MOSA provides our clients with much more than just certification.

Joe Pedretti

MOSA Client Services Director



Stephen Walker, MOSA Operations Manager

Over recent months, we’re doing a lot of thinking about MOSA’s organizational mission, vision, and values. In strategic planning work, we realized that while we had a solid mission statement - “We promote organic integrity through practical, reliable, and friendly certification services” - and had solid values expressed in our daily work, we’d never formally named our values. So, we brought the discussion to our full staff, which brainstormed a list of over 100 values words. We then drilled down to common themes, and defined our vision, our ideal state future state, which articulates what MOSA is trying to accomplish. That vision is “a thriving organic world.” And, we named our values, four basic principles by which we operate:

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.

Since our start in 1999, MOSA has always been a valued voice in local and national discussion about the development and direction of our National Organic Standards. Our organizational vision and values, even unnamed, have been put to the test over many years. That continues. Lately, many news articles - some very hopeful, some critical - have us rethinking how organic should best continue to thrive. In 2016, organic sales in the US were about 47 billion dollars. Our movement has grown into an economic engine. We understand organic’s ability to give life, to help solve global crises. Yet in our maturation, we face new, competing challenges in enforcement, adaptability, defining boundaries, and retaining our principles. We value innovative spirit even as we are connected to an agricultural history dating back thousands of years. We recognize that organic integrity and success depends on a strong National Organic Program. The Program improves, but struggles to keep pace with development of the industry. (More on that, in a bit.) Some of the debates in our community are perennial, such as, “Is increasing market share for organic better?” Or, “Where should we draw lines?” The most viable answers find a sound balance between reason - regulations, statistics, logical arguments, etc. - and the deep passions on both sides of a debate. Organic conversation embodies being alive.

Each spring and fall, we provide written and verbal feedback to the National Organic Standards Board (and, we encourage you to join in). I’ll be representing MOSA with testimony at the NOSB meeting in Jacksonville, FL, 10/31 to 11/2/2017. These meetings may be the best place to witness organic grow, and to consider our reason and passion. A full 177 pages of Fall NOSB meeting proposals and discussion documents can be found on the USDA website It’s an interesting agenda. Here’s some of what’s growing:

Proposal: Eliminating the Incentive to Convert Native Ecosystems to Organic Production - This aims to strengthen the General Organic Production and Handling Requirements. Standards §205.200 requires operations to “maintain or improve the natural resources of the operation, including soil and water quality.” Our standards define “natural resources of the operation” as the “physical, hydrological, and biological features of a production operation, including soil, water, wetlands, woodlands, and wildlife.” “Organic production” is a “system managed to respond to site-specific conditions by integrating cultural, biological and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” As we think holistically and globally, we have new perspective on the interface between organic operations and the resources that surround them. It’s proposed to add a specific prohibition (at §205.200) so organic operations don’t convert fragile, important native ecosystems for crops or livestock use.

Proposal: Excluded operations in the supply chain - This defines limits for uncertified organic product handlers. The NOSB recommends the National Organic Program changes their guidance (NOP 5031): to clarify that exemption from required certification only applies to packaged, labeled product; unlabeled, unenclosed produce handlers in a non-retail environment must be certified; to provide additional examples to show when certification is required; to provide additional supply chain auditing training; and to assess our auditing as a part of certifiers’ accreditation.

Proposal: Strengthening the Organic Seed Guidance - We’ve weighed in on this one, a lot. This proposal affirms that “seed is much more than just an input. It is the fundamental starting point for transforming agriculture through nutritious ecologically grown food, feed and fiber, especially when coupled with the principles behind organic production of building healthy soils, using non-toxic inputs, and stewarding natural resources and the environment.” The proposal also acknowledges frustration at slow progress towards full adoption of organically grown seed. Many changes are proposed to §205.204 (Seeds and planting stock practice standard) and to NOP 5029 Guidance on Seeds, Annual Seedlings, and Planting Stock in Organic Crop Production. Improvements address: crops at risk from GMO contamination; organic seed usage as an Organic System Plan “goal;” continuous improvement; documentation of quality, quantity and equivalent variety; handlers supplying seed to contract growers; an Organic Seed Finder; and certifier and inspector training.

Proposal: Hydroponics and Container Growing Recommendations - We’ve discussed this issue at length. Suffice it to say, it’s brought our values to the test, with debate about soil as intrinsic to organic production, alternative production systems, food security and conservation issues. The proposal is to prohibit hydroponic, aeroponic and aquaponic systems from using the organic label, and says that for container production to be certified organic, a limit of 20% of the plants’ nitrogen requirement can be supplied by liquid feeding, and a limit of 50% of the plants’ nitrogen requirement can be added to the container after the crop has been planted. For perennials, the nitrogen feeding limit is calculated annually. Transplants, ornamentals, herbs, sprouts, fodder, and aquatic plants are exempt. Related, a Field and Greenhouse Container Production document asks for feedback on artificial light, synthetic mulches, and disposition of by-products of container operations.

Livestock inputs - A clarification on “emergency” for use of synthetic parasiticides in organic livestock production offers language for addition to §205.238(c)(4), outlining a graduated emergency treatment approval process. A number of materials due for sunset review are proposed to be re-listed as allowed for organic use, but, oxytocin is proposed to be removed, and the future of procaine is uncertain. Sulfur is proposed to be added as a livestock parasiticide.

Participation in NOSB discussions forces us to check our values, define our boundaries, and sometime to also see our weaknesses, as we hear the perspective of others. The hydroponic debate is a great example. Some stakeholders are speaking with passion about a need for organic to look toward future food security needs, to adapt to enable water-based systems into our Standards. Others are adamant that organic, by definition and principle, must be based in the soil. Others are open to allowance of hydroponic systems, but would first require specific applicable standards. Though there’s passion backing all perspectives, folks seem to understand the reasoning of those with a different view. It’s good democracy.

So, let’s get back to that comment about our Standards keeping pace with changes. Sometimes we move too quickly into new territory; other times we’re too slow to adapt. Standards development is a very deliberative and transparent process. It takes time. And sometimes that pace causes strife and harm to our label, such as when the NOP is too slow to adopt NOSB recommendations, or when innovation gets ahead of our ability to reasonably regulate it. Examples include hydroponics, organic livestock and poultry practices (OLPP) rule implementation, and defining boundaries around new GMO technology. Maturation can be bumpy, but we continuously improve.

Sometimes we release a policy, and the target moves. This happened over the summer. In July, we announced our Import Grain Policy, to prevent fraudulent organic imports. With new NOP instruction, we’ve revised that Policy. It now applies to MOSA-certified operations that directly receive imported organic corn, soy, edible dry beans, wheat, flax, or sunflower meal from Kazakhstan, Moldova, Romania, Russia, Turkey, and Ukraine. We require full traceability back to the last certifier in the supply chain, sample and residue testing for each shipment, unannounced inspections, and reporting requirements. The revised policy is available on our website.

And there are those who, though they may want the best for the organic label, have a passion that outpaces the Standards’ reason. So, they push for requirements that are - dare I say - “beyond organic.” That term bothers me, even when I can relate to the passion. A piece of balance I like about our organic regulatory process is that while we set achievable, sound requirements, our underlying values and passion pull us along to want to do better. Going beyond the standards is encouraged, but not by disowning organic.

My personal organic principles were tested as I attended Natural Products Expo East, in Baltimore, in September. One afternoon I came across a big hullabaloo that pulled at my heartstrings but pushed my NOP Organic certifier buttons. A crowd gathered to hear about a new Regenerative Organic Certified Standard put forth by the Rodale Institute. This standard starts with NOP organic, and additionally reels in animal welfare, social fairness, and additional regenerative requirements, which increase soil organic matter over time and sequester carbon in the soil. While I’d heard a Regenerative definition was in development, I was surprised by how far it had come along, and I found my passion at odds with my reason. On one hand, since coming into organic work over 25 years ago, I’ve been most driven by carbon cycles and soil building as a solution to global urgencies. I agreed with something John Jeavons said in his keynote talk at the MOSES Organic Farming Conference a few years ago, “Organic is a step in the right direction, but we gotta keep on walking.” On the other hand, I’m wary of more label confusion, and I mostly see our NOP Organic Standards’ “maintain or improve” language as sufficient. In a recent post to the Accredited Certifiers Association, I wrote, “Perhaps §205.200 and 205.205 are sufficient regulatory tools to enforce meaningful impact on natural resource conservation and improvement, atmospheric carbon, regeneration of soil, and so on. But, maybe not, and some folks are seeking something more impactful. I’d like to see us all do better, somehow, and hope that NOP Organic can be a viable solution. I assume that such progress will take a combination of enforcement with a hammer, and a qualitative/ethical appeal more like a carrot.”

MOSA’s Sara Tedeschi gave some perspective from her previous work with a big organic company, and acknowledged her own mixed feelings. “They were pretty down on ‘additional labels’ and felt strongly that we all need to pull together (with consumers, too) to make the National Organic Standards what we really want them to be and live up to the original vision as much as possible (with continual improvement). But that was some years ago and given the stutter steps with the LPP rule and the fact that the NOP is not agile enough to respond to mounting concerns, I wonder if they are more in support of these ‘beyond organic’ certification and labeling efforts? I am on the fence. Like you, I think the (re-)focus on soil health, social justice and animal welfare issues is so critical (more publicity the better, in some ways), but have grave concerns about circumventing the NOP and dis-empowering the USDA Seal. Consumers are fickle and distrust and disillusionment (whether real or perceived) is dangerous and can take a lot of re-education, resources and time to get the story straight.”

The maturing of organic has always been about comparing current standards with new ideas, and seeking to do better. Recently, my reason and passion are both inspired by the many new writings about carbon sequestration and organic methods as a solution to climate change. This is right in line with MOSA’s value of optimism. Using “Arlo Guthrie’s Alice’s Restaurant measure,” if we find that more than three people are talking about something, it’s a movement. How about we call this “the optimism movement?”

Parts of this optimism movement came to attention at Expo East in 2016, where Paul Hawken spoke on climate change solutions. Hawken helped to initiate Project Drawdown, a climate change mitigation project. To support the Project, he edited the 2017 New York Times bestseller, Drawdown: The most comprehensive plan ever proposed to reverse global warming. The book lists the “100 most substantive solutions to global warming.” The list, encompassing only technologically viable, existing solutions, was compiled by a team of over 200 scholars, scientists, policymakers, business leaders and activists. For each solution they modelled and measured the carbon impact through the year 2050, the total and net cost to society, and the total lifetime savings. Of the 100 solutions, eight are agricultural, including regenerative practices.

Also in September, we saw release of new optimistic research on organic solutions to climate change. Northeastern University and The Organic Center released a breakthrough study providing significant proof that organic agricultural practices build healthy soils and sequester carbon. Doctors Elham Ghabbour and Geoffrey Davies, from the National Soil Project at Northeastern University, compared 659 organic soil samples from 39 states and 728 conventional soil samples from the 48 contiguous states. They found that ALL components of humic substances - comprised mostly of very stable, carbon-storing fulvic and humic acid - were higher in organic soils. On average, soils from organic farms had 13% higher soil organic matter, 150% more fulvic acid, 44% more humic acid and 26% greater potential for long-term carbon storage.

In another recent article, in (Can American Soil be Brought Back To Life), Jenny Hopkinson calls it a soil health movement. By whatever name, it’s not new information. It’s a movement born from our values. What’s new is how this sensibility is gaining traction.

In a recent MOSA budget discussion, we noted how financial efficiency is directly related to compliance with our standards. I considered ways we might help boost enthusiasm - heartfelt passion - for compliance. We have a very sound and improving organic standard, and we have deep organic principles that continue to inspire. As we mature, we are driven not so much by being told what to do, but rather by being pulled by what is right, by what works. Organic is already a gold standard, and it pulls us forward. I hope that your values call you to always do better.

In The Prophet, Kahlil Gibran put it well:

“Your reason and your passion are the rudder and the sails of your seafaring soul. If either your sails or your rudder be broken, you can but toss and drift, or else be held at a standstill in mid-seas. For reason, ruling alone, is a force confining; and passion, unattended, is a flame that burns to its own destruction.

Therefore let your soul exalt your reason to the height of passion, that it may sing;

And let it direct your passion with reason, that your passion may live through its own daily resurrection, and like the phoenix rise above its own ashes.”

A thriving organic world must have balance, indeed.