**WRITTEN SUBMISSION**

**RESPONSE TO COMMENTS FROM COMMITTEE**

**REGARDING THE PETITION FOR**

**THE NATIONAL ORGANIC PROGRAM**

**[FOR: SALVIA HISPANICA L.]{.mark}**

***[Via Courier and by email]{.underline}***

**March 14, 2007**

**To: Ms. Valerie Frances**

**Executive Director**

**NOSB, National Organic Standards Board**

**USDA-AMS-TMP-NOP**

**Room 4008 -- South Building**

**1400 Independence Avenue, SW**

**Washington, D.C. 20250-0020**

**[Docket \# AMS-TM-07-0032; TM-07-05]{.mark}**

**From: Trudy Brown**

**c/o Salba Nutritional Solutions Inc.**

**51 SW 11^th^ St., #1226**

**Miami, Florida 33130**

**Tel: Toll FREE 1 800 916 6938**

**Contact in Toronto : Trudy Brown**

**Tel: (Daytime) 416.861.2410**

**Email: <trudybrown@salba.info>**

**(Please use Toronto contact)**

**Dear Ms. Frances:**

First and foremost, I wish to extend our sincere thank you for your
helpful direction regarding preparation of our submission, which we very
much appreciated.

Salba Nutritional Solutions would like to expand on some of the
commentary by the Committee as it relates particularly to the following
Questions in certain of the Categories set out in the NOSB Evaluation
Criteria for Substances Added to the National List for **Salvia
hispanica L**. as follows:

**Category 4. Question 1: [Is the comparative description
provided]{.underline} as to why the non-organic form of the
material/substance is necessary for use in organic handling?**

While the high content of Omega-3 in Salvia hispanica L. is the primary
reason we are seeking NOSB status, it is not the only reason. Salvia
hispanica L. is more than just a source of Omega-3; it is also a high
source of protein, fiber, calcium, potassium, antioxidants, and vitamins
and minerals.

Any manufacturer, for example, Salba Smart, who produces snack foods and
flour tortillas, can add 5% Salvia hispanica L. to their product,
thereby vastly improving the nutritional benefit and the overall
nutrient density of that product.

Excerpts from the clinical studies performed by Dr. Vladimir Vuksan,
Professor, Departments of Endocrinology and Nutritional Sciences,
Faculty of Medicine, University of Toronto and Director, Risk Factor
Modification Centre, St. Michael's Hospital, and Chair, National
Nutrition Committee, Canadian Diabetes Association on the benefits that
can be achieved by adding Salvia hispanica L. to a product, which will
be published before the end of 2007, in part states the following:

*"Salvia hispanica L. has a rich nutrient composition compared to most
whole grains currently recommended. Salvia hispanica L. represents the
highest whole food source of omega-3 fatty acids and dietary fiber in
nature. In addition it is an exceptionally rich source of vegetable
protein, calcium, magnesium, iron and antioxidants.*

*All of these nutrients have been implicated in lower Cardiovascular
Disease Risks (CVD), and as they occur naturally in Salvia hispanica L.
we hypothesized that Salvia hispanica L. may reduce CVD risk factors
when added to the diet of individuals with well controlled Type 2
Diabetes."*

\[A copy of the entire published report can be provided upon
completion\].

These findings would apply to the overall population.

> **Category 4: Question 2: Does the current and historical industry
> information, research, or evidence provided explain how or why the
> material/substance cannot be obtained organically in the appropriate
> [form to fulfill an essential function in a system of organic
> handling?]{.underline}**
>
> Salvia hispanica L. is a new crop and needs to be developed in
> "natural" and amenable atmospheric and soil conditions, and as such,
> no suitable area has been located with certified organic soil for
> growing this crop at the moment. Research is ongoing to both locating
> and creating "test plots". These test plots require up to a 5-year
> period to cultivate.
>
> **Category 4: Question 5: (a) Does the industry information provided
> on material/substance non-availability as organic, include (but not
> limited to) the following: Regions of production (including factors
> such as climate and number of regions):**
>
> Salvia hispanica L. requires a minimum number of growing days and
> weather conditions, which are not available in all areas of the world.
> Ongoing research is being conducted on potential new amenable
> geographical locations with appropriate climactic and soil conditions.
>
> **Category 4: Question 5: (b): Number of suppliers and amount
> produced:**
>
> At the present time, we are the primary suppliers of Salvia hispanica
> L. While we cannot address other suppliers, we believe that their
> production is minimal.
>
> **Category 4: Question 5 (c): Current and historical supplies related
> to weather events such as hurricanes, floods and droughts that may
> temporarily halt production or destroy crops or supplies:**
>
> While most of Salvia hispanica L. is presently cultivated in South
> America, and primarily in Peru, other geographical locations are being
> researched. Each location presently being utilized has been assessed
> for projected crop viability and supply. In developing other growing
> areas, "test plots" are required due to the growing cycle of this crop
> and viability of the land and this process takes up to 5 years to
> develop.
>
> **Category 4: Question 5 (d): Trade-related issues, such as evidence
> of hoarding, war, trade barriers, or civil unrest that may temporarily
> restrict supplies;**
>
> Great deliberation, consideration and travel are conducted in each
> region where Salvia hispanica L. is grown. Supply is primarily
> targeted to countries generally recognized with no barriers to entry,
> thus assuring perpetual supply. There are no impediments in the
> country where Salvia hispanica is primarily grown, or the countries
> where it is contemplated to be grown at this time.
>
> **Category 4: Question 5 (e): Are there other issues which may present
> a challenge to a consistent supply?**
>
> Ongoing investigation has been underway to obtain suitable additional
> land for growing because the consumption of Salvia hispanica L.
> world-wide has increased. We are expecting this growth to continue
> over time and are planning and forecasting accordingly. Because Salvia
> hispanica L. is grown under controlled conditions, a more reliable
> crop supply is achieved.