The fall edition of this year’s NOSB meeting will be held in Jacksonville Florida, just in time for a few goblins to come groping for organic candy. We engage in this magic twice a year to give voice to the issues and engage in the rulemaking process in a transparent and diverse manner. We summon up communal consensus with a brew of public comment and a pinch of participation. Will this Halloween NOSB invoke solidarity or discord? I plan to be there to report on all the tricks performed and any special treats offered up.
Don’t be spellbound by the process.
It’s really not that spooky. This diligent 15-member board meets twice a year with the public to discuss and vote on subcommittee proposals related to the National List and other organic standards issues.
They have already published their proposals and requested public comments. Prior to the meeting, they diligently reviewed thousands of pages of comments. During the meeting, they will listen to in-person oral comments and discuss the proposals once again before voting on whether to pass the original proposals. If passed, they will submit their final recommendations to USDA.
What does this fall pageant hold in store?
High on the list of tricks will be how the NOSB votes on Hydroponics and Container growing methods. Currently, the crops subcommittee has proposed definitions for aeroponics, hydroponics, and aquaponics and recommends that these practices be prohibited in organic production.
They propose that for container production to be certified organic, a limit of 20% of the plants’ nitrogen requirement can be supplied by liquid feeding, and a limit of 50% of the plants’ nitrogen requirement can be added to the container after the crop has been planted. For perennials, the nitrogen-feeding limit is calculated on an annual basis. Transplants, ornamentals, herbs, sprouts, fodder, and aquatic plants are exempt from these requirements.
There is a minority view on the committee which proposes an alternative with changes to the original 2010 NOSB Recommendation. They suggest that instead of focusing on inputs as the defining characteristics of various production systems, it should focus more on the outcomes. They suggest that minimum soil biology diversity be applied to all container and hydroponic systems to ensure that soil biology remains an essential element of all organic systems.
The minority view recommends not voting on any of these systems at this meeting but wants to get additional feedback from the public before taking any action.
There is an important proposal to Strengthen and Clarify Organic Seed use Requirements. One of the criticisms of the current seed guidance is that it fails to provide a good framework for what continuous improvement looks like and how to achieve it in the context of organic seed.
The subcommittee is proposing to amend the regulations so that improvement in sourcing and use of organic seed is demonstrated every year until full use of organic seed is achieved. Their suggestions address GMO contamination especially in high-risk varieties like corn and soy and stipulate the number of sources that must be contacted (FIVE for at-risk crops) when sourcing organic seed.
We are well aware that products fraudulently labeled as organic are entering the complex organic supply chain, specifically in organic imports. The NOSB is looking to address this ongoing problem with a proposal that clarifies and expands Excluded Operations in the Supply Chain.
The board is requesting feedback from the organic community on the negative and/or economic impact there might be on the trade and movement of organic product with these clarifications.
They are finally addressing concerns about the loss of ecosystems caused by the conversion of land to organic production. Because the regulations require the land be free from prohibited materials and methods for at least three years, there is a built-in incentive to start farming wild native ecosystems.
If approved, the Eliminating the Incentive to Convert Native Ecosystems to Organic Production proposal would add the following language to the regulations: A native ecosystem site that has not been previously grazed or cultivated cannot be certified as organic as provided for under this regulation for a period of 10 years from the date of conversion to crop or livestock production.
…and here comes the Sunset.
All three NOSB subcommittees, Crops, Livestock, and Handling will engage in what is somewhat mysteriously called “Sunset Review.” Every five years or so, synthetic and non-agricultural materials allowed in organic production come up for review (think soap and baking soda). The decision to keep or prohibit them from use in organic production is based on three criteria: 1) The material is necessary or essential because it is not available in an organic form; 2) It isn’t harmful to human health or the environment; and 3) It is in line with the basic premise of organic farming and handling.
I quite like the way the Organic Trade Association (OTA) likens the National List of Allowed materials to a toolbox. “The restricted toolbox can only be opened when mechanical, cultural, and biological controls are insufficient to control pests, weeds, and disease. This is foundational to organic farming.” You can view all of the materials and inputs under Sunset Review at this meeting in the NOSB agenda.
These in-person stakeholder meetings can be creepy and contentious, but the diverse stakeholder feedback is a critical component to the evolution of the organic standards. Wouldn’t it be a treat if the various opinions expressed at these meetings were embraced, given respectful consideration, and allowed to be heard without fear of public bullying or political fallout? That would be a very Hallowed Day for us to celebrate.
If you want to dig deeper into this meeting, the OTA provides a spectacular resource in their 2017 Fall Resource Booklet. It will help you fly through this year’s meeting—no broom needed.
Hope to see you in Jacksonville next week!