The Organic Trade Association
Supports NOSB’s proposed
Recommendation on Livestock Feed Ingredient Issues
Submitted by
Tom Hutcheson
November 29, 2002
The Organic Trade Association (OTA) thanks the National Organic Standards Board (NOSB) for giving priority to resolving livestock feed ingredient issues. OTA supports these recommendations and notes the clear sense of the Board as indicated by the lack of any votes opposed to the proposals.
OTA supports allowing synthetic vitamins and minerals and broadening the annotations to include specific materials either listed in specific appropriate sections of the CFR or in the AAFCO Official Publication Sections 57 or 90, with the exceptions listed.
OTA hopes that the recommendation that the materials listed in the fourth paragraph of the recommendation be reviewed by a Technical Advisory Panel will be considered by the National Organic Program sufficient reason to initiate those TAP reviews.
OTA supports allowing incidental ingredients as defined by CFR 570(a)(3), and allowing carriers derived from agricultural products used in feed additives, as defined by AAFCO.
OTA supports using AAFCO definitions where these prove useful. Organic production has distinguished itself sufficiently from conventional production; now is indeed the time to incorporate useful definitions and other work used by other organizations into the National Organic Standards.
OTA supports NOSB recommending rule changes where these seem appropriate, in this case by adding a new section 205.603(g). Organic standards have been refined over the past several decades and OTA hopes that this process of continual improvement makes the National Organic Program a dynamic partner with organic producers in improving all aspects of organic production.
Finally, OTA supports NOSB and NOP recognizing in all official work that the AAFCO feed ingredient label term for “probiotics” is “ direct-fed microorganisms”.
Comments of the Organic Trade Association
on NOSB’s proposed
Guidance Document on Handling Operation Ingredient Affidavits
Submitted by
Tom Hutcheson
November 29, 2002
The Organic Trade Association appreciates NOSB’s desire to provide an example of an ingredient affidavit that would be acceptable to the National Organic Program.
OTA cautions NOSB, though, that accredited certifying agents (ACAs) have been judged competent to assure the organic integrity of products, and that ACAs may wish to create forms dissimilar to this example. OTA therefore urges NOSB to recommend this template only as an example of the minimum information needed to establish accountability, with explicit language to that effect, so that the right of ACAs to develop their own forms according to their own needs is upheld.
Comments of the Organic Trade Association
on NOSB’s proposed
Guidance Document on Organic Handling Plans
Submitted by
Tom Hutcheson
November 29, 2002
The Organic Trade Association appreciates NOSB’s desire to provide an example of a handling plan that would be acceptable to the National Organic Program.
OTA cautions NOSB, though, that accredited certifying agents (ACAs) have been judged competent to assure the organic integrity of products, and that ACAs may wish to create forms dissimilar to this example. OTA therefore urges NOSB to recommend this template only as an example of the minimum information needed to establish accountability, with explicit language to that effect, so that the right of ACAs to develop their own forms according to their own needs is upheld.
Comments of the Organic Trade Association
on NOSB’s proposed
Guidance Document on Organic Farm Plans
Submitted by
Tom Hutcheson
November 29, 2002
The Organic Trade Association appreciates NOSB’s desire to provide an example of a farm plan that would be acceptable to the National Organic Program.
OTA cautions NOSB, though, that accredited certifying agents (ACAs) have been judged competent to assure the organic integrity of products, and that ACAs may wish to create forms dissimilar to this example. OTA therefore urges NOSB to recommend this template only as an example of the minimum information needed to establish accountability, with explicit language to that effect, so that the right of ACAs to develop their own forms according to their own needs is upheld.
Comments of the Organic Trade Association
on NOSB’s proposed
Guidance Document on Organic Farm Plan Updates
Submitted by
Tom Hutcheson
November 29, 2002
The Organic Trade Association appreciates NOSB’s desire to provide an example of a farm plan update that would be acceptable to the National Organic Program.
OTA cautions NOSB, though, that accredited certifying agents (ACAs) have been judged competent to assure the organic integrity of products, and that ACAs may wish to create forms dissimilar to this example. OTA therefore urges NOSB to recommend this template only as an example of the minimum information needed to establish accountability, with explicit language to that effect, so that the right of ACAs to develop their own forms according to their own needs is upheld.
