Organic Dairy National Organic Program Update
A summary of what transpired at the recent NOSB meeting in Baltimore.
Added June 1, 2008. The National Organic Standards Board met May 20 - 22, 2008 in Baltimore, MD. A very weary Barbara Robinson, Acting National Organic Program Director, gave a brief overview of the Program activities. She introduced new NOSB Board Member Barry Flamm. Barry is the new Chair of the Policy Committee. He serves in one of the environmentalist seats on the Board and has worked in conservation efforts throughout his life. He also formerly farmed, raising organic cherries. He has recently sold his farm.
She also reported that:
In answer to a question from NOSB member and NY dairy farmer, Kevin Englebert, on the status of the access to pasture clarifying rule and whether it will reflect the NOSB recommendation, Barbara Robinson’s response was that it “will meet everyone’s needs.”
Ed Maltby, NODPA Executive Director, gave a 5 minute comment period to stress the need for the immediate publication of the access to pasture rule before any more harm is done to organic dairy and requested a proposed rule instead of an Advanced Notice of Proposed Rulemaking (ANPR) for the origin of livestock as there was a lot of comment on the issue during the comments on pasture and because we have consensus in the industry about last third of gestation as the governing principle. This will save at least 6 months in the publication of the rule and probably more time without restricting the ability to comment. Other speakers, principally members of the National Organic Coalition supported the publication of the access to pasture rule as part of their comments as well.
Kelly Shea, Horizon Organic, the only representative from organic processors at the meeting, included Horizon’s support for the minimum of 120days/30% DM as part of the access to pasture rule, the immediate publication of the access to pasture rule and not having an ANPR for the origin of livestock rule as part of her comments. Barbara Robinson responded directly to Kelly Shea and announced that she had neglected to mention in her NOP update that the NOP had decided to issue a proposed rule for origin of livestock rather than an ANPR. This should shorten the process, by how much is difficult to gauge.
During the Board discussion of materials, it was noted that the NOP has indicated that the Board members may conduct the tap reviews for materials to be added to the National List. The Policy Committee will be developing a procedure regarding when an “outside” reviewer will be utilized.
Comments on this topic from meeting attendees ranged from “how will they find the time” to “are they qualified to conduct tap reviews” to “isn’t this a conflict - voting on their own work”. During the Public Comments there were many comments indicating the NOP should utilize some of the additional funding for tap reviews. Several commentators advocated for a moratorium on the review of materials until tap reviews could be conducted.
There were many public comments given regarding the Certification, Accreditation & Compliance Committee & Crops Committee joint recommendation regarding the Commercial Availability of Organic Seed. The majority of commenter’s noted that the requirement that farmers provide lists of seeds to seed companies, and then provide the list to certification agents, who would then submit the list to a “recognized organic seed trade association” was burdensome. Commenters expressed that the use of organic seed had been increasing. It was also noted that if there is a complaint regarding whether a certifier is enforcing this rule section, then this could be addressed during the NOP accreditation process. It was also noted that there is no requirement currently to review how a certifying agent handles this process, as the auditing checklist does not contain a requirement to review this.
Portions of this report are courtesy of the Accredited Certifiers Association, Inc : http://www.accreditedcertifiers.org/
For NODPA’s own recent comments to the NOSB, click here.