October 23, 2019

RE: General Comments to the NOSB

Thank you, members of the National Organic Standards Board for the opportunity to speak before you today. My name is Kate Mendenhall, I am the director of the Organic Farmers Association and I am also an Iowa organic farmer. OFA is led and controlled by domestic certified organic farmers and only certified organic farmers determine our policies using a grassroots process. We believe organic farmers were instrumental in creating our successful organic market and must be leaders in directing its future.

Organic Farmers Association greatly supports the work of the NOSB and finds your role crucial to maintain integrity in the USDA organic label. We also support NOSB recommendations moving forward to rulemaking or guidance in a timely manner.

We appreciate the NOSB’s 2018 resolution to move Origin of Livestock standards quickly to a final rule, and the USDA’s recent decision to not issue a second rule. We are concerned that the number of comments coming in might delay the process and we ask that the USDA work to move to an immediate implementation of a Final Rule. We are also hearing from farmers they still see a lack of oversight on pasture rule compliance. We appreciate the increased dairy oversight effort and we need to see more.

Last month we sent a letter to the Secretary of Agriculture in response to Undersecretary Ibach’s July statement expressing interest in a dialogue about gene-editing in organic. 78 organic organizations joined OFA to clearly communicate our unified opposition. We thank Dr. Tucker for confirming that gene editing has always been prohibited in organic agriculture. The organic community is NOT interested in a dialogue about gene editing. We do encourage robust dialogue about the numerous critical issues organic farmers are facing—protecting farmers from genetic and pesticide contamination, protecting farmers from import fraud, etc.

Organic Farmers Association continues to oppose the certification of hydroponic operations, a position passed by 90% of our certified organic farmer members nationwide and in each of our six geographic regions. We are concerned about the consequences to the integrity of the organic label as a result of the USDA and NOSB moving forward to allow for organic hydroponics without clarity on how it complies with OFPA and standards for this type of production system. At the spring NOSB meeting there was much conversation regarding whether container farms needed to comply with the same three-year transition as soil-based farms. Organic Farmers Association was pleased to receive NOP clarification for certifiers on transition time for container systems after the application of a prohibited substance; however, it left some ambiguity about how greenhouse production fits in. Is a three-year transition needed for a container system inside a greenhouse after application of a prohibited substance? It is important that the organic standards are clear and equitable across growing systems so that certifiers are implementing and enforcing the standards uniformly—if ambiguity is present, the NOP must provide clarity.