Apr 23, 2020
OFA directors speak to NOSB

The National Organic Standards Board (NOSB) received public comments on April 21 and 23 during its spring meeting.

The meetings were held in a webinar format due to the new coronavirus, COVID-19, pandemic.

The Organic Farmers Association published comments from Director Kate Mendenhall and Policy Director Patty Lovera about the organization’s priorities for the future.

Mendenhall’s general comments to the NOSB via webinar testimony:

Thank you, members of the NOSB for the opportunity to speak before you today.  My name is Kate Mendenhall, I am the director of the Organic Farmers Association and am also an Iowa organic farmer.  OFA was created to be a strong voice and advocate for certified organic farmers.  We are led and controlled by domestic certified organic farmers and only certified organic farmers determine our policies.

Each year U.S. certified organic farmers are invited to participate in our grassroots policy process and identify their top policy priorities.  Organic farmers have stated that their top 5 policy priority for 2020 are:

  1. NOP Enforcement to Ensure Organic Integrity
  2. Organic Import Fraud
  3. Prohibit Hydroponics in Organic Production
  4. Climate Change
  5. Organic Dairy Standards & Enforcement (Includes Origin of Organic Livestock & Pasture Rule)

For the past three years, organic integrity has been at the top of the list.  Organic farmers built and established the organic label, and now they rely on the National Organic Program and the NOSB to preserve and enforce it.  Without strong regulations and standards enforced equitably across size, region, and commodity, the organic label will wither.  Prohibiting hydroponics has returned to 3rd place on the OFA priority list for the second year in a row.  Farmers nationwide are committed to healthy soil and the crucial role it plays in a healthy organic agro-ecosystem, and even conventional farmers and politicians are beginning to advocate for its important role in mitigating climate change. For organic to underplay the importance of organic soil now would be misguided.

Since the NOP declared just a few years ago that hydroponics is allowed, we have seen a burst of hydroponic operations and enforcement issues that highlight real problems and concerns on this issue.  We cannot have a production system out of compliance with the definition of organic.  We cannot have certifiers creating their own standards to regulate this booming sector, and we cannot undercut a label that farmers have built over the past 40 years.  With the 50th Anniversary of Earth Day celebrated yesterday, we should focus on making sure that certified organic, the gold production standard, is upholding its values, not undercutting them when Mother Earth needs us most.  The NOSB needs to revisit this issue.

Organic Farmers Association supports the NOSB process and agrees with the Crop Subcommittee’s assessment and support for paper-pots as an allowable synthetic and defined planting aid.  One lesson that is clear from COVID-19 is that we need more small to mid-size organic farmers throughout our communities able to meet our local food needs.  Paper pots help small organic farmers and are similar to already-approved inputs.

While Organic Farmers Association does not have a position on biodegradable mulch, I will comment that this policy issue was proposed in our grassroots process, yet it did not receive any farmer support to bring it forward.  With domestic and import fraud still gaining headline space nationwide, a lack of guidance from NOP on 3-year transition equity across growing practices, hydroponic production operating on a per-certifier basis and undermining the very definition of organic, biodegradable mulch seems like a low-priority topic for precious NOSB volunteer time.  Let’s get busy on the issues that are crucial for the organic community, not special interests.

I appreciate all of your dedication to working for the full organic community, for hearing public comment today, and for the farmers especially, who have had to find others to cover their farm-work so they can fully participate in this process over the two-weeks of meetings.

Lovera’s general comments to the NOSB via webinar testimony

My name is Patty Lovera, and I am the Policy Director for the Organic Farmers Association. Thank you for finding a way to have these public comments happen during the disruption of the pandemic and welcome to the new board members.

The Organic Farmers Association is led by domestic certified organic farmers. The integrity of the organic label continues to be organic farmers’ top priority.

We appreciate the role NOSB plays in the process of keeping organic integrity high, and would like to point out that an important piece of the board being able to perform this role would be restoring their ability to set their own work agenda.

Because this is space for the whole organic community to gather, I am going to mention a few things that we need from the National Organic Program to move forward on issues the board has already considered.

  1. The rulemaking on Origin of Livestock is desperately needed to address inconsistency on the ground in transition of organic animals. There are more details about OFA’s specific policy on the origin of livestock in our written comments, but two key needs for the rule are:
  • A producer can transition bovine dairy animals into organic production only once.
  • Once the regulation is finalized, fast effective date. This confusion has gone on long enough and created an unlevel playing field for those producers who have been meeting the intent of the standards for many years.

In addition to OOL rule, we also urge the NOP to continue to focus on compliance with the pasture rule, with an emphasis on higher risk operations

  1. Strengthening Organic Enforcement – we are catching up to build the enforcement capacity necessary for a $50 billion industry with complicated, often global supply chains. We understand this rule appears to be stuck in the White House review process, but we urge the program to move as quickly as possible to finish it up once it moves out of the review process. We desperately need more enforcement in organic markets.

Finally, we have a request to the program relating to the USDA’s plan for pandemic response. Organic farms have adapted very quickly to the disruption caused by the pandemic, figuring out new supply chains, online ordering, dealing with local and state regulations that change every day or every week, learning for the first time about the Small Business Administration, and host of other adjustments. In a lot of ways, the organic sector has proven more resilient and flexible than our conventional counterparts who deal with more consolidated supply chains.

But that does not mean that organic farmers don’t need help. And it is not yet clear how the USDA’s pandemic response programs – either the commodity purchasing or the direct payments – will work for organic farms. We urge the program to advocate for organic producers inside the USDA to make sure organic operations can access these new programs.

Thank you.
Patty Lovera

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