Managing
NOSB Update: The Long and Winding Road
of Continuous Improvement
By Andrea Caroe
The most recent National Organic
Standards Board (NOSB) gathering in
Washington D.C. covered a wide range of
important topics from commercial availability
guidelines and grower group certification, to
animal welfare and organic aquaculture standards. Many members of the organic community offered their public comment as the
board deliberated and decided on many of
the issues that will affect organic processors
creating products for the U.S. market worldwide.
Certification and Compliance
The Certification Accreditation and
Compliance Committee (CACC) shepherded
some of the most difficult documents to the
meeting. These included a rule change recommendation on standardized certificates,
guidance on commercial availability, and lastly, the highly debated multi-site certification
proposal.
Standardizing certificates. The organic
regulation includes only a few requirements
for the organic certification document, and
thus each certifier uses a their own version.
With 95 accredited certifiers working as
agents of the USDA, it has become increasingly difficult to elicit pertinent information
from these diverse documents. This has
caused difficulty for buyers of these products,
making it more challenging to ensure that
the product they are purchasing is indeed
covered under that certification. Likewise,
the regulation does not require that the certificate even include the standard (EU,
USDA, etc.) in which the product was certified, which can lead to confusion and quality
control issues.
Certifiers testified that they were generally
in favor of a standardized certificate, but cautioned the board against requirements that
would be too restrictive. For these reasons,
the CACC recommended a rule change that
would require that specific relevant information appear on the certificate such as the
name of the standard, brands used to represent the product and products certified. The
board agreed with the recommendation and
the vote passed.
Commercial availability. The National List
205.606 includes non-organic agricultural
materials that are allowed in organic production when an organic form of the product is
not “commercially available.” Although there
are already rules in place for defining commercial availability, many of the real-life
details like “who does what” were never clearly defined. With the recent addition of a significant number of materials to 205.606, it
was imperative that the board establish a set
of guidelines for operators using materials
listed on 606 that clarifies exactly how they
must justify that ingredients are not available
as organic. The CACC’s guidelines, which
were passed by the board, ensure that proper
documentation of commercial availability is
included in a company’s organic system plan,
including test data and detailed results of
efforts to find sources of ingredients. The
guidelines also require documentation of
proactive steps that the operator is taking to
generate the organic form of unavailable
ingredient including: research, funding or
promotion to develop the ingredient in
organic form, incentives or bonuses to crops
in transition to organic, hiring of consultants
to help promote and source organic material,
