Organic Trade Association Comment to NOSB, 10-15-01, p.2

OTA supports NOSB’s intention to appoint a peer review panel soon enough so that the peer review panel may lend NOP appropriate technical support in the development and implementation of NOP’s accreditation program.

OTA is concerned that at least one certifier may have been treated differently from others by requiring them to change their by-laws before applying for accreditation, while others have been told to apply even though changes have not been made.  OTA urges NOSB to recommend to NOP that NOP address any perceived unfairness through a written statement.  In addition, when considering the effect of certifier requirements, OTA requests that NOSB recommend to NOP that NOP consider the number of certified operations affected by a decision as well as the number of certifiers affected.

OTA also requests NOSB to recommend to NOP that not-for-profit certification agents be permitted to receive and distribute donations for charitable and educational purposes.

OTA strongly urges NOSB to recommend to NOP that a quality system manual for program accreditation be written, as required by ISO 61, to obviate inconsistent decisions.

OTA understands from Bill Wolf that NOP has not ruled yet on the technical correction regarding certification of final labelers, and urges NOSB to continue advocating this change, which OTA believes is simply clarifying the intent of the Organic Foods Production Act.

OTA is in the process of trying to determine how various standards will work out in practice.  While the following two positions on livestock issues are not yet official OTA policy, they do represent the direction of the Livestock Subcommittee of OTA’s Quality Assurance Committee.

OTA’s Livestock Subcommittee wishes to express unanimously that its reading of part of Section 236 is that replacement animals for dairy which have been under organic management for one year may be used if organic replacement animals are not available.  If this is not the understanding of the NOSB Livestock Committee, or of NOP, please inform OTA of your interpretation.  The goal of OTA’s Livestock Subcommittee is to refine the standard, working towards a higher bar, perhaps eventually recommending organic management from the last 3 months of gestation.

Regarding access to the outdoors, OTA is leaning towards interpreting this to mean an area without a roof.  It is important to note that this is not a nutritional requirement, or free-range requirement, but a matter of humane treatment.  In addition, this is an issue that must be addressed in the farm plan, especially as it relates to manure management.  OTA will keep the NOSB informed as proposed program requirements are developed, including how to deal with the issue of raising broilers in winter.