The Organic Trade Association is the only industry-wide business association representing the entire organic industry in North America. Our 1095 members include growers, shippers, retailers, processors, certifiers, farmer associations, brokers, consultants, importers, exporters, restaurants, distributors and others involved in producing or selling organic products or providing services (Appendix C). Established in 1985 as the Organic Foods Production Association of North America (OFPANA), the name was changed in 1994 to the Organic Trade Association (OTA) to better represent the diversity of the industry.
OTA’s mission is to encourage global sustainability through promoting and protecting the growth of diverse organic trade. To accomplish this mission, the goals of the Organic Trade Association are to provide leadership consistent with organic principles and values; create and expand market opportunity; promote awareness and understanding of the organic production; provide a unified voice on legislative, regulatory and policy issues affecting the business of organic production; promote the sustainability of a balanced ecosystem; and protect the integrity of organic standards. As a member of the International Federation of Organic Agriculture Movements (IFOAM), the Organic Trade Association is an active participant in creating a global system of organic production and verification. OTA works in cooperation with environmental, consumer and other groups committed to the principles of organic agriculture.
Throughout its history, OTA has worked with all segments of the industry to blend individual voices into a unified chorus. Last year the Association undertook the project of writing the "American Organic Standards" (Appendix D) which is a major revision of its "Guidelines for the Organic Foods Industry," originally written in March 1986 with amendments added in 1988, 1990 and 1992. The American Organic Standards embody the principles and practices of organic agriculture and certification that are embraced by the members of the Organic Trade Association.
OTA’s Quality Assurance Committee (QAC) is responsible for developing the American Organic Standards and other technical policies, and preparing the Association’s comment on the USDA Proposed Rule. Its subcommittees include Accreditation; Certification; Distribution; Farm Practices; Fiber; Input Supply; Inspection; Livestock; Manufacturing, Processing, Packaging, and Labeling (MPPL); Retail; and Trading and Ingredient Supply.
One in five OTA members participates actively in one or more of the Association’s policy committees or three sector councils – Certifiers (OCC), Fiber (OFC), and Agricultural Suppliers (OSAC.) This high level of participation ensures that OTA positions accurately reflect the opinions of all its members, providing a balance of interests between sectors.
Because of our history and membership, the Organic Trade Association is uniquely qualified to comment on the USDA’s Proposed Rule for a National Organic Program. The members of the OTA are the creators of the organic industry, current organic standards, and organic certification procedures. OTA’s members have built the market identity for organic. From the very first discussion of federal standards for organic production and labeling, the Association has been actively involved. Now that the industry is heading toward full partnership with the federal government, we ask that our creation, our contract with our customers, be treated respectfully.
Over the past decade the Organic Trade Association has consistently supported the implementation of the Organic Foods Production Act. It is the opinion of the Association that consistent market standards and a program to enforce regulations will stabilize the market place, stimulate market development and facilitate future expansion of the organic industry. Therefore, OTA on more than one occasion has argued for USDA to pick up the pace of their work on the Proposed Rules for the National Organic Program. We must now ask that USDA pick up the pace of their work in reviewing materials used in organic production and processing.
OTA and the Organic Materials Review Institute (OMRI) have compiled a list of materials that are currently used by certified organic producers and processors which have not yet been addressed by the National Organic Standards Board (NOSB) (see Appendix B). It is critical to the health of the organic industry that an efficient and timely process be implemented to review, publicly discuss and decide on these essential materials. It is unacceptable that a petition process for the National Materials List has not yet been posted in the Federal Register. The National Organic Program must effectively operate on behalf of the organic industry and its customers. These delays undermine our confidence in the National Organic Program.
Because of our interest in the completion of a Final Rule, the Association is reluctant to offer any comments which would cause delay. But, there are missing sections in the Proposed Rule and sections that need further development before a comprehensive National Organic Program can be implemented. These include production standards for organic sprouts, greenhouse operations, mushrooms, maple syrup and apiculture, as well as descriptions of "reasonable security" in Section 205.501 (c)(2), and "reasonable cause to believe" in Section 205.670 (b). In order to accommodate the completion of a Final Rule for the National Organic Program by the end of this year, OTA suggests that all missing or incomplete sections be written as submitted by the Association, posted in the Federal Register for public comment, and then added as amendments to the Final Rule.
It is OTA’s understanding that there will continue to be clarifications made to the National Organic Program through the development of program manuals and practice standards. It is imperative that these documents be developed in consultation with the NOSB and also be posted in the Federal Register with adequate time given to review their contents for comment. Without such procedures, the success of public-private partnership entered into by the government, the organic industry and other stakeholders in organic agriculture will be jeopardized.
Establishing acceptable procedures for public participation now will ensure industry support and cooperation in future development of amendments and additions to the National Organic Program. For example, OTA is currently developing organic fiber standards which, upon completion, we expect to submit to the National Organic Standards Board and USDA for inclusion in the National Organic Program standards.
OTA is optimistic about the completion of a Final Rule and the implementation of the National Organic Program. The increasing pressure of the market demand for organic products, both nationally and internationally, necessitates a national standard for organic production and labeling. Despite over 10 years of discussion, certifier reciprocity and a process for mutual recognition has not been achieved. Diverse country and certification standards and additional document exchange and paperwork requirements often result in expensive delays and lost opportunities for organic producers. It is incumbent on USDA to work quickly to negotiate equivalency agreements with other countries or with private accreditation agencies. The experiences of the USDA in negotiating interim agreements with the European Union and Japan are indications of the barriers that currently exist and the obstacles that must be overcome even when a Final Rule is published. OTA urges USDA to consider all possibilities for equivalency agreements that will facilitate trade in US organic products.
OTA would like to thank USDA for its care in responding to comments on the first Proposed Rule. The revised Proposed Rule is a significant improvement, due in large part to USDA’s willingness to listen and respond to the organic community. OTA looks forward to working with USDA to make this the best organic program in the world. It is with this in mind that the Association offers detailed and specific comments and changes to the revised Proposed Rule. It is our expectation that USDA will respond positively to these comments and incorporate OTA’s changes into the Final Rule. We urge USDA to refer to the American Organic Standards for guidance in areas where there is need for additional clarity.
This Proposed Rule for the National Organic Program has preserved many of the essential characteristics of the principles and practices of organic agriculture as an ecological management production system. The organic industry works consciously to make choices that increase the health of farms and the natural environment. Organic agriculture is more than a marketing scheme; it is a way of relating to our environment. Insofar as this concept is reflected in the revised Proposed Rule, we applaud it. Where OTA feels the needs of this ecological system of management could be better met, we have so indicated.
OTA fully supports strict regulations for the National Organic Program but the regulations must be based on the realities of organic farming and handling and balanced to the extent possible with consumer expectations. Where the proposed rule creates undue burdens on organic producers and processors, we have included changes. Where the proposed rule creates a prescriptive approach, we have included system solutions that can be applied in an equitable manner.
The Organic Trade Association thanks all those who have helped advance organic agriculture through their work on this Proposed Rule, and hope that your work, together with ours, will result in a National Organic Program that ensures protection for the consumer and the environment and supports growth of the organic industry.