Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday January 13, 2015, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Harold Austin (HA); John Foster (JFo); Jean Richardson (JR); Joe 

Dickson (JD) - Vice Chair; Jennifer Taylor (JT); Lisa de Lima (LD) - sitting in; Tom Chapman (TC) - sitting in

Absent: Wendy Fulwider (WF); Nick Maravell (NM); Mac Stone (MS)

Staff: Emily Brown Rosen (EBR), Michelle Arsenault (MA)

Workplan

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/JFo DD fall 2014 08 28 14 Proposal 

Spr 2015

Future Potential Projects Contact Status Vote Meeting

Peer Review JFo Added to CACS at Fall 2014 

NOSB meeting. Memo from 

NOP sent to HS 11 19 14

01 13 15 Proposal 

Spr 2015

Agenda

• Approve notes of December 9, 2014

• Discuss/vote on final Peer Review proposal (JFo)

• Discuss the DRAFT Soil Conservation Practices Assessment Proposal (CBo)

• Adjourn

Discussion

• The notes from December 9, 2014 were approved with no changes.

• Peer Review Proposal - The draft proposal was circulated prior to the call and the group 

discussed it before proceeding to a vote. The members were very supportive of the document 

overall. Three topics that the group explored further involved: 1) The potential for conflicts of 

interest if current Board members were to sit on the peer review panel; 2) The addition of 

language in support of the findings by the OIG of using an independent third party assessment 

body rather than a FACA panel as the auditor; and 3) The role of the NOSB post-review. 

Motion to accept the Peer Review Proposal as amended

Motion by: JFo

Seconded by: JR

Discussion: No additional discussion except to note that the lead reviewer resent the amended 

version to the members during the call and before they voted.

Yes: 8 No: 0 Abstain: 0 Absent: 1 Recuse: 0 
Members that were absent for the vote will be allowed the opportunity to vote until COB Friday 

Jan 16. ABS note: Two members voted via email and the vote above was changed to reflect 

this.

• Draft Soil Conservation Practices Assessment - The lead noted that the document needs some 

word-smithing, and will edit and recirculate to the members so they can review it and vote on 

next call. 

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule

December 9, 2014 3:00 ET

January 13 - Discuss Soil Conservation Practices Assessment Public Comment Narrative - CBe/TBD

February 10 - Discuss Soil Conservation Practices Assessment Public Comment Narrative/vote (CBe) 

 Complete final documents (2) for submission to NOP

March 10, 2015 3:00 ET

April 14, 2015 3:00 ET

Spring 2015 Milestones Target date

NOSB Training Feb 4-5, 2015

NOP - Complete Spring 2015 NOSB meeting tentative agenda Feb 7, 2015

NOSB - Spring 2015 proposals due to NOP Feb 25, 2015

NOP - Post proposals, Publish FRN, Open public comment Mar 9, 2015

Discuss work agendas on ES call Mar 13, 2015

Public comment closes Apr 6, 2015

Work agendas finalized on ES call (last call before spring mtg) Apr 10, 2015

NOP - Send compiled public comments to NOSB Apr 13, 2015

Spring 2015 NOSB meeting - La Jolla, CA Week of April 27 - 30
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday February 10, 2015, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Lisa de Lima, Vice Chair (LD); Tom Chapman (TC); Jean Richardson 

(JR)

Absent: Nick Maravell (NM); Mac Stone (MS); Jennifer Taylor (JT)

Staff: Emily Brown Rosen (EBR), Michelle Arsenault (MA)

Work Agenda

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/LD NA Proposal

Fall 2015

Peer Review JFo

CBe

Added to CACS at Fall 2014 

NOSB meeting. Memo from 

NOP sent to HS 11 19 14

01 13 15 Proposal 

Spr 2015

Future Potential Projects Contact Status Vote Meeting

Agenda

• Approve notes of January 13, 2015

• Discuss changing name of CACS to include ‘International Equivalency”

• Discuss the possibility of eliminating the “100% organic” category

• Discuss/vote Draft Soil Conservation Practices Assessment Proposal (CBo)

• Adjourn

Discussion

• The notes from January 13, 2015 were approved with no changes.

• Draft Soil Conservation Practices Assessment - Several Board members met with NRCS staff

while in DC last week for training and discussed various ways in which the NOSB, NOP, and NRCS 

overlap and can work more efficiently. Topics included: The NRCS CAP 138 program 

(Conservation Activity Plan) which offers support for farms in transition to organic. The group 

also discussed training and ways to perhaps coordinate resources of the NRCS and NOP.. Based 

on these conversations and input from NOP, the CACS will delay the proposal on Soil 

Conservation Practices Assessment to the fall 2015 meeting in an effort to add more specificity. 

LD will reach out to NRCS to learn more about their available tools. 

• Discuss changing name of CACS to include “International Equivalency” - The NOSB chair 

suggested that the name of the CACS be changed to reflect the fact that the NOSB 
Subcommittees always review and consider materials in light of international activities. 

Members discussed the pros and cons of doing this. The NOP will discuss this further and let the 

CACS know. JR will write an email to the Deputy Administrator proposing the name change.

• Discuss the “100% organic” category - Members discussed the idea of requesting an addition to 

the work agenda about the 100% organic label, to seek public comment. Several members 

indicated that based on feedback from many segments of the organic community, the label 

claim of 100% organic is confusing. One member noted that it is not used outside of the US. The 

NOP added that it was not part of OFPA, but that it was originally added by USDA AMS 

Administrator Merrigan in response to a segment of the community opposed to the inclusion of 

any synthetics in processing. The CACS will develop a request and submit it to the NOP Deputy 

Administrator for consideration as a work agenda item for 2016. 

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule

January 13 - Discuss Soil Conservation Practices Assessment Public Comment Narrative - CBe/TBD

February 10 - Discuss Soil Conservation Practices Assessment Public Comment Narrative/vote (CBe) 

Complete final documents (2) for submission to NOP

March 10, 2015 3:00 ET

Discuss Soil Conservation Practices Assessment Public Comment Narrative

April 14, 2015 3:00 ET

Discuss Public Comment pertaining to the Peer Review & other topics if applicable

May 12, 2015 1:00 ET

June 9, 2015 1:00 ET

July 14, 2015 1:00 ET

August 11, 2015 1:00 ET

September 8, 2015 1:00 ET

October 13, 2015 1:00 ET

November 10, 2015 1:00 ET

December 8, 2015 1:00 ET

Spring 2015 Milestones Target date

NOSB Training Feb 4-5, 2015

NOP - Complete Spring 2015 NOSB meeting tentative agenda Feb 7, 2015

NOSB - Spring 2015 proposals due to NOP Feb 25, 2015

NOP - Post proposals, Publish FRN, Open public comment Mar 9, 2015

Discuss work agendas on ES call Mar 13, 2015

Public comment closes Apr 6, 2015
Work agendas finalized on ES call (last call before spring mtg) Apr 10, 2015

NOP - Send compiled public comments to NOSB Apr 13, 2015

Spring 2015 NOSB meeting - La Jolla, CA Week of April 27 - 30
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday March 10, 2015, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Lisa de Lima, Vice Chair (LD); Jean Richardson (JR); Mac Stone (MS); 

Jennifer Taylor (JT); Tom Chapman (TC)

Absent: Nick Maravell (NM)

Staff: Emily Brown Rosen (EBR), Michelle Arsenault (MA)

Work Agenda

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/LD NA Proposal

Fall 2015

Peer Review JFo

CBe

Added to CACS at Fall 2014 

NOSB meeting. Memo from 

NOP sent to HS 11 19 14

01 13 15 Proposal 

Spr 2015

Future Potential Projects Contact Status Vote Meeting

Agenda

• Approve notes of February 10, 2015

• Discuss Soil Conservation Practices Assessment Public Comment Narrative Adjourn

Discussion

• The notes from February 10, 2015 were approved with no changes

• Soil Conservation Practices Assessment. Members discussed the draft document and made 

various editing and proofreading changes. The CACS received feedback from several 

stakeholders and discussed the incorporation of these comments into the discussion document. 

The lead reviewer will weave these comments into the narrative for review on the next call. One 

member asked about international implications for this document. Another member added that 

there is a need within the Organic System Plan or organic agriculture to address farmworker 

welfare, and she suggested that the NOSB consider issues that improve the organic farm 

environment, soil conservation, biodiversity, animal welfare, and contamination issues.

• The Chair asked about the status of the 100% organic topic that was posed as a possible work 

agenda item. The topic was deferred until the Sunset review is completed. 

• The meeting was adjourned
Previous CACS Notes

Future Call Schedule

February 10 - Discuss Soil Conservation Practices Assessment Public Comment Narrative/vote (CBe) 

Complete final documents (2) for submission to NOP

March 10, 2015 3:00 ET

Discuss Soil Conservation Practices Assessment Public Comment Narrative

April 14, 2015 3:00 ET

Discuss Public Comment pertaining to the Peer Review & other topics if applicable

 Discuss Soil Conservation Practices Assessment

May 12, 2015 1:00 ET

June 9, 2015 1:00 ET

July 14, 2015 1:00 ET

August 11, 2015 1:00 ET

September 8, 2015 1:00 ET

October 13, 2015 1:00 ET

November 10, 2015 1:00 ET

December 8, 2015 1:00 ET

Spring 2015 Milestones Target date

NOSB Training Feb 4-5, 2015

NOP - Complete Spring 2015 NOSB meeting tentative agenda Feb 7, 2015

NOSB - Spring 2015 proposals due to NOP Feb 25, 2015

NOP - Post proposals, Publish FRN, Open public comment Mar 9, 2015

Discuss work agendas on ES call Mar 13, 2015

Public comment closes Apr 6, 2015

Work agendas finalized on ES call (last call before spring mtg) Apr 10, 2015

NOP - Send compiled public comments to NOSB Apr 13, 2015

Spring 2015 NOSB meeting - La Jolla, CA Week of April 27 - 30
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday June 9, 2015, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Lisa de Lima, Vice Chair (LD) Tom Chapman (TC); Jean Richardson 

(JR); Jennifer Taylor (JT)

Absent: Nick Maravell (NM)

Staff: Emily Brown Rosen (EBR), Michelle Arsenault (MA)

Work Agenda

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/LD NA Proposal

Fall 2015

Future Potential Projects Contact Status Vote Meeting

Agenda

• Approve notes of March 10, 2015

• Discuss Soil Conservation Practices Assessment 

Discussion

• The notes from March 10, 2015 were approved as is.

• Soil Conservation Practices Assessment. The lead sent out the newest draft document prior to 

the call and the group discussed several minor changes and modifications. The lead will make 

additional edits and resend the document to the members for review on the next call. NOP 

suggested that the proposal outcome should have clear objectives, and be framed as a request 

for NOP to publish guidance. 

• The CACS would like to invite an NRCS representative to participate on the July 14 call. MA will 

extend the invitation.

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule

May 12, 2015 1:00 ET - cancelled

June 9, 2015 1:00 ET

July 14, 2015 1:00 ET

August 11, 2015 1:00 ET
September 8, 2015 1:00 ET

October 13, 2015 1:00 ET

November 10, 2015 1:00 ET

December 8, 2015 1:00 ET

Fall 2015 Milestones Target date

NOP - Complete Fall 2015 NOSB meeting tentative agenda July 8, 2015

NOSB - Fall 2015 proposals due to NOP Aug 26, 2015

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2015

Discuss work agendas on ES call Sep 11, 2015

Public comment closes Oct 5, 2015

Work agendas finalized on ES call (last call before fall meeting) Oct 8, 2015

NOP - Send compiled public comments to NOSB Oct 13, 2015

Fall 2015 NOSB meeting - Stowe, VT Oct 26 - 29, 2015
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday July 14, 2015, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Lisa de Lima, Vice Chair (LD) Jean Richardson (JR); 

Absent: Tom Chapman (TC); Nick Maravell (NM); Jennifer Taylor (JT)

Staff: Emily Brown Rosen (EBR), Michelle Arsenault (MA)

Work Agenda

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/LD NA Proposal

Fall 2015

Future Potential Projects Contact Status Vote Meeting

Agenda

• Approve notes of June 9, 2015

• Guest speaker: Lindsay Haines NRCS (Discuss Soil Conservation Practices Assessment)

Discussion

• The notes from June 9, 2015 were approved with no changes.

• Soil Conservation Practices Assessment. Guest speaker: Lindsay Haines NRCS. The members 

discussed the purpose and scope of the document and also assessed specific sections and 

language. The members also discussed the fact that there is no definition of soil erosion in the 

organic regulations, while NRCS has metrics for compliant, tolerable, and sustainable soil loss 

levels. 

• The CACS discussed the intent of the document and will bring it forth as a proposal for the fall 

2015 NOSB meeting

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule

June 9, 2015 1:00 ET

July 14, 2015 1:00 ET

Guest speaker: Lindsay Haines NRCS

August 11, 2015 1:00 ET

September 8, 2015 1:00 ET
October 13, 2015 1:00 ET

November 10, 2015 1:00 ET

December 8, 2015 1:00 ET

Fall 2015 Milestones Target date

NOP - Complete Fall 2015 NOSB meeting tentative agenda July 8, 2015

Request for TRs for 2018 sunset materials July 15, 2015

NOSB - Fall 2015 proposals due to NOP Aug 26, 2015

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2015

Discuss work agendas on ES call Sep 11, 2015

Public comment webinars Sep 22 & 29, 2015

Public comment closes Oct 5, 2015

Work agendas finalized on ES call (last call before fall meeting) Oct 8, 2015

NOP - Send compiled public comments to NOSB Oct 13, 2015

Fall 2015 NOSB meeting - Stowe, VT Oct 26 - 29, 2015
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday August 11, 2015, 3:00 pm ET 

Attending: Carmela Beck (CB), Chair; Lisa de Lima, Vice Chair (LD) Jean Richardson (JR); Tom Chapman 

(TC); 

Absent: Nick Maravell (NM); Jennifer Taylor (JT)

Staff: Emily Brown Rosen (EBR), Michelle Arsenault (MA) 

Work Agenda

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/LD NA Verbal Report

Fall 2015? 

Future Potential Projects Contact Status Vote Meeting

Agenda

• Approve notes of July 14, 2015 

• Adjourn

Discussion

• The notes from July 14, 2015 were approved with no changes.

• Soil Conservation Practices Assessment. The group discussed the draft document, and came to 

the consensus that the scope of the question they were tasked with answering is too broad for 

the NOSB to address in any meaningful or useful way. The CACS may present a verbal report, 

instead of a discussion document, at the fall 2015 meeting instead. Members discussed various 

approaches to move forward including seeking more information and guidance from the NOP, 

and contracting a TR on soils to determine what tools are being used to assess soil health. The 

NOP will discuss this and provide some additional input. 

• Wild Farm Alliance document: “Eliminating the Incentive to Convert Native Ecosystems into 

Organic Crop Production”. The members discussed the possibility of adding this project to the 

CACS workplan. (In order to do that they would write a justification as to what the problem is, 

how they would address it, and what the intended outcome is. Then it would have to be 

approved by the NOP). After a lengthy discussion about the scope of the problem, and the 

possible paths and outcomes, the members acknowledged that Conversion of native ecosystems 

into organic crop production is a serious problem, but that it is too large in scope for the CACS or 
NOSB to take up. 

• The CACS will cancel the September 8 meeting

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule

July 14, 2015 1:00 ET

August 11, 2015 3:00 ET

September 8, 2015 3:00 ET 

October 13, 2015 3:00 ET

November 10, 2015 3:00 ET

December 8, 2015 3:00 ET

Fall 2015 Milestones Target date

NOP - Complete Fall 2015 NOSB meeting tentative agenda July 8, 2015

Request for TRs for 2018 sunset materials July 15, 2015

NOSB - Fall 2015 proposals due to NOP Aug 26, 2015

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2015

Discuss work agendas on ES call Sep 11, 2015

Public comment webinars Oct 13 & 20, 2015

Public comment closes Oct 8, 2015

Work agendas finalized on ES call (last call before fall meeting) Oct 9, 2015

NOP - Send compiled public comments to NOSB Oct 13, 2015

Fall 2015 NOSB meeting - Stowe, VT Oct 26 - 29, 2015