Organic Farmers Association’s Director, Kate Mendenhall, participated at the Pre-NOSB Meeting in Seattle, Washington to discuss 2019 organic integrity priorities including:
1. Organic Import Integrity—ensuring that organic imports are indeed authentically organic and not fraudulent. 
2. Organic Dairy Integrity—which includes enforcement of the Pasture Rule and Clarity in the Origin of Livestock Rule.
3. Organic Production Integrity—Honoring the integral role of soil in organic production and prohibiting the organic certification of hydroponic operations

Meeting Panel Discussion: Organic Integrity Priorities for 2019
April 23, 2019
Presented by Kate Mendenhall, Organic Farmers Association
Additional Panel Members:
Laura Batcha, Organic Trade Association
Abby Youngblood, National Organic Coalition

Organization History, Mission, Who we represent in our policy work
Good morning! Thank you for the opportunity to participate on this panel. I am looking forward to hearing how our three organizations’ policy priorities align and diverge around organic integrity.

The mission of the Organic Farmers Association is to provide a strong and unified national voice for domestic certified organic producers. We are organic farmer-run and farmer controlled. Only certified organic farmers determine our policy positions and have the power of a vote on our farmer-elected leadership committees. Our vision for the future is that organic agriculture is the basis of a viable United States food and agricultural policy and production system.

We officially launched in the fall of 2016, after three years of farmers and farm organizations meeting regularly to determine what was needed in the organic farming movement to ensure that organic farmers’ policy needs were heard and rising to the top of the conversation around organics. Organic Farmers Association launched under the fiscal sponsorship of the Rodale Institute, so while we have political autonomy in our positions and process, the Rodale Institute provides a lot of organizational capacity to support this work. Rodale has been an advocate of organic farming in the United States since 1947 and so it is a perfect partnership to our work to represent organic farmers nationwide.

The focus of our work at Organic Farmers Association is to build and support a farmer-led national organic farmer movement and national policy platform by:

• developing and advocating policies that benefit organic¹ farmers;
• strengthening and supporting the capacity of organic farmers and organic farm organizations;
• supporting collaboration and leadership among state, regional and national organic farm organizations; and
• welcoming support and cooperation with like-minded individuals and organizations.

Describe the top 3 issues that you think should be the priority in the next year to protect organic integrity
Our top organizational policy priorities focus specifically on organic integrity. This is at the top of almost all organic farmers’ minds. OFA’s priorities align with two stages of our policy development process—Every year we survey all certified organic farmers nationwide to ask them to identify their policy priorities and to offer policy positions for Organic Farmers Association to consider. Our certified organic farmer members then vote on the vetted proposed policies. The top organic integrity policies identified in our 2019 wide-net survey serve as the focus for our 2019 policy work:

1. Organic Import Integrity—ensuring that organic imports are indeed authentically organic and not fraudulent.
2. Organic Dairy Integrity—which includes enforcement of the Pasture Rule and Clarity in the Origin of Livestock Rule.
3. Organic Production Integrity—Honoring the integral role of soil in organic production and prohibiting the organic certification of hydroponic operations.

Throughout all three of these priority areas, the element most crucial and universal is sufficient and consistent National Organic Program enforcement of the National Organic Standards and ensuring the standards uphold the intention and written words of the Organic Foods Production Act of 1990—the law defining organics.

Organic Import Integrity
Our first integrity priority is ensuring that organic imports are in fact legitimately organic—following the same standards our domestic certified organic farmers are held to. Organic Farmers Association was supportive of the Organic Farmer & Consumer Protection Act, which was included in the 2018 Farm Bill. This portion of the Farm Bill gives additional authorities to the National Organic Program to better monitor the organic integrity of imports as well as improve their database to better track the organic import audit trail. We understand that the NOP is working on incorporating the components of this into their Enforcement Rule this spring and we will be eager to see the new regulations and their swift implementation.

Domestic organic farmers work hard to follow the national organic standards and they deserve fair competition. We will be monitoring the implementation of the rule to ensure that fraudulent organic imports cease so that U.S. organic farmers are not undercut by fraud. This is a top priority of certified organic farmers because it is crucial that organic consumers trust that all organic products are raised according to the standards and that the USDA organic seal ensures the integrity of the standards. We want swift correction and implementation on this
problem—especially focused on organic grain imports since the lack of enforcement here has been most egregious. We feel that risk assessment will aid the targeting of small resources to focus on countries that present higher risk.

Organic Dairy Integrity
Organic farmers nationwide have also placed a high priority on rectifying the current problems we are seeing in organic dairy. Organic dairy continues to be an entry-point for new organic consumers and we cannot lose consumer trust on what is inside that carton. We want better guidance and enforcement by certifiers and overall enforcement by the NOP during the accreditation process on the monitoring of pasture rule compliance and consistent interpretation of the origin of livestock for bovine dairy transition.

The Organic Farmers Association encourages the USDA to take effective actions to ensure that organic dairy products meet consistent standards for all producers, large and small, domestic and foreign. We believe that risk assessment should be a priority when conducting inspections and accreditation. Organic Farmers Association has shared with the USDA our concern about a lack of consistency in the enforcement of the Access to Pasture rule. There are physical and biological limitations to grazing milking cows daily and bringing the cows back to the milking facility. As herd sizes increase, it becomes increasingly difficult to meet the grazing requirement, “that ruminants derive not less than an average of 30 percent of their dry matter intake (DMI) requirement from pasture grazed over the course of the grazing season.” Experienced organic dairy farmers have expressed concern that when milking herds reach or exceed 1000 cows, it becomes difficult to meet the NOP grazing rule, especially for operations that practice more than two milkings a day. It may not be difficult to grow enough pasture to meet the DMI requirements, but to logistically get the cows to the pasture to graze the living pasture out of the field to reach the 30%DMI requirement and then back for milkings presents particular challenges for larger herds. Organic Farmers Association (OFA) has asked the NOP to strengthen its enforcement of the Access to Pasture rule by instructing certifying agents to identify high risk dairy operations as those with over 1000 milking and dry cows and farms that regularly land just at the minimum 30%DMI mark. Specific recommendations for these operations include: • Requiring certification file review staff and organic inspectors to have documented training and experience in livestock nutrition and grazing. • Requiring a calculation matrix to verify meeting the grazing requirement documenting: average animal weight, individual and verifiable unique identification of each animal, milk production, daily DMI requirement, daily non-pasture dry matter consumption, acres of pasture, forage yield of pasture, and maximum distances cows walk to pasture.
• Confirmation that DMI is calculated as an average over the entire grazing season for each type and class of animal and that milking and dry cows are not being mixed in those calculations.

• Two inspections during the grazing season, one announced and one unannounced.

Origin of Livestock Rule
The other priority dairy issue for us is Origin of Livestock. There currently is a two-track interpretation being allowed under the current regulations and it is a major contributor to the existing dairy crisis, along with pasture rule compliance. We are asking the USDA to release the final rule to the 2015 Origin of Livestock Rule in 2019. They have sufficient comments from the 2015 rule, they want and need clear standards to be able to do their job of enforcement, and they have the legal authority to be able to issue a final rule this year. While it may be more comfortable for the administration to release a 2nd rule and ask for additional comments and economic analysis, not moving to a final rule would be a mistake. This nation’s organic dairy farmers cannot wait for two more rounds of rule-making especially heading into an election year—which could result in additional delays. The NOP’s prediction of a clarified origin of livestock standard by 2021 to 2022 is unacceptable and irresponsible. We know with proper attention USDA can get it done this year. The organic community is aligned on the need for this voluntary regulation, which is simply a fix to a poorly written old regulation.

Organic Certification of Hydroponics
The third priority identified by U.S. certified organic farmers is keeping soil as the keystone to organic certification. This is not a priority pushed solely by our elected policy committee or our elected governing council—this is a priority that has been identified over the past two years consistently by certified organic farmers nationwide from our annual surveys. Participants have asked that OFA prioritize its work and resources on opposing the organic certification of hydroponic systems. In 2018 it was the #4 priority and in 2019 it moved up to farmers’ #3 priority. In 2018 our farmer members proposed and passed two strong policies regarding hydroponics:

1. OFA OPPOSES organic certification of hydroponic production.
2. 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 first policy opposing organic certification of hydroponic production passed with a national organic farmer vote of 90%. It also passed in each of OFA’s six regions: Organic farmers in California passed it by 78%; organic farmers in the Western Region by 86%; in the North Central Region by 92%; in the Midwest by 96%; in the Northeast by 89%, and in the South by 92%. Organic farmers are united in their concern regarding the organic certification of hydroponic production.

Organic Farmers Association feels that there is a place for hydroponic production within sustainable agriculture; however, we DO NOT think it can nor should be certified organic. It does not and cannot meet the USDA definition of organic nor the standards if it is not grown in soil.
This organic movement was created and based on soil health as the foundation to all future standards. We cannot waiver from that foundational principle. Farmers will not stand for it. Organic Farmers Association will challenge this until the USDA does what is right—revoking organic certification of hydroponic systems and returning to a commitment of organic soil health and biological systems that contribute to a cleaner and healthier food system.

Organic Farmers Association has signed a petition with many other organizations written by the Center for Food Safety challenging the USDA NOP’s statement that it is and always has been allowed. The NOSB’s historical discussion, debate, and thousands of work hours discussing and researching the topic clearly supports that this has never been a clarified subject and we will not accept the NOP’s simple statement hoping to quiet certified organic farmers on the subject. We will be creating a comprehensive strategy this Spring and welcome organic farm organizations to join us in this campaign to defend organic integrity here on U.S. soil.

1 OFA acknowledges that across the country different terms are used within the agricultural community. When OFA uses the term “organic farmers,” it includes certified organic farmers and ranchers as well as organic producers exempt from certification (grossing under $5,000 annually).