Know Your NOSB: Winter Report

USDA organic label

The National Organic Standards Board (NOSB) meets twice each year to hear public comments, discuss agenda items, and vote regarding issues and materials for use in organic production and handling systems. The outcomes of the board votes are shared as advice to the Secretary of Agriculture, which then often returns to the organic community with clarifications or changes to the organic standards.

The last meeting was held online October 25-27, 2022. Thanks to those of you who submitted comments to the NOSB or shared your ideas with us. OEFFA drew on that feedback to provide comprehensive comments to the NOSB.

The following are highlights from that fall NOSB meeting. The spring NOSB meeting will take place April 25-27, 2023, in Atlanta, Georgia, with the National Organic Coalition pre-meeting on April 24.

If you’re interested in participating in future NOSB meetings or engaging in OEFFA’s Organic Work Group, contact Julia Barton.

OFRF: National Organic Research Agenda Report Update

Brise Tencer and Thelma Velez of the Organic Farming Research Foundation (OFRF) shared highlights from the National Organic Research Agenda report, highlighting particular challenges and opportunities for organic growers.

Proposal: Human Capital Management, NOSB Technical Support

Serving on the NOSB is a huge job, and OEFFA has long supported technical support for the NOSB, especially for farmer members. Although OEFFA’s comments, those of the National Organic Coalition, and others urged the board to seek this support in a way that fits each individual board member, and to look outside of the USDA for this technical support, the board voted to move forward with technical support from within USDA staff. We will be closely following this recommendation as it moves forward to the National Organic Program.

Proposal: Oversight Improvements to Deter Fraud, Acreage Reporting

OEFFA has included acres per crop type on our organic certificate for many years. As a fraud prevention tool, the NOSB proposed requiring acres per crop type and total acres on organic certificates. This makes audits easier to conduct and offers another publicly available verification point. It was recognized that there will need to be accommodations made for how acreage of small, diversified growers is listed on the certificate. OEFFA currently uses a “mixed vegetables” designation for this purpose. The board voted to require acreage reporting on the certificate moving forward.

Discussion Document: Oversight Improvements to Defer Fraud, Minimum Reporting Requirements

Discussion continued regarding other tools to help prevent fraud through consistent reporting. The OEFFA Grain Growers Chapter led in comments supporting a universal Bill of Lading, a tool grain growers use to communicate with mills about what’s in the truck, what field it came from, whether its food or feed quality, and its organic status. The thinking is that a standardized document would better serve farmers, mill operators, certifiers, and inspectors alike. They are often looking at these documents from multiple farmers during busy times of year, in performing mass balances, trace back audits, and noticing areas of potential fraudulent activity.

Discussion Document: Organic and Climate Smart Agriculture

OEFFA urged the USDA to take ownership of organic as a climate-smart agriculture tool, and proudly promote it as such in USDA communications. Instead, the NOSB took the approach of outlining the many climate-smart attributes of organic agriculture by category. We will be closely tracking the next iterations of this discussion document, as it may move forward in proposal form for the spring 2023 NOSB meeting.

Verbal Update: Excluded Methods

After some initial discussion regarding a possible place for genetic engineering (GE) technology in organic by outgoing board member Rick Greenwood, fellow NOSB member Mindee Jeffrey reiterated that GE technology remains a method excluded from organic production, stating:

“I appreciate the tone of yesterday’s conversation indicating the USDA’s commitment to open and collaborative dialogue. In that light, respectfully, stakeholders, consumers, and previous boards have been unanimous in upholding the excluded methods provisions, including the part of those definitions that refer to gene editing techniques. We are united in the understanding that this organic system has positioned all forms of genetic manipulation as excluded from organic systems, just as we have prohibited other substances, natural or synthetic. I also appreciate that when stakeholder groups have questioned USDA on this issue, the USDA has responded by saying, ‘We appreciate your initiative in discussing the role of gene editing with your members and sharing the outcome with USDA. Genetically modified organisms, including gene editing, are considered excluded methods, and are prohibited in organic agriculture under the USDA Organic Regulations.”

No NOSB recommendations will take effect until the National Organic Program alters the regulations through rulemaking.