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A Review of the
Fall NOSB Meeting
By Harriet Behar
The National Organic Standards Board (NOSB) was
and influences that go into these discussions that affect
designed to include the voices of many stakeholders,
what materials you can use for fertility or pest control,
including public input, with an emphasis on being
as well as the methods of production mandated by the
responsive to the needs of organic farmers. The National
rules. The NOSB has a unique place among USDA
Organic Standards Board meetings, which happen twice
advisory boards. For example, no material can be
each year, need strong organic farmer representation to
approved or denied use in organic production, unless it
keep the program rooted in the realities you face on your
has been reviewed and voted upon by the NOSB. Under
farm or ranch. As the organic movement matures, there
the “sunset” provision in the organic law, every material
are powerful corporate interests that seek to build in
on the National List must be reviewed and approved to
loopholes and at times, make it difficult for family-scale
remain on the list every five years. The NOP cannot put
farmers to remain viable. Organic farmers are by far the
new materials on the National List without this NOSB
largest constituency of certified organic producers in the
review and approval.
U.S. (69% of U.S. certified operations are farms), but are a
very small percentage of those who seek to influence the
ORAL COMMENTS SUMMARY
regulations through public comments.
Two items not on the NOSB agenda did have a
significant amount of written and oral comments with no
THE PROCESS
specific path determined at this meeting for fixing these
At the recent NOSB October meeting, there were two
issues. Inerts used in pesticide formulations are
public comment webinars through Zoom, and three days
currently allowed, but the National List refers to an
of in-person NOSB meetings in Rhode Island where the
obsolete EPA list. The NOSB and NOP have struggled
Board discussed public input and voted on numerous
for over a decade to determine a better method for
proposals.
allowing more than 130 “inert” materials on organic
The comments and NOSB discussions culminate with a
formal recommendation to the National Organic Program
(NOP) and eventually end up as regulation. It’s very
interesting to hear the various viewpoints
land, some more benign than others. In addition, there
were also numerous comments from consumers, asking
the NOP to stop allowing hydroponic production to
carry the organic label.
The Organic Farmers Association, as well as other organic
The Board expressed concern of the long-term
groups, agree that hydroponic production should not be
sustainability of plastics such as: reliance on fossil fuels
labeled as organic. It is inconsistent with the Organic
for manufacture, soil erosion issues, microplastics in
Foods Production Act and ignores many of the
soil and water, and single-season plastic covers and
requirements soil-based organic farmers must follow.
mulches filling up landfills. The Board also discussed
PROVIDENCE, RI MEETING OF THE BOARD
the multiple benefits plastics provide, and the
challenges of finding economical alternatives. In the
The meeting started with two discussions of interest to
end, the NOSB voted to continue to allow both paper
organic producers. First, numerous groups in the
and plastic mulch, and keep these materials on the
Northeast who are funded under the USDA’s Transition
National List. Other materials under sunset review that
to Organic Partnership Program (TOPP) gave reports on
were voted to relist for another five years include:
their many activities to grow the pool of organic farmers
alcohols, newspaper, sulfurs, lime, and liquid fish
across the Northeast. Second, a good conversation
products.
between NOSB members and the Risk Management
Agency
explored
a
variety
of
crop
insurance
improvements recognizing the unique challenges faced by
organic farmers.
MATERIALS FOR ORGANIC USE
Livestock Materials: The materials on the livestock list
were all reapproved for 5 years. During the discussion on
vaccines, the NOSB made it clear that GMO vaccines are
included in the re-approval of vaccines for the National
List. This is the one exception for Excluded Methods
allowed in organic because vaccines are important for
animal health and the broad majority of vaccines on the
market use genetically engineered technology. It was
acknowledged that certifiers vary in their interpretation
of whether phosphoric acid needs to be rinsed after use in
dairy operations, and the NOSB is going to develop a
system to review and improve annotations in the coming
months.
Crops Materials: The crops subcommittee voted to keep
all materials up for sunset review on the National List.
Two items with significant discussion were paper and
plastic mulches: paper for mulch and compost feedstocks
and plastic for mulch and coverings. Many papers now
contain plastic. Leaching of PFAS and phthalates into soil
is a concern, as well as microplastics contaminating soil
and water.
Processing/Handling Materials: There were no changes
to handling materials on the National List; all materials
under sunset were voted to be relisted for another five
years.
RESIDUE TESTING
The Board discussed where in the supply chain and
how much pesticide residue testing should be done on
organic crops. They discussed the importance of
continued support for organic transition and how that
needs to be matched with efforts to grow the organic
markets. Final proposals on those two areas are due in
the spring.
GPS FIELD/PARCEL COORDINATES
Based on feedback from oral and written comments,
the NOSB modified the proposal mandating GPS
coordinates for all farm and facility locations in organic
system plans to allow certifiers to use a variety of
different methods for identification; they passed the
amended recommendation.
NEW & FUTURE NOSB WORK
AGENDA ITEMS
LET YOUR VOICE BE HEARD!
Compost & Compost Feedstocks: Two items have been
added
to
the
NOSB
work
agenda.
The
crops
subcommittee will be reviewing the definition of compost
and compost feedstocks. The prescriptive nature of the
current rule can be a barrier to some and compost
feedstocks are not clearly defined.
Inerts: The NOSB will continue working with the public
comments and the NOP to address inerts present in
pesticide formulations used on organic crops and land.
Without the EPA providing this analysis of inerts, it is
difficult to identify how to tackle this issue.
Annotations: The Board committed to working with the
NOP to develop a better mechanism to address the need
to add, remove, or change annotations to items on the
National List. At this time, these annotations cannot be
changed when the material is being reviewed for sunset,
and the NOSB would like to develop a way to allow the
change when the Board and public are giving these
materials a higher degree of scrutiny than at other times.
Organic Animal Welfare Criteria for Swine: The final
Organic Livestock & Poultry Standards Rule (OLPS) that
was announced on Wednesday, October 25 at the
meeting, failed to address animal welfare standards for
swine. OFA and other advocacy groups identified that
this animal group was left out of the organic animal
Farmer voices are important to the NOSB process! It’s
easy to testify to the NOSB, and OFA can help you
bring your on-farm concerns to the volunteer board
working for you!
THE BASICS: Oral comments are no more than 3
minutes (one page written) and shared via Zoom. You
can give your testimony from the field, tractor, or at
home.
REGISTER: About 6-8 weeks ahead of the meeting you
must register to testify. Visit the NOSB Meetings page
to register and indicate your availability.
SCHEDULE: The NOSB will send a schedule prior to
the meeting with your approximate 3 minute time slot.
OFA will have staff on the call, so if you are not able to
listen the whole time, we can let you know when it’s
almost your turn.
PRACTICE: Practice your comments out loud ahead of
time to make sure you come in under 3 minutes and
sound clear and confident.
QUESTIONS: The Board likes to ask farmers questions,
so be prepared to answer questions based on your
experience. This is a great way to give more than 3
minutes of input. OFA can help you prepare!
welfare standards, and some organic swine producers
OFA’s Farmer Services Team is here to support you.
participate in additional animal welfare standards to
We’d be happy to talk with you about your ideas and
supplement their organic certification.
concerns, and how to give effective public comment at
the upcoming spring meeting.
The Board discussed whether or not to add organic swine
production to their work agenda as requested by OFA.
Please call the Farmer HelpLine at 1-833-724-3834, or
They seemed unsure if there was a market for organic
email Farmer Services Director Julia Barton at
pork, and did not feel this was a priority.
julia@organicfarmersassociation.org
information or to get involved.
All of the proposals and discussion documents from all
NOSB meetings are posted online.
Harriet Behar is OFA’s Farmer Services
Consultant, and serves on the Governing
Council and Policy Committee. She has been
involved with federal, state, and local policy
advocacy for over 30 years. She runs organic
Sweet Springs Farm in Gays Mills, Wisconsin.
for
more