MOSA provides our clients with much more than just certification.

Joe Pedretti

MOSA Client Services Director

Finding Home: Organic’s 2020 Vision

A few weeks ago I had some dreams with themes of being lost in some sort of transportation system, surrounded by unfamiliar people and culture, and unable to find my way home. Back when I could remember the details better (we forget these quickly), I described one dream to MOSA colleagues, and Cori said, “That’s a Covid dream!” Yep. Between the pandemic, climate crisis, inequity, and financial uncertainty, rest is disturbed for many conscientious people as we’ve negotiated 2020. Lately, we’ve heard so much about “new normal” that I rather object to the term. It smacks of pessimism. On the other hand, many folks are seeing how so many of our systems are out of balance and not working, and they’re seeking a better place akin to our optimistic movement and values statement, “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.” We want to get to a more comfortable and safe place. The good life, a better place, has been at the heart of our global organic movement for over 100 years.

For most of 2020, while recognizing deep value in a strong local community, our wider organic movement has taken much of its interdependency to online connections like webinars and video meetings. As the world awakes to changes we all must make, there are opportunities and global urgency for our movement’s missions, principles and values.

EU Green New Deal

In an encouraging example for the rest of us, the European Commission has proposed a target to increase organic farming in the EU to 25% by 2030, in their just published Farm to Fork (F2F) strategy and Biodiversity strategy.

Jan Plagge, IFOAM EU President, stated: “(This) is a landmark decision that puts organic farming at the core of a transition of European agriculture towards agroecology. Organic farming is a successful economic model for farmers with proven benefits for the environment. Making it a cornerstone of a future EU sustainable food system is the right decision.” He continued: “We need to transform EU agriculture if we want to address the climate and biodiversity crisis and make our farming systems more resilient. The F2F strategy provides a clear vision for the future of our food system.” Plagge called for necessary policy reform to reward farmers for their contribution such as the preservation of our natural resources. And he warned, “We must not make the mistake of using Covid-19 as an excuse to continue a backward-looking agricultural policy.”

Here in the US, the Organic Trade Association featured a webinar on discussing the EU's Green Deal. The recorded webinar is available for OTA members after registration.

Optimistic Research

Science explains why organic is a good choice for our planet, and more studies are published each week. The Organic Center summarizes the latest peer-reviewed studies at its research blog: Recently published summaries show: Green manure reduces weeds while improving soil fertility in organic rotations; Production of organic cotton is more profitable and less risky than GM cotton; More antibiotic-resistant E. coli is found in conventional and antibiotic-free chicken meat than organic; and, levels of glyphosate (aka Roundup) in families drop dramatically after one week of eating organic.

The Organic Center also recently shared a study from Thailand. While many countries are implementing programs to expand organic farming, it’s important to understand why farmers are willing to adopt organic practices. A recent study in the Journal of Agricultural Extension showed that environmental concerns were the top incentive for switching to organic, for Thai rice farmers. The Thai government has been actively encouraging farmers to transition to organic production since 2018, and Thailand’s organic industry is growing by 16% annually. Those who were most willing to adopt organic were farmers with more years of schooling, of younger age, with smaller pieces of land, and who had more experience in farming rice.

Climate action in US

An August 27th OTA webinar focused on U.S. Climate Policy & Organic Agriculture. The Organic Center presented an easy-to-understand scientific grounding in the connections between organic practices, increases in soil carbon, and reductions in nitrogen pollution. OTA Board Members then shared the latest policy recommendations to support organic as a key to mitigating climate change. Panelists discussed U.S. Congressional legislation prioritizing agricultural solutions, and a new report from the U.S. House Select Committee on the Climate Crisis. This webinar recording is also available.

OTA’s website includes good support for organic’s battle on climate change. A new white paper offers specific recommendations for Federal policymakers to support organic farmers and encourage transition to organic farming as a key strategy for mitigating climate change mitigation, which threatens our communities, economies and ecosystems. Policy recommendations in the white paper include:

  • Elevating organic as a key voice in climate-smart agricultural policy;
  • Establishing a national program to support transitioning organic farmers by reducing financial risks, improving market infrastructure development and increasing access to land;
  • Developing a competitive grant program to provide technical services to organic and transitioning farmers to create better access to information about organic production methods that sequester greenhouse gases and improve crop yields, and
  • Creating a federal Healthy Soils pilot program, based on USDA’s Natural Resources Conservation Service and the California Healthy Soils Initiative programs.

Fall NOSB meeting

As we consider our organic movement impact in this world in crises, we continue work to improve our Standards. You can tune in to the deliberation in October as the National Organic Standards Board (NOSB) Meeting will be held live online. We’ll miss the in-person collaboration, but appreciate that the online format enables more organic stakeholders to participate, safely. Full meeting details are at the NOSB Fall 2020 Meeting webpage. Consider registering (by 10/1) to present public comment or provide written feedback on agenda items. Public comments will be heard on October 20th and 22nd, and the Board will consider agenda items from October 28th-30th. Here’s a brief agenda summary.

From the NOSB Crops Subcommittee:

1- A proposal would add Paper (Plant pots and other crop production aids) to the National List. This would define a paper-based crop planting aid as “A material comprised of at least 60% cellulose-based fiber by weight, including, but not limited to, pots, seed tape, and collars that are placed in or on the soil and later incorporated into the soil. Contains no less than 80% biobased content as verified by a qualified third party assessment.”

2- A proposal seeks to limit the impact of harvesting wild, native fish for fertilizer and to ensure that liquid fish fertilizer products are not harmful to the environment. This restricts liquid fish products to those sourced only from fish waste, bycatch, or invasive species.

3- A proposal would add Sodium carbonate lignin to the National List at 205.601(j)(4

4- All subcommittee recommendations support continued allowance of 2022 sunset substances, with the exception of Aquatic plant extracts, and EPA List 4 - Inerts of minimal concern. For aquatic plant extracts, the subcommittee was divided. Two members wanted more information on marine macroalgae in plant fertility products (described below) and one member was concerned about the environmental impact of harvests. For inerts, EPA List 4 is outdated and may include materials inappropriate for organic. The Crops Subcommittee strongly requests that the NOP act on a 2015 NOSB recommendation, since the NOSB, NOP, and EPA now have tools to work together, including the established EPA Safer Choice Program.

5- Two discussion documents include a petition seeking to prohibit nonsynthetic ammonia extracts for use in organic crop production, and more discussion on Biodegradable biobased mulch (annotation change).

From the Livestock Subcommittee:

1- The fenbendazole allowance is proposed to include: Fenbendazole-for use in laying hens or replacement chickens intended to be laying hens.

2- The subcommittee recommended that all 2022 Sunset substances should continue to be allowed for use.

From the Handling Subcommittee:

1- A proposal seeks to add Low-acyl gellan gum as an allowed substance on the National List.

2- For ion exchange filtration, to correct inconsistency in certifier reviews, the subcommittee recommends the recharge materials, but not the resins or membranes themselves, must be reviewed and included on the National List.

3- A number of 2022 Sunset substances are NOT recommended for continued allowance. The Subcommittee vote on carnauba wax was split based on concerns about the use of volatiles in its production, possible availability of organic forms, and concern with an unlabeled ingredient/additive used on produce. For 18 colors currently allowed, almost all subcommittee votes were split. In 2015, the NOSB noted the emerging certified organic colors and recommended future review of each color individually rather than lumping them as a group. Persons interested in maintaining a particular color’s allowance should speak up, or the NOSB will assume the color no longer needs to be listed. The Subcommittee was split over relisting orange shellac. There is lack of information about whether its use in organic products is widespread or necessary as well as an absence of comments on this ingredient. The Subcommittee also recommends removal of cornstarch, sweet potato starch, and Turkish bay leaves because of the presence of organic sources for these.

4- Whey protein concentrate is also petitioned for removal from the National List. There’s been no public comment indicating inadequate organic supply. In fact, some say that at this point the supply exceeds the demand.

A NOSB Materials Subcommittee proposal on Marine Macroalgae in Crop Fertility Inputs provides parameters on harvesting addressing conservation areas, bottom trawling, protecting reproduction of the population and ecosystem functions, biomass and architecture, and bycatch.

And, the Compliance, Accreditation, & Certification Subcommittee will wrestle with a discussion document on our critical challenge of “Human Capital Management” for Organic Inspectors and Reviewers, after a July memo from the NOP. Organic certifiers, including MOSA, and organic farms and businesses, have raised the problem of a known shortage in organic inspectors and reviewers. This comes from a rapidly expanding industry, the need for specialized skills, and competition for well-qualified individuals both inside the organic community and with other industries. With the increasing size and complexity of organic supply chains, developing, recruiting, and retaining well-trained and well qualified inspectors and reviewers is essential for organic integrity. Got skills? Consider jumping into our line of work.

In our many comments to USDA on the organic regulatory process, we’ve often noted this human capacity challenge. We support strengthened standards, to regulate a growing industry and to correct gaps, but we’re conflicted when these improvements so often place more burden on certifiers. The proposed rule for Strengthening Organic Enforcement (see Jackie’s article in this newsletter) continues more of the same regulatory scheme which IFOAM describes as “Organic 2.0,” a phase of organic development started in the 1970s when the writings and agricultural systems developed by our pioneers were first codified into standards and later into legally-mandated regulatory systems. Though proposed SOE changes are well-targeted, we have some concern about capacity challenges, costs, and whether the strengthening makes certification less widely accessible. IFOAM’s Organic 3.0 concept paper considers new “Diverse Ways to Ensure Transparency and Integrity.” This foresees that “different, new verification schemes may become practiced depending on the length and complexity of value chains. Reputation economy and web-based communication technology offer new opportunities; the organic movement must be open to this. For long chains, the process-oriented paperwork might be complemented and reduced by modern authentication, tracing and tracking technologies, which will become widely used as they become more affordable (e.g. remote sensing, highly improved analytics). Third-party certification will remain important particularly for marketing in large quantities in retail chains. The Organic 3.0 model in this case must entail reforms to lower the burden of producers for onerous reporting requirements.”

Sometimes, our burdensome regulatory process gets in the way of getting back home even when there’s wide support for changes.

OLPP dead again

As of this writing, we’ve just learned that the Organic Livestock and Poultry Practices (OLPP) rule, which aimed to strengthen animal welfare requirements, is dead. The OLPP proposed rule was published in January, 2017, with most work completed under the Obama Administration, then stalled under the current administration and was withdrawn in March, 2018. The Withdrawal rule noted errors in cost/benefit assessment, and projected that OLPP rule costs likely exceeded benefits. The Agricultural Marketing Service (AMS) also concluded there was no organic market failure sufficient to warrant the OLPP regulations, and said the Organic Foods Production Act did not permit regulating organic solely on animal welfare concerns. Last October, OTA filed a motion for summary judgment, including a private economic analysis. In reviewing the private economist’s work, AMS found additional OLPP flaws. In January, USDA requested time to clarify. Dr. Peyton Ferrier produced an Economic Analysis Report concluding that there were significant methodological flaws in the rules’ Regulatory Impact Analyses, and his economic analysis report findings were opened for more public comment.

After reviewing 551 public comments, including MOSA’s input, AMS says the OLPP rule should stay withdrawn. Many commenters addressed matters which favored the OLPP rule, but were unrelated to the Economic Analysis Report specifics. One commenter stated that USDA failed to give enough time for review and comment. However, a longer comment period would not have allowed completing the Final Decision by the deadline, and it was opined that since the OLPP Regulatory Impact Analysis was available since 2017, stakeholders had ample opportunity to familiarize themselves with the noted flaws.

After working for 10 years to develop the organic community consensus that led to the OLPP, we find this disappointing to say the least, and question whether most family farm stakeholders truly have the time or “human capital” to digest complex economic analyses and push against corporate interests. Likely, this withdrawal decision will be fodder for more criticism of NOP/USDA and the organic industry, contrary to a better-place vision from organic’s heart.

Sights forward

On a Monday last March, as the Covid-19 pandemic hit the US and our culture changed quickly, my daughter quickly packed up and decided she was going to ride this out in a small apartment with her friend. She figured it would be a few weeks; I knew it might be a one-way trip. I watched as the small car rounded the corner, unsure of our future, and wondering if I might not see her again. Recalling a century-old writing from Kahlil Gibran’s The Prophet, I said to myself, “There goes the arrow.”

When a young mother with a newborn baby at her breast asks for advice on children and parenting, Gibran’s prophet responds:

Your children are not your children.

They are the sons and daughters of Life’s longing for itself.

They come through you but not from you,

And though they are with you yet they belong not to you.

You may give them your love but not your thoughts,

For they have their own thoughts.

You may house their bodies but not their souls,

For their souls dwell in the house of tomorrow, which you cannot visit, not even in your dreams.

You may strive to be like them, but seek not to make them like you.

For life goes not backward nor tarries with yesterday.

You are the bows from which your children as living arrows are sent forth.

The archer sees the mark upon the path of the infinite, and He bends you with His might that His arrows may go swift and far.

Let your bending in the archer’s hand be for gladness;

For even as He loves the arrow that flies, so He loves also the bow that is stable.

In these times, many figurative arrows have already been released from our bow. There’s not much we can do but pray that good arrows go swift and far, learn how to set a better course where our efforts fall short, and take action to keep ourselves healthy and safe. But, with the praying we still must move our feet toward home, to be like a steady archer setting course for our house of tomorrow. I am grateful for this organic movement and hopeful that our clear vision, forward thinking, and better regulatory teeth help us all find our way home.