Miles McEvoy, Deputy Administrator
National Organic Program
United States Department of Agriculture
1400 Independence Ave. SE
Washington, DC 20250
December 13, 2010
RE: NOP Draft Guidance: AMS-NOP-10-0048
Dear Mr. McEvoy:
The Organic Trade Association (OTA) thanks the National Organic Program (NOP) for this opportunity to comment. OTA especially appreciates NOP’s publication of draft guidance for comment. This helps the trade, either by anticipating possible shifts in interpretation or by re-affirming current interpretation.
OTA appreciates the work that has gone into producing these documents. It is very important that guidance be sufficiently detailed and actionable to support certifiers and inspectors in their uniform interpretation and verification of operations’ compliance.
Compost and Vermicompost in Organic Crop Production (NOP 5021)
Ever since the NOP rule was promulgated, input suppliers and farmers have sought clarification on how the well-accepted process of vermicomposting fits with the NOP rule.
OTA applauds NOP for concurring with the National Organic Standards Board (NOSB) that “the examples provided in §205.203(c)(1-3) [are] not a finite list of acceptable plant and animal materials for use in organic production” and for proposing a policy and procedure that allow this well-established method of recycling nutrients.
Wild Crop Harvesting (NOP 5022)
OTA finds the policy appropriately inclusive, and the procedures as outlined both reasonable and thorough. However, operations certified to cultivate various crops or livestock should be able to include wild crop harvesting in their scope when appropriate, and the language in the proposed guidance does not make that clear. Also, the identification of an endangered organism should not be read as a reason to deny certification; instead, it should simply be information to consider. Finally, verification of harvest practices may be possible without interviewing all collectors. This point should be made clear in any final guidance.
Outdoor Access for Organic Poultry (NOP 5024)
OTA understands that this guidance, including its policy statement, stands as a clarification of the current rule, not as a proposal to change the current rule. OTA realizes that both NOSB and NOP are considering further work on this and other closely related topics. OTA requests, however, that the draft guidance clarify the meaning of the terms “outdoor” and “outdoors.”
Commingling and Contamination Prevention in Organic Production and Handling (NOP 5025)
OTA agrees that it could be useful for accredited certifying agents to be able to request operations to assess their risks and provide preventive practices. The responses of operations to such requests could be a valuable tool for inspectors.
The Use of Chlorine Materials in Organic Production and Handling (NOP 5026)
OTA understands that for sprouts, FDA guidelines include a 20,000-parts-per-million wash, which would require at least 4,000 gallons of water per gallon of solution to dilute. Since there are other sanitization methods that appear to be as effective as chlorine, OTA requests that NOP work with FDA in determining practices that would meet both agencies’ needs and then make that information available to organic sprout growers.