Origin of Livestock Letter to Sonny Perdue

 Organic Farmers Association submits letter to Sonny Perdue, Secretary of Agriculture, expressing concerns with the Origin of Livestock. Read the full letter below.


November 26, 2018

The Honorable Sonny Perdue Secretary
U.S. Department of Agriculture 1400 Independence Avenue SW Washington, D.C. 20250

Dear Secretary Perdue,

The Organic Farmers Association is concerned that the current Origin of Livestock standards are creating unfair and inconsistent interpretations of the standards and inconsistent implementation by certifiers across the country. We respectfully ask that USDA prioritizes implementation of an Origin of Livestock Rule. To accomplish this goal, w

The current rule is inhibiting the National Organic Program’s ability to provide sufficient enforcement to ensure that our nation’s organic animal standards are fair and consistent. The effect of this is market instability which could lead to a lack of consumer confidence in the domestic organic dairy industry.

Our members, efficient domestic organic dairy producers, have seen inequities in the enforcement of regulation for dairies around the issue of the Origin of Livestock. They believe they can compete with the most efficient organic dairy producers if they are treated equitably. The Office of Inspector General (OIG) report supports their fears and concerns. The organic dairy industry lacks a clear uniform national standard for Origin of Livestock, a concept that is at the core of the creation of the Organic Food Production Act and the National Organic Program.

As you well understand, regulations must be enforced in a uniform and consistent manner to ensure all industry participants are competing on a level playing field. That is not the case of the current organic dairy industry.

USDA’s Office of Inspector General audit confirmed that certain segments of the organic dairy industry are being treated differently than other segments and that certifiers are interpreting the standards for origin of livestock very differently.

We ask that USDA fix those inequities by implementing the attached Organic Farmers Association Origin of Livestock suggestions (Attachment A). We base the policies on the OIC’s audit. We ask the Secretary to work with the National Organic Program to immediately issue Guidance on the interpretation of the one–time transition provision.

Our policy would clearly state that the provision for transitioning conventional cows to organic in one year is a one-time allowance and continuous transition of conventional livestock is not permitted. This language is not controversial and mirrors language first published in the 2015 Proposed Rule. It also mirrors the language in the preamble of the rule further supporting this interpretation. This would put organic dairy on the same level as all other organic commodities, would stop the fraud and confusion existing within the organic dairy industry, would stop continual transition of non-organic dairy heifers, would open the market for certified organic replacement animals, and would ensure that all US-based and international-based certifiers are using the same standards. Please see the Attachment B for more details on our proposal.

Detailed data needed to make sound policy decisions is difficult to find for the organic dairy industry. Despite the lack of macro level information, our members understand the daily impact of regulation failure (See Attachment B). Creating sound dairy policies and regulations needs sound data.

The organic industry is a $50 billion industry. We ask that USDA give serious consideration to providing more economic capabilities to collect the data and help the industry better understand the impact of proposed policies on the industry. The Organic Farmers Association is ready to work with USDA and Congress to build support for that request.

Founded in 2016, Organic Farmers Association is a national, grassroots, membership organization that provides a strong and unified national voice for domestic certified organic producers. Organic Farmers Associations works to build and support a farmer-led national organic farmer movement and national policy platform by: developing and advocating policies that benefit organic farmers; strengthening and supporting the capacity of organic farmers and farm organizations; and supporting collaboration and leadership among state, regional and national organic farmer organizations. Only certified organic farmers drive our policy positions. Our membership and network of certified organic farmers is diverse and spans all 50 states and U.S. territories.

We would be happy to talk with you and your leadership within Agricultural Marketing Service more about origin of livestock. We urge you to move swiftly as family organic dairy farmers are suffering because of the lack of uniform and strict enforcement. We know you share this priority for strong enforcement and integrity and look forward to hearing from you.


David Colson
President, Organic Farmers Association

Cc: Gregory Ibach, Under Secretary for Marketing and Regulatory Programs, Jennifer Tucker, Director, National Organic Program

Voters Decide to Divide Power in DC

Mark Rokala, Policy Director

Voters gave the Democratic Party keys to the House of Representatives on election night. On the other side of the Capitol, Senate Republicans grew their majority.

The House of Representatives is the body of Congress with the investigative responsibilities allowing Democrats the opportunity to investigate President Trump and his federal agencies. This month's election resulted in 100 new members of Congress. That is a turnover of one in every four members. Most of those newly elected officials come from urban and suburban areas with very few organic farmers. Educating those new members of Congress will be a top priority for the Organic Farmers Association in 2019.

The change in power has significant impact on the House of Representatives, the House Committee on Agriculture and the farm bill conference work. Congressman Colin Peterson (D-MN) will become the new Chair of the House Agriculture Committee. While current Chairman Mike Conaway (R-TX) will become the new Ranking Member. Senate farm bill negotiators, Senator Roberts (R-KS) and Senator Stabenow (D-MI), will continue in their roles on the Senate Committee on Agriculture, Nutrition and Forestry and as farm bill negotiators.

Congressman Peterson has said repeatedly that he wants to finish conference committee work in 2018. Since 2019 will be a new Congress, the process of writing a farm bill would start over.

A quick review of the elector map shows that most of those newly elected members come mostly from suburban areas.

We will have a huge job getting those members up to speed on issues important to organic farmer policy. Organic Farmers Association will be reaching out to new members once the first session of the 116th Congress is sworn in after the first of the year.  We start the task by reaching out to new members of the Agriculture Committee.

NOSB considers pilot program for genetic contamination transparency for seed used on organic land

NOSB seeks corn growers' Feedback

The National Organic Standards Board (NOSB) is an advisory board to the USDA National Organic Program (NOP). The NOSB is a multi-stakeholder volunteer board that advises the USDA NOP.

At the October 2018 NOSB Meeting in St. Paul, MN, the NOSB discussed a possible pilot project to measure GMO contamination in organic field corn seed. The goal of the proposal is to aid farmers in their choices of seed and provide farmers with more information about levels of GMO contamination in seed. The proposed pilot project is limited to field corn seed and was drafted by an organic farmer and longtime organic inspector.

The NOSB materials subcommittee continues to work on this proposal and would like more feedback from organic corn farmers on the proposal so that they have more farmer input leading into the Spring 2019 NOSB meeting.

The USDA is collecting comments on this proposal for the Spring NOSB meeting.  Submit comments to the Federal Register by JANUARY 2, 2019.

The proposal was sent back to the NOSB materials subcommittee for more work. They would like more feedback from organic corn farmers on this proposal. You can submit your feedback on the proposal by submitting a comment in the Federal Docket for the NOSB meeting.  Submit your Comment Here.  Comments must be submitted by DECEMBER 7, 2018.
Read the proposal below.  Or click here to read the proposal in the context of the full NOSB discussion.

VI Proposal

1. A system of sampling, testing and transparency of findings of GE contamination on all field corn seed planted on organic land is required. Once this has been implemented for one or two years, other at-risk crops could be added.
2. We request the NOP develop an "Instruction to Certifiers" based upon this recommendation and place this in the NOP Program Manual.
3. All field corn seed lots planted on organic land, both organic and nonorganic seed, and whether sold or used to feed on-farm livestock, shall be tracked in the farm Organic System Plan (OSP) with information detailing the state/province and country of origin of the seed, as well as the level of purity from GE contamination. In addition, certified organic field corn seed suppliers must track these items in their OSPs. If nonorganic field corn seed is planted, the organic farmer is mandated to obtain the level of purity information, determined through approved protocols, and document this in their OSP. The organic farmer would need to have this test performed before planting each lot of nonorganic seed they purchase. This information can be supplied in the submitted OSP at the beginning of the crop year, or at the annual inspection.
4. Seed suppliers or farmers have the option of five levels of purity, determined through approved sampling and testing protocols.
The detectable levels of purity from GE contamination for organic field corn seed are:
a.       0.1% or less
b.       0.25% or less
c.       0.9% or less
d.       5% or less
e.       Over 5%
5. Documentation that the testing and sampling met these requirements must be provided to buyers of the seed.
6. The level of purity must be included on the seed tag, or for bulk shipments, on the invoice or other sales document.
7. Testing must include all known GE traits available in that crop species.
8. Outside labs used for this testing must be accredited to ISO 1 7025.
9. The testing technology must be capable of providing accuracy within a 20% relative standard deviation of the target concentration of GE contamination.
10. If in-house testing is done, the equipment must be validated to have the accuracy required to declare the specific targeted level of purity from GE contamination. Additionally, personnel using the in-house equipment must have training and demonstrate proficiency on an annual basis, through the quantitative analysis of a blind sample.
11. Sampling protocols must be recognized as having at least a 90% statistical rate of accuracy for confidence in the quantification of GE presence. Sampling protocols, such as those performed by various state "crop improvement" age ncies, would meet this requirement. Information on various state and international agencies that subscribe to these protocols and can explain these protocols can be found here. http://www.aosca.org/seed-certifying-agencies/
An example of the seed sampling protocol, from the California Crop Improvement Association is here. http://ccia.ucdavis.edu/files/178676.pdf
12. Sampling must include a demonstrated method of achieving a homogeneous blend representative of the finished seed lot derived from the cleaned and ready-for-sale seed.
13. Sampling must be documented to illustrate the sample was sufficiently intact for valid PCR quantitative analysis.
14. Each lot of seed must be sampled and tested.
15. The certifier will keep track of this information and send this information to a central database, without the farmer or seed supplier information. This information would help the organic community gain a better understanding of the levels of seed purity from GE contamination used on organic land, as well as regional differences in seed production.
16. This GE purity testing and information transparency is required of all organic field corn seed suppliers and must be documented in the annual organic seed handler OSP. The organic field corn farmer would document the information from their organic field corn seed supplier in their OSP as well.
17. Organic farmers should retain samples of each lot of seed they planted for at least one year after their crop grown from this seed has been sold.

Natural Grocers customers raise nearly $100,000 in support of organic farming and sustainable agriculture

Natural Grocers customers raise nearly $100,000 in support of organic farming and sustainable agriculture

Customers made in-store donations during Organic Harvest Month, exceeding the original goal of $50,000

In September, Organic Harvest Month, Natural Grocers customers raised $94,500 for the Organic Farmers Association, an organization that represents organic U.S. farmers via grants, research and organic farming policy matters in Washington, D.C. Natural Grocers shoppers across 19 states made in-store contributions and exceeded a $50,000 target goal by 88 percent, further proving shoppers are voting with their dollars to support organic farmers and the creation of more organic farmland in the U.S.

"Organic Farmers Association feels so fortunate to have fostered a partnership with Natural Grocers in preserving opportunities for certified organic family farmers," said Kate Mendenhall, director of the Organic Farmers Association. "This fundraising effort will greatly elevate the national voice of certified organic farmers—ensuring that their policy priorities are heard in Washington and they receive the policy and regulatory support they need to focus on farming good, healthy food."

The funds raised will also help provide scholarships to organic farmers to travel to Washington, D.C., where they will receive training for effectively communicating the challenges they see on their farms and those of their fellow organic farmers to our federal representatives and senators. Scholarship recipients will have the opportunity to personally meet with their local elected officials.

“Our relationship with the Organic Farmers Association is an extension of Natural Grocers’ commitment to providing consumers with access to high-quality natural and organic foods at affordable prices. When you purchase organic food, you’re supporting local, organic farmers and fostering a healthier environment,” said Kemper Isely, Co-President of Natural Grocers. “We are proud to partner with the Organic Farmers Association to help amplify the voice of certified organic farmers.”

The United States includes over 18,500 certified organic farmers, and 96 percent of them are small businesses. "Increasing the numbers of real organic farmers entering the halls of Washington makes a large impact and helps keep the needs of real farmers at the center of sustainable food and agriculture policy," said Mendenhall.
About Organic Farmers Association
The Organic Farmers Association, sponsored by Rodale Institute, is a national membership collective of certified organic farmers that provides a strong and unified voice for those who make their livelihood on the land. In addition to developing and advocating for policies that benefit domestic organic producers, the Organic Farmers Association aims to strengthen and support the capacity of organic farmers and farm organizations while encouraging collaboration among state, regional and national organic farmer groups. Learn more at OrganicFarmersAssociation.org

About Natural Grocers by Vitamin Cottage
Natural Grocers by Vitamin Cottage, Inc. (NYSE: NGVC; NaturalGrocers.com) is an expanding specialty retailer of organic and natural groceries, body care and dietary supplements. The company offers a flexible, neighborhood-store format, affordable prices and free, science-based nutrition education programs to help customers make informed health and nutrition choices. Founded in Colorado in 1955, Natural Grocers has more than 3,500 employees and operates 149 stores in 19 states.


Farm Bill Conferees Target Lame-duck Session Following November Elections

Mark Rokala, Policy Director

Farm bill negotiators said they will need to complete farm bill conference committee work after the November 6th election, hoping they can vote on the final agreement the following week.

This past week, Senate Agriculture Committee chair, Pat Roberts (R-KS), said he hoped progress could be made between now and the election to allow a vote on a final agreement during a lame-duck session. The lame-duck strategy is a logical next step for the negotiators; however, that strategy is not without its challenges.Senator Roberts hopes the extra time allows negotiators to make progress on several outstanding issues that have held up conference work like work requirements of SNAP, conversation title, spending per title and final scores on programmatic changes. However, no one knows what the pressure point is that makes negotiators compromise.Wait, no farm bill extension? Past Congresses have used the threat of permanent law, with 1930s parity pricing formulas for commodities and milk, as the heavy hammer to complete a farm bill.  A closer look shows that none of the damaging policies kick in until December 1 for dairy and after the first of the year for commodities. So, Congress feels it has time to bring everyone to the table before those deadlines.  Staff is saying that taking time to work on an extension delays their work on conference negotiations. The reality is there remains an immediate downside where 39 current farm bill programs baseline funding expired when the 2014 farm bill expired on the weekend.Expiring baseline means conferees will need to find $2.85 billion from farm bill programs to reauthorize those programs including programs important to our members like organic certification cost-share, organic research and extension, collection of organic data, beginning farm programs and necessary updates for National Organic Program (NOP).   Negotiators also recognize that elections have consequences.  One consequence would be who controls Congress, which would dramatically change negotiators' political environment.  If voters give Democrats the keys to Congress, that could be the pressure needed for members to get back to finish conference during the lame duck session.House Ranking Member Peterson has said numerous times that he wants to complete this farm bill yet this year; however, if Democrats gain control of Congress, Peterson would be the chair of the Committee.  Peterson’s rank and file members of the Democratic party, all whom were shut out of the process of draft the farm bill policy as Republicans drafted a partisan bill, would have a strong message to House leadership that Democrats should rewrite the legislation to address their priorities.While the House has adjourned until after the November 6 election, the Senate remains in session for most of October.  Both House Chair Conaway (R-TX) and Ranking Member Peterson (D-MN) have said they are ready to return to DC when needed.

We will continue to keep you updated on farm bill progress and negotiations.


Farm Bill Update:  Farm Bill Conference Tension Escalates

Farm Bill Update:  Farm Bill Conference Tension Escalates

Monday, September 17, 2018

Mark Rokala, Policy Director

Before a rare evening meeting of the farm bill negotiators last week, lead Senate Republican, Ag Chairman Roberts (KS), said negotiators are running out of time to complete a farm bill by September 30, 2018 when current farm programs expire.  Senate leaders were hoping to be able to come to an agreement on spending numbers for each title of the farm bill last week.

Discussions related to conservatives’ work requirements for Supplemental Nutrition Assistance Program (SNAP remain a huge road block.

On Friday, President Trump’s tweet accused Senate Ranking Member Stabenow (D-MI) and Democrats of being the problem for not agreeing to the House’s work requirements for SNAP.  However, Agriculture Chair  Senator Roberts has said numerous times that he would not be able to get to 60 votes to prevent a filibuster of the conference report if the work requirement is included.  This continues to be the road block of the Farm Bill.

The top four negotiators continue to say they want a bill before the end of the month. Senators are hoping that the two lead House negotiators, Chairman Conaway (R-TX) and Ranking Member Peterson (D-MN) will be staying in town this week to continue negotiations.  The House is scheduled to be in recess this week.

At the opening meeting of the farm bill conference the first week of September almost all 56 members expressed their desire to complete their work in time to send the bill to the President for signature  before the current farm bill expires (deadline September 30).

While much of the farm policy merging should be painless, a couple of major policy changes have the potential to derail the process. In addition to the work requirements, House of Representatives eliminated the Conservation Stewardship Program (CSP) to pay for other priorities.  The Senate farm bill continues the program.

The upcoming deadline is crucial because 39 currently authorized farm and food programs will lose their baseline funding  on October 1, 2018 if they are not re-authorized. Six programs important to the organic industry will lose baseline funding and be put at a standstill including Organic Certification Cost-Share, Organic Research (OREI), organic data collection (ODI), National Organic Program upgrades, NRCS EQIP,  and Beginning Farmer and Rancher Development Program (BFRDP).

These six programs important to organic farmers are included in a group of programs that received mandatory funding in the 2014 farm bill but do not have a baseline beyond the end of that five-year farm bill. These are referred to as “farm bill programs without a baseline” and do not have assured future funding.

In addition to the organic programs needing funding reauthorization in the 2018 farm bill, the new bill language for Organic Farmer and Consumer Protection Act is necessary right now to protect American family farmers from fraudulent organic imports.  If the farm bill is not completed, organic farmers will miss out on the needed funding and authorization measures this bill gives the National Organic Program to tighten up its enforcement to protect our domestic organic brand.

In our letter to conferees explaining our conference position, Organic Farmers Association pointed out the baseline issue and encouraged conferees to complete their work by the end of the month.  We continue to work with other organic organizations to encourage Congress to work on behalf of America’s family farmers and bring the farm bill to the finish line. We encourage Congress to do the same.

Action Alert: Final Stages of 2018 Farm Bill

Congress is in the final stretch of completing the 2018 Farm Bill but they may not get the job done! Your legislators need to hear from YOU on organic programs. Call your legislator & ask them to help finish this farm bill! YOUR VOICE MATTERS!

TARGETS: Your legislators


WHY:  Congress must send a farm bill to the President for signature before the current farm bill expires on September 30, 2018.  We are asking them to preserve funding for important organic programs and encouraging them to not make any changes to the National Organic Standards Board.  Congress may not finish the farm bill in time---they need to hear from you!


Call your elected officials to pass a farm bill before the current bill expires.  Ask to protect funding for organic programs and leave NOSB changes out of this farm bill.

Call the Capitol Switchboard: 202-224-3121

Please email: Mark@organicfarmersassociation.org with an update of how the call went.


  • Ask for the Agriculture Legislative Assistant (LA).
  • Tell your Senator or House of Representative’s office that you are an organic farmer.  Tell them the town where your farm is located and describe your farm business.
  • Urge them to pass a farm bill before the current farm bill expires and oppose any attempts to change the National Organic Standard Board in the Farm Bill.
  • Congress needs to complete their conference committee work before the end of September—organic farmers are counting on Congress to plow to the end of the row and get the job done.
  • If they pass an extension of current programs, they create funding problems for many of the organic programs you use on your farm like cost-share, organic research, data collection and needed National Organic Program upgrades.
  • The National Organic Standards Board (NOSB) plays an important role in supporting the organic seal.  NOSB determines which materials can be used in organic farming and is the heart of the transparent process that upholds the integrity of organic seal.  It must be protected—NO CHANGES are needed.
  • Invite them to visit your farm.

(See below for more detailed background and talking points if interested.)




Farm Bill Conferees met last week to start the negotiating process of ironing out the difference between the House and Senate farm policy proposals. Current farm policy expires the September 30, 2018.

Congress needs to send a farm bill to the President for signature by September 30 to preserve baseline funding for many organic programs. If Congress misses the deadline and only passes an extension of current farm programs, many important programs across 10 of the 12 farm bill titles lapses. Of particular importance to the organic industry are cost-share, organic research, data collection and National Organic Program upgrades.

These lapsed programs have been nicknamed “orphan programs”.  There are 39 programs that do not have a continuing baseline after September 30,2018 and cost $2.824 billion over the 5-year farm bill. If Congress extends the current farm bill, we lose our “baseline” or future funding commitment.

Almost every farm group in DC has been encouraging Congress to complete their work before the farm bill expires.  We need to keep the pressure on Congress.

Both the Senate and House farm bills would change the structure and authority of the National Organic Standards Board (NOSB).  The hydroponics industry has been working with Senate Agriculture Committee to change how NOSB operates. We do NOT need changes to NOSB, it is working well.

The NOSB is at the heart of the transparent process that upholds the integrity of the organic seal. Organic Farmers Association supports organic production that is soil-based.  We believe that the organic process should remain transparent and that farmers should have an authentic representation and role in the process.

The National Organic Standards Board (NOSB) is made up of 15 dedicated public volunteers from across the organic community. The Board advises the Secretary of Agriculture on a wide variety of topics related to organic standards, including what materials should be allowed in organic farming.

Organic standards must remain strong to ensure trust in the label and to create a level playing field for the vast majority of organic farms and businesses that are playing by the rules.

Organic farming improves farmers’ incomes and boosts rural economies.

Your Outreach is Important to the Last Step of the Farm Bill

Congress recently named farm bill conferees to start the final step in re-authorizing farm programs.  Naming conferees was required to start official discussions between the House and Senate to iron out the differences between the two farm bills proposals.  The Senate farm bill contains many of the Organic Farmers Association’s top priorities.

This is a critical time in the final steps of reauthorizing programs important to you, our members, and the whole organic community.  We need you to reach out to your elected officials to remind, and to explain, the importance of our policy priorities.

Agriculture Committee members need to hear from YOU!

Call 202-224-3121 and ask for your Senator or Representative’s office.

Please call both Senate offices & your Congressperson.  Ask to speak to their Agricultural Legislative Assistant.

Talking Points:

·       Introduce yourself, your organic farm or business, and include your location.

·       Ask your Senator or Representative to reach out to Conferees to include in the final conference committee bill:

·    The Organic Farmer and Consumer Protection Act as included in both bills, which improves the oversight of global organic trade, creates a level playing field for American organic farmers, and establishes a better system to ensure the integrity of organic import supply chain. Our policy poll shows 100% of our members support this effort;

·       Increased funding for organic research, as written in the Senate bill:  The Organic Extension and Research Initiative with full funding of $50 million by 2023. Again, our policy poll shows 97% of our members support this effort.

·       Re-authorizing the Cost-Share Program and providing $11.5 million of mandatory funding which is the Senate language, 89% of our membership support this position. and

·       No changes to the operation of the National Organic Standards Board (NOSB).  Our members see the board working as the industry intents and the organic market is growing. 93% of our members are asking OFA to work to keep NOSB operating as it is. This requires eliminating changes to the NOSB in both bills.  It’s not broken=don’t fix it!

Please let Organic Farmers Association know the results of your conversation by sending us a short email to: mark@organicfarmersassociation.org.

We appreciate your help at this critical time in the Farm Bill’s development.

We will continue to keep you in the loop.  Please keep an eye on your inbox the first week of September as we will update you on the conference committee process. Since current farm programs expire the September 30, 2018, we expect to have another need for OFA member outreach to keep the pressure on conferees to honor organic farmers’ priorities.

2018 Policy Platform

Each year, Organic Farmers Association solicits input on policy priorities and policy positions from ALL U.S. CERTIFIED ORGANIC FARMERS and organic farm organizations, which we did in December 2017. The OFA Policy Committee reviewed the results, identifies the top priorities, and drafted policy statements from this broad-based solicitation to submit to Organic Farmers Association members for comment, which was completed in May 2018.  In June, FARM MEMBERS of Organic Farmers Association voted on these policy positions.

For a position to become adopted as Organic Farmers Association policy, it must have 60% of the popular national vote and 60% popular support in at least two-thirds of the regions. Each year, newly adopted policies will become part of the Organic Farmers Association Policy Platform.

In 2018, all proposed policy positions were passed by the Organic Farmers Association Farm Members.  All proposed positions received 60% of the popular national vote and 60% popular support in each of the six regions.  The policy voting results are here.


Organic integrity is the bedrock of the organic label.  We must have equitable and honest enforcement of the National Organic Standards across all commodities, states, farm size, and throughout the international trade.

POSITION: OFA SUPPORTS full and equitable enforcement of NOP standards: USDA should take immediate action to focus first on high-risk operations and to bring non-complying operations and their organic certifying agents into compliance or exclude them from the program. USDA should be required to provide more transparency about the enforcement actions taken by NOP and their accredited certifying agents. Congress should use its oversight authority to ensure that USDA takes the necessary actions to tighten enforcement.

POSITION: OFA SUPPORTS strengthening USDA import inspection, review, and testing protocols to ensure organic label integrity.

POSITION: OFA SUPPORTS the Organic Farmer and Consumer Protection Act, which includes new Farm Bill requirements for USDA, in coordination with Customs and Border Protection, to implement enhanced procedures to track organic imports and ensure that imported products fully comply with U.S. organic standards.

POSITION: OFA SUPPORTS a consistent interpretation and implementation of §205.237 Livestock feed and §205.239 Livestock living conditions that uphold the intent of the rule; requiring access to pasture during the pasture season and a minimum of 120 days on pasture and 30% daily dry-matter intake from pasture for each herd subgroup (milking cows, dry cows, heifers). There must be a consistent and required policy and calculation matrix for pasture dry matter intake and pasture consumption for the 120-day organic dairy pasture rule.

POSITION: OFA SUPPORTS the USDA hiring leadership that has demonstrated expertise and experience in organic production, and USDA providing staff education that results in organic knowledge and proficiency.

POSITION: OFA SUPPORTS that USDA develops specific qualification criteria, expertise, and testing to illustrate proof of knowledge and that this is required of all accredited certifiers, inspectors and review staff to result in consistent oversight and interpretation of the rule for each scope of production.

POSITION: OFA SUPPORTS the clarity and integrity of organic standards in the marketplace.

POSITION: OFA SUPPORTS a fully funded certification and accreditation process that is transparent, risk-based (prioritization of problem areas) and requires producers and handlers to uphold high integrity in their organic production practices.

POSITION: OFA SUPPORTS the certification of all non-transport handlers and brokers of bulk, non-retail certified organic products including importer-handlers of organic products and ingredients.


Contamination is a major threat to the integrity of organic production. Avoidance and mitigation methods, as well as compensation for damage and market losses caused by genetic or pesticide trespass, must be developed and implemented. Pesticide applicators must have stricter rules for use and application of materials. Research and education are needed for pesticide applicators and users of genetically engineered technologies.

POSITION: OFA supports prevention of, and compensation for losses associated with, damage caused by genetic engineering and pesticide contamination of organic crops and other affected areas.


Hydroponics In 2010, the National Organic Standards Board (NOSB), by a 14 to 1 vote, recommended that hydroponic production not  be allowed to be certified organic, stating “systems of crop production that eliminate soil from the system, such as hydroponics or aeroponics cannot be considered as examples of acceptable organic farming practices…due to their exclusion of the soil-plant ecology intrinsic to organic farming systems and USDA/NOP regulations governing them.” Many USDA-accredited certifying agencies have avoided certifying hydroponic operations as organic because of the long-standing requirement—rooted in the Organic Foods Production Act (OFPA)—that organic production must be in the soil. Organic Farmers Association is concerned by the National Organic Program’s (NOP) January 25, 2018, statement that “Certification of hydroponic, aquaponic and aeroponic operations is allowed under the USDA organic regulations and has been since the National Organic Program began.” We are concerned this action is revisionist history and an incorrect interpretation of organic law.

POSITION: OFA OPPOSES organic certification of hydroponic production.

POSITION: OFA urges the National Organic Program (NOP) to revoke the organic certification of currently certified hydroponic systems and cease certification of new hydroponic operations.


The National Organic Certification Cost Share Program and the Agricultural Management Assistance Act (AMA), provide organic farmers with modest reimbursements for a portion of their annual organic certification fees.

POSITION: OFA SUPPORTS renewal of organic certification cost-share programs, with adequate mandatory funding to meet projected demand. Additional flexibility should be given to the Secretary to support programs beneficial to transition and ongoing organic production.


U.S. organic production lags far behind U.S. organic demand. This market gap hurts U.S. farmers and it is crucial that we invest in organic research to support the domestic production of organic crops. Farmers need a bigger investment in public organic agricultural research. Organic research is a win-win for all U.S. farmers, as the basis of organic agriculture is soil health and alternative pest and disease management strategies—research in these areas benefit both organic and conventional farmers. Research dollars for conventional agriculture and organic agriculture are out of balance.

The bipartisan Organic Agriculture Research Act (H.R.2436/S.2404) has been introduced in the House and Senate to authorize $50 million in mandatory funding annually for the Organic Agriculture Research and Extension Initiative (OREI). Funding for OREI has been stagnant at $20 million since fiscal year 2010, while many of the production challenges of organic farmers go unaddressed.

POSITION: OFA SUPPORTS increasing funding of federal organic agricultural production research to at least the same percentage represented by retail organic sales within the US marketplace.

POSITION: OFA SUPPORTS passage of the Organic Agriculture Research Act (HR2436/ S2404).


The National Organic Standards Board (NOSB) was created as a citizen stakeholder advisory committee to allow for a formalized process to ensure grassroots organic input into standard-setting and decision-making processes at USDA.

The Organic Foods Production Act (OFPA) statutory language lays out the details of the authorities and composition of the NOSB to ensure that the various stakeholder sectors of organic (farmers, handlers, retailers, environmental/conservationists, public interest/consumer groups, and scientists) all have a seat at the table.

The Board meets twice a year and invites the public to provide comments during the meeting, at pre-meeting webinars, as well as in writing before the meeting. There is no place in our food system that is more transparent than in organic production, and the role of the NOSB is central to that transparency.

POSITION: OFA OPPOSES any efforts to reduce the authority and role of the National Organic Standards Board (NOSB) in the overall standard-setting process, or to seek statutory changes to the delicate balance of stakeholder slot allocations for the Board membership.


The Organic Livestock and Poultry Practices Rule (OLPP) or “animal welfare rule” would have allowed the NOP to consistently enforce stronger animal welfare standards on organic farms and remove loopholes being taken advantage of by some large operations. The USDA withdrew the rule in May 2018.

POSITION: OFA SUPPORTS animal welfare requirements as proposed in the Organic Livestock and Poultry Practices Rule (as withdrawn 2018).


Organic farmers should be able to ensure their crops based on organic prices, not conventional prices. While USDA’s Risk Management Agency (RMA) has made progress in this area, crop insurance programs still need updating to make them relevant and competitive for organic and transitioning to organic farmers.

POSITION: OFA SUPPORTS equitable and fair-market insurance programs that are accessible and relevant for all sectors of diversified organic (and transition-to-organic) producers.

POSITION: OFA SUPPORTS Congress to direct the Risk Management Agency (RMA) to prioritize development of additional organic price elections for crop insurance coverage, and review policies that cap Contract Price Addendums at two-times the conventional price election for any specific crop.

POSITION: OFA SUPPORTS allowing organic transition producers to calculate the Actual Production History Yield (APH) for acres under organic transition using the APH of other organic acres on their farm, rather than the county T-Yield for the acres under transition.

POSITION: OFA SUPPORTS continuation of Whole-Farm Revenue Protection established in the 2014 Farm Bill and recognize the change in farm revenue after a farm has transitioned to organic. Raise the cap to 50% on increased production value under the expansion provision.

POSITION: OFA SUPPORTS Congress to direct the Farm Service Agency to develop organic price elections for storage loans offered. Producers will then have the ability to access working capital based on the actual value of their crops to cash flow their operations. Utilize existing organic price data developed by RMA to establish storage loan prices.

POSITION: OFA SUPPORTS extension of the Dairy Margin Protection Program to cover organic dairy operations by using the cost of organic dairy feed and inputs to calculate organic milk margin. This change would make the program relevant to the needs of small to midsize dairy operations.


The FDA Food Safety Modernization Act (FSMA) was signed into law by President Obama on January 4, 2011. It aims to ensure the U.S. food supply is safe by shifting the focus of federal regulators from responding to contamination to preventing it.

POSITION: OFA supports improvements to the Food Safety Modernization Act, providing science-based and practical guidelines that are in line with organic practices and standards.


Over the last decade, Americans have become increasingly interested in where our food comes from, how it is produced, and by whom. This interest has driven the organic food market to become the fastest growing agricultural sector, creating opportunities for beginning farmers to capitalize on this increased market demand as they start their businesses.

Unfortunately, high barriers to entry, such as difficulty accessing affordable farmland, high upfront startup costs, and inadequate training and technical assistance, make it difficult for beginning farmers and ranchers to pursue careers in agriculture. Young and beginning farmers entering agriculture today have different needs and face different challenges than those who started farming decades ago.

Many new farmers operate smaller farms, run diversified operations, and come from non-farm backgrounds and therefore struggle to access farmland, which has traditionally been passed down from generation to generation. Many beginning farmers chose to farm using organic methods and need specified technical assistance to enter this growing consumer market.

POSITION: OFA urges Congress to include a Beginning Farmer & Rancher Development Program (BFRDP) funding priority for projects focused on providing organic technical assistance to beginning farmers.


Organic Market Growth
U.S. consumers are demanding more organic food, and they have proven this desire by growing the U.S. organic market by at least 10 percent annually since the inception of federal organic standards in 2002.  In 2017, U.S. organic sales reached $47 billion (exceeding 5% of the total food sales in America) with over 17,500 U.S. certified organic farmers and 7,500 processors.

The organic market has helped preserve family farms across the country, paying farmers up to two to five times what they make under conventional agriculture. However, domestic organic production is not keeping pace with demand—we simply do not have enough certified organic farmers in the United States, and thus organic imports are filling the gap.

Less than 1 percent of U.S. farmland is certified organic and thus, U.S. farmers are losing opportunities to fill this consumer demand locally. Many conventional farmers are looking for alternatives to help them survive in agriculture but do not know how to start with the transition to organic.

POSITION: OFA SUPPORTS targeted outreach, training, information and technical assistance on organic farming systems, USDA organic certification and transition, and organic market development to historically underserved, minority and beginning farmers through USDA agency programs, land-grant institutions, and NGOs.

Organic Production Market and Data Initiatives (ODI)
The USDA’s Organic Production Market and Data Initiatives (ODI) collects information vital to maintaining stable markets, creating risk management tools, tracking production trends, and increasing exports. Good and consistent data collection is imperative to support a growing agricultural industry.

POSITION: OFA SUPPORTS reauthorization of the Organic Data Initiative (ODI) to provide $5 million per year in mandatory funding for USDA organic data efforts, as well as a continuation of existing language authorizing additional funding through the annual appropriations process.


USDA Natural Resource Conservation Service programs help farmers and ranchers implement and enhance conservation systems on their operations.

These programs align with conservation priorities of organic farms and should be expanded to encourage more organic participation so that organic farmers are supported in continually improving their farming operations.

POSITION: OFA SUPPORTS raising the six-year payment limit from $80K to $450K under the Organic Initiative within the Environmental Quality Incentive Program (EQIP) making these payments equal to the rest of the EQIP program, and thereby ensuring full opportunity for organic farmers to participate in the program.

POSITION: OFA SUPPORTS Congress to direct USDA to recognize required organic practices within the full suite of conservation programs including the Conservation Stewardship Program (CSP) and expand CSP organic bundles to transitioning organic farmers. CSP transition bundles will assist farmers with implementing organic practices, provide technical assistance during the transition period, and offset the financial costs of transitioning.

POSITION: OFA SUPPORTS reform of Conservation Reserve Program (CRP) to include organic producers and producers planning to transition to organic as additional allowed applicants to be eligible to participate in CRP Transition Incentive Payments (TIP).


Both organic and conventional farmers need seeds and animal breeds well-suited to their local growing conditions, changing climates, and farming systems. Without these tools, farmers are handicapped, and their productivity is negatively affected.  Congress, USDA, and our nation’s public research universities must work together to reinvigorate public plant and animal-breeding programs to provide farmers with continually improving and regionally adapted seeds and breeds.

POSITION: OFA SUPPORTS the new Farm Bill requiring USDA’s National Institute for Food and Agriculture (NIFA) to use its existing competitive grants research programs to collectively allocate $50 million annually to public plant and animal breeding programs, with a priority focus on developing regionally adapted organic cultivars and animal breeds excluded from the Plant Protection Act.


From 2010 – 2014, the USDA funded a position titled: Organic and Sustainable Agriculture Policy Adviser, which coordinated organic issues across different USDA agencies under the Secretary of Agriculture. This position was helpful in coordinating organic farming policy issues across agencies and assisting with the “Know Your Farmer, Know Your Food” initiative.

POSITION: OFA SUPPORTS funding and filling the Organic and Sustainable Agriculture Policy Advisory staff position to serve as a communications link between the National Organic Program (NOP) and the Office of the Secretary of Agriculture to work directly with the Secretary, the Deputy Secretary, and the agency leaders within USDA to coordinate organic policy and educate the Department’s personnel about organic farming and what the National Organic Program (NOP) does and why it is important to the other goals of USDA.


The mission of the Organic Farmers Association is to provide a strong and unified national voice for domestic certified organic producers. With the purpose to build and support a farmer-led national organic farmer movement and national policy platform by: developing and advocating policies that benefit organic farmers; strengthening and supporting the capacity of organic farmers and farm organizations; and supporting collaboration and leadership among state, regional and national organic farmer organizations. Learn more at OrganicFarmersAssociation.org.

Policy Platform voting open through July 8, 2018

Each year, Organic Farmers Association solicits input on policy priorities and policy positions from ALL U.S. CERTIFIED ORGANIC FARMERS and organic farm organizations, which we did in December 2017. The OFA Policy Committee reviewed the results, identified the top priorities, and drafted policy statements from this broad-based solicitation to submit to OFA members for comment, which was completed in May 2018.

Now, the certified organic FARM MEMBERS of Organic Farmers Association, will vote on these policy positions.

For a position to become adopted as OFA policy, it must have 60% of the popular national vote and 60% popular support in at least two-thirds of the regions. Adopted policies will become part of the Organic Farmers Association Policy Platform.

BALLOT OPEN: Tuesday, June 5 -- Sunday, July 8. 

If you are not yet a certified organic farm member of Organic Farmers Association but want to participate in the vote, join today to receive your ballot.

Only one ballot per farm is accepted to honor our ONE FARM, ONE VOTE policy.

To view policy positions click here.