Melissa Bailey, Director
National Organic Program
Ag Stop 0268
1400 Independence Ave., SW
Washington, DC 20250-0268
October 25, 2010
RE: National Organic Program; Amendment to the National List of Allowed and Prohibited Substances (Livestock); Document Number AMS-NOP-10-0051; NOP-10-04IR: Interim rule with request for comments.
Dear Ms. Bailey,
The Organic Trade Association thanks USDA’s National Organic Program for this opportunity to provide comments.
OTA is the membership-based business association for organic agriculture and products in North America. Its members include growers, shippers, processors, certifiers, farmers' associations, distributors, importers, exporters, consultants, retailers and others. OTA’s Board of Directors is democratically elected by its members. OTA's mission is to promote and protect the growth of organic trade to benefit the environment, farmers, the public and the economy (www.ota.com).
OTA supports the interim rule as written.
It is critical that the second proposed annotation move through the regulatory process in due course. If there is any delay, the listing could inadvertently expire in 2012. This is not the stated intention of the NOSB, nor would it be in the best interest of the trade. OTA’s support of this approach by NOSB is entirely conditional on the future inclusion of methionine in the usual five-year materials review process. Anything less would represent a breach of good faith, as it would be contrary to the intent of the National Organic Standards Board.
Thank you for your consideration.