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.
An example of the seed sampling protocol, from the California Crop Improvement Association is here.
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.