Organic Farmers Association’s Director, Kate Mendenhall, provides oral comment at the 2019 Spring NOSB meeting in Seattle, Washington. Read her full statement below:

Thank you, members of the National Organic Standards Board for the opportunity to speak before you today.
My name is Kate Mendenhall, I am the director of the Organic Farmers Association and I am also an organic
farmer in northwest Iowa. Founded in 2016, Organic Farmers Association provides a strong and unified national
voice for domestic certified organic producers. We are led and controlled by certified organic farmers—only
certified organic farmers drive our policy positions and our policy work agenda. We have farmer-members in 48
of the 50 states.

Organic Farmers Association greatly supports the work and role of the National Organic Standards Board and
finds your role paramount in maintaining integrity in the USDA organic label.
Organic farmers were active in every step towards building our national organic movement and market, and we
believe organic farmers deserve a driving seat in setting the future of the organic label. Our 2019 certified
organic farmer policy survey identified five top priorities from the wider certified organic farmer community—
feedback that extends beyond our membership and invites all U.S. certified organic farmers to participate in.
This winter, organic farmers ranked the top five priority issues as:

1. Organic Import Fraud
2. NOP Enforcement to Ensure Organic Integrity
3. Prohibiting Hydroponics in Organic Production
4. Pasture Rule Enforcement
5. Organic Dairy Standards & Enforcement

We urge the National Organic Standards Board to:

1. Reaffirm their October 2018 resolution regarding Origin of Livestock urging NOP to move to a final rule
   in 2019.
2. Encourage NOP to issue training and guidance for risk-based certification oversight in organic dairy
   focusing on operations on the margins of the 30%DMI rule and dairies with 1,000 or more milking and
   dry cows.
3. Call for the NOP to issue an immediate moratorium on any new hydroponic operations and return this
   issue to the NOSB work agenda as a top priority. OFA believes the NOP should implement the 2010
   NOSB recommendation to not allow certified organic hydroponics, but we recognize there is an
   immediate urgency to put a moratorium on new hydro operations so that we can have more
   conversation and consensus within the organic community. The current lack of uniform standards,
   implementation, and enforcement for hydroponic certification is publicly undermining the integrity of
   organic farmers nationwide. The lack of clarity around a 3-yr transition following the use of a prohibited
   substance is unacceptable. This ambiguity to a clear rule enforced throughout the life of organic
   certification calls to question the integrity of entire NOP program.

Thank you for the opportunity to address you today.