Comment to NOSB
June 6, 2001
Thank you very much for this opportunity to comment. OTA would like to comment on the NOSB aquatic animals task force report and the upcoming recommendation from the Livestock Committee on pasture. Also, OTA would like to inform NOSB of a technical correction OTA will be requesting—to have the NOP rule explicitly require that the name or identity of the certified operation appears on final product labels. OTA will further urge NOSB to support this request.
The Organic Trade Association would first like to commend NOSB for its work on aquatic animals. The Task Force has thought through a great number of details in a relatively short period of time and developed a creative recommendation which adheres closely to the spirit of the Organic Foods Production Act. OTA urges the National Organic Standards Board to adopt the recommendation on aquatic animals and looks forward to commenting on specific standards.
OTA will need time to review the recommendation of the Livestock Committee being presented at this meeting. OTA greatly values the broad and deep consensus that both public and private members of the organic community have been able to forge over time and notes that this consensus is the result of substantial dialogue regarding issues of the industry, NOSB, and NOP.
The Livestock Subcommittee of OTA’s Quality Assurance Committee (George Siemon, Chair) is conducting a survey of OTA livestock producers and certifiers to determine the range of practices and policies currently in place. This study could not be completed by this meeting but will be completed shortly. The results of this study should prove most useful to NOSB. OTA therefore respectfully requests that a vote on the NOSB recommendation on pasture be postponed until the public has had a chance to comment.
OTA must repeat a request you have heard numerous times—NOSB must work with complete transparency and must actively seek public input on their work before voting on recommendations. To help this process, OTA is willing to bear the burden and cost of posting NOSB proposed definitions and recommendations on our own web site to keep the organic community involved in the development of organic standards. Please let OTA and other willing organizations know if this proposal would help further NOSB’s goals and the public-private partnership.
OTA would also like to inform the Board that OTA is in the process of finalizing a request for a technical clarification that the certified entities name should appear on the final consumer product label. OTA believes this to be the intent of OFPA. Further, this requirement was assumed in rulemaking, and that making this explicit will solve a problem that is appearing in organic labeling and audit trails. Please find a draft request attached to this comment. OTA hopes that NOSB will agree that the writers of OFPA intended the certified entity’s name to appear on the label and that having the certified entity’s name on the label will aid the audit requirements of the NOP and to help ensure organic integrity.
Finally, OTA would like to submit a letter supporting the current structure of certification organizations in light of the conflict of interest sections of the final rule. Thank you very much. | 
