Comments of the Organic Trade Association
to the
National Organic Standards Board
September 17, 2002
The Organic Trade Association is in the process of developing comments on clarification of the dairy herd replacement clause, health care materials for young stock, and inclusion of fiber and non-food items produced from livestock into the NOP livestock standards.
You will soon have a chance to hear some of the concerns that OTA members have raised as well as ideas on how to address these concerns. Several members of the Livestock Subcommittee of OTA’s Quality Assurance Committee are presenting comments which OTA hopes to present as a final comment after due deliberation by OTA’s Quality Assurance Committee.
Unfortunately, OTA must note that although the NOSB’s request for comments stated that there would be a 60-day comment period, there has been substantially less than that. A calm, deliberate process is necessary for commenting on items as complex as the dairy herd replacement clause, and OTA requests that NOSB postpone a decision on this item.
OTA will be submitting formal comments on the NOSB grower group recommendation by the deadline, September 20. OTA anticipates that these will include supporting the conditions recommended by the NOSB for participation in a Grower Group, suggesting that the certifying agent have policies and procedures as to how many growers will be inspected annually (with specific language to follow), and supporting the guidance offered for inspection of Grower Groups, and supporting having specific information included into the NOP accreditation requirements for certifiers, as well as in the NOP’s Accreditation Procedures Manual.
Further, OTA applauds the NOSB for working so hard on the numerous materials petitions on the agenda. The timely and responsible resolution of materials questions and petitions is vital for the continued healthy growth of the industry. OTA urges the NOP and NOSB to continue to work to ensure that materials petitions are given full and timely reviews. In addition, materials reviews should be available to the NOSB and the public sufficiently in advance of NOSB meetings so that interested parties may have access to them. | 
