At the National Campaign for Sustainable Agriculture meeting earlier today, over a dozen national groups came together to discuss the work of the NOSB, as well as general organic standards-setting issues. The discussion centered around issues of process, and those of content, and include the following recommendations to this Board:

PROCESS ISSUES:
TAP Review
TAP review needs to continue with much more transparency as well as with clear rules regarding public participation. Comments from the public should help inform the Board decisions, and therefore public notice must be given with a reasonable time frame for analysis and comment, with a schedule clearly laid out, and preferably be available on the website. Public notice solely in the Federal Register, while legally sufficient, is not conducive to public comment.

In addition, a signed Conflict of Interest clause must be a part of any review. Reviewers should reveal if they have any interest in a material or a company that manufactures or distributes the material they are reviewing.

NOSB Board process
The NOSB needs to re-establish and clarify its process for drafting recommendations in order to enable clear documentation, and to inform its decision-making process, as well as to encourage continued public participation. A recommendation coming out of a committee should be labeled as a Draft Committee Recommendation, and then labeled as a Board Draft when it has been considered by the entire board and is presented to the public. A clear time-frame for public comment should be laid out so that useful input from the community is presented at the appropriate time (prior to board decisions on a recommendation) and so that expert input from the community is encouraged.

There is a need for NOSB to internally re-establish its protocol for the forwarding of executive committee minutes/notes to the entire board in a timely manner, and then for the release of these minutes to the public.

The Board needs to clarify its intentions with regard to the OTA/AOS. Whether or not the Board intends to make official comments to this document, a declaration of how the Board intends to use the document is important.

NOSB needs to clearly articulate its process for responding to any proposals from the public. A process should be defined detailing a time frame for response to any public proposal: i.e., a delineated time period for a declaration of whether or not it will be addressed by the Board, and if so, at what time (meeting) it will be taken up for discussion.

CONTENT ISSUES:

NOSB Resolutions

1. The NOSB is urged to pass a resolution endorsing the inclusion of language on biodiversity and social/economic equity in USDA Organic Standards.

NOSB Work

1. The NOSB is urged to establish organic principles to be included in the USDA Rule
2. We reiterate our previous request for NOSB to take up the issues of Genetic Drift, and Genetic Engineering. These issues should not be tabled because of their complexity.
3. The NOSB should take up the issue of animal alterations.

NOSB Recommendations to USDA. As the advisory body in the USDA on organic standards, the NOSB has a responsibility to make recommendations to the Department regarding issues housed in other parts of the Department that affect the implementation of the standards.

1. USDA should be encouraged to seek remedies that do not place the burden of proof or liability on organic farmers for GMO drift resolution. Urge USDA to use the "polluter pays" principle.
2. Urge USDA to immediately begin research to track genetically engineered crops and their location to be published on a regular basis for use as a tool for organic certifiers and others wishing to evaluate the potential for genetic drift.
3. Urge USDA to put research dollars into expanding non-GMO seed availability for the organic trade.
4. USDA should establish a simple, cost-effective, cost-share program for organic small farmers to offset the costs of certification, and encourage the participation of more farmers.

Thank you for the opportunity to present these comments,

Michael Sligh
RAFI-USA
P.O. box 4672
Chapel Hill, NC 27515-4672
919-929-7099