Continuous Improvement and Accountability in Organic Standards

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• Is this recommendation feasible to implement?
• Does it expand U.S. organic acreage?
• Does it resolve inconsistencies in the existing organic regulations?
• Does it address the marketplace needs of producers, handlers,
certifiers and consumers?
*The recommendation that you rank as number one should be what is most important or critical to the success of your business or farm.
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Question Title
* 4. Rank these NOSB Recommendations from 1-15. 1 being most important, 15 being least important.
DEVELOP guidance for RETAILERS about organic compliance: NOSB recommends to provide education and guidance on organic compliance to the retail sector, and clarify several specific sections of the regulations as it applies to retail. These recommendations will also improve consistency and integrity in merchandising, handling and marketing of organic products in retail establishments, and improve consumer understanding of the distinction between “organic” and “certified organic” retailers.
RESTRICT conversion of NATIVE ECOSYSTEMS to organic production:  NOSB recommends to require a ten-year waiting period between conversion of land supporting native ecosystems and subsequent organic certification.
CREATE new standards for GREENHOUSE and CONTAINER PRODUCTION:  NOSB recommends to allow container and greenhouse production of organic crops under specific provisions that support natural and diverse soil ecology within the container, while prohibiting hydroponic production. This recommendation would minimize the wide variation currently used by applying the current crop production standards to these production systems. 
DEVELOP guidance on GMO CONTAMINATION PREVENTION strategies: NOSB recommends to identify best management practices for organic operations to prevent of unintended GMO presence in seed and crop production, livestock production, and handling. NOSB also recommends to instruct certifiers to inform certified producers that information on possible genetic contamination of seeds with GMO equivalents could be obtained from their seed suppliers to improve transparency of genetic integrity of seed grown on organic land.
CREATE new standards for organic PET FOOD products: NOSB recommends to recognize pet food under the scope of National Organic Program enforcement. This recommendation will ensure that USDA can police organic claims on pet food and require compliance with organic standards specific to organic pet food composition, handlings, and labeling.
Clarify the ORIGIN of ORGANIC DAIRY LIVESTOCK- NOSB recommends clarifying and narrowing the requirements for the transition of dairy animals (cows, goats, sheep) into organic milk production as a one-time event. Once a distinct herd has been converted to organic production through one year of organic management, all dairy animals must be under organic management from the last third of gestation. The practice of continuously transitioning and/or cycling dairy animals in and out of organic production would be explicitly prohibited. NOP published a proposed rule that would implement this policy in 2015, re-opened the comment period 2019, but has still has not implemented a final rule.
REQUIRE increased used of ORGANIC SEEDS: NOSB recommends to require certified crop producers to demonstrate improvement in sourcing and use of organic seed/planting stock every year. NOSB also recommends a series of improvements to the existing NOP Guidance 5029 Seeds, Annual Seedlings, and Planting Stock in Organic Crop Production that includes both incentives and practical language to aid producers and certifiers in overseeing and encouraging the use of organic seed.
CREATE new standards for organic AQUACULTURE PRODUCTION: NOSB recommends to authorize organic certification of aquatic animals including finfish and molluscan shellfish, and establish specific standards for feed, health care, facilities, and living conditions for this unique type of livestock. Aquatic animals are currently excluded from the organic regulations, therefore this series of recommendations would create a new certification scope and market for organic aquaculture products.
DEVELOP guidance for determining which new technologies are considered EXCLUDED METHODS:  NOSB recommends to establish guidance for interpreting the excluded methods provision of the organic regulations. The recommendation includes definitions, principles, criteria that help address the increased diversity in types of genetic manipulations performed on seed, livestock and other inputs used in agriculture. Several recommendations together lists specific technologies and whether they are prohibited under the existing regulatory definition of excluded methods.
RESTRICT the use of livestock VACCINES made from excluded methods: NOSB recommends to limit the use of livestock vaccines made from excluded methods only when an equivalent alternative not made from excluded methods is not commercially available to prevent a specific disease.
STRENGTHEN ANIMAL WELFARE standards for organic livestock and poultry:  NOSB recommends to further clarify and refine the requirements for mammalian and poultry living conditions, stocking rates, heath care, transportation, and slaughter. Several recommendations together support a comprehensive animal welfare program for organic livestock. These recommendations are reflected in the Organic Livestock and Poultry Practices Final Rule which has been withdrawn by USDA. The Organic Trade Association is in active litigation against USDA for failure to implement this regulation.
CLARIFY procedure for calculating ORGANIC INGREDIENT COMPOSITION: NOSB recommends to clarify the requirements for determining the percentage of organic ingredients in multi-ingredient products. The recommendation would make calculations based on "all ingredients", not "finished product", which is consistent with OFPA and NOP. The recommendation would standardize practices for developing self-calculating forms, excluding salt, excluding water, processed-single ingredient calculations, multi-ingredient product calculations, and organic labeling versus organic content.
CREATE new standards for organic PERSONAL CARE products:  NOSB recommends to recognize personal care products (cosmetics, body care) under the scope of National Organic Program enforcement. This recommendation will ensure that USDA can police organic claims on personal care products and require compliance with organic standards.
PROHIBIT HYDROPONIC and AEROPONIC PRODUCTION: NOSB recommends to prohibit hydroponic production of organic crops, with an exception for mushrooms, sprouts, and micro-greens. NOSB also recommends to prohibit production systems where terrestrial plants are suspended in the air and misted with nutrient rich water.
CREATE new standards for organic APICULTURE PRODUCTION:  NOSB recommends to establish specific production standards for organic apiculture (honeybee) production. This recommendation would minimize the wide variation currently used by applying the current crop production standards to these production systems.
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Thank you for taking this survey! The Organic Trade Association is committed to ensuring continuous improvement and accountability in advancing organic standards. We are working on a long-term solution with Congress to ensure that all future NOSB recommendations are implemented by the USDA National Organic Program in a timely manner. To learn more about this work and get involved, contact Megan DeBates (mdebates@ota.com).
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