COMMENTS
of the Organic Trade Association
 to the National Organic Standards Board, 10-17-01

Good morning.  I’m Tom Hutcheson, from the Organic Trade Association.

First, OTA supports the comments of the Organic Material Review Institute.

OTA will be working with FAS, as per their presentation, to help identify specific problems experienced by exporters of organic products.  Please consider referring organic exporters with such problems, whether or not they OTA members, to me at OTA, so OTA can compile evidence of export problems.

OTA also strongly urges NOSB to approve the recommendation of the Accreditation Committee for private labels.  Bill Wolf will be happy to clarify the issue and present the argument for the need for the provision.

OTA urges NOSB to explore the possibility of establishing a rolling review of materials, one-fifth of the list every year over the five year review schedule.

OTA applauds the work of the Aquatic Animals Task Force but has reservations about allowing an exception to the requirement for 100% organic feed.  OTA is also concerned about animal health care when unhealthy animals must be treated by treating a whole group of animals.

OTA notes the time spent on discussion of the allowability of a sunset clause in annotations and urges NOSB to request the presence of a representative of OGC at all NOSB meetings.