MOSA provides our clients with much more than just certification.

Joe Pedretti

MOSA Client Services Director

Checking our Temperature: considering the state of organic and planetary health

Checking our Temperature: considering the state of organic and planetary health

By Stephen Walker, MOSA Accreditation and Industry Affairs Manager

This writing occurs at the conclusion of the 26th United Nations climate conference. COP26 is criticised for not achieving the transformative breakthrough scientists say must happen if humanity is to avert disastrous planetary warming. COP26 agreements push countries to strengthen near-term climate targets and move away from fossil fuels faster, and insist that wealthy countries fulfill a broken promise to help vulnerable nations cope with the rising costs of climate change. But, the conference didn’t achieve critical actions to limit Earth’s warming to 1.5 degrees Celsius above pre-industrial levels. We’re still marching toward escalating weather crises and irreversible damage to ecosystems. Optimistically, the climate crisis and organic solutions remain a major focus of the worldwide organic movement. I’m reminded again of the necessity of “plugging away with purpose,” discussed in the Summer 2021 Organic Cultivator.

Recent opinion from Kathleen Merrigan, published in The Conversation, compares the U.S. response to the climate crisis with better efforts in Europe. Merrigan helped write the Organic Foods Production Act (OFPA) and served as the U.S. Deputy Secretary of Agriculture from 2009 - 2013. She now directs the Arizona State University’s Swette Center for Sustainable Food Systems. As President Biden’s climate change response looks for solutions and opportunities in every U.S. economic sector, including agriculture (which emits over 600 million metric tons of carbon dioxide equivalent every year - more than the total national emissions of the United Kingdom, Australia, France, or Italy) Merrigan notes, “A majority of Americans are concerned about climate change and willing to make lifestyle changes to address it. Surveys show that many U.S. consumers are worried about possible health risks of eating food produced with pesticides, antibiotics, and hormones. One way to address all of these concerns is to expand organic agriculture. … In contrast with the EU, the U.S. has no plan at the national level for expanding organic production, or even a plan to make a plan.” She points to the EU’s Farm to Fork strategy’s ambitious 2030 targets: a 50 percent cut in greenhouse gas emissions from agriculture, a 50% cut in pesticide use, and a 20% cut in fertilizer use.

“Less than 1% of U.S. farmland — about 5.6 million acres — is farmed according to national organic standards, compared with 36 million acres in the EU. This small sector doesn’t produce enough organic food to meet consumer demand, so much of the organic food consumed in the U.S. is imported from nearly 45,000 foreign operations.” She calls this gap a huge missed opportunity. “While the U.S. and the EU are working together to address agriculture’s contribution to climate change, they have very different views on the role of organic farming. At a U.N. Food Systems Summit... Agriculture Secretary Tom Vilsack launched a new international coalition on sustainable productivity growth, calling on countries and organizations to join the U.S. in the cause of increasing yields to feed a growing world population… Vilsack promoted voluntary, incentive-based, and technological approaches to producing more food, such as gene editing, precision agriculture, and artificial intelligence. Vilsack asserts that the EU’s emphasis on organic production will reduce output and push up food prices.”

Merrigan says “these U.S. talking points are outdated. The world’s farmers already produce enough food to feed the world. The question is why many people still go hungry when production increases year over year.”

“At the U.N. Food Systems Summit, many world leaders called for reforms to eradicate hunger, poverty and inequality, and address climate change. Food systems experts understand that global nutrition security depends on empowering women, eliminating corruption, addressing food waste, preserving biodiversity and embracing environmentally responsible production — including organic agriculture. Not on the list: increasing yields.”

“Addressing agriculture’s role in climate change means changing how nations produce, process, transport, consume, and waste food. I believe that when leaders call for cutting-edge, science-based solutions, they need to embrace and support a broad spectrum of science, including agroecology — sustainable farming that works with nature and reduces reliance on external inputs like fertilizers and pesticides.”

“The Biden-Harris administration could do this by developing a comprehensive plan to realize the untapped potential of organic agriculture, with clear goals and strategies to increase organic production and with it, the number of organic farmers. Consumers are ready to buy what U.S. organic farmers raise.”

The organic pathway for the future

As we consider the state of organic in the U.S, The Swette Center and the Organic Trade Association are gathering diverse organic stakeholders in a series of workshops to assess what’s worked, and what hasn’t, since OFPA became law 30 years ago, and where we should be headed. OTA’s CEO and ED Laura Batcha said, “The unique private-public partnership that is the backbone of organic has generally served the sector well, but over the past several years the federal regulatory apparatus has stifled innovation and stalled continuous improvement within the industry. Our partnership with ASU has been created to gather ideas from all corners on ways to reverse this trend and to make organic the best it can be.” Merrigan added, “It was a diversity of minds that created the novel scheme that became the 1990 OFPA. It is time to re-engage that original coalition of organic, consumer, and environmental organizations, and bolster it with many new stakeholders. We need everyone seated at the table to successfully plot the next 30 years of organic.”

Several MOSA staff were at the table on October 27th, in the workshop for certifiers. We answered questions on: structure of the NOP public-private partnership, including the role and future of the National Organic Standards Board (NOSB), and how to provide accountability and transparency that allows standards to keep pace with consumer and environmental demands; continuous improvement, how it should be defined in regulations, and how standards can address labor, social and environmental challenges; accreditation, certification, accountability and enforcement, including improving the Organic System Plan, and exploring new approaches to certification; and, the future of marketing claims and whether the USDA Organic label still breaks through to consumers.

On December 13th, the Organic Farmers Association is co-hosting one workshop exclusively for farmers and farming organizations, to get extensive farmer input and help pave the way for farmers to help shape farm bill priorities and organic’s future.

Several ongoing organic community discussions are considering the future of organic in our part of the world. At the National Organic Coalition’s biannual Pre-NOSB meeting, NOC proposed Structural Reforms to Advance Organic at USDA, including elevating the role of the NOSB, and activating support for organic agriculture across USDA agencies. Lively stakeholder discussion at that meeting included observations that power imbalance is hurting the regulatory process, that now is the time to be bold in pushing for improved balance, as the Biden administration speaks to fairness, that carbon markets must be truly regenerative, and that the organic movement might benefit from working on the fringes if the Program is not going in the desired direction.

These temperature-checking and forward-thinking discussions may point the way to assessing and updating the National Organic Action Plan, published in 2010. Organic action plans can bring together community stakeholders to advance organic regionally, nationally, or at more local levels. Organic action plans identify specific action items, who is responsible for them, and resources needed to accomplish goals. Now, the organic pathway for the future must also lead beyond our borders and consider the global context. As we discussed this recently in IFOAM North America circles, Ken McCormick reminded, “we’re all in this together.”

NOSB’s Fall Meeting

The National Organic Standards Board meets biannually to gather input and advise the Secretary of Agriculture on organic regulatory concerns. The October live webinar meeting included welcoming remarks from California Department of Food and Agriculture Secretary Karen Ross, noting the unique importance of organic to California’s climate smart growth priorities. Remarks from new USDA appointees Jenny Lester Moffitt and Marni Karlin also highlighted organic as critical toward creating a resilient and equitable food system. (Moffitt, who grew up on an organic farm,is the new Under Secretary for Marketing and Regulatory Programs. Karlin is the new USDA Senior Advisor, Organic and Emerging Markets. The reinstatement of this post after its elimination during the Trump administration ensures organic’s part in activities and policy throughout the USDA.) NOSB Chair Steve Ela led the last meeting of his five-year term and steered through a large agenda including consideration of 13 proposals, three discussion documents, and over 30 sunset materials. I was among many meeting participants who found the debate among Board members to be respectful, and again, a good example of democratic process.

MOSA submitted seven written comments, available on our website, on agenda items including organic as a climate change solution, fraud prevention and modernization of traceability systems, updating how excluded methods (GMOs) are defined, the structure of the NOSB public comment process, ammonia extract as a nitrogen source, biodegradable biobased mulch film, and sodium nitrate restrictions. Jackie DeMinter and I also presented verbal comments and answered some questions from the NOSB. Jackie summarized our written comments on biodegradable mulch film, sodium nitrate, and ammonia extract. I spoke to modernization of fraud prevention systems and ensuring that certification remains accessible. (Keeping organic accessible has been a major theme in many MOSA comments to the USDA as of late, as we balance improving organic enforcement with minimizing documentation and other burdens on organic producers, processors, inspectors, and certification staff.) All meeting documents, and transcripts, can be found at the USDA website. The Cornucopia Institute website has a thorough summary of NOSB public comments.

Hot topics included ammonia extract, sodium nitrate & other highly soluble nitrogen sources. The NOSB voted 13-1 to prohibit stripped ammonia and concentrated ammonia. Most agreed that ammonia extracts don’t meet environmental impact, soil health, and sustainable ag system compatibility requirements. The NOSB also voted unanimously to reinstate a restriction on sodium nitrate, another highly soluble nitrogen source. Wider discussion on highly soluble nutrients in organic agriculture was sent back to the Crops Subcommittee.

All 30 materials currently undergoing sunset review were voted to be approved for another five-year cycle. Only copper sulfate (rice production), EPA List 3 inerts (passive pheromone dispensers in crop production), and carrageenan (gelling agent in food processing) received votes for removal. Carrageenan fell just short of the ⅔ majority required to remove its allowance. No new materials were allowed. The NOSB rejected three new synthetic materials petitioned for allowance (chitosan, kasugamycin, and hydronium), a petition for manure biochar, and a petition to allow Zein as a non-organic ingredient in food processing.

The Board narrowly voted to allow biodegradable mulches that are 80% biobased. Public comments were balanced across both sides of the issue. The NOSB added language to encourage improvement beyond 80% if commercially available. Concerns included the impact to soil microbes after consecutive uses, and over-use of plastic in agriculture. Some saw biodegradable plastic as an imperfect solution but at least as a step in the right direction. NOSB members hope growers will switch to biodegradable alternatives if they become commercially available at the 80% threshold.

The NOSB recommended to further restrict the allowance of fish oil as a nonorganic ingredient, to minimize environmental harm from fishing: “Sourced from fishing industry by-product only and certified as sustainable against a third-party certification that is International Social and Environmental Accreditation and Labeling (ISEAL) Code Compliant or Global Seafood Sustainability Initiative (GSSI) recognized.”

We’re pleased that the NOSB will now be able to add items to its own work agenda. The Board expressed interest in considering continuous improvement, climate change, organic seed requirements, forever chemicals in packaging, integrity and enforcement, greenhouse/container standards, and excluded methods.

The Spring 2022 NOSB Meeting is scheduled for April, near Washington, DC. Agenda topics will likely include oversight improvements to deter fraud, supporting the work of the NOSB, nitrogen fertilizers, GMO determinations for cell fusion and protoplast fusion, and several new materials petitions.

NOP update

At the NOSB and in a recent “Coffee with the Deputy” meeting for certifiers, we’ve heard reports on National Organic Program activities from Deputy Administrator Dr. Jennifer Tucker. A full update is available at the Organic Integrity Learning Center.

The Biden administration is prioritizing catching up with needed rulemaking. Dr. Tucker noted the Moffit and Karlin appointments as bringing more political leadership for organic needs. The NOP Standards Division is well-staffed, and Final Rules on Origin of Livestock, Strengthening Organic Enforcement, and Organic Livestock Practice Standards (including poultry production) are under interagency review.

The NOP is drafting an Advanced Notice of Proposed Rulemaking (ANPR) related to EPA Lists 3 & 4 inert ingredients. Discussions with senior EPA staff revealed challenges in working with the EPA Safer Choice Program. The ANPR will summarize challenges. Dr. Tucker warned this will be a long road and there will be tough trade-offs.

Current NOP Strategic Initiatives include on-ground surveillance to monitor compliance with key livestock regulations, including pasture compliance, animal traceability, and origin of livestock. Imports oversight is also a focus, and Import Certificates will be required. NOP is working on building an Organic INTEGRITY database/import certificates interface. Certifiers will enter data, the database will generate the certificates, and importers will use the certificate as part of Customs and Border Protection’s Automated Commercial Environment import filing processes. This is targeted for completion in late 2022.

Dr. Tucker also noted various initiatives related to improving human capital and capacity for organic enforcement underway. Certifiers gave feedback on what we look for when hiring inspectors and review staff. We also answered questions regarding technical assistance/education needs.

Diversity, Equity, and Inclusion

Our organic community’s assessment of where we’ve been and where we should be headed includes some awakening around fairness and organic accessibility. In December, IFOAM North America, the Accredited Certifiers Association, the International Organic Inspectors Association, the Organic Farmers Association, and the National Organic Coalition are collaborating on a project to offer Diversity, Equity, and Inclusion Resources for Organic Professionals. This includes a December 8th webinar on the History of Racism in US Agriculture & Organic.

We’ve recognized the need for training on baseline knowledge and common language for diversity, equity, and inclusion across the organic community. This will give an overview of systemic racism in organic agriculture systems, data on current demographics in organic, and existing policies. The webinar is open to all, but is designed for inspectors, certifiers, and organic farm education organizations. Registration is open through December 6th, at


Feel free to contact me at MOSA for additional information on any of the organic community news noted above. There’s much work to be done, and optimism runs through it.