continuous improvement, where we promote agriculture that works with functional ecosystems. Can we promote both healthy food and habitat, etc. Those are organic principles. Despite the non-partisan premise of my comments we have always lived in imperfect ag system just like we live in an imperfect democracy.

Jody Manuel – Farmer (General)

My wife Krystal and I own a ranch near Habber, MT. We raise a multitude of crops, and maintain a certified beef herd.

The educational efforts have shown us that the vast majority of consumers have a limited understanding of USDA organic. It seems that it is a widely accepted idea that it is a marketing ploy for more money. This confusion around USDA organic may be at it’s highest around beef. There has to be a clear understanding that USDA organic always means GMO free, any animal raised under the label has always had ample access to pasture, has never received a parasitic treatment. In addition, there are numerous environmental benefits. As the thankful recipients of a USDA grant to launch our program. Our program is called GRUFF. We humbly ask for any help in educating consumers on the benefits of organic.

Nate Powell-Palm: When you think about the investment into organic, what is the one takeaway for why organic is worth consumer attention?

Jody: It is funny, because I felt it was necessary to mention the things that my wife has been so passionate about over the years. We’ve heard it over and over again today. We’ve been having these conversations for years about the lack of education and knowledge about what it means to be organic. That is one of the things we have set out to do. In our hometown, it is a common sentiment that USDA organic means nothing other than it’s more expensive. I think the first step is helping people who are at ground zero and don’t really understand that it is free from a lot of harmful substances. The other thing is that it covers things like animal welfare and soil-building practices. The one takeaway that I would like to leave in people’s minds is that the NOP does, in fact, cover all of the bases that the other certifications seek to cover.

Allison: Curious to hear more about your product development process, and what was helpful to develop new product line.

Jody: We are at the ground level, just getting started. As I briefly mentioned, we did apply for a value-added producer grant. I don’t think we could have done it without that. We have learned so much through the process – not only in the grant application, but post award – that we would be able to do differently next time. There is an organization in MT called Mission West that is a nonprofit organization that helps businesses like ours from everything from packaging, nutritional label designs, etc. The MT Dept of Ag has been instrumental. We just attended the MT Food and Bev show yesterday. So many local business development companies that we are thankful to have helping us along the way, as well.

Kim: Excited for you and your wife – amazing award. Talking about marketing, the internet has connected people outside of your geographic region. Had you had any barriers to entry to sell your products, or do you find it has to be zone into one facility to not hamstring your operation. Anything from online marketing that can be done.

Jody: The name of the company is based on the folk tale of the three bill goats – Gruff. We just assumed that everyone would be familiar with that story, but we have found it’s not true. There is a troll that stands on this bridge and the goats want to get across to the other side to the good food – it’s a metaphor for so many things, but also about this broken food system. There is this whole world of retail distributors… The goal when we started, we were just going to do direct to consumer, but through other things that happened, it led us into that world of brokers and distributors. We are learning how to navigate as we go. We would love to be available in the future to help anyone along with what we’ve learned through this process. We are hoping that we can knock the troll off the road and let everyone cross.

Jerry: Wrestling with a number of callers today who have a common theme and trends. Does there have to be a comparison – better and worse – how do we grapple with our message. The label is a guarantee and a contract between the producer that is willing to put more effort in and the consumer that is willing to pay. When you try to tell your story you are running into roadblocks. I think we could tell the story that organic is the only thing that has the teeth in it, and can be quoted and demonstrated, and followed up upon. In my mind it has a lot of value that is not about better or worse. It just is a contract that is based on performance. No one else has that. How can you guarantee what you are representing is enforced?

Doug Crabtree – Organic Farmer (General)

Diverse crop operation with 12-15 crops/year, as well as a custom grazing enterprise. Our operation has been certified organic from the start in 2009. In addition to organic crop and livestock production, my wife Anna has started a nonprofit dedicated to training new agrarians. We have hosted more than a dozen apprentices over the past years.

Organic has grown to a $60B+ industry. This is a great accomplishment given that there has never been a checkoff program or anything else from the USDA. Glad to see there are some grants helping producers grow. But the only way to ensure that this growth does keep up is to educate consumers. We would like to see USDA initiate some programs to help with this. We believe it is only fair that organic receives our share of USDA marketing dollars. All of the great attributes of the seal needs to be everywhere to help people stay informed.

Nate: Thank you so much for taking the time out of your day to make your voice heard.

Paul Neubauer – Organic Farmer (General)

As Doug mentioned, we work together. I serve as the assistant manager at the farm in MT. I also have PN Custom Grazing. I grew up in Buffalo, NY, and I’m a first generation farmer and rancher.

Been working in organic farming from the very beginning of my experience more than a decade ago. I don’t know how to do what I do any other way than with organic methods, and that’s shaped a lot of the directions I take. Doug and Anna being chief among those people. I have a bit of a side job that isnt paid – the president of the Montana premium processing cooperative. It is a project created in close cooperation with MT farmers union. And I serve in the national farmers union convention. My ability to enter farming as a first generation is closely linked to certified organic. The new operations I see that find a foothold in agriculture tend to be in organic. Point out that the organic community needs to build a wider network and keep an eye on the prize. A wider network that stewards the land is important. Organic can’t just be an intellectual exercise, it gives us all a shot at real sovereignty. Organic gives us a chance to reclaim the dream to farm and make a living doing it.

DAY 2 Public Comment: October 19, 2023

Michele Arsenault take a roll call of National Organic Standards Board: all members are present except for Javier Zamora.

Mike Dill Organic – Produce Wholesalers Coalition (CACS; Crops (CS))

Representing OPWC. Oversight and transition comments. GPS proposal: OPWC does not think it is a good fraud prevention practice but will not deny that it should be enacted as guidance. The proposal will do little to verify and track fraud. Consider: collection of GPS data should be cert responsibility, not grower, should not be recorded in OSP, do not use center of field as marker, have trained inspectors on approved devices, have certifiers record fields on their audits, etc. Other suggestions: “transitional land” should be defined. Transition often refers to the practical regulatory effect and the biological effects on the land. Old organic farmers should get technical assistance for succession planning, farm transition, etc. As technical assistance. There should be a system for transitioning farmers themselves, not just new farmers.

Logan: Question about market demand. The current growth in organics right now is limited because of demand (in produce)?

Mike: Concerned we are going to transition farmers and they will not have markets for those crops. Some growers want to expand, and others do not, and it came back to not having that market support.

Amy: Crop insurance: what fruits and veggie growers are experiencing in your area. Why is group insurance not popular in your region? You gave examples in your written comments. If there were policies that could protect both regions, would growers be more interested in taking on crop insurance? Is it the quality of offerings that is the problem?

Mike: Wish I had more info to give you. The producers we spoke with had zero experience with crop insurance; had more familiarity with commercial liability insurance. The feedback we got was that they diversified to hedge their bets. Some growers said they would be interested if they got more information, but most hear the rumors that its bad and don’t want to bother with it. I’ll reach out to different growers we are working with later.

Allison: Follow up about what we should do to create more markets. What are the opportunities to grow that demand

Mike: Food service and institutional purchasing is an area. Our feedback for organic market dev grant: they looked at institutions and townships and if there was a was too increase funds to have premium products. Retailers are the key to a lot of this. If they are promoting conventional they don’t want to kill that market by saying organic is the answer. Hard to grow retail sales, so left with institution , restaurants, direct to consumer. Without retailer support it’s tough. We need to emphasize educating consumers, because they can put pressure on retailers.

Nate Powell-Palm: Where does the best education for consumers happen?

Mike: We need to hit them in stores and everywhere. Packaging. Old school of painting trucks, billboards, etc. Some of the basic things we walked away from. We have to be creative and simple. Looking at what regenerative community is going now – we have to find spokesperson, influencer. Seems to be working for them.

Nate: You like the geo-doc, but you want to keep it on the certifiers, which it is. And that you want to keep it private with the certifier.

Mike: Right, totally fine with that.

Phil Vavracek – farmer (CACS)

Farmer in eastern Nebraska. Going through transition and first organic certified organic crops, going to talk about insurance. Had a good corn crop and then wind storm came through. Most of that is down and will be lost. County averages going to be considerably less than what I need and what I was going to produce. Holding me back to transitioning more acres. Takes so many years to produce yields of corn and soybeans so this year going to be poor. Going to be 2-3 years before can get back to a corn crop and improve yields – holding me back from transitioning conventional acres. My other concern is using alfalfa, just putting – on that. Would like to protect tons year in and year out. The first two cuttings of alfalfa were good – actually first and third – had to watch amount of water being limited there.

Amy Bruch- sorry about the wind storm. When insurance doesn’t match output, it’s really impactful. You will be deterred from transitioning acres? What’s the deterrent there?

Phil: gross revenue. Farms in now have good insurance levels. Everything has been affected by the wind. Most of these fields would have been better if in conventional with the county T yields being much lower on the organic.

Amy: how many acres are you looking to ad in over time?

Phil: at 500 now and would like to double. Makes think going through a process like this.

Bryce Irlbeck – Farmer (CACS)

Farm organically in Iowa and run organic cert process. The suspected fraudulent imports have real life effects on farmers, due to lack of oversight. Ports that have the most lax control is where people are going to go. As a farmer I have to bring all my grain to the end user. We import millions of bushels from Brazil in the last few months and no one is asking question. No one is asking questions or we will continue to lose farmers. I speak for grain farmers because that what I am. As a processor, it is becoming evident that processors are burying a lot of this too. Worried about processors saying viable too. Easier to idle them than run the very few grain they have. The investments into organic: I read the hemp industry has about 15billion from the UISDA, but organic gets comparatively less. Looking at cost share. And other efforts to increase monies to organic farmers and processors.

Logan: There is a lot of money going into transition. Is it necessary to tackle the imports to make that successful? We are missing the demand according to a lot of people. What do you think would make that possible?

Bryce: The lack of demand is not there in grain, talking to end users. Demand is rowing. Just importing faster than demand is growing. Acres are decreasing across USA. What happens when imports go away? We see expensive corn and soy and demand bottoms out. We test a very small amount coming in the USA.

Logan: You said there is an increase in demand, but also increase in imports. Why are we producing less?

Bryce: For me its psychological. Timely process to become organic. We get 50 questions that are different every year. Then we see imports that come in at lower prices. Psychologically very difficult to stay in when imports are coming in by boatload.

Amy: Said that some processors thing that idling their systems this year may be more cost effective than trying to compete? Can you expand on that?

Bryce: We were going to sell beans and got into a conversation with a processor. The imports are flowing in aster than they can count. They said they can’t make money of it.

Amy: Land is expensive. Do you lease land?

Bryce: Yes, we lease quite a bit of land. It’s a 5-year commitment. There is a demand from land owners to want their leased years as organic. We want to have the guarantee to operate the land for at least 2 years after going through transition.

Jerry: I have zero doubt that you concerns are valid and urgent. Interesting that a significant part of your solution is moving through SOE. Were you in charge of inspections from oversea, where would you inspect?

Bryce: Go to origin of country. Seems highly likely we don’t know where this grain is coming from. Verify which farms its coming from. It appears to me the fraud is so easy they keep doing it.

Jerry: The idea of trying to find the people at source is very difficult. The ability to change the certificate of origin is easy. What are your thoughts about inspections being done on a risk analysis?

Bryce: Yes, the farmers are already paying for it by loss of revenue and profits. At the port of USA it’s a great step of upping the testing and knowing where this came from. We have to put our field. Why shouldn’t they. Would be a great step forward.

Kim: You mentioned whip-saw effect of pricing. Costly soybeans, that does not make sense. There has to be a market for everyone. What financial risk tools do you have available today to manage risk? Would the market benefit from having a tool like the board of trade? Maybe market is lacking a financial risk management tool.

Bryce: Crop insurance – its not great. Having multiple crops go to market is the best way. Biological factor, which organic was made for. Yes, we don’t have a financial management tool. Don’t try and make conventional tools work for organic.

Nate: Powell-Palm: The geo-doc that’s going through CACS. Thoughts?

Bryce: Fully support geo-location of fields both here and abroad. Will help with tracking and accountability that organic standard was built on. Can be implemented with very little nuisance with grower.

Byron Wiemer – Wiemer Agency (CACS)

Basically want to touch on risk management side of organic. Going to touch on T yields – I’m a crop insurance agent in Nebraska. We write pretty much eastern half of Nebraska. On irrigated corn, if conventional farmer your yield is … and if organic 67 bushel short. If transitioning start out with 156 bushel yield and start out with $297 less coverage per acre. Last 2 years of my area have had serious hail storms. Producers produced nothing. If you’re that person, this is a big hit if in transitional phase. This year storms hit later date. They going to live on insurance money. With corn, starting out 67 bushel less and on soybeans losing 20 bushel on organic. At 13.76 which is price this year that’s $206. That’s a huge hit financially if transitioning. Still at a disadvantage.

Amy: unfortunate stories to hear. Wondering about crop insurance – do you think it would be beneficial for RMA to consider history as conventional farmer?

Byron: would help. If got conventional yield history, then we know going organic is different, but should be a system of yield history. Should be able to use percentage of that to bump up proven yield. Big hit for people is that 3 years transitional.

Kim: How is crop insurance price per acre determined for organic crops?

Byron: for conventional, corn, then determined in Feb. As far as organic price, that is set by RMA – don’t have good answer for how they come up with it. For organic certified it’s 11.10 for corn and 28.29 for soybeans, but if ask how came up with it, I don’t have a good answer for it.

Carolyn: how are prices determined? So complicated when looking at risks organic grain farmers? No one seems to know how prices determined. No transparency about price calculation.

Byron: I’m at crop insurance work shop today, and that is a question I’m going to ask today. I do not know that right now.

Carolyn: Let us know what they say.

Bill Wolf – Wolf & Associates, Inc. and Second Star Farm (MISC)

[Presenter has slides.] CEO. Increasing organic acreage with integrity. Farmers organically for 50 years, served in OTA, etc. Please note our written comments, including that essentiality applies even when only needed by a few. Some suggestions on how to increase organic acreage: organic pet food, organics in farm bill I(getting 5% of USDA RND), I ask that you support organic marketing bills in the House. Communicate the true value of organic. The only inspection from seed to table. Develop overall residue guidance testing to help certifiers focus, and better cataloguing of the findings. Having no inerts policy has stalled new control methods. SOE is coming: we’ve got work to do! Moving beyond plastic: we do support relisting it, but only for now. Allow currently available biobased biodegradable mulch films.

Logan: Question on the transition label: I am nervous about a transition label. We’ve heard challenges with demand and over-supply. Where is that demand going to come from? It’s not going to pull from conventional consumer but rather organic, pulling demand. I found what was economically best was doing lots of covers and building soil during transition; our nematodes are awful here. The funding can help with that but growing covers is a lower cost.

Bill: A limited use of transition label focused on US acreage of what’s now taking over the market: uninspected products, non-GMO, etc. Before NOP was implemented there was an in-transition label. The economics of transition – the new transition program is a help – the economics are costly.

Jerry: Twice in my career I broke my teeth on trying to make transition work and how it could be funded. The consumer does not understand it well enough to pay for it.

Delip: Clarify about 5% funding for research and education?

Bill: The USDA research and education dollars are not allocated property to the part of agriculture that’s growing well based on how organic is growing. They should change how they allocate funds to get organic more. See written comments for discussion about inerts.

Kylie Mausser – Organic Consumer (General)

Calling in as consumer after hearing farmers talk and awesome to hear what you’re doing. I am from Iowa and calling to ask you to look at the enxt generation. I home school 4 kids. My mom got really sick and with help of holistic people and food healed her. I’ve been educating myself about organic herbs and other healing remedies. It’s difficult to find accurate factual info and what I do find out is that it’s difficult to find info at all. Most of population doesn’t know anything about it. We’re missing opportunity to educate public. People what hear on TV is largely from big corporations. WE don’t hear the truth. Whether it’s a curriculum or the labels in the grocery store. We could offer commercials. I’m glad I can see through the propaganda and what is truly going on with food in our country.

Nate: appreciate you calling in.

Mindy: Thank you so much for showing up in democracy. If people like you didn’t show up, I wouldn’t know as much as I do. Expresses appreciation.

Logan: So glad came on. Not marketing very well and huge opportunity to get to people. What are other ways – podcasts, influencers?

Kylie: In home school community we all talk about it, but other friends don’t know as much. Public education would be huge. We sell regular and non-GMO feed, but people don’t even know what non-GMO is sometimes. Most people getting info from TV and usually that’ go big, or go home.

Logan: Maybe a QR code?

Kyle: Yes.

Amy: Thanks for lending voice. Consumers are very powerful. Farmers want more markets. Thank you for sharing.

Kylie: so many people are sick and don’t know why. People don’t know what they’re missing.

Nate: we’re only here b/c of consumers.

Zach Porter – Organic Farmer (CACS)

Converting about 5k acres to organic in Nebraska right now. As a relatively new entrant and after having traveled the world looking at food and ag opportunities, things have struck me. From paperwork management perspective surprised by the lack of digitization and geo-tagging of fields. Especially as we are taking on new acreages. The lack of digital process seems inefficient. Secondly, found that it astounded me how much products was organic fraud and being shipped into country. Feed is lacking oversight. This may also benefit from geo-tagging and digital tracking. Would love to support rolling those things out.

Nate Powell-Palm: We have geo-referencing document, which is a guidance for certifiers to collect GPS coordinates for each field.

Zach: The amount of paperwork headache from something like that not happening is astronomical.

Frank Austin – Clear Frontier Ag (CACS)

Organic and sustainable farmland fund. Speaking about stronger measures to prevent fraud. We’ve imported 170,00 tons of cracked corn from Turkey, etc. If look at example, let’s take Ghana, they’ve represented 16% of soybean imports, but if step back and look at likely certified organic acres, for 2022 or 2021 – just do some basic fact checking and you’ll see it’s very unlikely soybeans coming from Ghana. Fraudulently labeled product drives down prices and misleads consumers. A key priority should be to require GPS locations would be very helpful across the entire organic supply chain. Another critical step is stricter HS codes and way the import codes are labeled. Often time a lot of fraud gets under the radar to track real volume. A lot of different growers don’t know what’s going on in the market. Utmost importance for us that we follow through on this b/c this is fraud that is happening today or it might. I’m pulling data and getting to rough estimate that 65% of acres in Ghana must be planted to soybeans. This is looking at us righ in the eyes. I can’t say it’s 100% correct. It should be a call to action.

Kyla: SOE requires supply chain traceability – certifiers are going to need to work with each other b/c they may only certify a portion of the supply chain. With data presented, do you think this will help to detect fraud in supply chain all the way back to country of origin?

Frank: Given where grain prices are today, what is NOSB here for. It’s here to protect integrity of organic supply chain. The red tape we get with regulation doesn’t work. It would be wise for NOSB to cut head off the snake. Margins are getting thinner. Inflation is not slowing down. How many can we expect to be organic? Supportive of audits, but don’t think you have the time for an audit. Need emergency call to action, put together a task force, pull data. You have to go after the buyers. System is set up for buyers to be a black box if they want to be. When you have that volume of cracked corn coming out of Turkey and look at soybean prices – not dealing with a real market when percentage o what you’re seeing is contaminated. No financial institution will want to touch that. If not actually enforcing the law – these countries don’t penalize criminally – making a fortune and our growers are losing. There needs to be additional action.

Amy: Challenges about foreign trans-shipments? Point of departure of import certificates.

Frank: Need to think about financial instruments and commodity trading, you can put the institution that is underwriting and where did the soybeans come from. Know a large percentage of acres in Ghana and some must have been re-labeled in Ghana – that’s difficult to track. Look at spread between conventional and organic corn – families have invested future in this label. There’s nothing but administrative processes and it’s very disappointing. If job of NOSB is to protect integrity of supply chain, it isn’t happening.

Franklin: Yield per acre estimates? What did you use? Import data? What is the main loophole?

Frank: Give me a call. I don’t know main loophole, I would have sent it to you. It seems to be that we need to make them less agile. In India, post-anti soybean dumping, they disappeared when India went offline and then suddenly Canada has it. What is percentage of US acres planted to soybeans versus Ghana and estimating certified organic acres is incredibly difficult. What is the margin of error that USDA is willing to accept? It should be zero b/c fraud destroys the market.

Justin Raikes – Raikes Organic Farms (CACS)

Certified organic for 5 years, employs about 20 people part-timers included. Fraud issues: we agree with what Franklin is saying. We’ve had hug losses due to fraud. Our whole team works hard to follow letter and spirit of the law. Doing everything we can to protect integrity of the label. We also sell non-organic retail beef. Through our retail relationships I can tell you retailers are not interested in carrying fraudulent products. They are looking for guidance form NOSB and USDA. I support geo-tagging and anything else that would clamp down on the fraud.

Ginny Olson – Lockton Companies Crops (CS)

Crop insurance agent. Work primarily with organic growers. What’s considered good farming practice? Can I plant my soybeans into rye? This question came to me 6 years ago and got different answers about what is considered a good farming practice. Took letters received from experts and after RMA said good farming practice, insurance approved it. If agents not getting pre-approval, there are farmers that are not being paid claims. I get calls from farmers that say, hey should this be paid? They are being told they are out of luck. Different farmers, different scenarios, but was able to help by providing info about good farming practices – 3 of 5 got claims paid. Lack of consistency is a concern. Farmers are following expert advice. I have reached out to many different experts and sometimes it’s crickets and don’t get a response. One extension office said they see this is benefit but can’t put in writing b/c not enough data to support it.

Wood: Are you saying we’re dealing with human error, subjectivity, bias against organic?

Ginny: Lack of education possibly. Have good adjusters who want to do right, but insurance company shuts them down. Not sure it’s a thing against organics. Can do practices that may not be norm for conventional. Ask them to provide at adjuster training – what’s a common practice – not sure if they do that.

Aaron Hobbs – North American Coalition for Insect Agriculture (Crops (CS);Policy Development (PDS);General)

Executive Dir. Want to introduce our industry, what it is w are doing, and the work we are looking to do in the organic industry. We are a trade organization growing insects, mealworms, crickets, and BSF larva. Our industry is growing. Our two areas of focus are 1. our FRASS (byproduct) being certified as organic. FRASS is only referred to in the negative in USDA documenting and that makes it hard to register our FRASS. 2. Short term goal is getting our products to be used up to 5% including rate in foods. We want to sell our meal and products into organic pet food. These are our first two priorities.

Nate Lewis: Are you looking to get those registered as a crop input? Livestock manure there are ways to reduce pathogens, what is the way to do that with FRASS?

Aaron: Some of our members already have an OMRI certification. It’s just not repeatable due to the feedstock they are feeding their insects. We have a variety of processes for FRASS handling, the three insects the processes are slightly different. Some products don’t require processing, others its heat.

Kim: From a protein standpoint going into petfood industry is the market entry? Correct? Can you see this as a protein offset into livestock feed. This has a lot of room for growth.

Aaron: We want to provide our products into all food and feed. Absolutely. Tyson is partnering with one of our members.

Emily Musgrave – Driscoll’s Inc. Crops (CS)

Organic Regulatory Manager. We are a community with a common goal. Continued allowance of plastic mulch and covers – plastic mulch is essential tool for controls of weed and disease. Plastic mulch is widely used by Driscoll growers, particularly strawberry growers. Working to reduce plastic footprint. However, without viable alternative would be catastrophic. Although not being widely recycled we are seeing more options available. Recycling companies are using innovative technologies. Widespread practice of recycling is a few years aways and we will continue to work on this to make it an industry wide practice.

Jerry: What percentage of strawberries are organically grown?

Emily: depends on which region. Want to say it’s the highest in Baja – 100%. Across the board, I’d say about 20% are organic.

Jerry: How can we move this needle – how much of your time do you spend with conventional side working with this issue?

Emily: None of growers want to see plastic going to landfill. We work with organic and conventional across the board.

Nate: Growth in availability of recycling – is there an open door to make recycling a requirement for use of plastic mulch? How can we encourage it?

Emily: Don’t think we’re there yet on a requirement b/c still not facilities to take it all to. Need to make sure have enough facilities otherwise growers couldn’t meet it.

Jerry: Were you asking Nate about a requirement into organic or organic and conventional?

Nate: Not much control over conventional.

Harriet Behar – Farmer, former NOSB Chair (General)

[This commenter provided their comments in full.]

Hello, my name is Harriet Behar with the Organic Farmers Association. I am a past NOSB chair, a certified organic farmer and long time advocate for organic integrity. Please refer to my written comments, as well as the OFA and NOC comments for more detail.

Vaccines: The current rule mandates for a GMO vaccine to be allowed in organic, it must be reviewed, approved and placed on the National List. 205.105e. The National Organic Program is allowing accredited certifiers to ignore this part of the rule, and some allow GMO vaccines, or do not inquire what is the GMO status of vaccines used on livestock. It is a dangerous precedent to allow a section of the rule to be ignored in an arbitrary way. The previous NOSB recommendation to allow GMO vaccines if there are no commercially available nonGMO vaccines is a workable solution to this issue, and the current NOSB should pressure the NOP to implement this as soon as possible.

Consistent Location Identification: This proposal has some merit, but organic farming is very diverse, with producers having various knowledge and willingness to engage with technology as well as a variety of ways of farming their various fields. The current proposal mandates the use of GPS coordinates for all organic locations. The proposal should go back to subcommittee and remove the mandate. This should be seen as one of many ways to locate organic production. There are many scenarios for both small and large farms where this mandate would put a significant burden on farmers.

Excluded methods: The recent SECURE rule by APHIS which does not recognize gene-editing, such as CRISPR ,as genetic engineering. The USDA has not required a marker to be put in these gene-edited seeds, so use of testing to determine gene-editing is impossible. The developer of the seed does not need to inform their buyers that the crop was gene-edited. Our organic friends in Canada have a similar rule and we and they are concerned that protecting organic from this form of genetic engineering will become very difficult. Please pressure the NOP to adopt the NOSB recommendations on excluded methods, which state gene-editing is considered genetic engineering in organic. The CACS subcommittee needs to have this gene-editinissue on their work agenda.

Hydroponic: The members of the Organic Farmers Association have consistently identified the false organic certification of hydroponic as a priority issue. Many of the written public comments also expressed this same concern. This is not a settled issue.

Amy: Talk about consistent location – in terms of GPS coordinates, it could be street addresses, parcel numbers – do you think these are acceptable?

Harriet: Yes, in concert with more than one. This mandate of GPS location as one mandate has gone a little too far. Can have different GPS coordinates in one field. A lot of little issues having been an organic inspector, being a mandate, in tracking those numbers.

Nate: what language would you like to see in this document to show only on certifiers?

Harriet: Having it be a mandate, in every single field and every single location will be a big burden on certifiers. Not against it, but don’t think it should be a mandate.

Mindee: Gene editing on agenda?

Harriet: APHIS – 2 years or so ago approved gene editing to not be labeled. If it was not a plant pest, or if developer determined it could have been accomplished through natural mutation then USDA does not consider it genetic engineering. If gene editing is excluded in organic, we need USDA to recognize. USDA could have mandated a marker so nowhere to test if been gene edited. The only commercially available crop is mustard greens, but wheat corn and rice are all in the pipeline. Will come to the forefront fairly quickly.

Mindee: What can CACS do?

Harriet: Need to look into the issue – EU may say since can’t track whether gene edited, not going to accept it. Think NOP needs to say gene editing is genetic engineering practice.

Allison: Back to locations – take seriously your concern. Minor requirement spirals into something else, is there language to recommendation that provides for exemption.

Harriet: Have a menu of various items, if certifier can’t figure out where the field is then that is a problem.

Allison: simplicity and consistency w/ narrow conditions that address concerns. I wouldn’t want deal breaker for farm and still get at this.

Nicole Dehne – Vermont Organic Farmers (General)

[This commenter provided their comments in full.]

My name is Nicole Dehne, I’m the certification director for Vermont Organic Farmers –the certification program owned by NOFA-VT representing close to 750 organic producers in the state of Vermont. I would like to thank the NOSB and NOP for all of your hard work.

I would like to comment today not on any specific agenda item but to discuss a broader topic of concern that we are noting in Vermont but that I believe is also felt beyond our state. This is the increased record keeping and paperwork burden on certified producers.

Over the decade, our industry has been working hard to reduce fraud and improve enforcement of the organic regulations. This work has culminated in the recent SOE rule. We are now at a crossroads for how we implement and interpret this rule.

I am concerned that if we use this rule to require more records and paperwork we will discourage small farmers and processors from getting certified and will likely see certified producers drop their certification.

The vast majority of our farmers in Vermont wholeheartedly believe in organic farming practices. Whether certification existed or not, they would be using organic practices on their farms and in their processing facilities. However, many of them struggle with keeping up with the record requirements we demand of them. Ironically we could lose these growers despite their alignment with the practices.

We have to keep in mind that records are important but are not the whole story. Records and paperwork can be falsified. I recently had an auditor tell me with a smile- that if it isn’t written down then it didn’t happen. But the absurdity of that idea really struck me. Because obviously, things can easily be written down that don’t happen. Putting too much of an emphasis on the paperwork means we may be missing what is actually occurring on the farm. Imagine an inspector furiously calculating the dry matter intake from pasture, but not looking up to determine whether there is even enough grass to support that number. My point is that the paperwork and audits can tell you some things, but they can’t tell you everything.

So here are my suggestions-

We need to invest in education. Our producers are most successful when they adopt organic practices because they believe in them, because they see that they work, vs. only seeing the benefit of a higher price. TOPP is a great start in this direction.

We need to be sound and sensible about using record keeping as a tool. We can not only depend on records to prove compliance. And we need to keep a 30,000 foot view on why we are asking for records and what we are trying to prove.

But most importantly, we need to start treating operations differently. SOE is giving us an opportunity to assess each farm or processing facility’s risk. We should use that risk assessment to then determine what proof we need to verify their practices. It may be that operations that are high risk with complex supply chains will be required to provide more proof and more paperwork while those farms selling direct to consumers will provide less.

Kyla: Speaking about the requirements morso in how we might see attrition. I do a lot of moderation at PCO, and almost all of them are because of recordkeeping issues. It’s a real challenge for those who are certified. Wondering how better record keeping systems come into play to not make them a barrier?

Nicole: All of transition work will benefit certifiers too. Increasing level of recordkeeping is an improvement, but it has changed. Helping producers understand requirements so they can be prepared is important. Certifiers and inspectors often just require records because it’s easier. But for example, some farmers have a sales record that should sub as their harvest record.

Nate Powell-Palm: How do we not let perfect be the enemy of the good. What is the role of consultants here?

Maddie Kempner – NOFA‐VT (General)

Skipped/unable to join.

Jaydee Hanson – Organization‐Center for Food Safety Materials (MS); General

Center of Food Safety has been involved with NOC comments and we support those. We have some add ons. Focused on 3 things. I’m going to talk plastics and GMO vaccines. Center encourages the NOSB to initiate discussions for reducing plastic in organic production and handling. Break discussion into plastic use and production and plastic used in packaging. Within those 2 areas need to identify which plastic uses are essential and which can be moved away from. I would be careful about assuming how much any plastic is recyclable. Plastic manufacturers have been misrepresenting extent of recycling capabilities. Need to look at what plastics doing with soil. We’ve talked before about PFAS and our organization is pushing EPA and FDA to curtail PFAS.

Steve Ela National – Organic Coalition/farmer (CACS; Crops (CS); Handling (HS))

[This commenter provided their comments in full.]

Good afternoon,

I am Steve Ela, the National Organic Coalition NOSB Specialist and an organic fruit farmer in western Colorado.

NOC appreciates the work of the Board to distribute a document on Inert Materials for public comment, despite the fact that it could not be included in the formal NOSB material packet for the Fall. The Boards diligence and work on this topic is noted!

Inerts should be individually listed on the National List. OFPA requires that materials be listed individually. The National List is inherently a positive list – meaning that synthetics must be listed in order to be used. To accept a broad category listing and then expect the organic community to petition for prohibition of certain materials turns the list into a negative list, something that runs against the basic principles of the use of synthetics in organics. It also puts the onus on the organic community to petition to keep endocrine disruptors and carcinogens out of organic production when in fact the onus should be on the user to show that the synthetic is needed.

Furthermore, if only a reference to a broad EPA category is used, the organic community has no way of even knowing what materials are being used since only a Material Review Organization would have that information. If we simply move from List 4 to a reference to another EPA category we are taking the proverbial frog in the pot of boiling water and simply moving it to another pot of boiling water rather than rescuing the frog. I would be happy to talk more about this if you have questions.

NOC recognizes that individual listings will take work, but we have provided ideas for reducing the Board workload in our written comments. For example, materials could be grouped into classes and reviewed as a class, similar to how the Board treats coppers and chlorine materials. Each material is specifically listed, but the Board does one sunset write-up for the group and then makes any specific notes if one material is slightly different.

On a separate note, NOC urges the Board to ask for a work agenda on organic swine management. Swine were primarily omitted from the OLPS and should be covered in similar ways.

NOC also urges the Board to start work on the use of excluded methods in fermentation. This is a rapidly expanding field and one that we must get a handle on before we inadvertently start allowing excluded methods in organics because we simply don’t know where and when they are being used. A prime example is the work agenda item on biodegradable biobased mulch film where it is acknowledged that excluded methods are being used to make the films. If we don’t establish a policy on the use of excluded methods in fermentation soon, we risk losing control of the whole topic.

Finally, NOC will continue to raise the issue of the potential environmental damage in marine ecosystems from the harvesting of marine materials for use on organic farms. This applies specifically to liquid fish and alginates, but also more broadly to any marine materials used in organic products.

Since the National Organic Coalition is known as NOC, I will finish with a NOC NOC joke.


Whos there?


Gum who?

Gum ption. The Board should have the gumption to add annotations to all the gums and other materials on 605 requiring use of organic materials when they are commercially available. We have seen organic gums used in a variety of dairy products from major producers, showing that they are certainly commercially available.


– Organic swine management

– Fermentation

– Sunsets – liquid fish & Alginates – oppose irresponsible harvesting of them

– Gums – out there in organic form

Delip: Gene editing, since you mentioned excluded methods. Can you elaborate.

Steve: NOC is very concerned about the use of gene editing not following traditional breeding techniques. CRSPR is a concern. We will have a call soon talking about Canadian side of things. Seeing more issues of CRSPR tech not being as clean as expected, seeing some mutagenic and carcinogenic effects in the plants it’s being used. We certainly don’t want any of the gene edited plants or seeds being used in organic.

Delip: I think gene editing or removing is

Nate Lewis: OFPA and international criteria require inerts to be listed individually. Some things are grouped together, what makes inerts different to list individually?

Steve: I disagree, the groupings are fairly tight categories and they are the exceptions and they were used as a shorthand to get things done when resources were scarce. I don’t think that should deter is from doing better at what we are doing now. Would be wrong to say we should ignore OFPA once again. How would be NOSb decide is an inert is essential if it’s confidential? NOC’s push is more transparency. We want to be able to know what is being used in organic. Thanks to OMRI from putting together list of what is being used, otherwise we couldn’t even talk about this.

Amy: On risk, regarding NOC’s comments on residue testing for global supply chain. A lot of certifiers use global matrix for risk. Split or parallel operations: one trend I am seeing is conventional under one company name and organic under another. That could circumvent them being included in risk assessment.

Steve: The inspection is key, when the company is organized under two different names, and it’s obvious the two things are being run simultaneously, the inspector has to ask questions. The inspector should raise a risk flag. The inspection is going to be key.

Brian: Wondering if you could share with group some of your insights from past work. Potential for NOSB & NOP to make requirements that go beyond the other gov’t requirements? Like requiring inert ingredients be publicly disclosed in organic pesticides, even though that private in other uses? Or could w require that any plastics used in ingredients not include PFAS, BPA, etc. Thing we know are dangerous components.

Steve: It’s complex. The NOP does not have the authority to usurp the EPA on pesticide labeling. But we do have the authority that synthetics have to be on the National List. And if it’s a synthetic it has to be reviewed. So we might not know what that products is in, but I would at last know the subset of inerts that COULD be in the products. As a consumer and end user I’d like to know what I am spraying. Plastics are kind of similar. We cant usurp FDA overall, but we do have authority over contamination over organic products.

Mindee: In conversations with consumers, on “why organic?” how do you inspire them?

Steve: Note we are trying to keep soil on farms, keep nitrogen in farm, keep nutrients where they are supposed to be. Your tax dollars are subsidizing what damage agriculture does. Organic is spending the time so that your taxpayer dollars don’t have to do that.

Anne Ross – The Cornucopia Institute (General)

Good afternoon. My name is Anne Ross. I am an Organic Investigator for the Cornucopia Institute and member of the policy team. I’d like to thank the NOSB members for their time here today.

I’ll briefly address three issues:

The first, is the consistency in parcel identification. We support the baseline requirement of using GPS coordinates to obtain consistent location information, unless the operation or certifier can articulate with specificity why an exception is appropriate. As noted in some of the comments, a one size fits all approach may not be appropriate for some operations. For those operations, we urge the NOP to issue guidance specifically articulating the circumstances in which an exception to providing GPS coordinates would be acceptable. Clearly, the goal is to establish an accurate means of identification so inspectors can do their jobs – if it’s not GPS, then a verifiable alternative for that operation should be required and the guidance should clearly articulate the standards for exceptions.

Second, we support building on the SOE framework of additional residue testing. We have long supported testing of bulk imports. We know thousands of metric tons of fraudulent grain were imported into the U.S. having been treated with prohibited fumigants. We called for consistent, unannounced testing then and continue to do so – let’s identify the noncompliant product before distribution, and when possible before it travels through the supply chain. At the very least, testing is a deterrent for bad actors. Strengthening periodic, and unannounced residue testing will stop noncompliant product from entering the supply chain or help identify where it has.

Finally, we must join together in dispelling anti-organic propaganda. Consumers often ask about information they see from sources like social media. A look at social media content, for example, shows there is in an increasing amount of misleading information about food labels generally – often hailing the virtues of some that carry no legal or generally agreed upon definition –and others that disparage “organic.” Transparency in “organic” helps ensure that there remains some baseline consensus about the facts.

We must ensure authentic “organic” is not redefined by misinformation campaigns, the disastrous impact and influence of factory farming, and the unchecked power of monopolies in our food system. When a few mega companies consolidate and control the food system and the messaging around it, consumer choice is nothing more than an illusion. A food system where several corporate giants dictate what we eat, what we grow, and how much farmers are paid is without a doubt a threat to the “organic.” These few should not define, dictate, or dilute what “organic” means.

Thank you for your time today.

Linley Dixon – Real Organic Project; Adobe House Farm, CO (General)

[This commentary was provided in full by the commenter.]

I’m Linley Dixon, an organic vegetable farmer from SW Colorado and the co-director of the farmer-led Real Organic Project. Last spring I had the privilege of going to Washington DC with the Organic Farmers Association to talk to our US representatives about the fact that organic should automatically be considered “climate smart” agriculture because of the soil health practices and pasturing requirements that are written into the law. The quick response of congress, it was almost on autopilot, was “Organic can never be “climate smart” because organic farmers till”. I was taken aback by this because conventional “no till” farming that they were saying was “climate smart” uses herbicide termination and synthetic fertilizers that are now running off the land even more because the fertilizers are now applied on the surface and they also run down cracks in the soil that are now there because of the lack of tillage and this is creating eutrophication in the waterways worse than it’s ever been. So we need a new term: Real “climate smart farming”. This is low-input farming where organic farmers grow their own fertility for the next crop and then may or may not incorporate or till that organic matter. I understand that “organic” is always up against these kind of misinformation campaigns generated by the chemical industry. The CEO of Syngenta recently called for an end to organic farming claiming that organic has 50% lower yields and because of that, quote “People are starving in Africa because we are eating more and more organic products.” Everyone here know we have global overproduction and a lack of distribution. So I understand that we are up against a HUGE chemical lobby that rewrites the story of organic. And the natural response especially when I talk to the current NOSB members has been to band together to fight these strong attacks against organic. And they use words like “bigger tent” and “inclusivity” and “commonality” so we can be stronger against the chemical lobby at the USDA. However, I want to caution that we should be aware of who is saying these things. Because that same subsidized chemical soybean production is what is being used for the fertility for the organic hydroponic industry in the form of hydrolyzed soy. The Organic hydroponics industry benefits from subsided conventional soybeans so everyone in the “big organic tent” has very different interests. The organic hydroponic industry is now so powerful that they set the price point and control the shelf space for the most profitable crops there are. My take home point today, is that In the EU where there is higher integrity under the organic program, where they do not certify CAFOs or hydroponics as organic, organic is growing faster. 10 times faster than in the US where we are creating a big tent. This is an important point, in the EU where a higher bar has been set for organic and there is better enforcement of the rules, there is faster growth. Because people have faith in the label. With a “watered down” standard, people are looking to other labels to find good food like “pastured” or “grass fed” or “comes from family farms” or “non GMO” none of which have a legal meaning and all of which allow chemicals.

Mindee: I think about messaging all the time. How do we postition organic as a positive?

Linley: losing our power and choices b/c of consolidation.

Allison: the solution I’m struggling with is if do more research, my understanding is it’s challenging for small scale producers to participate in the research. How can data and research help?

Linley: no-till chemical farming might sequester more in upper layers, but at deeper layers – if you just look at synthetic fertilizer production, just production of them alone should be enough – need to rewrite the story – we need to go after the inputs.

Amy: What are definitions of no-till?

Linley: some farmers incorporate a little bit of compost. In general, no-till is chemical farmed. For vast majority there is tillage involved if organic and no—till is chemical.

Tony Michaels – Organic Farmer (CACS)

Transitioning acres in Western Nebraska. Our team has been farming organic for the last 20 years. We primarily do row crops and alfalfa. Crop insurance: the conventional crop insurance does not work well. Solution: Problem with insurance is you use your past history to determine future risk. The problem when you do something new you don’t have “past” experience This happens many times in insurance industry. They use other tools to forecast future in the past: we need to do this for organic! They need to get more comfort with this. We are a lot more knowledgeable and a lot less risky than shooting a rocket into the sky, but those rockets are insured. Organic is heavily regulated which they worry about But if we do this correctly it can create new products, allowing banks to engage with them. It can be part of how banks loan. We can take insurance model and apply it to fraud coming over on ships. We could have an insurance model that insurance against those ships having real product. We could engage insurance industry more: the knowledge that they would apply would also mesh with the practices we want to encourage.

Dustin Ploeger – Scoular Grain ‐ Organic Grain Merchandizing CACS

With Scoular Co. Been in organic market for 25 years. Represent blended view of market. Customers who want to buy lowest cost and those who want to sell the highest. It’s a balancing act to risk management. At end of day flat priced traders. In organic grain market, it’s ripe with several high profile bankruptcies. Trade environment is difficult. My belief is that we have been successful focusing on domestic. U.S. relies heavily on imports – participants in this trade absorb tremendous risks. We champion testing requirements, geo tracking to level the playing field. That said, we would ask for recommendations of reporting noncompliance – we see negative and positive effects of price movement – immediate reporting of fraud that could tamp down shock waves that are highly disruptive.

Nate: “organic” – carbon based and other solvents for deterring fraud in see meal world? And standards already require periodic residue testing must be made publicly available?

Dustin: there are more ways to trace hexane and solvents – should be done at ports of entry. CPB should rapid run and if something is found how does it get communicated back to market. Standard would be 3rd party to run tests at ports of origin and entry.

Amy: have you seen any interactions w/ international brokers? Is there more?

Dustin: a lot is not necessarily solicited and we get international inquiries of purchasing Indian, African, Turkish origin. We’ve taken an active pass on a lot of business. Net effect is to let others know who to stay away from – again looking for how CPB can communicate to market “buyer beware.”

Kimberly: Lack of transparency tends to create hearsay without factual components. Do you do international and domestic?

Dustin: Yes, in organic space but it has been minimal for not fully trusting the supply chain. Probably 10-15 years ago, company had a larger footprint. 5-6 years ago it trumped back considerably.

Kimberly: If you bought product and had it tested and it tests clean, product gets to clean and doesn’t test clean. Who becomes financially liable?

Dustin: Usually depends on trade terms and where risk transfer happens.

BJ McNeil – organic farmer (CACS)

I want to expand on what Dustin just talked about. The impact of the import on organic is quite severe, especially for our farm. Sunflowers form 2022 there is no market for due to imports. Caused us to move a lot of acres out of organic because there is not a reliable market. Weve had trouble collecting on contracts this year due to competition. Reiterate what Dustin said: quite an emphasis on whether an acre is certified organic or not but don’t emphasize the products in the food chain are organic. That needs to be looked at. What’s more important: verifying that every acre in US is organic, or verify all the food and feed sold is organic? The approval of some products to be used as organic: we don’t use enough common sense. For example, this year we were low on molybdenum. We couldn’t use a product due to issues with proving we needed selenium.

Kristopher Klokkenga – organic farmer CACS

4th generation farmer. Speaking about insurance and things can improve on. This was first year ever had insurance claim on field. My conventional t yields are in 70s for soybeans and mine is 36 b/c I had one year of 50 bushels. The t yields discourage farmers from getting into organic. Understand in 2017 that conventional t yields were no longer allowed and dropped in half. If I know I can produce 50 bushel beans could we not raise that to make it more attractive to grown. Whole farm insurance – started organic entity in 2019 and I need 5 years of taxes to justify whole farm insurance. Problem is that I came in under previous entity and converted farm to organic, if I pull in conventional yields, and sell twice as much $ in organic, how do you bridge that gap. I’m a multi-generational farm trying to exist. Some things need to be in place for organic farmers in the stage I’m in.

Peter Gunther – Organic Cotton / Peanut producer (CACS)

Farmer in West Texas, growing for 18 years. Organic peanuts: we have a lot of organic peanuts being imported. Heard that peanuts are not tested when coming in overseas. When they do it’s small amounts. Very challenging to compete.

Amy: Heard some farmers from Midwest talk about grain imports have impacted them. From peanut perspective, how have imports impacted you?

Peter: We’ve had to take some of ours out of organic because its not cost effective. The price they are getting shipped in for is cheap. The only way we can make money is with new ground to develop that does not need as many inputs. The organic peanut market is going to take a huge hit. In 2011 we had a major drought here and there was a major shortage. So there was a lot of Chinese peanuts to fill that gap, and since then it’s opened the floodgates.

Logan: What do you rotate with? Any cash crops?

Peter: Wheat and corn is the better rotation for peanuts. There is no market for organic corn either. Organic peanuts is the only thing that’s worth growing to make money.

Kim: Thank you for sharing how your farm is competing in the marketplace.

Aaron Zimmerman – organic producer (CACS)

Two topics: 1) crop insurance; 2) imports/fraud

Northeast Nebraska. 2500 acres of certified organic – diverse farm. Crop insurance: when start transitioning and when get to certified organic start over with t yield, but needs to be addressed. Biggest challenge is the imports that are not necessarily organic competing with organic producers and they are flooding our markets and squeezing margins. In favor of standard location info and testing on all imported grains. I don’t know if 100% cure all, but we need to put those road blocks up to keep bad players out. Need more equitable market that works for U.S. producers.

Amy: on crop insurance, you mentioned many crops and how many are insurable?

Aaron: Only corn and soybeans of what grows is insurable. Could insure the wheat, but juice isn’t worth the squeeze so I have not taken insurance on wheat. It would be nice if we could address this. There’s more to it than profitability. It also has to do with American consumer being able to trust organic brand.

Mathew Keegan – Caprock Grain (CACS)

Been involved in organic industry predominantly on animal feed and global supply chain. Want to chime in on concerns that if consumer knew what was really going on, we have a lot of problems in this industry. There is a tremendous amount of fraud and I think we are stepping over dollars to pick up dimes. Imports like to be picked on and rightly so. We all know that organic program is process based system. There is deliberate fraud going on and north of 50% coming into U.s. is fraudulent, blended with solvent extracted meals. They are blending with other than hexane, but when look at African meal they are using acetone and methanol. There is precedent to test this cargo when it comes in. If you recall, in early 2000s we had melamine out of China – FDA got involved so when product came in you got a letter from FDA saying it was adulterated and need to destroy or reexport it. Had to hire a lab and then prove it was not adulterated. We have technology, labs, and need to test at ports. We have a huge risk. If want to pick on imports, this is easy solution.

Kim: What do you do to validate supply chain?

Mathew: Every product goes to 3 labs. Then sample goes to pesticide residue and another lab for all solvents. Whole profile and can see the analysis. The request of the lab is full solvent profile.

Kim: how do you make this info transparent? And if testing at origin and at destination and something flags, how do you handle it?

Mathew: shipper, 100% and I’m extremely disappointed with certifiers and how handle these things. 60-90 days ago requested certifier look and there was fraudulent material; when talking about solvents, this is purposeful. We had supplier and I asked for sample and we had it go directly to the lab. We got the test report and certifier asked what the chain of custody was and certifier didn’t believe. Got the bill of lading for proof. They didn’t’ do anything. Somebody in the market place is going to buy this cargo and it has implications for domestic farmers. Fact that certifiers not stepping up and not even sure if they know what to do.

Nate: Could you provide us with solvent screens? Could you email it?

Mathew: Sure. I’ll send email with certifier.

Jack Fehr – Organic Farmer (CACS)

Northwest Iowa, organic corn, soy, and oats. The imports are a problem. The certification here domestically, especially inspectors, a lot of the inspectors we’ve dealt with do not understand large row crop organic farms. Weve been doing it 25 years, and no one really knows what they are looking for on a large organic farm. I don’t know how that gets fixed.

Nate Powell-Palm: You are not the first person to raise this concern. There is a lot of movement in human capitol.

Amy: Your family have been organic since the 90s, have you had experience selling products internationally and can you highlight those experiences

Jack: Weve had Chinese inspectors come to certify our oat fields. They do a better job with large scale farm certification than the inspectors we have domestically. So that causes an issue with thinking a lot of imports being fraudulent, when actually the inspectors do a better job.

Amy: Are they asking tougher questions? Or how do you think it’s better?

Jack: Yes, definitely. They also ask the right questions. It feels like the inspectors that we’ve had domestically don’t deal with a lot of large acreages, but the Chinese do, so the numbers make sense to them.

Rhodes Yepsen – Biodegradable Products Institute (BPI) General

Executive Director of BPI – focusing on importance of compost and for collective efforts to address climate change. Compost is a biological process and is a result of that process as a stable soil amendment. Compost definition was written when on-farm activity and now need updated definitions. BPI does not want to see synthetics allowed in compost.

Allison: PFAS is a concern in compost. Any developments in detection?

Rhodes: very concerning. BPI established a rule prohibiting it in compostable products. There have been advancements in testing. Remains a challenge for test methods, sensitivity of tests. BPI has multi-tiered approach to screen to cast a wide net, but also established rules around screenings around all ingredients used. Looking at all ingredients use and going far enough through supply chains.

Nate Lewis: welcome input on who should be at the table. Don’t need to make the list on this webinar, but I’m intrigued to get this info. Clear players that you could help us paint partnership map.

Charlotte Vallaeys – General Mills (General)

[This commentary was provided in full by the commentor.]

I’m Charlotte Vallaeys, the organic expert at General Mills. General Mills is a 155-year old company and a leading producer of certified organic packaged food in the United States.

We are a proud member of the Organic Trade Association, and please refer to their comments on other topics that are on the agenda for this meeting.

I’d like to comment on the CACS Discussion Document on Opportunities in Organic, and on expanding opportunities for organic farmers.

At General Mills, we’ve long recognized the value of organic practices for consumers, farmers, and the planet. As a global food industry leader, we understand that organic is an approach to food production with many positive environmental and social outcomes.

The potential for growth in organics is significant, and we recognize the important role that our company plays in assisting organic farmers in expanding their businesses, specifically by increasing their access to organic markets. To succeed in producing and selling more organic food, it’s crucial for consumers to fully understand the benefits of the USDA organic seal.

We are doing our part to help educate consumers about organic benefits in several ways. We were part of the OTA task force that created a data-driven toolkit on the Organic Wheel of Sustainability, which highlights the many ways that organic is good for the planet, people and animals, and business. We recently updated the back of our Cascadian Farm cereal boxes to highlight that “organic is good for the planet.” It calls out several benefits, including that organic agriculture regenerates soil health, reduces chemical pollution and promotes ecological balance. We support organizations like OFRF, Organic Voices and the Organic Center that do critical work to raise awareness of the many ways in which organic is good for people and the planet.

We appreciate recent investments from the USDA in supporting the transition to organic farming. Building on this momentum, we are asking for consideration of a consumer-facing organic promotion initiative, which would support public and private sector investments in organic agriculture and practices, and promote the benefits of organic.

Thank you, and thank you to all the board members for your time and dedication to the organic industry.

Amy: Thanks for participating and everything General Mills is doing. Our farmers really wanted help in expanded markets, and consumers anted more education.

Nate Lewis: Want to celebrate Cascadian partnership.

Charlotte: General Mills donated the Cascadian farm to the Rodale Institute for a research center.

Allison: Are you seeing much connection with TOPP program from where you sit; getting connected to producers?

Charlotte: Not being directly integrated, but love to see what is happening. We have more consultants in the supply chain due to partnership with Rodale. Help to keep existing organic farmers to keep pushing their practices.

Heather Spalding – Maine Organic Farmers and Gardeners Association General

Deputy Director, MOFGA. Certify 535 organic farms. 15,000 members. Urge you to adopt rigorous review process for inert ingredients. Revision to National List must include full evaluation of human health effects, whether suitable nonsynthetic alternatives. Agree certifiers should know location of all operations. GPS is just one tool, but should not be mandated. Regarding residue testing – support. Regarding equity – imbed racial equity in NOSB programs. Oppose use of organic label for hydroponics. Finally want coordination to address crisis of PFAS contamination. More than 4100 farms have been notified by DOD of possible contamination.

Greg Schreiner – Silver Reef Organic Farms (CACS; Crops (CS); Policy Development (PDS); General)

Organic Farmer rotates between bean, corn, and small grains. Crop insurance makes a difference in keeping the farm. Don’t believe NOSB document is missing anything and think it accurately reflects problems. Need crop insurance to work for all farmers. Need crop insurance to mitigate risk. I’ve read USDA Risk Mgmt website, but I didn’t know before this was available. Still disconnect b/w farmers knowing the tools available. Farmers don’t know about this website. This info should be sent to certifiers. Many farmers don’t adopt crop insurance b/w or cost/risk assessments. Can’t find data on how t-yields established. Suggest 20% reduction against conventional yields. More farmers will buy crop insurance – suggest USDA collect pricing by region. Believe more farmers would adopt if premium due date is 30 days after harvest. Operational cost often take priority over others.

Francis Thicke – Certified Organic Farmer; Former NOSB member (CACS; Crops (CS))

Stated farming organically in 1975. Back then the pioneering organic farmers did it for principle not profit. Real organic farming is real regenerative. Rodale paired regenerative with organic early on, but that has disappeared. Big food industries want part of the organic pie: they came in and scaled up, they industrialized it. Hydroponics, CAFOS, livestock in warehouses. Industrialization in organic. The NOP has not been able to combat that; because there is a huge lobby power for industrial organic. So the Real Organic Project became necessary. Now the regenerative and “climate smart” is being co-oped, and a real plus for industrial forces. They want to make it as cheap as possible. We have to watch out for that/ No-till and roundup are considered climate smart for many people. It does not regenerate the soil. We can do that with real organic, and for me real organic is real regenerative.

Dave Chapman – Real Organic Project; OFA; Long Wind Farm (CACS; Crops (CS); Policy Development (PDS))
[This commentary was provided in full by the commenter.]

I am Dave Chapman, farmer and co-director of the Real Organic Project.
I want to address some recent efforts at reform of the NOP. $300 million dedicated to the New Organic Transition Initiative could be a very hopeful sign. Strengthening Organic Enforcement might be a very hopeful sign.
However, it appears that the SOE is creating a huge burden on the very farms that are the backbone of organic. What massive fraud is it preventing?
What huge CAFO will be closed down by the updated OLPS?
We have to distinguish between new regulations that create actual reform and those that just check off a box but don’t change reality. The $300 million is an attempt to address the plummeting rate of farmers who transition to organic. It is down 70% from the transition rate in 2008.
But wouldn’t it be vastly better to actually enforce the law?
Prohibit ruminants living in confinement from being certified as organic? Prohibit hydroponic from being certified as organic? Then let the market reward farmers who are doing it right. Build it and the farmers will come!n
And so will the eaters.
The complicated part is WHY this is failing. We all agree that real organic is based on soil health, not on processed fertilizers. We all agree that we want to eat organic eggs that come from hens that go outside and scratch in the soil. We all agree that we want to drink milk coming from cows who graze in a diverse pasture.
Organic in the EU follows the principles of organic. Hydro is prohibited, and sales are growing faster than USDA organic in the marketplace. Now it is a billion dollars ahead of US organic food sales.
The US has about 20,000 farms certified as organic. There are 350,000 certified organic producers in the EU.
The US has 9 million acres of certified organic farmland. The EU has 40 million acres.
Is it possible that maintaining integrity and transparency is a better strategy for the growth of organic than building a “Big Tent” to welcome multinationals who twist the meaning of organic?
The NOSB has known this in the past. Francis Thicke organized a letter to Secretary Vilsack in 2021. It called out the disintegration of the National Organic Program. It was signed by 43 of your predecessors. They wrote that “the integrity of the National Organic Standards has eroded significantly over the years.”
None of this is a settled issue. It will never be settled until it is made right.
I call on you to follow in the footsteps of those 43 former NOSB members. We need all hands on deck to fix organic before we lose organic. There is a real danger. It will not be easy.

Kirsten Novak – organic consumer (CACS; General)

Mother of 5 children and farmer. We are transitioning small farm to organic. Want to share proper labeling and why organic so important. 3 out of 5 children became sick and we sought out medical help. When it failed we found holistic doctor. We found out all children had extremely high levels of glyphosate. We eat 90% organic b/c believe in it and kids still became ill. We are very passionate about labeling in organic and for farmers. If we can’t get farmers to transition and understand what this does for them and environment we can’t produce necessary amount of organic in America. Finding the truth is so vital. Organic truly does give us the best standard. Would love to see labeling jointly b/w organic and regenerative and I believe that is our best standard. We need to let consumer know what that means.

Bryon: where located? Source of glyphosate ingestion?

Kirsten: Iowa – nothing but farm fields around us. We had well tested and it had glyphosate in the water. We didn’t drink our water from well and when kids were sick and sure enough water was extremely high. Had to go through 3rd party to get water tested. Anything not organic, then glyphosate can still get in. Coming from conventional farm practice, the farmer in the 70s and 80s thought that sprays were the answer. It’s hard to get that older farmer into an organic practice. However, new farmers want to do what is right. Chemical companies are really knocking on organic saying it’s just a labeling gimmick. We need to focus education on this and let farmers know what’s in it for them and for environment and for next generation.

Adele Durfey – Clear Frontier Ag Management (CACS)

Director of sustainability. First, we need standardized location tracking; especially important because it’s a global program. That can take the form of GPS location or township information. Second, testing of imported products including quantity and breadth of chemicals. Only 5% of imports are being tested. Spent time in Ukraine managing 30k acres there. Organic production is almost non-existent there. I doubt that the farms fit the actual volume of things being tagged as organic. If there are not repercussions for not adhering to the standard. Ukraine is a non-GMO country, and prohibits all GMO products, it was a rare occurrence for me to see farms without GMO crops. Ukraine does not have processes in place to control their own agriculture. We are being charged for products that are likely not legitimately organic.

Jessica Schulken – Organic Produce Association (Crops (CS); Policy Development (PDS); General)

Rob Peters – Naturefresh Farms (CACS)

Naturefresh Farms, conventional and organic greenhouse. Strawberries uner glass. Speaking on behalf of organic produce association (OPA). As organic grows, should lean into techological advances. OPA supports USDA’s efforts to help transition, including in ground and controlled environments for decades. As technological advances continue this transition period is not reflective of the need to avoid prohibited substances. There should be an alternative to the 3-year transition period. All growers should be provided with ability to test out of 3-year transition. They should be able to get an immediate certificate if they can show no substance that is prohibited, including in non-soil mediums. Just have to show no substances are actually present. To foster a more inclusive sector, the USDA should break down all barriers to organic production. Looking forward to future work on container standards.

Jerry: You use CEA – controlled environment agriculture. That does not speak to the delivery system to the plant. Are you in soil?

Rob: In soil, in coco bags. It’s a soil, it’s a growing medium.

Jerry: Inert?

Rob: Yes.

Jerry: Okay then it’s a growing medium (not soil). We can go off that.

Nate Lewis: The law states the three-year transition so you’d need to have an act of Congress to remove that barriers.

Sylvia Wu – Center for Food Safety (Materials (MS))

Attorney for CFS. Inert ingredients in pesticides – main point is that as board considers this that the board must not accept blanket of inert ingredients, must be specifically approved. EPA review process is different. OFPA is limited to only those absolutely necessary. Must look at each new ingredient separately. Mandated by OFPA. Should move away from individual evaluation – they have to be. All OFPA requirements must be complied with. Individual review are required and necessary for organic integrity.

Nate Lewis: how about all other classes of substances? What’s unique about inerts?

Sylvia: depends on individual approaches to adoption to reference lists. Can’t say expert on all. Think there could be MOU or group reviews, but Board has to have understanding of what list entails. With inerts there is a know difference b/w EPA review and OFPA mandates.

Anais Beddard – Lady Moon Farms (CACS; Crops (CS))
[This commenter provided their comments in full.]

My name is Anais Beddard and I am the 2ndgeneration now running Lady Moon Farms. My parents founded LMF in the late 80s and were part of the founding farmers of the modern OG movement in this country. Our PA farm was the 7th certified OG farm in the state. We grew over the years alongside the OG industry and now have nearly 3000 acres with farms in FL and GA. These additional states allow us to offer year-round employment and minimize gapping on product to our partner customers. We are a fully diversified farm growing upwards of 40 different commodities ranging from the leafy greens to lettuce to tomatoes. We have been committed to the organic program for over 3 decades now and believed deeply that the program (while not perfect) was the gold standard for producing healthy food for our communities while leaving the land better than how we found it. It is our belief that the OG program no longer is the gold standard. There have been many issues plaguing the program, but the one that we have seen significantly impact our business is the allowance of hydrponics into the program. There have been a hand full of certifiers who refuse to certify these operations and we believe that this is not only right, but it is necessary. Improving soil health was written into the law as it is integral to the organic system model. Lady Moon Farms participated in that conversation when it happened. We do not need special circumstances to farm competitively, yet that is exactly what these farms are receiving. The standards are not the same. The audits are not the same. The quality of the produce is not the same. The consumer deserves better as many believe they are buying the gold standard in vegetable production when they buy the OG seal.

We do not necessarily think add-on labels are the best choice to differentiate in the marketplace, but are given no choice when the OG seal no longer fully represents what we do. Being one of the original certified organic farms in the country, it hurts to admit that the program has lost its way. We believe programs like the Real Organic Project are necessary to provide transparency and integrity to the end consumer. If we lose the consumer’s trust than we really have lost it all.

With the allowance of varying types of production methods, it is critically important that they are treated equally. There are already barriers in place for soil grown food that are not in place for hydroponic. I know the crops subcommittee discussed the use of plastic mulch in OG production. I wanted to touch on our view on this tool. While we try to minimize our plastic use across the farm, the use of mulch is critical to successful production, particularly in FL. While there are many benefits with weed and fertility management, growing in SW FL means we grow in very sandy soil. If we did not have the ability to use mulch, we would not be able to keep our beds physically maintained. One heavy rain of 4” and the entire bed would wash away along with the fertility we laid out prior. It is not unusual to get this kind of rain in SW FL especially during the start of our season. When you see other operations and the use of plastic laid onto the ground, plastic buckets, plastic everything….it is hard to stomach that those items are not being considered dis-allowed but plastic mulch is part of the discussion. It shows a disconnect between this group and how actual farming is occurring in the field.

Farmers are an incredibly resilient and optimistic group of people. Organic farmers even more so. I grew up on the farm and yet my perspective has changed completely now that I am running it. The challenges we face are constant. We need our organic seal to stand up for what we do and represent us to the larger community. I thank you all for you time and commitment to this endeavor.

Jerry: I would ask: do you not believe that the entire organic program is built around exceptions and scrutiny around those exceptions?

Anais: Yes and no. The entire organic program is built around soil. I am asking for an even playing field. You cant lose the original intent. They are saying they want to get rid of 3-year transition? But testing coco choir and soil and have that be equal. Don’t think that hydro is operating under an exception in the same was we are using plastic.

Jerry: The plastic covers are “not allowed, except for…” in FL you are using an exception to operate.

Anais: Are all these hydro farms not allowed to farm the farm where they are? Because that can’t be true for everyone.

Nate Powell-Palm: What products have you experienced the most competition from hydro?

Tomatoes. Some lettuce. Usually our lettuce is going more local, where tomatoes are coming rom far away and flooding the market.

Mindee: I joke I am the first generation not raised on the farm. As an NOSb member, I have not experienced so much pain in the compromise. Helps me to see that this is democracy. Does that help you in participating in the narrative.

Anais: I would answer differently 6 years ago. I feel like the outcome wasn’t heard by the farmers. I need the USDA organic label. If I didn’t need it, I wouldn’t keep it. I am going to continue to let our voices be heard not sure if I have faith it will change anything.

Gwendolyn Wyard Strengthening Organic Systems, LLC CACS; Handling (HS)

Slides. Founding partner; dedicated to fraud prevention. Organic wheel of sustainability. Spearheaded wheel while at OTA – benefits of organic. Sum of all of it’s parts. Backed by data and enforced by government agency. Created business to help deliver guarantee. Three points – focus first on updating guidance in NOP handbook for residue testing. More than pesticides – testing includes GMOs, heavy metals, others. Testing is critical tool for fraud mitigation. Industry and labs look to guidance and it is out of date.

Jerry: Heard a lot about SOE and one piece of SOE that haven’t heard concept, but in terms of detection and randomness as a tool. How do we stop these bad actors and strongly in favor of recognizing these folks are nimble and smart and take randomness as central element of detection?

Gwendolyn: SOE codifies unannounced inspections. Testing is most important part of this. That is why my comment about increased testing from industry. They are doing it for their own business purposes. In being prepared for inspections, they will start doing more of routine testing to make sure they are good for the unannounced inspections. Fraudsters go where it’s easy. Target hardening. Everybody makes it difficult for fraudsters. Randomness attached to unannounced testing is key.

Amy: Fraud prevention and room to increase testing from 5%. How far can we go up?

Gwendolyn: 5% is small. Many certifiers are above and beyond that. Not like everybody holding at 5%. Could see it go up to 10%. Before start increasing percentage. We need to look at where we’re at right now w/ training and education before start increasing the number. Testing is a tool to understand how well process is working.

Kim: A lot of fraud that is detected is transmitted via the rumor mill. Suggestions to increase transparency when entity is found to have committed fraud?

Gwendolyn: By time info becomes available, it has been years. We think it’s important to help before report fraud and early detection. Tricky b/c a lot of liability and legalities. Need to increase communication and education to find out where fraud is occurring. It has to come from a private entity that holds a lot of that info.

Kyla: Feel hopeful that going to be a useful tool in widespread way?

Gwendolyn: info that will start with operations doing a supply chain map; new certified operations will be doing supply chain mapping with info that you’ve probably never seen before. Certifiers will be connecting dots. Certified operations must do one up and one back and hopefully doing more. Think we’ll see huge increased visibility and challenge will be make info work as fast as it needs to work. Central data base and figuring out technology piece is so important.

Nate Powell-Palm: sustainability wheel is very helpful to describe what organics is. Where and who are best messages?

Gwendolyn: we all play a part; but I’m believer it is at the point of sale; it is at the point of making a decision. The champions in all of this are the retailers. It is absolutely the retailers that are the champion. IF you look at wheel – it was to educate large retailers. If some of largest retailers aren’t accepting USDA organic label to meet sustainability standards, that is a real problem. Educating retailers is where it’s at.

Jackie DeMinter – MOSA Certified Organic (Crops; Misc)

Certification policy manager. We certify 1850 operations. We request guidance on future data collection for OID. MOSA intends to provide products lists as an addendum: is it required to make this info public. Geo-locations: there are things we can do to limit the difficulty of collection this data without excessive burden. Any unnecessary burden to certifiers, farmers, and handlers should be minimized. Especially low risk operations. The same requirements should not be applied to everyone – focus on impactful areas. Reducing regulatory burden: focus on livestock and high risk. Additional requirements impact clients. Inspection this year impact costs. Small dairy has been taking the biggest hit. We can’t address the lack of inspectors by adding more regulatory burden at the same time.

Nate Powell-Palm: Thank you for all your work.

Kim Dietz – Strengthening Organic Systems (SOS) (CACS; Handling)

Founding partner. Served on NOSB from 2000-2005. Slides. Natural flavor sunsets – thousands of organic flavors in the market. We need to continue with natural flavors on the NL. Commercial availability clause is not working. Many companies are not following the intent which was to require use of organic flavors. Encourage task force prior to next sunset. Committed to SOE rule.

Allison: Concerns around check-off about who would benefit.

Kim: it was a controversial topic and many have failed. Some were good. At end of the day, we need funding to get the marketing out. We’ve been challenged as an industry. We need something to work. It won’t please everyone, but if now is the time, we should try it.

Lily Hawkins – Organic Farmers Association (OFA) (General)

Work agenda request for BBMF: this issue is a low priority for OFA farmer members; OFA urges NOSB to prioritize other issues. We’d urge you to add organic swine management of organic swine management. OLPS does lack detail in swine management. In order to expand organic pork industry, more clarity is needed and communicate how organic pork is different from other labels. We hope pork can go on the NOSB work agenda. The WI NOSB meeting is a great opportunity to have an organic swine panel and OFA could help arrange that. We want greenhouse standards; OFA opposes certification of organic hydro production. We ask the NOP to revoke that certification. There is widespread differences in certification in this area. Urge continued work on greenhouse and container production.

Nate Powell-Palm: I don’t see a market for organic swine. How can we get that pull to get more folks to transition.

Kate Mendenhall – Organic Farmers Association (OFA) (General)

Executive Director. Racial equity – when founded OFA, farmers wrote race and gender matter. We understand structural racism, sexism and committed to addressing race, gender, racial equity. We hope to hear more about how Board will address racial equity. SOE – regretfully, small farmers are being impacted – record keeping requirements have unfairly burdened small farmers and were intended for higher risk operations. Putting increase in enforcement where most needed and shield negative impact from small farms.

Allison: Ideas about help marketing, check-off or some other option?

Kate: marketing is needed. Farm Bill focuses on this. Just want to caution about check-off b/c it was so divisive and created a lot of distraction from positive organic. Using concept of check-off but something that benefits entire organic community would be way to go.

Amy: Are we talking about grain farmers? Veggie farmers when talking about check off?

Kate: I grew up during farm crisis of 80s. The check off then we lost auction opportunities, small farmers went out of business. The marketing was focused on industrial model. They tried to overturn it and couldn’t. This causes a lot of concern. At NOFA NY a lot of produce producers not participating b/c amount of paperwork and same problems with how to define net profit with such diverse producers (dairy, vegetable, etc.) hard to make a rubber stamp with all commodities. A lot of challenges for applying model for full organic industry.

Amy: Storage loans offered by FSA – if want a storage loan we’re using organic prices – didn’t get over finish line.

Kate: Some good crop insurance Farm Bill suggestions. Going to work with focus groups for farmer driven solutions.

Kyla: SOE impact on small farmers. PCO took issue seriously. Certifiers are collaborating through ACA. Not going to get it perfect. Trying to find ways to navigate it. NOP continues to drop trainings. Want to recognize comments to say things are moving along.

Kate: Getting call from farmers. Maybe we can bring feedback to working group.

Erin Meschke – Citizen (CACS; CS; LS; MS)


Sal Pinkham – OEFFA (CACS)

[This commentary was provided in full by the commenter.]

Good afternoon. I’m Sal Pinkham, Certification Program Manager at OEFFA. We certify about 1100 organic farmers and food processors in a 12-state region. I appreciate the opportunity to comment today on behalf of our certification program and our farmers, many of whom were unable to join this meeting due to harvest timing. We were disappointed by some of the comments made to our farmers by the Board at the spring meeting. We hope that, moving forward, the Board will treat public commenters with the same respect that you wish for yourselves. Regarding the CACS topics:

We appreciate the Board’s elevation of organic as climate-smart farming. We suggest ensuring that NOSB research recommendations always include directing USDA to study carbon sequestration and greenhouse gas emissions across a wide variety of organic and conventional farming systems, conducting a panel discussion with soil health and climate scientists to inform the Board, and developing principles for the NOP to use in conversation with others at USDA to illustrate the multifaceted nature of the organic systems approach.

We thank the Board for delving into the critical topic of risk protection for organic farmers and conducting such a comprehensive evaluation of the subject matter. This topic is too large to do justice in a 3-minute comment, so I urge the Board to read OEFFA’s written comment and recommendations in our Crop Insurance Platform, which were developed by our farmers and address the subcommittee’s questions in detail.

Certifiers absolutely need to know the locations we certify; however, we offered a nuanced perspective on the spring discussion document that appears to have been foregone in this proposal, which we strongly oppose. This would be an unfunded mandate for certifiers, with neutral to negative effects on farmers. It will fall hardest on certifiers like OEFFA who certify operations that do not use digital technology. And perhaps most crucially, it will not help us prevent fraud, support farmers, or improve the most consequential inconsistencies among certifiers.

A fundamental inconsistency is the certification of hydroponic and aeroponic crops. We ask the board to call for a moratorium on the certification of new operations that grow crops to maturity in containers and to add Field and Greenhouse Container Production back to your work agenda.

We fully support broadening the net for residue testing to better encompass the entire global organic supply chain. Residue testing is costly and we would love guidance on how to use it most effectively. We support the proposed framework for evaluating residue testing, with a few nuances mentioned in our written comments. And we suggest that NOP aggregate positive test results from certifiers and share that data with certifiers, so that we can continually adjust our sampling efforts to focus on areas of highest risk.

Finally, we appreciate the Board’s interest in organic transition support. Rollout of the Organic Transition Initiative has been less than ideal but the program’s objectives are extremely important. In future, we ask that USDA develop such programs by first seeking partners among BIPOC-led organizations and those that are already doing the work, so that resources can be used most effectively and support those who are most in need.

Thank you for your service to the organic community and for taking the time to listen to my comments.

Amy: I wanted to understand standardized location tracking comment: effort to understand feedback including parcel number issues. Is allowing the township info helpful?

Sal: Thank you for incorporating that. Joel Hertz is one of our members that spoke to that issue. The fact that some plain farmers can provide geo-codes, does not mean all of them can. Which means certifiers have to play catchup. It’s based in database consistency, but that in and of itself is not enough to increase burdens on small certifiers and farmers. The proposal in soring, to have very specific geo-locating like the center of the field, is very difficult. The new proposal isn’t specific enough so it’s not actually helpful for fraud either, which is the goal. The only benefit to the GPS pins is to ensure we can find everything for inspections. But that’s already a requirement.

Carolyn: The info you provided on crop insurance was helpful in crafting that document.

Sam Welsch – One Cert (General)

Founder. Certify 1300 operations. OFPA is unambiguous that OSP include provisions of soil fertility. Based on this requirement, many requirements for soil. USDA does damage when says only applies to operations that grow in soil. All exceptions must be in regulations. As SOE implemented, need to start with enforcing law as currently written. Already heard many comments about additional record keeping requirements. Large exporters, importers, etc. Benefit from import certificate requirement. If single import certificate is valid for 12-18 months, then it’s no better than what we currently have. Also creates competitive advantage to certifiers who issue import certificate for year or more rather than for each shipment. Hydro producers are major beneficiaries of certificates for a year or more. For grain also fails.

Sara Neagu‐Reed International Fresh Produce Association (Crops (CS); Materials (MS); General)

Director of production and environmental policy. Emily Moyer shared oral comments on behalf of IFPA. Plastic mulch and covers: supports the continued listing. They are necessary to produce wide array of fresh organic produce. They are used to control weed, improve crop yield and quality. They are readily available at low costs. Survey of members had key findings: 60% of large growers and 100% of small growers said need control was primary reason. Easier to use than alterative and more affordable. There would be additional labor and resource costs if plastics were not allowed. We recognize the concerns of environmental impact of plastics, however the removal from the National List would have damaging effects. Happy to pass along the survey referenced earlier.

Jerry: Please sed the survey. Summarizing what you said: plastic mulch and covers do their job so well, they are indispensable. For me the problem is they do do everything very well. It does not negate the need to address and stay with it. Sometime in the future we can have an equitable solution to that issue.

Bob Quinn – Organic Farmer (General)

In 1986 started first experiment with regenerative organic systems. Converted entire farm in 1988. Promoted system and served on NOSB. Over last 35 years, market has grown to about 6% of food sold. Three areas to help: marketing will help shoppers understand benefits of organic (health, environmental, and high cost of cheap food); only about 1% of farmers are organic. Cheap imports are stealing markets. Why not give a country of origin labeling. Robust local and regional food supply necessary for food security. 99 percent of research dollars going to chemical agriculture seeking chemical answers for chemical problems. Divert some of that money to organic systems. Organic is the future. Need to promote in country of origin labeling, marketing and research.

Wood: ever had a conversation locally with neighbors farming conventionally?

Bob: Biggest challenge is they don’t know where to start. They are in debt, afraid of making a mistake. Research could help in getting them started.