Click here for OFA Submitted Written Comments:  Fall 2021

Below: OFA Oral Comments to the NOSB via Webinar Testimony:  Fall 2021

October 13, 2021

Kate Mendenhall, Executive Director

Thank you, NOSB members for the opportunity to speak before you today.  My name is Kate Mendenhall, I am the Executive Director of the Organic Farmers Association.  OFA was created to be a strong national voice and advocate for domestic certified organic farmers.  Our policy positions are created through a nationwide grassroots process that invites the participation of all domestic certified organic farmers and then our certified organic farm members vote on these policies.  We operate a strict one farm- one vote policy so all farmers have an equal seat at the table.

Today I will address three areas:  Public Comment Process, Ammonia Extract, and Sodium Nitrate.

Public Comment Process:   We have found a more diverse group of organic farmers able to participate in the oral testimony virtual format and encourage you to continue to offer this platform.  Without both the webinar and in-person oral comment opportunities it seems there is less time for comments, so we encourage you to keep this a priority of the NOSB process.  We also encourage you to adjust the rules for how comment slots are assigned to make sure that organic farmers have some priority to testify to the board.  Many of the registrations occur during high-farm production cycles and the oral comment slots often fill up weeks before the deadline- often with multiple people from the same company or organization.

Ammonia Extract Prohibition:  OFA recently adopted a policy position, which states:

“OFA supports prohibiting the use of ammonia extract for use in organic production because such use is incompatible with OFPA and good soil health practices.”

Therefore, we support the first two National List Motions: to add Stripped Ammonia and Concentrated Ammonia at §205.602, non-synthetic substances prohibited for use in organic crop production.

Sodium Nitrate:  We have testified before on OFA’s  policy position, which states:

Consistent with NOSB’s April 2011 recommendation, the Organic Farmers Association SUPPORTS re-listing Sodium Nitrate on 7 CFR 205.602 without annotation. This rulemaking action would make sodium nitrate prohibited in organic farming and eliminate the use of this soluble, plant-available fertilizer, which circumvents natural nutrient cycling in organic soil management.

Therefore, we support the Subcommittee’s motion to reinstate the listing of sodium nitrate at 7 CFR 205.602(g) – prohibited nonsynthetic. But wish it was more restrictive.

When we have discussed both Ammonia extract and sodium nitrate with our farmer-policy committee,  the larger topic about soluble nitrogen comes up.  OFA encourages the NOSB to review soluble nitrogen as a whole rather than addressing individual nitrogen products or forms.  Cultural management like preventative practices that limit the need for external and off-farm inputs for building a healthy agroecology system is a critical piece of building organic matter and good soil health.    Organic is a solution for climate change because we have demonstrated standards that celebrate and demand good soil health as an essential component of organic certification for decades.  We must protect that for the future of organic.

 

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October 13, 2021

Patty Lovera, Policy Director

My name is Patty Lovera and I am the policy director for the Organic Farmers Association (OFA). We appreciate the opportunity to provide comments and the time and energy Board members devote to this process.

Oversight Improvements to Deter Fraud and Improve Traceability

We are happy the Board is discussing oversight improvements to deter fraud and improve traceability. Dealing with fraud has been a top priority for OFA members since the organization’s founding. We provided more detailed comments in writing, but wanted to offer some general concerns:

1. It will be important to ensure that any new traceability requirements do not create additional burdens on farmers who already do a lot of recordkeeping to be certified organic. Any new traceability requirements must ensure that farms are not required to use specific software, technology or other services beyond certification in order to comply, and paper-based systems must be allowed.
2. The evaluation of new requirements should assess the likelihood that buyers will impose certain traceability practices on their suppliers.
3. The NOP should also consider if technical assistance will be needed for farms or certifiers to comply with any new traceability requirements.

In response to Question 6 in the discussion document — Are there additional areas that need to be considered for improvement to prevent fraud or react to fraud?:

We would say emphatically, Yes.

First, we need the Strengthening Organic Enforcement rule finalized as soon as possible.

NOP also needs to continue to coordinate with other USDA agencies as well as U.S. Customs and Border Protection to leverage other agencies’ inspection resources at ports of entry.

NOP should develop investigative procedures that are triggered by import data, such as automatically starting an investigation when there is a significant surge in imports for a specific product category.

NOP should collaborate on enforcement (not just standards setting) with our trading partners. If a country we have a trade relationship with has taken enforcement action against a certifier or certified operation, that information should be shared as part of the trade relationship.

In response to question 7 –Should the industry require the registration of land 36 months before certification?:

Yes. In addition to allowing better audits that can detect fraud, this type of data could help current organic farms make better decisions about how to participate in their markets. We had additional thoughts in our written comments about the need for some flexibility in how this data is collected and presented to avoid creating a burden for farmers.

Proposal: Kasugamycin – petitioned

OFA urges the Board not to allow kasugamycin for plant disease control. Using antibiotics in organic production is contrary to consumer expectations, as organic marketing commonly states that no antibiotics are allowed in organic production. Antibiotic resistance poses a serious threat to human health, and use of antibiotics in agriculture contributes to that threat.