Protecting Organic Integrity – NOC comments to the National Organic Standards Board

During the past two years, the USDA’s National Organic Program (NOP) has received significant boosts in funding to address import fraud and enforcement issues. The NOP is in the process of growing their team from 42 to 59 employees, with additional D.C. and field-based positions including new auditors, accreditation managers, and compliance and enforcement specialists. These are positive developments given that the NOP’s capacity to oversee the growing organic industry has long lagged behind growth in the marketplace.

But despite this progress, we remain deeply concerned about the future of organic.

That is why NOC comments to the National Organic Standards Board (NOSB) focus on the issues that matter most to protect the integrity of organic.

Here are some of the topics NOC discussed in our written and oral testimony to the NOSB:

1.       Import Fraud: The NOSB should continue its work to combat organic import fraud and should hold the NOP accountable in its mission to protect the livelihoods of U.S. organic farmers and the integrity of organic seal. NOC has identified several issues that we would like to see addressed in the new Strengthening Organic Enforcement regulations (which we expect will be published this fall), as well as topics we would like to see the newly formed USDA-Customs and Border Protection working group tackle.

2.       Organic Dairy: USDA has reopened the comment period for the 2015 proposed rule on Origin of Livestock. NOC strongly supports the proposed rule, does not want to see it weakened, and urges USDA to issue a final rule as soon as possible. We also urge the USDA to continue to focus on compliance with organic dairy regulations overall, including pasture rule enforcement. Without new regulations to level the playing field and strong enforcement, we will see continued consolidation in the organic dairy sector.

3.       Transparency: Each year there is a “peer review audit” conducted to assess the NOP’s program to accredit more than 80 certifiers and 50 foreign satellite offices. For the past two years, the NOP has failed to make public the full results from these audits, despite the requirement that they make the findings available to the NOSB and public stakeholders. NOC has urged the NOP to be transparent and to make the findings of these audits public and to provide an explanation when they deny NOSB requests for topics to be added to the NOSB work agenda.

4.       Prohibiting GMOs: Gene editing is a form of genetic engineering that is clearly excluded in organic by definition. NOC appreciated the clarification from USDA at the Pittsburgh NOSB meeting that gene editing is not allowed based on the excluded methods definition in the organic regulations. NOC supports for the NOSB recommendation from 2016 to prohibit new forms of genetic engineering, including gene editing, and urges USDA to take action to move this recommendation forward.

5. Inerts: There needs to be a system for reviewing and identifying inert ingredients that are allowed in organic production. “Inert” ingredients frequently compose as much as 99% of pesticide products, and due to NOSB scrutiny of active ingredients, they may be the most hazardous ingredients in pesticide products used in organic production. NOC recommends that the NOSB move forward with evaluating NPEs in inerts and urges the NOSB to ask the NOP to move forward quickly with implementation of the NOSB recommendations on “inert” ingredients.

 

Abby Youngblood