Organic Farmers Association Policy Positions

Each year, Organic Farmers Association solicits input on policy priorities and policy positions from all U.S. certified organic farmers and organic farm organizations, which we did in December 2018. The OFA Policy Committee reviewed the results, identified the top priorities, and drafted policy statements from this broad-based solicitation to submit to OFA members for comment, which was completed in April 2019. In May, farm members of Organic Farmers Association voted on these policy positions.  

For a position to become adopted as OFA policy, it must have 60% of the popular national vote and 60% popular support in at least two-thirds of the regions. Each year, new adopted policies will become part of the Organic Farmers Association Policy Platform.

In 2019, all proposed policy positions were passed by the Organic Farmers Association Farm Members. All proposed positions received more than 60% of the popular national vote and more than 60% popular support in each of the six regions.

ORGANIC INTEGRITY

POSITION:  OFA SUPPORTS full and equitable enforcement of NOP standards: USDA should take immediate action to focus first on high risk operations and to bring non-complying operations and their organic certifying agents into compliance or exclude them from the program. USDA should be required to provide more transparency about the enforcement actions taken by NOP and their accredited certifying agents. Congress should use its oversight authority to ensure that USDA takes the necessary actions to tighten enforcement. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS strengthening USDA import inspection, review, and testing protocols to ensure organic label integrity. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS the Organic Farmer and Consumer Protection Act, which includes new Farm Bill requirements for USDA, in coordination with Customs and Border Protection, to implement enhanced procedures to track organic imports and ensure that imported products fully comply with U.S. organic standards. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS a consistent interpretation and implementation of §205.237 Livestock feed and §205.239 Livestock living conditions that upholds the intention of the rule; requiring access to pasture during the pasture season and a minimum of 120 days on pasture and 30% daily dry-matter intake from pasture for each herd subgroup (milking cows, dry cows, heifers). There must be a consistent and required policy and calculation matrix for pasture dry matter intake and pasture consumption for the 120-day organic dairy pasture rule. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS the USDA hiring leadership that has demonstrated expertise and experience in organic production, and USDA providing staff education that results in organic knowledge and proficiency. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS that USDA develop specific qualification criteria, expertise, and testing to illustrate proof of knowledge and that this be required of all accredited certifiers, inspectors and review staff to result in consistent oversight and interpretation of the rule for each scope of production. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS the clarity and integrity of organic standards in the marketplace. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS a fully funded certification and accreditation process that is transparent, risk-based (prioritization of problem areas) and requires producers and handlers to uphold high integrity in their organic production practices. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS the certification of all non-transport handlers and brokers of bulk, non-retail certified organic products including importer-handlers of organic products and ingredients. (Adopted by the farmer membership 2018.)

POSITION: OFA SUPPORTS the reactivation of the 2015 Origin of Livestock Proposed Rule and the publication of a Final Rule in 2019 that revises the current regulation so that it aligns with the principles expressed in the preamble of the December 21, 2000 Federal Register National Organic Program Final Rule (page 80570).  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS an immediate implementation of the Final Origin of Livestock Rule and asks the USDA to prioritize the following prior submitted comments in the writing of the Final Rule:

  1. A producer as defined by the USDA NOP may transition bovine dairy animals into organic production only once.
  2. A producer is eligible for this transition only if they convert an entire established non-organic dairy operation to organic production at the same geographic location within a defined 12-month period. Once that transition has started, other non-organically certified animals cannot be added to the herd.
  3. This transition must occur over a continuous 12-month period prior to production of milk or milk products that are to be sold, labeled, or represented as organic.
  4. A producer must not transition any new bovine dairy animals into organic production after the end of the 12-month transition period.
  5. A producer is not eligible for the exemption if it has been used by a Responsible Connected person who has 20% or more ownership share in their legal entity.
  6. The certifying entity will file an organic system plan prior to the start of transition and the transition process is overseen by the certifier as part of their accountability.
  7. Transitioned animals must not be sold, labeled, or represented as organic slaughter stock or organic bovine dairy animals.
  8. If organic management of the dairy animal, starting at the last third of gestation or at any other time it has been organic, is interrupted, the animal cannot be returned to organic certification.
  9. Split bovine conventional and organic milking herds at the same location are prohibited.
  10. Once the regulation is finalized all entities will be required to immediately meet the requirements of the Final Rule. There will be no implementation period 

(Adopted by the farmer membership 2019.)

POSITION: 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.  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS that all National Organic Program materials go through the OFPA required independent five-year sunset review by the NOSB to remain on the National List and that the USDA immediately stop labeling a material listing as an “invalid listing” as no definition nor explanation of procedures for determination and management for the term exists. (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS requiring that the farmer-seat on the NOSB is filled by a farm operator (according to USDA-ERS definition).  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS a consistent interpretation and implementation of §205.237 Livestock feed and §205.239 Livestock living conditions that upholds the intention of the rule; requiring access to pasture during the pasture season and a minimum of 120 days on pasture and 30% daily dry-matter intake from pasture for each herd subgroup (milking cows, dry cows, heifers). There must be a consistent and required policy and calculation matrix for pasture dry matter intake and pasture consumption for the 120-day organic dairy pasture rule. Risk based unannounced additional inspections must be routinely conducted to ensure compliance.  (Adopted by the farmer membership 2019.)

ORGANIC CERTIFICATION COST SHARE

POSITION:  OFA SUPPORTS renewal of organic certification cost-share programs, with adequate mandatory funding to meet projected demand. Additional flexibility should be given to the Secretary to support programs beneficial to transition and ongoing organic production. (Adopted by the farmer membership 2018.)

CONTAMINATION

POSITION:  OFA supports prevention of, and compensation for losses associated with, damage caused by genetic engineering and pesticide contamination of organic crops and other affected areas. (Adopted by the farmer membership 2018.)

HYDOPONICS

POSITION:  OFA OPPOSES organic certification of hydroponic production. (Adopted by the farmer membership 2018.)

POSITION:  OFA urges the National Organic Program (NOP) to revoke the organic certification of currently certified hydroponic systems and cease certification of new hydroponic operations. (Adopted by the farmer membership 2018.)

BEGINNING FARMER & MARKET DEVELOPMENT

POSITION: OFA SUPPORTS a federal Dairy Supply Management program, to stabilize milk supply and prices for both conventional and organic dairies and their processors.  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS legislation which adds certified organic farmers to the “public service loan forgiveness program”.  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS the preservation of agricultural lands for organic production through programs such as agricultural land trusts, agricultural land easements, and agricultural land use protections.  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS targeted outreach, training, information, technical assistance, land access and ownership on organic farming systems, USDA organic certification and transition, and organic market development to historically underserved, minority and beginning farmers through USDA agency programs, land grant institutions and NGOs.  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS legislation such as the PRIME ACT, which permits state-inspected meat to be sold within that state, thus eliminating the intrastate marketing barriers placed on livestock farmers by the requirement for USDA inspected livestock slaughter and processing facilities which are few and far between.  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS the USDA prioritizing the collection of accurate organic commodity, poultry, dairy, livestock, and specialty crop pricing data, adjusted for inflation, so that market decisions can be made on accurate pricing information.  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS organic transition incentive programs that provide financial and technical assistance to non-organic farmers to help them convert land to certified organic management systems.  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS programs that facilitate the creation of small farmer production, processing and marketing cooperatives.  (Adopted by the farmer membership 2019.)

CROP INSURANCE

POSITION: OFA SUPPORTS crop insurance policies that do not require the organic certificate be dated prior to July 15 of the crop production year for which an organic producer receives the organic price.  (Adopted by the farmer membership 2019.)

POSITION: OFA SUPPORTS the creation of new crop insurance tools that serve the needs of diversified organic growers.  (Adopted by the farmer membership 2019.)

CLIMATE CHANGE & ENVIRONMENTAL POLICIES

POSITION: OFA SUPPORTS the vision of a Green New Deal that recognizes the vital role of organic agriculture as a part of the solution to climate change and asks that Organic Farmers Association has a seat at the table.  (Adopted by the farmer membership 2019.)

IMMIGRATION

POSITION: OFA SUPPORTS immigration reform that 1) legalizes the existing farm labor force, 2) retains the current H-2A program as is for those who need it, and 3) adds an agriculture work visa program that would require a specified number of years of at-will agricultural work for a specified minimum number of days per year that could lead to a green card if desired.  (Adopted by the farmer membership 2019.)

PUBLIC SEEDS & BREEDS

POSITION: OFA SUPPORTS increased and dedicated funding for organic public seeds and breeds research.  (Adopted by the farmer membership 2019.)

ORGANIC RESEARCH

POSITION:  OFA SUPPORTS increasing funding of federal organic agricultural production research to at least the same percentage represented by retail organic sales within the US marketplace. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS passage of the Organic Agriculture Research Act (HR2436/ S2404). (Adopted by the farmer membership 2018.)

NATIONAL ORGANIC STANARDS BOARD (NOSB)

POSITION:  OFA OPPOSES any efforts to reduce the authority and role of the National Organic Standards Board (NOSB) in the overall standard-setting process, or to seek statutory changes to the delicate balance of stakeholder slot allocations for the Board membership. (Adopted by the farmer membership 2018.)

ANIMAL WELFARE

POSITION:  OFA SUPPORTS animal welfare requirements as proposed in the Organic Livestock and Poultry Practices Rule (as withdrawn 2018). (Adopted by the farmer membership 2018.)

CROP INSURANCE

POSITION:  OFA SUPPORTS equitable and fair-market insurance programs that are accessible and relevant for all sectors of diversified organic (and transition-to-organic) producers. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS Congress to direct the Risk Management Agency (RMA) to prioritize development of additional organic price elections for crop insurance coverage, and review policies that cap Contract Price Addendums at two-times the conventional price election for any specific crop. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS allowing organic transition producers to calculate the Actual Production History Yield (APH) for acres under organic transition using the APH of other organic acres on their farm, rather than the county T-Yield for the acres under transition. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS continuation of Whole-Farm Revenue Protection established in the 2014 Farm Bill and recognize the change in farm revenue after a farm has transitioned to organic. Raise the cap to 50% on increased production value under the expansion provision. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS Congress to direct the Farm Service Agency to develop organic price elections for storage loans offered. Producers will then have the ability to access working capital based on the actual value of their crops to cash flow their operations. Utilize existing organic price data developed by RMA to establish storage loan prices. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS extension of the Dairy Margin Protection Program to cover organic dairy operations by using the cost of organic dairy feed and inputs to calculate organic milk margin. This change would make the program relevant for the needs of small to midsize dairy operations. (Adopted by the farmer membership 2018.)

FOOD SAFETY

POSITION:  OFA supports improvements to the Food Safety Modernization Act, providing science based and practical guidelines that are in line with organic practices and standards. (Adopted by the farmer membership 2018.)

BEGINNING FARMERS AND RANCHERS

POSITION:  OFA urges Congress to include a Beginning Farmer & Rancher Development Program (BFRDP) funding priority for projects focused on providing organic technical assistance to beginning farmers. (Adopted by the farmer membership 2018.)

ORGANIC MARKET GROWTH

POSITION:  OFA SUPPORTS targeted outreach, training, information and technical assistance on organic farming systems, USDA organic certification and transition, and organic market development to historically under- served, minority and beginning farmers through USDA agency programs, land-grant institutions, and NGOs. (Adopted by the farmer membership 2018.)

Organic Production Market and Data Initiatives (ODI)

The USDA’s Organic Production Market and Data Initiatives (ODI) collects information vital to maintaining stable markets, creating risk management tools, tracking production trends, and increasing exports. Good and consistent data collection is imperative to support a growing agricultural industry.

POSITION:  OFA SUPPORTS reauthorization of the Organic Data Initiative (ODI) to provide $5 million per year in mandatory funding for USDA organic data efforts, as well as a continuation of existing language authorizing additional funding through the annual appropriations process. (Adopted by the farmer membership 2018.)

NATURAL RESOURCE CONSERVATION SERVICE (NRCS) PROGRAMS

POSITION:  OFA SUPPORTS raising the six-year payment limit from $80K to $450K under the Organic Initiative within the Environmental Quality Incentive Program (EQIP) making these payments equal to the rest of the EQIP program, and thereby ensuring full opportunity for organic farmers to participate in the program. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS Congress to direct USDA to recognize required organic practices within the full suite of conservation programs including the Conservation Stewardship Program (CSP) and expand CSP organic bundles to transitioning organic farmers. CSP transition bundles will assist farmers with implementing organic practices, provide technical assistance during the transition period, and offset the financial costs of transitioning. (Adopted by the farmer membership 2018.)

POSITION:  OFA SUPPORTS reform of Conservation Reserve Program (CRP) to include organic producers and producers planning to transition to organic as additional allowed applicants to be eligible to participate in CRP Transition Incentive Payments (TIP). (Adopted by the farmer membership 2018.)

PUBLIC SEEDS AND BREEDS

POSITION:  OFA SUPPORTS the new Farm Bill requiring USDA’s National Institute for Food and Agriculture (NIFA) to use its existing competitive grants research programs to collectively allocate $50 million annually to public plant and animal breeding programs, with a priority focus on developing regionally adapted organic cultivars and animal breeds excluded from the Plant Protection Act. (Adopted by the farmer membership 2018.)

ORGANIC LIAISON AT USDA

POSITION:  OFA SUPPORTS funding and filling the Organic and Sustainable Agriculture Policy Advisory staff position to serve as a communications link between the National Organic Program (NOP) and the Office of the Secretary of Agriculture to work directly with the Secretary, the Deputy Secretary, and the agency leaders within USDA to coordinate organic policy and educate the Department’s personnel about organic farming and what the National Organic Program (NOP) does and why it is important to the other goals of USDA. (Adopted by the farmer membership 2018.)

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ABOUT ORGANIC FARMERS ASSOCIATION

The mission of the Organic Farmers Association is to provide a strong and unified national voice for domestic certified organic producers. With the purpose to build and support a farmer-led national organic farmer movement and national policy platform by: developing and advocating policies that benefit organic farmers; strengthening and supporting the capacity of organic farmers and farm organizations; and supporting collaboration and leadership among state, regional and national organic farmer organizations. Learn more at OrganicFarmersAssociation.org.