OFA Policy Director Testimony to NOSB

April 23, 2020

RE: General Comments to the NOSB via Webinar Testimony

My name is Patty Lovera, and I am the Policy Director for the Organic Farmers Association. Thank you for finding a way to have these public comments happen during the disruption of the pandemic and welcome to the new board members.

The Organic Farmers Association is led by domestic certified organic farmers. The integrity of the organic label continues to be organic farmers’ top priority.

We appreciate the role NOSB plays in the process of keeping organic integrity high, and would like to point out that an important piece of the board being able to perform this role would be restoring their ability to set their own work agenda.

Because this is space for the whole organic community to gather, I am going to mention a few things that we need from the National Organic Program to move forward on issues the board has already considered.

  1. The rulemaking on Origin of Livestock is desperately needed to address inconsistency on the ground in transition of organic animals. There are more details about OFA’s specific policy on the origin of livestock in our written comments, but two key needs for the rule are:
  • A producer can transition bovine dairy animals into organic production only once.
  • Once the regulation is finalized, fast effective date. This confusion has gone on long enough and created an unlevel playing field for those producers who have been meeting the intent of the standards for many years.

In addition to OOL rule, we also urge the NOP to continue to focus on compliance with the pasture rule, with an emphasis on higher risk operations

  1. Strengthening Organic Enforcement – we are catching up to build the enforcement capacity necessary for a $50 billion industry with complicated, often global supply chains. We understand this rule appears to be stuck in the White House review process, but we urge the program to move as quickly as possible to finish it up once it moves out of the review process. We desperately need more enforcement in organic markets.

Finally, we have a request to the program relating to the USDA’s plan for pandemic response. Organic farms have adapted very quickly to the disruption caused by the pandemic, figuring out new supply chains, online ordering, dealing with local and state regulations that change every day or every week, learning for the first time about the Small Business Administration, and host of other adjustments. In a lot of ways, the organic sector has proven more resilient and flexible than our conventional counterparts who deal with more consolidated supply chains.

But that does not mean that organic farmers don’t need help. And it is not yet clear how the USDA’s pandemic response programs – either the commodity purchasing or the direct payments – will work for organic farms. We urge the program to advocate for organic producers inside the USDA to make sure organic operations can access these new programs.

Thank you.
Patty Lovera