DEADLINE: OCTOBER 5

We need OFA members to weigh in during the public comment period for the Strengthening Organic Enforcement proposed rule to make sure it gets finalized quickly and that the final rule is a strong as possible. 

COMMENT ON STRENGTHENING ORGANIC ENFORCEMENT RULE

Here’s how you can comment:

The fastest way to submit a public comment is through the federal government’s online system. This proposed rule has its own web page and you can click on the “Comment Now” button on the top right to enter your comment. You can either copy and paste your comment into the system or attach a file.

If you want to submit a hard copy of your comments instead (you don’t need to do this if you submit online), send it to:

Jennifer Tucker, Deputy Administrator, National Organic Program, USDA-AMS-NOP, 1400 Independence Ave. SW, Room 2642-So., Ag Stop 0268, Washington, DC 20250-0268;  Fax: (202) 260-9151

What to include in your comment:

• Make sure to include the docket number for this proposed rule in your written comment: AMS-NOP-17-0065.
• Explain that you are an organic farmer and mention any specific concerns you have or examples of how fraud in organic supply chains has impacted you.

TALKING POINTS:

• This proposed rule is necessary and long overdue. I especially support the end to exemptions for uncertified handlers in the supply chain and the requirement of electronic import certificates.
• I urge the USDA to finalize this rule as soon as possible and speed up the effective date so that the agency can start enforcing these rules to prevent fraud in organic supply chains.
• For section 205.273(c), I urge the USDA to shorten the time frame allowed for an importer to submit an electronic import certificate into the ACES system. Allowing importers 10 days to file the electronic certificate after the shipment has reached a U.S. port could mean the difference between preventing fraudulent products from entering the U.S. and having to try to retrieve them once they have entered commerce.
• I appreciate the proposed rule’s requirements that non-retail containers be labeled with more information about the organic status of products (section 205.307). But I urge the agency to expand this requirement to large non-retail containers such as trailers, tanks, rail cars, shipping containers, grain elevators/silos, vessels, cargo holds, freighters, barges, or other method of bulk transport or storage. Providing a visual indicator that these contain organic products serve as a valuable backstop to other methods, such as organic certificates, and provide one last opportunity to prevent unintended commingling or treatment with irradiation or other prohibited substances. I also urge the agency to investigate technologies that indicate whether containers have been opened or tampered with during shipping for large-scale shipments.

 COMMENT ON STRENGTHENING ORGANIC ENFORCEMENT RULE