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USDA Does the Right Thing – Listens to the NOSB!

USDA Does the Right Thing – Listens to the NOSB!

A story of Paper Pots and Origin of Livestock

Last month, the USDA National Organic Standards Board (NOSB) met in St. Paul for their semi-annual meeting. The NOSB is a 15 member volunteer Advisory Board to the National Organic Program (NOP) which has legal authority for organic standards and the materials allowed to be used in the USDA Organic Label.1

NOSB meets twice per year in a public forum to discuss issues relevant to the organic industry and vote on final recommendations. As always, there was a huge agenda, lots of controversy, and many discussions about all things organic standards.2

 On a positive note, there was one particular issue where farmer action made the difference – and where USDA surprisingly took the advice of this citizens’ board in a timely manner on farmers’ behalf. For those of you following the NOSB meetings since even before the federal regulations came into effect, this is quite a huge step. The issue was the use of paper pots in organic production.

Paper Pots

In a surprise ruling earlier this year, the NOP stated paper pots would be banned after the 2018 season. NOP cited materials issues with the paper and glue, and that certifiers were differentially interpreting the regulations around use of paper pots. These paper pots are a huge timesaver and a boon to small and mid-sized farmers planting a variety of vegetables.3

Though the paper pot ban was not on the NOSB agenda, farmers in New York and around the country submitted comments, highlighting this as their top priority for the NOSB meeting. Many farmers noted that they would stop certifying if the paper pots were prohibited. NOSB listened, and passed a resolution requesting that the prohibition be delayed until full review can take place. This triggered NOP to issue a hold on the prohibition within a couple of weeks of the NOSB meeting.

In another move, the NOSB took strong leadership on behalf of organic dairy farmers – with the result at USDA still to be determined.

Origin of Livestock

Perhaps one of the most astounding examples of NOP’s failure to do its job has been their refusal to clarify the Origin of Livestock standards. Why? Because without clarity, while the majority of organic dairy farmers make sure that they raise or bring in fully organic young stock to add to their herd, large industrial “organic” operations claim a loophole and continually bring in non-organic animals. This has exacerbated the decline of family farm dairies as industrial dairies flourish. Despite six NOSB recommendations for clarity from 1994 to 2006, a 2013 USDA Inspector General report, and a 2015 proposed rule, USDA saw fit to remove it from their regulatory agenda in 2017. At this meeting, NOSB once again passed a strongly-worded resolution4 urging the Secretary to issue the Final Rule on Origin of Livestock immediately.

Other Items of Note

  • NOSB elects a new chair: Harriet Behar, a Wisconsin farmer, organic inspector, and a strong farmer advocate for many years has been named as the new chair of the National Organic Standards Board. Congratulations to Harriet!
  • Plastic Mulch & Covers: A motion to remove plastic mulches from the National List did not pass. While there are serious waste issues around large amounts of plastic mulch being removed to landfills each year, NOSB voted to continue its allowance, because there is still no true biodegradable plastic mulch.
  • Excluded Methods: The Board continues extensive work on refining the definitions of Excluded Methods (GE; GMO) to make sure that new methods continue to be reviewed on a timely basis.
  • Transparency: A proposal on Genetic Integrity Transparency of Seed Grown on Organic Land was sent back to committee in order to elicit more comments from farmers.
  • Apiculture Standards: Once again, the Board unanimously agreed that apiculture standards are needed.
  • Marine Materials in organic crop production: the Board agreed to form an informal working group to investigate whether there should be increased scrutiny and oversight of harvesting of seaweed and micro algaes.


1 See for more information.

2 For more information, visit the National Organic Coalition and the Cornucopia Institute.

3 Learn more about paper pots at

4 “It has come to the attention of the National Organic Standards Board (NOSB) that the continued state of varying interpretations and practices around the Origin of Livestock standards is creating market instability for organic producers. The 2015 USDA Origin of Livestock Proposed Rule was based on six recommendations from the NOSB between 1994 and 2006. The proposed rule responds to findings from the July 2013 USDA Office of Inspector General (OIG) audit report on organic milk operations stating that certifying agents were interpreting the origin of livestock requirements differently1. Rulemaking is necessary to ensure consistent interpretation and enforcement of the standards for origin of livestock and to provide industry with additional clarity of application of the organic dairy standards. In early 2017 the Origin of Livestock Proposed Rule was removed from the government’s Unified Agenda of Regulatory and Deregulatory Actions. Support for this rule has been expressed through public comment by the majority of organic stakeholders2.  Strong federal oversight is essential for fair, consistent certification and for creating a level playing field for all certified organic operations. Therefore, be it resolved by unanimous vote, the National Organic Standards Board—as USDA’s Federal Advisory Board on organic issues and representing organic farmers, ranchers, processors, retailers and consumers—urges the Secretary to directly issue a final rule for Origin of Livestock that incorporates public comments submitted in response to the Proposed Rule (Docket Number AMS-NOP-11-0009).”

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