NOC Asks NOSB to Take Action on Climate Change, Fraud, Enforcement for Dairy Operations, and Inert Ingredients

On April 3, 2020, NOC submitted comments to the National Organic Standards Board, calling on the Board to take actions to advance organic as a climate solution, to strengthen enforcement of the organic regulations to prevent fraud, and to restore fairness in the organic dairy sector. Specifically, NOC would like to see the NOSB use its authority as an advisory Board to USDA Secretary Perdue to:

1.      Create a work agenda item related to carbon sequestration and enforcement of soil-health provisions in the organic regulations and recommend a restriction on the use of highly soluble sources of nitrogen in organic agriculture.

2.      Review and analyze NOP accreditation audits (‘peer review audits’), track progress made by the Organic Imports Interagency Working Group, ask the USDA National Organic Program (NOP) to explain its risk-based approach to accreditation, request more information about how funding increases are being used to strengthen the NOP’s capacity to fight fraud, and to identify gaps that require further action.

3.      Urge the NOP to issue a final rule on Origin of Livestock and continue enforcement activities to ensure that the pasture rule and other requirements for organic dairy operations are adequately enforced.

NOC is also encouraging the NOSB to insist the NOP move forward quickly with implementation of the 2015 NOSB recommendation on “inert” ingredients and to develop an MOU with the EPA’s Safer Choice Program to ensure review of “inert” ingredients to the criteria laid out by the Organic Foods Production Act (OFPA).  So-called “inert” ingredients in pesticide products are neither chemically nor biologically inert. They are designed to enhance the pesticidal activity of pesticide products and can have toxic properties that do not meet the standards of the OFPA.

Finally, NOC is deeply concerned about the impact of COVID-19 on organic farmers, farmworkers, businesses, certifiers and inspectors, and consumers. We are mindful of the need to protect the health and safety of all who are involved in organic agriculture, certification, and compliance. We also seek to advocate for responsible actions that will protect the integrity of the USDA organic seal during this difficult time. NOC is asking USDA Secretary Perdue to take actions to protect organic during this crisis and we urge the NOSB to also make recommendations to Secretary Perdue related to the needs of the organic community during the coronavirus pandemic.

You can read NOC’s detailed comments to the National Organic Standards Board here.