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. | 
