MOSA provides our clients with much more than just certification.

Joe Pedretti

MOSA Client Services Director

A Wild God at our Table: calling for organic community action

On the wall of my office, I’ve posted a poem: Sometimes a Wild God, by Tom Hirons. It speaks to things that shake our comfort and might bring fear, but ultimately bring life.

“Sometimes a wild god comes to the table.
He is awkward and does not know the ways
Of porcelain, of fork and mustard and silver.
His voice makes vinegar from wine.

When the wild god arrives at the door,
You will probably fear him.
He reminds you of something dark
That you might have dreamt,
Or the secret you do not wish to be shared.

He will not ring the doorbell;
Instead he scrapes with his fingers
Leaving blood on the paintwork,
Though primroses grow
In circles round his feet.

You do not want to let him in.
You are very busy.
It is late, or early, and besides…
You cannot look at him straight
Because he makes you want to cry…”

If you’ve followed these industry updates, you know it’s been a challenging year for our organic standards. Regulators have been called to task toward better enforcement, while challenged to keep pace with rapid market changes. A year ago in these pages I considered absolutes and common ground, seeking a “heart full of inspiration to keep up the good fight.” With the new administration in DC, we assessed our intended food system revolution compared to corporate power concentration and economies of scale. Later in 2017, MOSA purposefully identified our vision - “A thriving organic world” - and named our values, to guide working toward a system that’s just, empowering, restorative, and biologically sound. These are: Service (Outstanding customer service and MOSA’s leadership within the organic community are vital tenets of our work.); Relationships (We value human connections and ethical interactions.); Quality (We believe that integrity, professionalism, and practicality lead to sound certification decisions.); and, Optimism (Organic offers viable solutions to urgent global challenges. A thriving organic world must have balance: socio-economic justice, ecological sustainability, and the interdependent well-being of individuals, communities, and ecosystems.) Through this work, we have considered how we handle “otherness.” When a stranger arrives, sometimes we have to balance an urge to fight, or hide, with recognition that breaking bread helps us discover common ground and new perspective. But, it can get uncomfortable.

“The wild god stands in your kitchen.
Ivy is taking over your sideboard;
Mistletoe has moved into the lampshades
And wrens have begun to sing
An old song in the mouth of your kettle...

...When your wife calls down,
You close the door and
Tell her it’s fine.
You will not let her see
The strange guest at your table…”

It’s a disconcerting time in our organic community. A number of issues are causing a questioning of our values and absolutes. The discontent is a call to adapt and assess, to prepare good ground for growing our deep values. The stranger at the door calls us to action.

For example, as of this writing, we are calling for changes to 2018 farm bill proposals that threaten to end organic as we’ve known it. An opinion piece in FoodTank gave a good summary of the farm bill’s threat to organic.

The Senate Committee on Agriculture, chaired by Pat Roberts, was expected to release its version of the farm bill in late May. Last July, Roberts slammed the organic regulatory process, targeting the National Organic Standards Board, and asserting a need for NOSB process reforms to help grow organic. This raised fears that the 2018 Farm Bill process could be used to cripple the NOSB and weaken our standards.

In fact, organic’s success has relied on strong standards, and consumer trust. We depend on the NOSB’s good governance and organic pioneers’ foresight in codifying the NOSB as a gatekeeper, a volunteer citizen board directly engaging with the organic community to continually improve our standards. However, the USDA increasingly is failing to enact key NOSB recommendations, growing community discontent.

MOSA was among nearly 150 organizations that signed on to a letter to Roberts, ranking member Debbie Stabenow and the Senate Agriculture Committee. We’re calling on lawmakers to oppose changes in the farm bill that would undermine the National Organic Standards Board. We also called for full funding for the Conservation Stewardship Program — which was slated to be phased out under the House farm bill.

The House farm bill was also damaging to good governance and sound standards enforcement. It also sought to undermine the NOSB, by, for example: allowing NOSB seats currently designated for farmers, handlers and retailers to be filled with business employees rather than owners or general managers; by enabling an “expedited process” for allowance of post-harvest handling and food safety materials; and by requiring the NOSB to work with FDA or EPA when reviewing petitioned materials approved by those agencies. The House version also refused to renew funding for programs that help family-scale farmers, including the National Organic Certification Cost Share Program.

Although the first House version of the farm bill was voted down (over disagreements on immigration), we’re calling for continued vigilance toward defending the integrity of our collaborative organic governance process.

“The wild god asks for whiskey
And you pour a glass for him,
Then a glass for yourself.
Three snakes are beginning to nest
In your voicebox. You cough.

Oh, limitless space.
Oh, eternal mystery.
Oh, endless cycles of death and birth.
Oh, miracle of life.
Oh, the wondrous dance of it all.

You cough again,
Expectorate the snakes and
Water down the whiskey,
Wondering how you got so old
And where your passion went…”

Where do we find our passion for organic vision? Much is expressed at NOSB meetings. In Tucson, AZ, in April, the NOSB debated eight proposals, two discussion documents, 40 National List inputs scheduled for 2020 sunset, and considered 1,600 written comments received prior to the meeting, plus over 13 hours of oral testimony. NOSB meetings shine as a functional democratic forum for checking our values and working towards continuous improvement.

Ahead of the meeting, we heard some controversy regarding NOSB authority over its own work plan. The delayed agenda had conspicuous omissions. And, at the start of the meeting, we still awaited appointments for two vacant NOSB seats. New representatives were named at the beginning of the meeting, but too late for their meeting participation. Eric Schwartz, handler appointee, is CEO of the United Vegetable Growers Cooperative and has held positions at several other fresh food companies. The new environmentalist appointee, James Greenwood, is an avocado grower who’s been active in UCLA’s Institute of the Environment and Sustainability and the Hass Avocado Board. Community eyes and ears are open to learn more about these appointees, while rhetoric about changing the NOSB’s makeup and authority raised some trepidation.

Jackie DeMinter represented MOSA at the Tucson meeting. She observed, “I think if I had to characterize this meeting it would be ‘quiet,’ lacking some loud and controversial voices and topics.” Compared to recent heavy organic news, she noted it was nice to have the break. Jackie also drew attention to expert panels’ (one comprised of representatives from trade, the other comprised of certifiers) discussions on integrity of imports and the organic supply chain. She observed that, after attending many NOSB meetings over the years, this was the most focused discussion she’d seen. These panel discussions took half a day, including NOSB subcommittee discussion. Trade panel suggestions included mandatory certification for currently excluded operations, Inspection systems at U.S. ports, increased testing, prioritizing use of organic (HS) codes, improving NOP’s complaint system, utilizing block chain or similar technology, and considering a US International Trade Commission study. Certifier panel suggestions included increased inspector qualifications and training, requiring acreage reporting to the NOP Integrity database, improved inter-certifier collaboration on investigations, and increased import/export activity tracking. The Organic Trade Association meeting report observed, “This discussion displayed the current Board’s confidence and effectiveness in advising USDA on matters where there is unanimity among organic stakeholders.” The Certification and Compliance Subcommittee now faces a tough task in collating all information, and preparing a fully developed Import Oversight proposal for the Fall 2018 meeting.

For this April meeting, MOSA submitted a half-dozen written comments (available on the news and commentary section of our website) on: defense of native ecosystems, emergency use of parasiticides, genetic integrity in organic seed, organic inspector qualifications, and sunset reviews. Additionally, I presented verbal comments on organic seed genetic integrity, and referenced a letter we recently sent to the Secretary of Agriculture expressing concern over the override of the NOSB’s carrageenan decision, and stressing the importance of NOSB support. In Tucson, Jackie sparked new discussion on paper pots and baling twine. (Details are in Jackie’s Policy overview in this newsletter.) It’s sometimes a challenge for us to get to these meetings, but we find that our voices make a difference, and, we gain new perspective.

The NOSB unanimously passed proposals on a Definition of “emergency treatment” in organic livestock; Inspector Qualifications and Training; Reclassification of Magnesium Chloride (natural forms only); and, a Petition to add Sulfur as a Molluscicide to the National List. The Board also passed (with ⅔ majority) a Petition to add Polyoxin D Zinc Salt as Biofungicide in organic crop production, and the Eliminating the Incentive to Convert Native Ecosystems proposal. Two petitions failed: one to allow Sodium Dodecylbenzene Sulfonate as a direct sanitizer for produce, and another to add Glycolic Acid as an organic livestock teat dip.

The next NOSB meeting is in our neck of the woods, in St. Paul, MN, October 24-26. We expect proposals for: Establishing a Seed Purity Standard (focus areas include scoping the problem, exploring theoretical thresholds on high-risk crops - with a focus on testing protocols and associated costs, and, exploring a process to work with farmers to retain seed samples for future testing); 2020 Sunset Materials. (The public raised some concerns about these inputs: For crops - Aqueous Potassium Silicate, Newspaper or other Recycled Paper; Elemental Sulfur, Liquid Fish Fertilizer, Ethylene, and Microcrystalline Cheesewax; For livestock - Sucrose Octanoate Esters; and, For handling - Glycerides, Fructooligosaccharides, Gums, Lecithin, and Tragacanth Gum.); Organic Seed Usage; Marine Materials; and, a new discussion document on Packaging Substances used in Organic Food Handling, including BPA.

The Tucson meeting also continued discussion regarding various additional verifications, including the regenerative movement, the Real Organic Project, and grassfed dairy standards. With concerns about the USDA’s pace, and intentions, in working toward standards change, these newly-arising additional standards have created a lot of buzz. It’s been difficult to digest the calling of this “wild god/stranger.” We value unity in diversity and inclusiveness. However, some add-ons have an air of divisiveness, and all point to discontent. Our stakeholders - certified clients, MOSA staff and Board, consumers - want Standards improvement, and continued recognition of our NOP regulations as the “gold standard,” with high vision and noble values. And yet, we recognize that sound improvements take time. Maybe we feel some hurt when comparing where we are now to our unachieved wilder, wider organic vision. Currently, we’re moving our feet on a few of these callings, developing a grassfed dairy verification, and helping to promote the development of the Regeneration Midwest Alliance. And yet, it’s hard to read how best to proceed. So, we do a lot of listening, holding close our optimism, setting our eyes on vision.

“In the distance, warriors pour from their tombs.
Ancient gold grows like grass in the fields.
Everyone dreams the words to long-forgotten songs.
The hills echo and the grey stones ring
With laughter and madness and pain...

...The wild god points to your side.
You are bleeding heavily.
You have been bleeding for a long time,
Possibly since you were born.
There is a bear in the wound…”

As of early May, there’s another call to action. The USDA is now seeking comments on its latest GMO disclosure rule, renamed as the “National Bioengineered Food Disclosure Standard.” Comments are being received until July 3rd. This 106-page rule leaves lingering questions, including whether the prohibition covers foods from gene editing, and how much GMO ingredient a food must contain before it requires GMO labeling. Our website includes details on how to submit comments, and, early comments can be viewed at

With this issue, it’s important to emphasize that organic is non-GMO, and much more. As such, organic is exempt from the GMO label disclosure regulation. Our regulations (§205.105) prohibit the use of “excluded methods,” defined as: “A variety of methods to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes and are not considered compatible with organic production. Such methods include cell fusion, microencapsulation and macroencapsulation, and recombinant DNA technology (including gene deletion, gene doubling, introducing a foreign gene, and changing the positions of genes when achieved by recombinant DNA technology). Such methods do not include the use of traditional breeding, conjugation, fermentation, hybridization, in vitro fertilization, or tissue culture.” Standards compliance requires that operations have verifiable practices in place to avoid contact with GMOs.

From a continuous improvement perspective, we’d emphasize NOSB work: GMO prevention strategies recommendations, ongoing assessment of new bioengineering technologies to determine which are defined as excluded methods, and development of seed purity requirements.

It’s encouraging to read the new public comments on this issue, which outcry for transparency.

‘There is a symphony of howling.
A cacophony of dissent.
The wild god nods his head and
You wake on the floor holding a knife,
A bottle and a handful of black fur.

Your dog is asleep on the table.
Your wife is stirring, far above.
Your cheeks are wet with tears;
Your mouth aches from laughter or shouting.
A black bear is sitting by the fire…”

These interesting organic times call for promoting that our success depends on strong standards and consumer confidence in organic values. An overview of the 2018 Organic Industry Survey from the Organic Trade Association indicates that organic grew at 6.4% in the US in 2017, reaching annual sales of $49.4 billion. The OTA report shows how organic has thrived since the advent of our NOP Standards, but also shows that consumer perception of weakness in our standards can hurt growth. “Pasture-raised eggs, which clearly delineate humane practices such as outdoor access, presented stiff competition for organic eggs in 2017. Consumers perceive organic as requiring a number of humane practices including outdoor access for livestock and poultry. However, the requirements as written within current federal organic standards are unclear and inconsistently applied. The organic industry worked to advance the Organic Livestock and Poultry Practices rule to clarify required practices, but the rule was abruptly withdrawn by the USDA in 2017. USDA's squelching of this regulation widely supported by the organic sector caused millions of consumers to question the meaning and relevance of the USDA Organic seal as it relates to dairy and egg products. This confusion and uncertainty dampened consumer demand for both organic eggs and organic dairy.” Perhaps this is tough news, but, it calls us back to our wilder origins, to action, to new life.

“Sometimes a wild god comes to the table.
He is awkward and does not know the ways
Of porcelain, of fork and mustard and silver.
His voice makes vinegar from wine
And brings the dead to life.”

Like new blood, the wild god comes to our table to spark the passion and values which persistently run deep in this organic movement, which continue to spur life. Let’s not tame our fear or shrink from his call.