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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, December 12, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Allison Johnson (AJ), Vice Chair; Carolyn Dimitri (CD); 

Nate Powell-Palm (NPP); Kyla Smith (KS); Nate Lewis (NL); Mindee Jefferey (MJ) - observer 

Absent: Jerry D’Amore (JD); Kim Huseman (KH) 

Staff: Michelle Arsenault (MA); Jared Clark (JC); Heather Kumar (HK); Esu Obu (EO) 

Agenda 

• Guest speaker: Lindsay Haines, NRCS. Transition to organic 

• Review December 5, 2023 notes 

• Improving Support for Organic Transition (AJ) - discuss draft 

• Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss draft 

• Additional Items 

• Adjourn 

Discussion 

• Guest speaker: Lindsay Haines, USDA Natural Resources Conservation Service (NRCS). Transition to 

Organic. The Subcommittee welcomed Lindsay Haines, and relayed background about the NOSB and 

NOP relationship, and the Board’s role in the transition to organic. Lindsay discussed the role of NRCS 

in relation to the TOPP project, as well as successes, and challenges. Successes include such things as 

training and outreach, and working with certifiers. Challenges include NRCS staff members’ lack of 

experience and knowledge about organic production, resistance to standards, lack of criteria (different 

than NRCSs), and decentralization of the organization. The NRCS is looking to broaden its collaboration 

network with certifiers farmers. The Organic Transition Initiative (OTI) is a priority for NRCS through 

2027, and Lindsay highlighted a funding opportunity that they managed to post as a National deadline 

of March 1 (rather than regional or state-level deadlines, which may be different and adds confusion). 

Lindsay also presented a list of needs and opportunities: more technical service providers (TSPs), 

assistance with communicating opportunities for funding (OTI, EQIP, AMS, CSP), training 

https://conservationwebinars.net/, OLPS rule, internal training for NRCS staff, coordination with TOPP. 

She emphasized that NRCS doesn’t want to conflict with TOPP mentors who are already funded to 

provide guidance. Members asked follow-up questions and the group ended with a discussion about 

ways to improve communication and outreach. Lindsay also noted that if folks are seeking information, 

it’s best to start at their local office, and if they can’t answer your questions, to elevate it to regional 

and then state, if needed. 

• December 5, 2023 notes were approved as written. 

• Improving Support for Organic Transition (AJ). The lead summarized the draft proposal, and asked for 

feedback. Members were supportive of the document and shared suggestions for minor edits. The 

lead will edit and reshare for the February 6 call. 

• Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH). Deferred to later call. 

• Additional Items. Market development. The CACS is seeking NOP approval to add this topic to the 

work agenda. 

• The meeting was adjourned. 
 

 

 

 

 

 

 

 

 

 

 

 

 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted). 

December 5, 2023 

December 12, 2023 

Possible Guest Speaker (NRCS) - Transition to organic 

Improving Support for Organic Transition (AJ) - discuss draft 

Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss draft 

January 9, 2024 

Climate Induced Farming Risk and Crop Insurance (CD) - discuss draft 

Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss draft 

January 23, 2024 

Possible Guest Speaker (OFA) - racial equity/transition 

Market Development discussion document (CD) - discuss draft 

February 6, 2024 

Climate Induced Farming Risk and Crop Insurance (CD) - discuss/vote 

Improving Support for Organic Transition (AJ) - discuss/vote 

Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss/vote 

Market Development discussion document (CD) - discuss/vote 

February 13, 2024 

March 5, 2024

 Possible speaker 

March 12, 2024 

April 2, 2024 

April 9, 2024 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion

and/or vote.

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

Residue Testing for a 

Global Supply Chain 

ADB/NPP/NL/KH Proposal Approved by Exec 

Cmmte/NOP 4.17.23 

11.14.23 

1.9.24 

2.6.24 

Spr 2024 

Organic and ClimateSmart Agriculture: 

Climate Induced Farming 

Risk and Crop Insurance 

CD Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

1.09.24 

2.6.24 

Spr 2024 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Proposal 07.31.20 NOP Memo 

to CACS. Proposal 

passed at April 2021 

NOSB meeting. Will 

remain an active 

agenda item for 

future work 

12.12.23 

2.6.24 

Spr 2024 
 

 

 

Milestones 

Spring 2024 Milestones Target dates (tentative) Weeks PTM 

(prior to meeting) 

NOP - Publish FRN, Open public comment ~Nov 17, 2023 16 - 20 

NOP - Draft Spring 2024 NOSB meeting tentative agenda Feb 9, 2024 ~ 10 

NOSB - Spring 2024 proposals due to NOP Feb 15, 2024 ~ 9 

NOP - Post proposals Mar 5, 2024 7.5 

Public comment closes Apr 3, 2024 3.5 

NOP - Send compiled public comments to NOSB Apr 5, 2024 3 

Public comment webinars Apr 23 & 25, 2024 1 

Spring 2024 NOSB meeting - Milwaukee, WI Apr 29 - May 1, 2024 0 

Final recommendations due May 29, 2024 30 days post 

meeting 
 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, December 5, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Allison Johnson (AJ), Vice Chair; Jerry D’Amore (JD); Carolyn Dimitri (CD); 

Kim Huseman (KH); Nate Powell-Palm (NPP); Kyla Smith (KS) 

Absent: Nate Lewis (NL) 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM); Heather Kumar (HK); Esu Obu (EO) 

Agenda 

• Review November 14, 2023 notes 

• Review schedule 

• Discuss any proposal updates 

• Finalize SC Guest Speaker List 

• Additional Items 

• Adjourn 

Discussion 

• November 14, 2023 notes were accepted as written. 

• Review schedule. The market development work agenda item was approved during the November 21 

Executive call. The CACS Chair will update the document, recirculate it to CACS members, then submit 

it to NOP for approval. 

• Proposal updates. Not discussed. 

• Finalize SC Guest Speaker List. The CACS discussed ideas for speakers to invite to future CACS calls 

pertaining to various topics on its work agenda, such as crop insurance, residue testing, and transition 

to organic. Members exchanged ideas for speakers from various sectors of the organic community 

including USDA (maybe the testing lab or ERS), NRCS (transition to organic experts), and the Organic 

Farmers Association (OFA) (racial equity/TOPP). The group also expressed an interest in re-inviting Jon 

Veley from NOP as he has expertise with customs and border protection. To start, AJ will reach out to 

NRCS and confirm availability for the January 9 call, then NOP will send an invitation. 

• Additional Items. 

o The group discussed an NRCS announcement about organic transition that seems to have gone 

unnoticed, and the NOSB Chair mentioned a working group looking at “shared resources for 

government entities, and the group discussed a clearing house/one-stop-shop/website to 

house this type of information, and how helpful that would be. 

o A member relayed an issue regarding bills-of-lading and liability for farmers. Members offered 

advice and suggestions, and one member pointed to § 205.103 for recordkeeping and audit 

trail requirements. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted). 

November 14, 2023 

o Testing – discussion 
 

 

 

 

 

 

 

 

 

 

 

 

December 5, 2023 

December 12, 2023 

Improving Support for Organic Transition (AJ) - discuss draft 

Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss draft 

January 9, 2024 

Possible Guest Speaker (NRCS) - Transition to organic 

Climate Induced Farming Risk and Crop Insurance (CD) - discuss draft 

Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss draft 

January 23, 2024 

Possible Guest Speaker (OFA) - racial equity/transition 

Market Development discussion document (CD) - discuss draft 

February 6, 2024 

Climate Induced Farming Risk and Crop Insurance (CD) - discuss/vote 

Improving Support for Organic Transition (AJ) - discuss/vote 

Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss/vote 

Market Development discussion document (CD) - discuss/vote 

February 13, 2024 

March 5, 2024

 Possible speaker 

March 12, 2024 

April 2, 2024 

April 9, 2024 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

Residue Testing for a 

Global Supply Chain 

ADB/NPP/NL/KH Proposal Approved by Exec 

Cmmte/NOP 4.17.23 

11.14.23 

12.12.23 

1.09.24 

2.06.24 

Spr 2024 

Organic and ClimateSmart Agriculture: 

Climate Induced Farming 

Risk and Crop Insurance 

CD Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

1.09.24 

2.6.24 

Spr 2024 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Proposal 07.31.20 NOP Memo 

to CACS. Proposal 

passed at April 2021 

NOSB meeting. Will 

remain an active 

agenda item for 

future work 

12.12.23 

2.6.24 

Spr 2024 

Market Development. CD Discussion Doc Approved by Exec 

Cmmte 11.21.23. 

Pending NOP approval 

1.23.24 

2.6.24 

Spr 2024 
 

 

 

Milestones 

Spring 2024 Milestones Target dates (tentative) Weeks PTM 

(prior to meeting) 

NOP - Publish FRN, Open public comment ~Nov 17, 2023 16 - 20 

NOP - Draft Spring 2024 NOSB meeting tentative agenda Feb 9, 2024 ~ 10 

NOSB - Spring 2024 proposals due to NOP Feb 15, 2024 ~ 9 

NOP - Post proposals Mar 5, 2024 7.5 

Public comment closes Apr 3, 2024 3.5 

NOP - Send compiled public comments to NOSB Apr 5, 2024 3 

Public comment webinars Apr 23 & 25, 2024 1 

Spring 2024 NOSB meeting - Milwaukee, WI Apr 29 - May 1, 2024 0 

Final recommendations due May 29, 2024 30 days post 

meeting 
 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, November 14, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Allison Johnson (AJ), Vice Chair; Jerry D’Amore (JD); Carolyn Dimitri (CD); 

Kim Huseman (KH); Nate Powell-Palm (NPP); Kyla Smith (KS) 

Absent: Nate Lewis (NL) 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM); Heather Kumar (HK); Esu Obu (EO) 

Agenda 

• Review November 14, 2023 notes 

• Review schedule 

• Discuss any proposal updates 

• Finalize SC Guest Speaker List 

• Additional Items 

• Adjourn 

Discussion 

• November 14, 2023 notes were accepted as written. 

• Review schedule. The market development work agenda item was approved during the November 21 

Executive call. The CACS Chair will update the document, recirculate it to CACS members, then submit 

it to NOP for approval. 

• Proposal updates. Not discussed. 

• Finalize SC Guest Speaker List. The CACS discussed ideas for speakers to invite to future CACS calls 

pertaining to various topics on its work agenda, such as crop insurance, residue testing, and transition 

to organic. Members exchanged ideas for speakers from various sectors of the organic community 

including USDA (maybe the testing lab or ERS), NRCS (transition to organic experts), and the Organic 

Farmers Association (OFA) (racial equity/TOPP). The group also expressed an interest in re-inviting Jon 

Veley from NOP as he has expertise with customs and border protection. To start, AJ will reach out to 

NRCS and confirm availability for the January 9 call, then NOP will send an invitation. 

• Additional Items. 

o The group discussed an NRCS announcement about organic transition that seems to have gone 

unnoticed, and the NOSB Chair mentioned a working group looking at “shared resources for 

government entities, and the group discussed a clearing house/one-stop-shop/website to 

house this type of information, and how helpful that would be. 

o A member relayed an issue regarding bills-of-lading and liability for farmers. Members offered 

advice and suggestions, and one member pointed to § 205.103 for recordkeeping and audit 

trail requirements. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted). 

November 14, 2023 

o Testing – discussion 
 

 

 

 

 

 

 

 

 

 

 

 

December 5, 2023 

December 12, 2023 

Improving Support for Organic Transition (AJ) - discuss draft 

Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss draft 

January 9, 2024 

Possible Guest Speaker (NRCS) - Transition to organic 

Climate Induced Farming Risk and Crop Insurance (CD) - discuss draft 

Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss draft 

January 23, 2024 

Possible Guest Speaker (OFA) - racial equity/transition 

Market Development discussion document (CD) - discuss draft 

February 6, 2024 

Climate Induced Farming Risk and Crop Insurance (CD) - discuss/vote 

Improving Support for Organic Transition (AJ) - discuss/vote 

Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH) - discuss/vote 

Market Development discussion document (CD) - discuss/vote 

February 13, 2024 

March 5, 2024

 Possible speaker 

March 12, 2024 

April 2, 2024 

April 9, 2024 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

Residue Testing for a 

Global Supply Chain 

ADB/NPP/NL/KH Proposal Approved by Exec 

Cmmte/NOP 4.17.23 

11.14.23 

12.12.23 

1.09.24 

2.06.24 

Spr 2024 

Organic and ClimateSmart Agriculture: 

Climate Induced Farming 

Risk and Crop Insurance 

CD Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

1.09.24 

2.6.24 

Spr 2024 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Proposal 07.31.20 NOP Memo 

to CACS. Proposal 

passed at April 2021 

NOSB meeting. Will 

remain an active 

agenda item for 

future work 

12.12.23 

2.6.24 

Spr 2024 

Market Development. CD Discussion Doc Approved by Exec 

Cmmte 11.21.23. 

Pending NOP approval 

1.23.24 

2.6.24 

Spr 2024 
 

 

 

 

Milestones 

Spring 2024 Milestones Target dates (tentative) Weeks PTM 

(prior to meeting) 

NOP - Publish FRN, Open public comment ~Nov 17, 2023 16 - 20 

NOP - Draft Spring 2024 NOSB meeting tentative agenda Feb 9, 2024 ~ 10 

NOSB - Spring 2024 proposals due to NOP Feb 15, 2024 ~ 9 

NOP - Post proposals Mar 5, 2024 7.5 

Public comment closes Apr 3, 2024 3.5 

NOP - Send compiled public comments to NOSB Apr 5, 2024 3 

Public comment webinars Apr 23 & 25, 2024 1 

Spring 2024 NOSB meeting - Milwaukee, WI Apr 29 - May 1, 2024 0 

Final recommendations due May 29, 2024 30 days post 

meeting 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, November 7, 2023 4:00 pm ET 

Present: Amy Bruch (ADB), Chair; Allison Johnson (AJ), Vice Chair; Kyla Smith (KS); Kim Huseman (KH); Carolyn 

Dimitri (CD) 

Absent: Nate Powell-Palm (NPP); Nate Lewis (NL); Michelle Arsenault (MA); Heather Kumar (HK); Esu Obu (EO) 

Staff: Jo Mirenda (JM) 

Agenda 

• Review October 10, 2023 notes 

• Fall NOSB meeting debrief 

• Finalize Work Agenda 

• Schedule work agenda items for the semester 

• Reminder: Cover Sheet for Geo Proposal - due 11.22 - attached 

• Review roster for upcoming Semester 

• Additional Items 

• Adjourn 

Discussion 

• October 10, 2023 notes were accepted as written. 

• Fall NOSB meeting debrief – CACS topics generated a lot of public comments and robust conversation at 

the meeting. 

o Crop Insurance: The presentation by Francie Tolle (USDA Risk Management Agency) was 

especially valuable. Members appreciated Francie’s time, expertise, and willingness to partner 

on solutions for the organic farming community. 

o Transition Support: Members were impressed by the volume and quality of public comments on 

transition. The TOPP presentations at the meeting were also impressive. There is a lot of positive 

work happening, and the Board needs to parse out where to be constructive. It is important to 

think about transition with a systems-based approach, to ensure that all steps of the supply 

chain are engaged, which includes market development and consumer demand. It is also 

important to think about different mechanisms for proving support; government programs are 

helpful, but industry solutions must also come in to play. The group discussed issues of 

profitability for farmers; prices need to reflect actual cost of organic production if farmers are 

expected to transition and stay in organic production. 

• Finalize Work Agenda – CACS will work on 3 proposals for the spring 2024 Meeting: Crop Insurance; 

Residue Testing; Transition Support. Work Agenda Table (below) is updated to reflect the plan. 

• Schedule work agenda items for the semester – Future call schedule (below) is updated to reflect the 

plan. 

• Cover Sheet for Geo Proposal is due November 22 – ADB is working on it. 

• Review roster for upcoming Semester 

• Additional Items 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted). 

October 10, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

November 7, 2023 

November 14, 2023 

o Testing – discussion 

December 5, 2023 

December 12, 2023 

o Transition – draft 

o Testing – discussion 

January 2, 2024 

January 9, 2024 

o Crop Insurance – draft 

o Testing – draft 

February 6, 2024 

o Crop Insurance – final 

o Transition – final 

o Testing – final 

February 13, 2024 

March 5, 2024 

March 12, 2024 

April 2, 2024 

April 9, 2024 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements ADB/NPP/NL/KH Proposal Approved by Exec 11.14 Spr 2024 

to deter fraud: Cmmte/NOP 4.17.23 12.12 

Residue Testing for a 1.09 

Global Supply Chain 2.06 

Organic and Climate- CD Proposal Approved by Exec 1.09 Spr 2024 

Smart Agriculture: Cmmte/NOP 1.18.22. 2.06 

Climate Induced Farming Memo sent to CACS 

Risk and Crop Insurance 02.23.22 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Proposal 07.31.20 NOP Memo 

to CACS. Proposal 

passed at April 2021 

NOSB meeting. Will 

remain an active 

12.12 

2.06 

Spr 2024 

agenda item for 

future work 

Milestones 

Spring 2024 Milestones Target dates (tentative) Weeks PTM 

(prior to meeting) 

NOP - Publish FRN, Open public comment ~Nov 17, 2023 16 -20 

NOP - Draft Spring 2024 NOSB meeting tentative agenda Feb 9, 2024 ~ 10 

NOSB - Spring 2024 proposals due to NOP Feb 15, 2024 ~ 9 
 

NOP - Post proposals Mar 5, 2024 7.5 

Public comment closes Apr 3, 2024 3.5 

NOP - Send compiled public comments to NOSB Apr 5, 2024 3 

Public comment webinars Apr 23 & 25, 2024 1 

Spring 2024 NOSB meeting - Milwaukee, WI Apr 29 - May 1, 2024 0 

Final recommendations due May 29, 2024 30 days post 

meeting 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, October 10, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Carolyn Dimitri (CD); Allison 

Johnson (AJ); Jerry D’Amore (JD); Logan Petrey (LP); Mindee Jeffery (MJ) - observer 

Absent: Nate Powell-Palm (NPP); Nate Lewis (NL) 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM); Heather Kumar (HK); Esu Obu (EO) 

Agenda 

• Review October 3, 2023 notes 

• Review public comments 

• Finalize crop insurance questions 

• Additional Items 

• Adjourn 

Discussion 

• October 3, 2023 notes were accepted as written. 

• Review public comments. Members briefly discussed written comments, as well as the oral comment 

webinars. The Chair was encouraged because there was increased participation from people who are 

new to the process, including more farmers. The group discussed oral and written comments, which are 

intended to inform the Board about topics that are on the agenda, although stakeholders are free to 

comment on any topics they want. The Chair added that commenters view the Board as their voice, and 

the vehicle to get their opinions and ideas to the government. The CACS discussed process and best 

practices for the oral comment webinars. The CACS received written comments on the Organic 

Transition Initiative, and indicated that it’s a great program and they are happy to help promote it. 

• Finalize crop insurance questions. The CACS reviewed the questions for Fancie Tolle, from the USDA 

Risk Management Agency (RMA), which they will forward to her this week in preparation for her 

presentation at the Fall 2023 NOSB meeting. 

• Additional Items. 

o Members discussed the conversation that was started during the Materials Subcommittee about 

the distinction between handling and post-harvest handling. 

o Residue testing. The group discussed the comments that referenced current guidance, which 

has not been updated in some time. The group asked about the 2019 NOSB recommendations 

on Genetic Integrity Transparency, and why it was not implemented. It is listed as “on hold” and 

it’s likely that there were no thresholds or tolerances by which to measure. 

o Members discussed timing for presentations of each of its four topics. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 
 

 

 

 

 

 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

Minimum Reporting 

Requirements 

ADB/NPP HOLD 08.10.17 NOP Memo to 

CACS 

8.1.23 TBD 

Oversight improvements 

to deter fraud: 

Consistent Location 

Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 

8.1.23 

8.8.23 

Fall 2023 

Oversight improvements 

to deter fraud: 

Residue Testing for a 

Global Supply Chain 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 

8.1.23 

8.8.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.27.23 

7.11.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.6.23 

7.11.23 

8.1.23 

8.8.23 

Spr 2024 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed 

at April 2021 NOSB 

meeting. Will remain 

an active agenda item 

for future work 

6.27.23 

7.11.23 

Fall 2023 

Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment Jun 8, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 
Fall 2023 NOSB meeting 

- Providence, RI Oct 24 -26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, October 3, 2023 4:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kim Huseman (KH); Nate Powell-Palm (NPP); Nate Lewis (NL); Carolyn Dimitri 

(CD); Allison Johnson (AJ); Jerry D’Amore (JD); Kyla Smith (KS), Vice Chair 

Absent: Logan Petrey (LP) 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM); Heather Kumar (HK); Esu Obu (EO) 

Agenda 

• Review September 12, 2023 notes 

• Discuss public comments (All) 

• SOE town hall (KS) 

• Potential work agenda item - Weed Management (NL) 

• Additional Items 

• Adjourn 

Discussion 

• September 12, 2023 notes were accepted with minor revisions. 

• New support staff. The CACS welcomed the newest NOSB technical support staff member. 

• Discuss public comments (All). The CACS reviewed the Fall meeting agenda and briefly discussed timing 

for discussions. A member asked about the process for the discussion documents and whether they will 

end up as proposals for the next meeting. It’s possible and depends on public feedback and Board 

discussion. 

• Guest speaker. The CACS discussed questions for Francie Tolle, (USDA Risk Management Agency) who 

was invited to speak at the fall meeting on the topic of crop insurance. Members suggested questions 

ranging from general thoughts about the discussion document, to price and yield data needs, to the 

relationship between RMA, NOP, and other agencies. A member added that there may be conflict 

between the organic regulations and what RMA considers good farming practices, and maybe there is 

room to discuss Organic System Plans (OSPs) and how to incorporate that into RMA guidance. A 

member mentioned draft Senate Bill 98, the Agriculture Advancement Act, for which data collection has 

occurred, and suggested working with other groups who may have data-collection-best-practices. 

• SOE town hall (KS). A member reported on an SOE town hall meeting that she was participating in. 

There were seven producers in attendance, and they asked good questions on a range of topics. In the 

farming community, the non-retail container labeling requirement is the part of SOE where farmers 

have the most questions. . The town hall also focused on recordkeeping for mass balance and traceback 

audits. 

• Weed Management (NL). The Crops Subcommittee discussed the BBMF work agenda request earlier 

today and has chosen to not revisit the topic at this time. The Subcommittee Chair will send a response 

to the NOP soon. Given that decision, the CACS will not pursue the weed management topic at this time, 

as they want to work on those topics in tandem. They may revisit this at a later date if it can be recoupled with BBMF as part of the BBMF sunset review or annotation change process. The group also 

talked about innovation, and the idea of solutions outside of BBMF. 

• Additional Items. 

o Handling standards. The group will continue exploring the possibility of a new work agenda 

items related to handling standards after members finish taking the Organic Integrity Learning 

Center (OILC) training on “Keeping It Organic”. A member suggested that this work agenda topic 

could also address post-harvest handling standards or guidance, to help improve consistency for 
 

 

 

 

 

 

 

 

certifiers in evaluating substances and practices that occur after harvest and prior to further 

processing. 

o SOE and Retailers. A member discussed the issue of large retailers perhaps not being able to 

meet the March 2024 implementation deadline, and whether or not they have a “soft landing” 

and a path to certification after that date. NOP is doing direct outreach to affected entities, and 

has asked that stakeholders identify anyone that should be included on that contact list. The 

CACS will ask NOP at the NOSB meeting about whether NOP will take a risk-based approach to 

assessing compliance after the SOE implementation date. A member identified one category of 

operation that he finds concerning, and that is a small-to-medium-sized distributors. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

Minimum Reporting 

Requirements 

ADB/NPP HOLD 08.10.17 NOP Memo to 

CACS 

8.1.23 TBD 

Oversight improvements 

to deter fraud: 

Consistent Location 

Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 

8.1.23 

8.8.23 

Fall 2023 

Oversight improvements 

to deter fraud: 

Residue Testing for a 

Global Supply Chain 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 

8.1.23 

8.8.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.27.23 

7.11.23 

Fall 2023 
 

 

Organic and Climate-Smart 

Agriculture: 

What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.6.23 

7.11.23 

8.1.23 

8.8.23 

Spr 2024 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed 

at April 2021 NOSB 

meeting. Will remain 

an active agenda item 

for future work 

6.27.23 

7.11.23 

Fall 2023 

Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment Jun 8, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 

Fall 2023 NOSB meeting - Providence, RI Oct 24 - 26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, September 12, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kim Huseman (KH); Nate Powell-Palm (NPP); Logan Petrey (LP); Nate Lewis 

(NL); Carolyn Dimitri (CD); Allison Johnson (AJ); Jerry D’Amore (JD); Mindee Jeffery (MJ) - observer 

Absent: Kyla Smith (KS), Vice Chair 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM); Heather Kumar (HK) 

Agenda 

• Review September 5, 2023 notes

• NOSB Technical representative introduction

• Potential Work Agenda Items Review

a. Follow-up on handling standards post-SOE training (KS)

b. Ideas on a processed-based approach for plastics (NL)

c. Ideas for a framework for sharing organic community challenges/solutions with other

agencies (NL); thoughts on a phase 2 examination of FSA/NRCS program offerings (CD) 

d. SOE and retailers - discuss (JD)

• Additional Items

• Adjourn

Discussion 

• September 5, 2023 notes were accepted as written.

• NOSB Technical representative introduction. Heather Kumar is the new NOSB technical representative/

food technologist. Heather has been with the NOP for over a year and has a graduate degree in Food 

Safety Regulations, and has worked as a chemistry teacher and a lab technician.

• Potential Work Agenda Items Review. The CACS had a brainstorming session on its last call about

potential work agenda items and revisited the topics.

a. Follow-up on handling standards post-SOE training (KS). Deferred to next call.

b. Ideas on a processed-based approach for plastics (NL). The NOP recently sent a memo to the

Board asking them to revisit the previous NOSB recommendation on BBMF. The Crops

Subcommittee received the work agenda item, and in parallel, the CACS is considering a potential

framework to work on plastic more broadly across the organic system plan. A member suggested

perhaps focusing on plastic as it relates to the weed management practice standards at §205.206

since that fits squarely in the purview of the NOSB. The lead will write a paragraph requesting a

work agenda item, will share it with other members for wordsmithing, then forward it to the

Executive team to discuss on the September 19 Executive call. Several members offered to assist/

support the leads. The group also discussed divvying up the 7 questions in the BBMF memo and 

having CACS address some of them, because they seem broader than just Crops.

c. Ideas on developing a framework for sharing organic community challenges/solutions with other 

agencies (NL). As discussed last week, the group considered whether to use the crop insurance and 

research priorities proposals as a model for other issues such as cost-share. The CACS is seeking a 

framework or process by which they can connect stakeholders to other agencies, for example 

when stakeholders have concerns or solutions about cost-share, or crop insurance, because the 

NOSB is frequently seen as a conduit for anything having to do with organic. The group did not 

decide to advance this work agenda topic, but may revisit cost-share at a later date after the crop 

insurance document is complete.

d. SOE and retailers (JD). The lead noted that there wasn’t much to add since the last discussion, but 

he continues to caution that the SOE implementation deadline of March 2024 may not be realistic 

for some companies. He is advocating for a “soft-landing” and clear guidance about how
 

 

 

 

 

 

 

 

 

 

to bring some of the entities into compliance if they cannot make the deadline. The CACS Chair 

previously mentioned the timeline involved in getting fully certified, and indicated that October 

would be the latest date to get started in order to meet the March 2024 deadline. Another 

member added that while the NOSB wants to be helpful, it is not the enforcement arm of the 

program. A member mentioned the recent OIG report regarding SOE: 

https://usdaoig.oversight.gov/reports/other/national-organic-program-strengthening-organicenforcement 

The NOP reminded the group that the program will record updates and make them available in 

advance of the NOSB meeting, including updates from the Compliance and Enforcement (C & E) 

and Accreditation Divisions that will likely address the Program’s activities related to SOE 

Implementation. After watching the recordings, perhaps they can pose any specific questions 

about SOE implementation and enforcement to the NOP during the Q and A session at the NOSB 

meeting. 

• Additional Items. None. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

Minimum Reporting 

Requirements 

ADB/NPP HOLD 08.10.17 NOP Memo to 

CACS 

8.1.23 TBD 

Oversight improvements 

to deter fraud: 

Consistent Location 

Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 

8.1.23 

8.8.23 

Fall 2023 

Oversight improvements 

to deter fraud: 

Residue Testing for a 

Global Supply Chain 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 

8.1.23 

8.8.23 

Fall 2023 
 

 

Organic and Climate-Smart 

Agriculture: 

Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.27.23 

7.11.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.6.23 

7.11.23 

8.1.23 

8.8.23 

Spr 2024 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed 

at April 2021 NOSB 

meeting. Will remain 

an active agenda item 

for future work 

6.27.23 

7.11.23 

Fall 2023 

Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment Jun 8, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 

Fall 2023 NOSB meeting - Providence, RI Oct 24 - 26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, September 5, 2023 4:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Nate Powell-Palm (NPP); Logan 

Petrey (LP); Nate Lewis (NL); Carolyn Dimitri (CD); Allison Johnson (AJ); Jerry D’Amore (JD); Mindee Jeffery (MJ) -

observer 

Absent: None 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM) 

Agenda 

• Review August 8, 2023 notes 

• Review work agenda/schedule 

• Additional Items 

• Adjourn 

Discussion 

• August 8, 2023 notes were accepted as written. 

• Review work agenda/schedule. 

o The CACS reviewed the work agenda, and discussed potential future work agenda items. There 

are several projects in progress that will be presented at the Spring meeting. The Chair 

highlighted the Strengthening Organic Enforcement (SOE) rule and possible projects connected 

to that, such as Oversight improvements to deter fraud: Minimum Reporting Requirements. A 

member mentioned a new training in the Organic Integrity Learning Center (OILC) regarding 

SOE called “Keep it Organic When Handling and Processing”. She indicated that she would take 

the training and let the CACS know if there are answers to the question about how or whether 

SOE will impact organic handlers. 

• Additional Items. 

o The group discussed plastic, which they view as a broad issue that encompasses more than just 

plastic mulch and covers for crop use. For example, it’s a food packaging problem, as well as an 

agricultural production problem. Members posed questions to the group about whether this is 

something the NOSB can contribute to in a meaningful way, and what impact the NOSB could 

make given that the problem is widespread, and largely outside of organic agriculture. A 

member recommended that if they work on plastic, that it be done in the CACS instead of just 

Crops, and will think more about possible ways the NOSB could work on this. The NOP will be 

sending a work agenda request to the Crops Subcommittee soon, asking them to reconsider a 

previous NOSB recommendation on BBMF, given new information about biodegradability. The 

group discussed several aspects: community support for addressing this problem; the need for a 

holistic solution; the value in addressing pieces of the issue on plastic; the acknowledgement of 

the complexity due to the scope of the problem, most of which is outside of the USDA/NOSB 

authority. The group questioned whether the work is worth doing if it's outside OFPA’s scope, 

and whether there is a path forward for this issue. A member suggested that if the CACS 

chooses to work on it, it would be beneficial to take an organic-systems-plan approach. One 

member noted that in her most recent inspection, her certifier asked specific questions about 

trash and recycling. 

o The group discussed the certification cost share program, and ways to make it more 

streamlined and more beneficial to farmers who need it. Members shared ideas that other 

organizations have been proposing, such as reallocating funds based on need to those farmers 

who see the cost-share as a lifeline; increasing the amount that beginning farmers receive; and 

making the process easier by giving funds directly to certifiers. A member noted that 
certification costs are rising, based on many factors such as transportation costs, staffing 

increases, etc. This effort could help reduce barriers to transition. The NOSB could characterize 

the problems and offer some possible solutions. CACS could approach the issue similarly to the 

crop insurance work agenda item: The Board doesn’t need to solve the problem but could be a 

clearing house for what producers are saying and compile potential solutions. The group talked 

about developing a framework for how NOSB Recommendations on issues like this are shared 

with other federal agencies, in this case FSA, using the NOSB Research priorities and NIFA as a 

model. They may revisit this at a later date. NL will consider ideas for the framework. 

o A member relayed concerns that large retailers/distributors will not meet the March 2024 SOE 

implementation deadline, and were unaware of who to contact for information. He questioned 

whether there could be an extension on the implementation date, or a soft landing for 

operations that don’t meet the deadline. The CACS may discuss this at the Fall 2023 meeting if 

the issues are not resolved prior. The group questioned what happens if some entities in the 

supply chain do not meet the deadline to get certified. Do they receive a non-compliance and an 

opportunity to correct and come into compliance? A member mentioned that some producers 

are getting letters from their certifiers about identifying uncertified operations in their supply 

chain under penalty of fines for not doing so. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

August 8, 2023 

Enforcement: Residue Testing for a Global Supply Chain Discussion Document (ADB/NPP/NL/KH) -

discuss/vote 

Organic and Climate-Smart Agriculture: What and Why Organic? Discussion Document (ADB/NPP/JD) -

discuss/vote 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

 

 

 

 

 

 

 

 

 

 

 

 

 

Target

meeting 

Oversight improvements ADB/NPP HOLD 08.10.17 NOP Memo to 8.1.23 TBD 

to deter fraud: CACS 

Minimum Reporting 

Requirements 
 

 

 

 

 

Oversight improvements 

to deter fraud: 

Consistent Location 

Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 

8.1.23 

8.8.23 

Fall 2023 

Oversight improvements 

to deter fraud: 

Residue Testing for a 

Global Supply Chain 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 

8.1.23 

8.8.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.27.23 

7.11.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.6.23 

7.11.23 

8.1.23 

8.8.23 

Spr 2024 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed 

at April 2021 NOSB 

meeting. Will remain 

an active agenda item 

for future work 

6.27.23 

7.11.23 

Fall 2023 

Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment Jun 8, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 

Fall 2023 NOSB meeting - Providence, RI Oct 24 - 26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, August 8, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Jerry D’Amore (JD); Kim Huseman (KH); Nate 

Powell-Palm (NPP); Logan Petrey (LP); Nate Lewis (NL); Mindee Jeffery (MJ) – observer; 

Absent: Carolyn Dimitri (CD); Allison Johnson (AJ) 

Staff: Michelle Arsenault (MA); Jared Clark (JC) 

Agenda 

• Review August 1, 2023 notes 

• Consistent Location Identification update 

• Enforcement: Residue Testing for a Global Supply Chain Discussion Document (ADB/NPP/NL/KH) -

discuss/vote 

• Organic and Climate-Smart Agriculture: What and Why Organic Discussion Document (JD) - discuss/vote 

• Additional Items 

• Adjourn 

Discussion 

• August 1, 2023 notes were accepted with several modifications to the discussion. 

• Consistent Location Identification: The lead highlighted changes that were made to the document after 

the last call, and after the vote. Members approved the changes without opposition. 

• Enforcement: Residue Testing for a Global Supply Chain Discussion Document (ADB/NPP/NL/KH). The 

lead highlighted changes that were included in the newest version of the document. The additional text 

was based on information from Strengthening Organic Enforcement (SOE) regarding contact 

contamination and certifier verification. 

Motion to accept the discussion document Enforcement: Residue Testing for a Global Supply Chain 

Motion by: NL 

Seconded by: NPP 

Yes: 7 No: 0 Abstain: 0 Recusal: 0 Absent: 2 

• Organic and Climate-Smart Agriculture: What and Why Organic Discussion Document (JD). The 

Subcommittee had a robust conversation around this topic and decided to defer this document to the 

Spring 2024 meeting. The CACS may use the open docket after the Fall meeting to post the document 

for preliminary public comment, and then develop a document for discussion at the Spring 2024 NOSB 

meeting. 

• Additional Items. None. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

August 1, 2023 

Enforcement: Residue Testing for a Global Supply Chain Discussion Document - discuss outline 

(ADB/NPP/NL/KH) 
 

 

 

 

 

 

 

 

 

Modernizing Organic Infrastructure: Consistent Location Identification (ADB/NPP) - discuss/vote 

Organic and Climate-Smart Agriculture: What and Why Organic? Discussion Document (ADB/NPP/JD) -

discuss 

August 8, 2023 

Enforcement: Residue Testing for a Global Supply Chain Discussion Document (ADB/NPP/NL/KH) -

discuss/vote 

Organic and Climate-Smart Agriculture: What and Why Organic? Discussion Document (ADB/NPP/JD) – 

discuss/vote 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

Minimum Reporting 

Requirements 

ADB/NPP HOLD 08.10.17 NOP Memo to 

CACS 

8.1.23 TBD 

Oversight improvements 

to deter fraud: 

Consistent Location 

Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 

8.1.23 

8.8.23 

Fall 2023 

Oversight improvements 

to deter fraud: 

Residue Testing for a 

Global Supply Chain 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 

8.1.23 

8.8.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.27.23 

7.11.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.6.23 

7.11.23 

8.1.23 

8.8.23 

Spr 2024 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed 

at April 2021 NOSB 

meeting. Will remain 

an active agenda item 

for future work 

6.27.23 

7.11.23 

Fall 2023 
Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment Jun 8, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 

Fall 2023 NOSB meeting - Providence, RI Oct 24 - 26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, August 1, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Jerry D’Amore (JD); Carolyn Dimitri (CD); 

Kim Huseman (KH); Allison Johnson (AJ); Nate Powell-Palm (NPP); Logan Petrey (LP); Nate Lewis (NL); Mindee 

Jeffery (MJ) - observer 

Absent: None 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM) 

Agenda 

• Review July 11, 2023 notes 

• Modernizing Organic Infrastructure: Consistent Location Identification Proposal (ADB/NPP) -

discuss/vote 

• Enforcement: Residue Testing for a Global Supply Chain Discussion Document (ADB/NPP/NL/KH) 

• Organic and Climate-Smart Agriculture: What and Why Organic Discussion Document (JD) - discuss/vote 

• Additional Items 

• Adjourn 

Discussion 

• July 11, 2023 notes were accepted as written 

• Modernizing Organic Infrastructure - Consistent Location Identification Proposal (ADB/NPP). This 

project received support at the Spring NOSB meeting. The group had a conversation about terminology. 

i.e., parcel vs. field vs. site, and decided to use the term “legal parcel” throughout the document. 

Members discussed implementation of the recommendation, and determined that this is a 

recommendation for NOP to provide guidance, instruction, or training to help certifiers be more 

consistent. . A member noted the connection to the Human Capital work, as it potentially could save 

certifiers time and resources. Another member raised a concern about confidentiality of information, 

and confirmed that the information would only be available to the operation’s own certifier. 

Motion to recommend that all accredited certifiers obtain consistent location information that can lead 

to GPS coordinates for all applicants for certification and certified operations (parcels, production units -

grower groups, handling locations, importers, brokers, etc.). 

Motion by: ADB 

Seconded by: NPP 

Yes: 9 No: 0 Abstain:0 Recusal: 0 Absent: 0 

• Enforcement: Residue Testing for a Global Supply Chain Discussion Document (ADB/NPP/NL/KH). The 

lead introduced the discussion document, which is meant to build on existing residue testing 

requirements to complement Strengthening Organic Enforcement (SOE). The concept is to modernize 

how certifiers conduct residue sampling along the supply chain. The current document includes a 

proposed framework to evaluate substances for testing, with an initial focus on two aspects: synthetic 

solvents used in oilseed extraction; and fumigants. It also includes questions to determine if and where 

gaps may exist. A member added that the timing may be interesting with the implementation date of 

SOE. The group had a robust conversation about the first iteration of the document. The lead will make 

some modifications based on today’s conversation and the group will discuss and vote on the next call. 

• Organic and Climate-Smart Agriculture: What and Why Organic Discussion Document (ADB/NPP/JD). 

The lead conveyed feedback from the NOP about the goal and scope of the document, emphasizing that 

it should be grounded in the “organic is climate smart” work agenda theme. The group reviewed the 
newest iteration of the document, which was focused and condensed to one page. Members asked 

several questions and provided feedback to the lead. The CACS will discuss the document once more 

and vote on the next call. 

Additional Items. The Oversight improvements to deter fraud: Minimum Reporting Requirements 

Proposal is on hold until SOE is implemented. The NOP corrected the table below to reflect that. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

July 11, 2023 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance (CD) - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? (JD) - discuss/vote 

Modernizing Organic Infrastructure - Consistent Location Identification (ADB/NPP) - discuss/vote 

Opportunities in Organic: Support for Transitioning Producers (AJ) - discuss/vote 

August 1, 2023 

Enforcement: Residue Testing for a Global Supply Chain Discussion Document - discuss outline 

(ADB/NPP/NL/KH) 

Modernizing Organic Infrastructure: Consistent Location Identification (ADB/NPP) - discuss/vote 

Organic and Climate-Smart Agriculture: What and Why Organic? Discussion Document (ADB/NPP/JD) -

discuss 

August 8, 2023 

Enforcement: Residue Testing for a Global Supply Chain Discussion Document (ADB/NPP/NL/KH) -

discuss/vote 

Organic and Climate-Smart Agriculture: What and Why Organic? Discussion Document (ADB/NPP/JD) – 

discuss/vote 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Target

meeting 

Oversight improvements ADB/NPP HOLD 08.10.17 NOP Memo to 8.1.23 TBD 

to deter fraud: CACS 

Minimum Reporting 

Requirements 
 

 

 

 

 

 

Oversight improvements 

to deter fraud: 

Consistent Location 

Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 

8.1.23 

Fall 2023 

Oversight improvements 

to deter fraud: 

Residue Testing for a 

Global Supply Chain 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 

8.1.23 

8.8.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.27.23 

7.11.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture: 

What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.6.23 

7.11.23 

8.1.23 

8.8.23 

Fall 2023 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed 

at April 2021 NOSB 

meeting. Will remain 

an active agenda item 

for future work 

6.27.23 

7.11.23 

Fall 2023 

Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment Jun 8, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 

Fall 2023 NOSB meeting - Providence, RI Oct 24 - 26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, July 11, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Jerry D’Amore (JD); Carolyn Dimitri (CD); 

Kim Huseman (KH); Allison Johnson (AJ) 

Absent: Nate Powell-Palm (NPP); Logan Petrey (LP); Nate Lewis (NL) 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM) 

Agenda 

• Review June 27, 2023 notes 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance (CD) - discuss/vote 

• Opportunities in Organic: Improving Support for Organic Transition (AJ) - discuss/vote 

• Modernizing Organic Infrastructure - Consistent Location Identification (ADB/NPP) - discuss/vote 

• Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic (JD) - discuss 

• Additional Items 

• Adjourn 

Discussion 

• June 27, 2023 notes were approved as written. 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance (CD). The group had a brief discussion about the minor edits that resulted from the last call, 

and moved to a vote. 

Motion to accept the discussion document on Climate Induced Farming Risk and Crop 

Insurance 

Motion by CD 

Seconded by ADB 

Yes: 6 No: 0 Abstain:0 Recusal: 0 Absent: 3 

• Opportunities in Organic: Improving Support for Organic Transition (AJ). The lead summarized the 

changes made since the last discussion, which included language about barriers to transition, and made 

some modifications to the question regarding diversity and inclusion. A member noted that outreach 

can be a barrier and offered an example that there was an NRCS program offering grants for transition 

that was only open for 3 weeks and many farmers did not know about it. The group talked about the 

information they are interested in gathering and the most useful way to disseminate it. The CACS would 

like to send this document to the people that it impacts, and also to certifiers that don’t necessarily 

participate in the NOSB process. The CACS views this as a way to build a movement, and trust, and a way 

to assist NOP in such activities. 

Motion to accept the discussion document on Improving Support for Organic Transition 

Motion by: AJ 

Seconded by: KH 

Yes: 6 No: 0 Abstain: 0 Recuse: 0 Absent: 3 

• Modernizing Organic Infrastructure - Consistent Location Identification (ADB/NPP). The group 

discussed the document, and the lead highlighted the information that was added since the last 

conversation. The co-lead is supposed to make some edits, and the CACS will vote on the next call. The 

document proposes the collection of field information/GPS coordinates for parcels, additional land use 

affidavits, and verification on an annual basis about farm location. A member supported the broader 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

definition to included other operations and not just farms. Members supported the idea of this proposal 

being implemented by NOP as an instruction to certifiers/best practices, and believes that verification 

across the supply chain could help prevent fraud, and will complement SOE. 

• Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic (JD). The lead 

reviewed the discussion document in its current form, and reviewed the five The document identifies 5 

competitive advantages that organic provides. Members offered feedback on the current iteration and 

feels there is value in having conversations with stakeholders as this moves forward. The goal is to tell 

the organic story to strengthen the label and to protect it. The group discussed challenges, like the idea 

of co-existence among other label claims, and would like this document to shore up organic and make 

sure it stays relevant. The lead will continue to modify the document and the CACS will talk more on 

next call. 

• Additional Items. None 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

June 27, 2023 - note date change 

Opportunities in Organic: Support for Transitioning Producers (AJ) - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance - discuss 

July 11, 2023 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance (CD) - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? (JD) - discuss/vote 

Modernizing Organic Infrastructure - Consistent Location Identification (ADB/NPP) - discuss/vote 

Opportunities in Organic: Improving Support for Organic Transition (AJ) - discuss/vote 

August 1, 2023 

Modernizing Organic Infrastructure - Consistent Location Identification (ADB/NPP) - discuss/vote 

Enforcement: Residue Testing for a Global Supply Chain - discuss outline (ADB/NPP/NL/KH) 

Oversight improvements to deter fraud: Minimum Reporting Requirements - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? (JD) - discuss/vote 

August 8, 2023 

Enforcement: Residue Testing for a Global Supply Chain. Discuss outline (ADB/NPP/NL/KH) -

discuss/vote 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 
 

 

 

 

 

 

 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

8.1.23 Fall 2023 

Oversight improvements 

to deter fraud: 

Modernizing Organic 

Infrastructure - Consistent 

Location Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 

8.1.23 

Fall 2023 

Enforcement: Residue 

Testing for a Global Supply 

Chain. 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 

8.1.23 

8.8.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture 

(Climate/Equity) 

- Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.27.23 

7.11.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture 

(Climate/Equity) 

- What and Why Organic? 

JD/LP Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.6.23 

7.11.23 

8.1.23 

Fall 2023 

Opportunities in Organic: 

Improving Support for 

Organic Transition 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed at 

April 2021 NOSB meeting. 

Will remain active agenda 

item for future work 

6.27.23 

7.11.23 

Fall 2023 

Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment Jun 8, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 

Fall 2023 NOSB meeting - Providence, RI Oct 24 - 26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, June 27, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Allison Johnson (AJ); Nate 

Lewis (NL); Carolyn Dimitri (CD); Mindee Jeffery (MJ) - observer 

Absent: Jerry D’Amore (JD); Nate Powell-Palm (NPP); Logan Petrey (LP) 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM) 

Agenda 

• Review June 6, 2023 notes 

• Opportunities in Organic: Support for Transitioning Producers (AJ) - discuss 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

• Insurance - discuss 

• Review work schedule 

• Additional Items 

• Adjourn 

Discussion 

• June 6, 2023 notes were accepted as written. 

• Opportunities in Organic: Support for Transitioning Producers (AJ). The lead summarized the draft 

document, and the group discussed the purpose of the document and the questions to stakeholders. 

The CACS wants to use the responses to guide follow-up actions that may inform recommendations to 

NOP. This could help to focus resources, and open parallel streams of work on equity and inclusion. A 

member indicated that there is already a large body of research as to why some operations have chosen 

to not be certified or have exited from organic transition or certification. A member suggested adding a 

question about long-term plans for farmers once they become certified. The lead will modify the list of 

questions based on the conversation, and the group will discuss this again on the next call. The CACS 

plans to post this in the open docket (AMS-NOP-23-0026) early to allow commenters more time to 

answer the questions. 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance Discussion document. The lead described the draft document she is developing. The 

document contains a summary of public comment from the last meeting, in which commenters 

conveyed personal experiences with crop insurance, and will also include a summary of data she 

gleaned from interviewing organic farmers, non-profits, researchers, and others, which she categorized 

by areas that were problematic. While there is nothing new or novel, the information is compiled in one 

place. The CACS will review the draft discussion document on the next call, and vote to send it to the full 

Board if ready. Members discussed other aspects of Crop insurance and the current drought that is 

affecting producers. 

• Review work schedule. The group reviewed the schedule for the next couple of CACS calls. 

• Additional Items. NL is meeting with a testing laboratory next month to discuss fraud detection and 

residue testing, which he feels will be helpful for inclusion in the discussion document on Enforcement: 

Residue Testing for a Global Supply Chain. Members also briefly discussed Strengthening Organic 

Enforcement (SOE) implementation and whether marketers/solicitors are required to be certified. 

• The meeting was adjourned. 

Previous CACS Notes 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

June 6, 2023 

Enforcement: Residue Testing for a Global Supply Chain. Discuss outline (ADB/NPP/NL/KH) 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? - discuss 

June 27, 2023 - note date change 

Opportunities in Organic: Support for Transitioning Producers (AJ) - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance - discuss 

July 11, 2023 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance (CD) - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? (JD) - discuss/vote 

Modernizing Organic Infrastructure - Consistent Location Identification (ADB/NPP) - discuss/vote 

Opportunities in Organic: Support for Transitioning Producers (AJ) - discuss/vote 

August 1, 2023 

Enforcement: Residue Testing for a Global Supply Chain - discuss outline (ADB/NPP/NL/KH) 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? - discuss/vote 

August 8, 2023 

Enforcement: Residue Testing for a Global Supply Chain. Discuss outline (ADB/NPP/NL/KH) -

discuss/vote 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

TBD Fall 2023 

Oversight improvements 

to deter fraud: 

Modernizing Organic 

Infrastructure - Consistent 

Location Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 Fall 2023 

Enforcement: Residue 

Testing for a Global Supply 

Chain. 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 

8.1.23 

8.8.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture 

(Climate/Equity) 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.27.23 

7.11.23 

Fall 2023 
 

 

 

- Climate Induced Farming 

Risk and Crop Insurance 

Organic and Climate-Smart 

Agriculture 

(Climate/Equity) 

- What and Why Organic? 

JD/LP Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.6.23 

7.11.23 

Fall 2023 

Opportunities in Organic: 

Support for Transitioning 

Producers 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed 

at April 2021 NOSB 

meeting. Will remain 

an active agenda item 

for future work 

6.27.23 

7.11.23 

Fall 2023 

Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment Jun 8, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 

Fall 2023 NOSB meeting - Providence, RI Oct 24 - 26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, June 6, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Jerry D’Amore (JD); Allison 

Johnson (AJ); Nate Powell-Palm (NPP); Nate Lewis (NL) 

Absent: Logan Petrey (LP); Carolyn Dimitri (CD) 

Staff: Michelle Arsenault (MA); Jared Clark (JC); Laura Gallagher (LG) 

Agenda 

• Review May 9, 2023 notes 

• Enforcement: Residue Testing for a Global Supply Chain. Discuss outline (ADB/NPP/NL/KH) 

• Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? 

• Additional Items 

• Adjourn 

Discussion 

• May 9, 2023 notes were accepted as written. 

• The group said farewell to Laura Gallagher. Laura will be focusing on other NOP duties, and will not join 

the CACS calls, but offered to assist when needed. 

• Enforcement: Residue Testing for a Global Supply Chain. Discuss outline (NL/ADB/NPP/KH). The lead 

presented a draft framework for testing and the group had a robust discussion. The proposed 

framework has three “buckets”: oversight, testing, response to positive results. The CACS will discuss 

And vote on the discussion document on the August 8 call. 

• Organic and Climate-Smart Agriculture (Climate/Equity) (JD) - What and Why Organic? The CACS 

discussed the desire to coordinate segments of the community, so we are all working together to 

market the benefits of organic. The lead discussed the history of how this project evolved and the 

important aspects. The lead recently traveled to Europe and highlighted the fact that organic operations 

and stakeholders all have common concerns. Members discussed the proposed check-off program from 

several years ago. For the most part, the community or segments of the community were not 

supportive, as there was general skepticism about the benefits. A member added that some view 

checkoffs as corrupt and non-transparent. She added that the conversation and environment has 

changed and perhaps the landscape is different now, and perhaps they can discuss this in the context of 

what’s important, and how the organic community can work collectively to promote organic. 

• Additional Items. None. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

May 9, 2023 

Discuss status/scope for work agenda items 

June 6, 2023 

Enforcement: Residue Testing for a Global Supply Chain. Discuss outline (ADB/NPP/NL/KH) 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? - discuss 

June 27, 2023 - note date change 

Human Capital Management: Support for Transitioning Producers (AJ) - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance - discuss 
 

 

 

 

 

 

 

 

 

 

 

 

 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? - discuss 

July 11, 2023 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? - discuss 

Modernizing Organic Infrastructure - Consistent Location Identification - discuss/vote 

August 1, 2023 

Enforcement: Residue Testing for a Global Supply Chain. Discuss outline (ADB/NPP/NL/KH) 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? - discuss/vote 

August 8, 2023 

Enforcement: Residue Testing for a Global Supply Chain. Discuss outline (ADB/NPP/NL/KH) -

discuss/vote 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

TBD Fall 2023 

Oversight improvements 

to deter fraud: 

Modernizing Organic 

Infrastructure - Consistent 

Location Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 Fall 2023 

Enforcement: Residue 

Testing for a Global Supply 

Chain. 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 

8.8.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture 

(Climate/Equity) 

- Climate Induced Farming 

Risk and Crop Insurance 

CD Proposal? Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.27.23 

7.11.23 

Fall 2023 

Organic and Climate-Smart 

Agriculture 

(Climate/Equity) 

- What and Why Organic? 

JD/LP Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

6.6.23 

6.27.23 

7.11.23 

Fall 2023 
 

Opportunities in Organic: 

Support for Transitioning 

Producers 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed 

at April 2021 NOSB 

meeting. Will remain 

an active agenda item 

for future work 

6.27.23 Fall 2023 

Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment ~May 20, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 

Fall 2023 NOSB meeting - Providence, RI Oct 24 - 26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, May 9, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kim Huseman (KH); Jerry D’Amore (JD); Carolyn Dimitri (CD); Allison Johnson 

(AJ); Nate Powell-Palm (NPP); Mindee Jeffery (MJ) - observer; Nate Lewis (NL) - observer 

Absent: Kyla Smith (KS), Vice Chair; Logan Petrey (LP) 

Staff: Michelle Arsenault (MA); Jo Mirenda (JM) 

Agenda 

• Review April 11, 2023 notes 

• Debrief from NOSB meeting 

• Scope/status update 

• Additional Items 

• Adjourn 

Discussion 

• April 11, 2023 notes were accepted as written with one minor grammar correction. 

• Debrief from NOSB meeting. 

o The Chair praised the Subcommittee for the great discussion at the Spring meeting. She also 

praised the community for their engagement and feedback. A member echoed the sentiment 

that the meeting went well and is looking forward to the Fall meeting. 

o The CACS is anticipating future work agenda item requests that will have a structured format. 

Another member reflected on the meeting and which stakeholders showed up. Took to heart 

comments from stakeholders needing enough time to react to proposals. Would like to explore 

ways to get draft documents or questions to the public for preliminary feedback sooner. 

o Members discussed numerous ways to engage the community and give them more time to 

contribute and be heard. 

o The CACS will talk more at the Executive Committee meeting about ways to engage with the 

community between NOSB meetings. 

• Scope/status update. The CACS scheduled discussions in preparation for the Fall 2023 meeting. See 

table below. 

o Consistent location ID. Will proceed as proposal for the Fall meeting. 

o Climate Induced Farming Risk and Crop Insurance. The lead will compile comments from the 

Spring meeting, and include that in a new discussion document for Fall, and plans to develop a 

proposal for Spring 2024. The group discussed the connection to the Farm Bill, and determined 

that timing is not critical. Another member suggested adding Crop Insurance to the work agenda 

and revisiting it once a year. 

o Residue testing. Several members discussed ideas about definitions and scope. The 

Strengthening Organic Enforcement Rule (SOE) provides supply chain transparency, and the 

NOP could move ahead with testing recommendations from the NOSB. A member suggested 

checking with other agencies (FDA and EPA) for residue testing protocols. Another member 

added that California has years of experience and a robust residue testing protocol. 

• Additional Items. None. 

• The meeting was adjourned. 

Previous CACS Notes 
 

 

 

 

 

 

 

 

 

 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

April 11, 2023 

Guest speaker - NOP Trade Systems Director Jon Veley. Discuss Soybean imports and CBP 

Opportunities in Organic: Support for Transitioning Producers (AJ). Discuss draft 

Review Public comment 

May 2, 2023 - cancelled 

May 9, 2023 

Discuss status/scope for work agenda items 

June 6, 2023 

Enforcement: Residue Testing for a Global Supply Chain. Discuss outline (ADB/NPP/NL/KH) 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? 

June 13, 2023 

Human Capital Management: Support for Transitioning Producers (AJ). Discuss/Vote 

July 11, 2023 

What/Why Organic (JD) - Status update 

August 1, 2023 

August 8, 2023 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements 

to deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

TBD Fall 2023 

Oversight improvements 

to deter fraud: 

Modernizing Organic 

Infrastructure - Consistent 

Location Identification 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

7.11.23 Fall 2023 

Enforcement: Residue 

Testing for a Global Supply 

Chain. 

ADB/NPP/NL/KH Discussion 

document 

Approved by Exec 

Cmmte/NOP 4.17.23 

6.6.23 Fall 2023 

Organic and Climate-Smart 

Agriculture 

(Climate/Equity) 

- Organic IS climate smart 

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22. Voted on and 

passed at Spring 2023 

meeting. 

NA 
 

 

 

 

Organic and Climate-Smart CD Proposal? Approved by Exec 6.6.23 Fall 2023 

Agriculture Cmmte/NOP 1.18.22. 7.11.23 

(Climate/Equity) Memo sent to CACS 

- Climate Induced Farming 02.23.22 

Risk and Crop Insurance 

Organic and Climate-Smart JD/LP Discussion Approved by Exec 6.13.23 Fall 2023 

Agriculture document Cmmte/NOP 1.18.22. 7.11.23 

(Climate/Equity) Memo sent to CACS 

- What and Why Organic? 02.23.22 

Human Capital AJ Discussion 07.31.20 NOP Memo to 6.13.23 Fall 2023 

Management: document CACS. Proposal passed 

Opportunities in Organic: at April 2021 NOSB 

Support for Transitioning meeting. Will remain 

Producers an active agenda item 

for future work 

Milestones 

Fall 2023 Milestones Target dates (tentative) 

NOP - Publish FRN, Open public comment ~May 20, 2023 

NOP - Draft Fall 2022 NOSB meeting agenda Aug 4, 2023 

NOSB - Fall 2023 proposals due to NOP Aug 10, 2023 

NOP - Post proposals Aug 30, 2023 

Public comment closes Sep 28, 2023 

NOP - Send compiled public comments to NOSB ~Oct 2, 2023 

Public comment webinars Oct 17 & 19, 2023 

Fall 2023 NOSB meeting - Providence, RI Oct 24 - 26, 2023 

Final recommendations due Nov 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, April 11, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Jerry D’Amore (JD); Carolyn 

Dimitri (CD); Logan Petrey (LP); Allison Johnson (AJ); Nate Powell-Palm (NPP); Mindee Jeffery (MJ) - observer 

Absent: None 

Staff: Jon Veley (Guest Speaker); Michelle Arsenault (MA); Laura Gallagher (LG) 

Agenda 

• Review April 4, 2023 notes 

• Guest speaker - NOP Trade Systems Director Jon Veley. Discuss Soybean imports and CBP 

• Human Capital Management: Support for Transitioning Producers (AJ). Discuss draft and name 

• Review Public comment 

• Additional Items 

• Adjourn 

Discussion 

• April 4, 2023 notes were accepted as written. 

• Guest speaker - NOP Trade Systems Director Jon Veley. Soybean imports and CBP. Jon introduced 

himself, and the AMS Trade Division. The Trade Division was started in 2016, and Jon was recruited from 

CBP, who partnered with AMS to work on cargo issues to improve enforcement. AMS has launched a 

new program on bulk commodities (grain). The Trade Division does unannounced inspections at ports, 

where they sample and send to the USDA lab in Gastonia, NC for testing. AMS is conducting a number of 

actions, but often the information isn’t released to the public until any court proceedings are 

completed. Members engaged in Q and A with Jon. A member asked why the current structure or rules 

might not be stringent enough and why it would need to change. Additionally, if the CACS were to work 

on the topic of strengthening enforcement with respect to grain, what would the goal of the document 

be? The group discussed the testing requirement of 5% and ideally would like to see it increased. A 

member suggested they may want to invite Peyton Ferrier to a future CACS call. Peyton is an economist 

at USDA, who has expertise in this area of economics, and he could inform them about analyses that 

factor into decision making, such as testing requirements. 

o A member asked where one could access public information about sampling results. NOP will 

follow up. 

o Since SOE implementation isn’t complete yet, the CACS Chair would like to get ahead of any 

potential issues, and feels that working on a proposal for testing requirements might be an area 

that could use some work. She added that she has read SOE and feels that this could build a 

complimentary pipeline and would rather not wait until there is a problem. 

• Opportunities in Organic: Support for Transitioning Producers (AJ). The CACS is interested in working 

on organic transition, and feels that the NOSB could serve as conduit between industry and NOP. The 

proposed work may contains a 3-pronged approach: 1. Partnership with certifiers 2. Financial support 

for transitioning farmers; and 3. Market development grants. The CACS would like to move ahead with a 

discussion document for the Fall meeting that includes discussion of barriers and goals for building a 

broad and diverse organic community. A member added that the climate document seems to fit under 

diversity and inclusion and would like to emphasize that they are already working on that piece. 

• Review Public comment. The CACS briefly discussed public comments. 

• Additional Items. The group renamed the Human Capital Management: Support for Transitioning 

Producers to Opportunities in Organic: Support for Transitioning Producers 

o The CACS asked for a progress report on their previous recommendation for NOSB technical 

support, and will ask about that during the next Executive call. TOPP has been priority, so there 

may not have been much movement. 
 

 

 

 

 

 

 

 

 

 

 

o The CACS is interested in inviting someone from the Equity Commission to speak on a future 

CACS call. https://www.usda.gov/equity-commission 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

April 4, 2023 

What/why organic (JD) - discuss draft 

April 11, 2023 

Guest speaker - NOP Trade Systems Director Jon Veley. Discuss Soybean imports and CBP 

Opportunities in Organic: Support for Transitioning Producers (AJ). Discuss draft 

Review Public comment 

May 2, 2023 - cancelled 

May 9, 2023 

Discuss outline for work agenda request on testing 

June 6, 2023 

June 13, 2023 

Opportunities in Organic: Support for Transitioning Producers (AJ). Discuss/Vote 

July 11, 2023 

What/Why Organic (JD) - Status update 

August 1, 2023 

August 8, 2023 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements to 

deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

Fall 2023 

Oversight improvements to 

deter fraud: 

- Parcel Identification 

Modernizing Organic 

Infrastructure Consistent 

Location Identification 

ADB/NPP Discussion 

document 

08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

2.14.23 

Spr 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Organic IS climate smart 

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.10.23 

2.7.23 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.3.23 

2.14.23 

3.7.23 

7.11.23 

Fall 2023 

Human Capital Management: 

Opportunities in Organic 

Support for Transitioning 

Producers 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed at 

April 2021 NOSB meeting. 

Will remain an active 

agenda item for future 

work 

4.11.23 

6.13.23 

Fall 2023 

Milestones 

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment Feb 14, 2023 10 weeks 

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks 

New NOSB member training TBD 

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023 

NOP - Post proposals Mar 6, 2023 7.5 

Public comment closes Apr 5, 2023 3.5 

NOP - Send compiled public comments to NOSB Apr 7, 2023 3 

Public comment webinars Apr 18 & 20, 2023 1 week 

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023 

Final recommendations due May 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, April 4, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Jerry D’Amore (JD); Carolyn 

Dimitri (CD); Mindee Jeffery (MJ) - observer 

Absent: Logan Petrey (LP); Allison Johnson (AJ); Nate Powell-Palm (NPP) 

Staff: Michelle Arsenault (MA); Laura Gallagher (LG) 

Agenda 

• Review March 14, 2023 notes 

• Review schedule - plan and schedule all topics 

• Review spring mtg (travel, agenda, comments). 

• Review potential work agenda item on enforcement: testing/analysis and prep for next week's guest, 

Jon Veley (NOP - former CBP experience) 

• Status update on enforcement: minimum reporting requirements/SOE 

• Status update - What/Why Organic 

• Additional Items 

• Adjourn 

Discussion 

• March 14, 2023 notes were accepted with a minor change to the conversation about soybean import 

issues. 

• Review schedule - plan and schedule all topics. 

Support for Transitioning Producers (AJ). The lead will be circulating some ideas for this project and 

the CACS will discuss on the April 11 call. 

• Review spring mtg (travel, agenda, comments). The CACS briefly reviewed the Spring meeting schedule, 

and discussed the three meeting agenda items for the Spring 2023 meeting and discussion time for 

each. 

• Review potential work agenda item on enforcement: testing/analysis and prep for next week's guest 

speaker, Jon Veley. The group discussed what this project could or would look like, the problem they 

are trying to solve. The NOP suggested thinking about how this would be implemented. i.e., Would it be 

a new rule, guidance to certifiers, etc., or is it something the NOP already has authority over? Members 

discussed how to move forward, and would like to present something to the Executive Committee on 

the April 17 call. 

• Status update on enforcement: minimum reporting requirements/SOE (NPP). Deferred to next call. 

• Status update - What/Why Organic (JD). Deferred to next call. 

• Additional Items. None. 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

March 14, 2023 

Oversight improvements to deter fraud: Minimum Reporting Requirements proposal (ADB/NPP) 

April 4, 2023 

What/why organic (JD) - discuss draft 

April 11, 2023 
 

 

 

 

 

 

 

 

Guest speaker - NOP Trade Systems Director Jon Veley. Discuss Soybean imports and CBP 

Human Capital Management: Support for Transitioning Producers (AJ). Discuss draft 

Review Public comment 

May 2, 2023 - cancelled 

May 9, 2023 

Discuss outline for work agenda request on testing 

June 6, 2023 

June 13, 2023 

Human Capital Management: Support for Transitioning Producers (AJ). Discuss/Vote 

July 11, 2023 

What/Why Organic (JD) - Status update 

August 1, 2023 

August 8, 2023 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements to 

deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

Fall 2023 

Oversight improvements to 

deter fraud: 

- Parcel Identification 

Modernizing Organic 

Infrastructure Consistent 

Location Identification 

ADB/NPP Discussion 

document 

08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Organic IS climate smart 

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.10.23 

2.7.23 

2.14.23 

Spr 2023 
 

 

 

 

 

 

 

 

 

 

 

 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.3.23 

2.14.23 

3.7.23 

7.11.23 

Fall 2023 

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency -

Support for Transitioning 

Producers 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed at 

April 2021 NOSB 

meeting. Will remain an 

active agenda item for 

future work 

4.11.23 Fall 2023 

Milestones 

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment Feb 14, 2023 10 weeks 

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks 

New NOSB member training TBD 

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023 

NOP - Post proposals Mar 6, 2023 7.5 

Public comment closes Apr 5, 2023 3.5 

NOP - Send compiled public comments to NOSB Apr 7, 2023 3 

Public comment webinars Apr 18 & 20, 2023 1 week 

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023 

Final recommendations due May 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, March 14, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Logan Petrey (LP); Allison 

Johnson (AJ) 

Absent: Nate Powell-Palm (NPP); Jerry D’Amore (JD); Carolyn Dimitri (CD) 

Staff: Michelle Arsenault (MA); Laura Gallagher (LG) 

Agenda 

• Review March 7, 2023 notes 

• Schedule Work Agenda Items for Spring/Summer 

• Oversight improvements to Deter Fraud: Strengthening Organic Enforcement (SOE) work agenda item 

(NPP/ADB) 

• Additional Items 

• Adjourn 

Discussion 

• March 7, 2023 notes were accepted with a minor change. 

• Schedule Work Agenda Items for Spring/Summer. The group reviewed the schedule for the next few 

months, and discussed the Human Capital Management: Support for Transitioning Producers (AJ). The 

lead will have an outline or draft for the April 11 call and will connect with NOP to refine the focus and 

gather resources. 

• Oversight improvements to Deter Fraud: SOE work agenda items (NPP/ADB). The group discussed 

potential work agenda items stemming from the final SOE rule. The Chair would like to get out ahead of 

any potential failure points and prevent them, rather than reacting to them. A member noted that given 

the implementation date of the rule, there may not be time to do that. Members talked about areas 

where the NOSB could contribute to be most helpful or meaningful. A member asked about the 

possibility of holding a panel at the Fall meeting regarding an update on SOE implementation. The NOSB 

leadership team will talk more about that at the Exec call. 

• Additional Items. 

o Soybean import issues. The Chair proposed that the CACS work on a project to address issues 

with soybean imports, such as testing at point-of-entry. Members discussed various challenges 

including the added burden for certifiers who would have to be available to institute the testing. 

Currently, certifiers have a protocol to test 5% and they get to choose when or where testing 

happens. Additionally, if an outside entity pulls the sample to test, then it may not be 

enforceable because the certifier was not in control of the sample through the entire chain of 

custody. Members suggested other ideas as well. The CACS will extend an invitation to Jon Veley 

of the NOP to join a future CACS call to talk about Customs and Border Protections’ (CBP) roles 

and abilities). 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

March 7, 2023 

March 14, 2023 

April 4, 2023 

What/why organic (JD) - discuss draft 
 

 

 

 

 

 

 

April 11, 2023 

Guest Jon Veley of NOP. Discuss Soybean imports And CBP 

Review Public comment 

Human Capital Management: Support for Transitioning Producers (AJ). Discuss draft 

May 2, 2023 - cancelled 

May 9, 2023 

June 6, 2023 

June 13, 2023 

Human Capital Management: Support for Transitioning Producers (AJ). Discuss/Vote 

July 11, 2023 

August 1, 2023 

August 8, 2023 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements to 

deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

Fall 2023 

Oversight improvements to 

deter fraud: 

- Parcel Identification 

Modernizing Organic 

Infrastructure Consistent 

Location Identification 

ADB/NPP Discussion 

document 

08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Organic IS climate smart 

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.10.23 

2.7.23 

2.14.23 

Spr 2023 
 

 

 

 

 

 

 

 

 

 

 

 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.3.23 

2.14.23 

3.7.23 

4.4.23 

Fall 2023 

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal 

- Support for Transitioning 

Producers 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed at 

April 2021 NOSB 

meeting. Will remain an 

active agenda item for 

future work 

4.11.23 Fall 2023 

Milestones 

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment Feb 14, 2023 10 weeks 

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks 

New NOSB member training TBD 

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023 

NOP - Post proposals Mar 6, 2023 7.5 

Public comment closes Apr 5, 2023 3.5 

NOP - Send compiled public comments to NOSB Apr 7, 2023 3 

Public comment webinars Apr 18 & 20, 2023 1 week 

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023 

Final recommendations due May 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, March 7, 2023 4:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kim Huseman (KH); Nate Powell-Palm (NPP); Carolyn Dimitri (CD); Jerry 

D’Amore (JD); Mindee Jeffery - observer 

Absent: Logan Petrey (LP); Kyla Smith (KS), Vice Chair; Allison Johnson (AJ) 

Staff: Michelle Arsenault (MA); Laura Gallagher (LG) 

Agenda 

• Review February 14, 2023 notes 

• Review the Calendar for Spring /Summer (All) 

• Discuss what/why organic (JD) 

• Oversight improvements to Deter Fraud: SOE work agenda item (NPP/ADB) 

• Additional Items 

• Adjourn 

Discussion 

• February 14, 2023 notes were accepted as written. 

• Review the Calendar for Spring /Summer (All). The Chair summarized the overall picture of workflow 

for the next few months. 

• What/why organic (JD). The lead summarized the draft document and emphasized the ultimate goal, 

which is to identify, communicate, and celebrate the accomplishments of the organic industry. He added 

that there is a good story to tell, but no one is telling it. Members contributed thoughts and ideas about 

the content, such as making sure the language is precise and accurate, and that it articulates the positive 

aspects of “why organic”. A member noted that organic can be challenging to market because there’s a 

broad range of stakeholders that all have different reasons for participating, and the benefits for each 

are diverse. The group also discussed the potential for a check-off program, which would require 

legislation and farm bill negotiations, and also how the Transition to Organic Partnership Program 

(TOPP) program could help share messaging. A member added that the structure of the document is 

great but would like to provide a clear actionable goal to promote voluntary functional governance. The 

CACS is excited to continue the positive conversation at the Spring meeting and hear feedback from 

stakeholders. 

• Oversight improvements to Deter Fraud: SOE work agenda item (NPP/ADB). Deferred to next call. 

• Additional Items. None 

• The meeting was adjourned. 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

February 14, 2023 

Oversight improvements to deter fraud: Modernizing Organic Infrastructure - Consistent Location 

Identification discussion document - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - Organic IS climate smart proposal - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance discussion document - discuss/vote 

March 7, 2023 

March 14, 2023 
 

 

 

 

 

 

 

 

 

Oversight improvements to deter fraud: Minimum Reporting Requirements proposal (ADB/NPP) 

April 4, 2023 

April 11, 2023 

May 2, 2023 - cancelled 

May 9, 2023 

June 6, 2023 

June 13, 2023 

July 11, 2023 

August 1, 2023 

August 8, 2023 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements to 

deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

3.14.23 

Fall 2023 

Oversight improvements to 

deter fraud: 

- Parcel Identification 

Modernizing Organic 

Infrastructure Consistent 

Location Identification 

ADB/NPP Discussion 

document 

08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Organic IS climate smart 

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.10.23 

2.7.23 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.3.23 

Fall 2023 
 

2.7.23 

2.14.23 

Human Capital Management: AJ Discussion 07.31.20 NOP Memo to TBD Fall 2023 

Inspector mentorship/ document CACS. Proposal passed at 

apprenticeship/consistency April 2021 NOSB 

proposal meeting. Will remain an 

- Support for Transitioning active agenda item for 

Producers future work 

Milestones 

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment Feb 14, 2023 10 weeks 

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks 

New NOSB member training TBD 

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023 

NOP - Post proposals Mar 6, 2023 7.5 

Public comment closes Apr 5, 2023 3.5 

NOP - Send compiled public comments to NOSB Apr 7, 2023 3 

Public comment webinars Apr 18 & 20, 2023 1 week 

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023 

Final recommendations due May 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, February 14, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Allison Johnson (AJ); Nate 

Powell-Palm (NPP); Carolyn Dimitri (CD); Jerry D’Amore (JD); Mindee Jeffery - observer 

Absent: Logan Petrey (LP) 

Staff: Michelle Arsenault (MA); Laura Gallagher (LG) 

Agenda 

• Review February 7, 2023 notes 

• Oversight improvements to deter fraud: Parcel Identification - discuss/vote 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Organic IS climate smart - discuss/vote 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance - discuss/vote 

• Additional Items 

• Adjourn 

Discussion 

• February 7, 2023 were accepted as written. 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance discussion document. The lead emphasized that the purpose of the document is to solicit 

feedback. She incorporated feedback from other members and the group moved to a vote. The CACS 

chair encouraged members to advertise the document, so they get a wide swath of stakeholders’ 

comments. 

Motion to accept the discussion document on Climate Induced Farming Risk and Crop Insurance 

Motion by: NPP 

Seconded by: KH 

Yes: 6 No: 0 Abstain: 0 Recuse: 0 Absent: 2 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Organic IS climate smart proposal -

discuss/vote. The lead indicated that the community was supportive of this project and during the last 

NOSB comment period, didn’t have suggestions for additions. This version is nearly identical to the 

previous version, and the CACS will present this proposal to the full board at the Spring meeting. The 

group discussed information to include in the cover letter. 

Motion to accept the proposal on Organic and Climate-Smart Agriculture (Climate/Equity) - Organic IS 

climate smart 

Motion by: NPP 

Seconded by: ADB 

Yes: 6 No: 0 Abstain: 0 Recuse: 0 Absent: 2 

• Oversight improvements to deter fraud: Modernizing Organic Infrastructure - Consistent Location 

Identification discussion document. Formerly called Parcel Identification. The lead summarized the 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

document, and the group discussed such things as universality, international standardization, and the 

fact that the GPS system is governed by the new Space Force agency. Members also discussed where 

the information could be housed and will continue that conversation. The group modified some of the 

questions included in the document and will post this discussion document for public comment for the 

Spring meeting. 

Motion to accept the discussion document on Modernizing Organic Infrastructure - Consistent Location 

Identification 

Motion by: ADB 

Seconded by: CD 

Yes: 7 No: 0 Abstain: 0 Recuse: 0 Absent: 1 

• Additional Items. Members discussed general Board procedures, the upcoming Farm Bill negotiations, 

and OFPA. 

• The meeting was adjourned 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

February 7, 2023 

Organic and Climate-Smart Agriculture discussion doc - What and Why Organic? (JD) - discuss/vote 

Oversight to Deter fraud: Parcel Identification discussion doc (ADB/NPP) - discuss/vote 

Organic and Climate-Smart Agriculture - Climate Induced Farming Risk and Crop Insurance 

discussion doc - discuss/vote 

Organic and Climate-Smart Agriculture - Organic IS climate smart proposal - discuss/vote 

February 14, 2023 

Oversight improvements to deter fraud: Modernizing Organic Infrastructure - Consistent Location 

Identification discussion document - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - Organic IS climate smart proposal - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance discussion document - discuss/vote 

March 7, 2023 

Oversight improvements to deter fraud: Minimum Reporting Requirements proposal (ADB/NPP) 

March 14, 2023 

April 4, 2023 

April 11, 2023 

May 2, 2023 

May 9, 2023 

June 6, 2023 

June 13, 2023 

July 11, 2023 

August 1, 2023 

August 8, 2023 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 
 

 

 

 

 

 

 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements to 

deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

3.7.23 

Fall 2023 

Oversight improvements to 

deter fraud: 

- Parcel Identification 

Modernizing Organic 

Infrastructure Consistent 

Location Identification 

ADB/NPP Discussion 

document 

08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Organic IS climate smart 

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Climate Induced Farming 

Risk and Crop Insurance 

CD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.10.23 

2.7.23 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

2.14.23 

Fall 2023 

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal 

- Support for Transitioning 

Producers. 

AJ Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed at 

April 2021 NOSB 

meeting. Will remain an 

active agenda item for 

future work 

TBD Fall 2023 

Milestones 

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment Feb 14, 2023 10 weeks 

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks 
New NOSB member training TBD 

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023 

NOP - Post proposals Mar 6, 2023 7.5 

Public comment closes Apr 5, 2023 3.5 

NOP - Send compiled public comments to NOSB Apr 7, 2023 3 

Public comment webinars Apr 18 & 20, 2023 1 week 

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023 

Final recommendations due May 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, February 7, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Allison Johnson (AJ); Nate 

Powell-Palm (NPP); Carolyn Dimitri (CD); Jerry D’Amore (JD); Mindee Jeffery - observer 

Absent: Logan Petrey (LP) 

Staff: Michelle Arsenault (MA); Laura Gallagher (LG) 

Agenda 

• Review January 10, 2023 notes 

• Organic and Climate-Smart Agriculture discussion doc - What and Why Organic? (JD) - discuss/vote 

• Organic and Climate-Smart Agriculture - Climate Induced Farming Risk and Crop Insurance 

discussion doc (CD/NPP) - discuss/vote 

• Oversight to Deter fraud: Parcel Identification discussion doc (ADB/NPP) - discuss/vote 

• Organic and Climate-Smart Agriculture - Organic IS climate smart proposal (NPP) - discuss/vote 

• Additional Items 

• Adjourn 

Discussion 

• January 10, 2023 were accepted as written. 

• Organic and Climate-Smart Agriculture discussion doc - What and Why Organic? (JD). Deferred to Fall 

meeting in order to refine the document. The CACS will discuss this at a later date. 

• Organic and Climate-Smart Agriculture - Climate Induced Farming Risk and Crop Insurance discussion 

doc (CD/NPP). The group discussed the document, the intended audience, and the ultimate goal. In its 

current iteration, the document will be used to solicit information and establish first steps. The group 

discussed the relationship to the Farm Bill and the Risk Management Agency (RMA). The lead will make 

some edits based on feedback and the CACS will vote on the document on the February 14 call. 

• Oversight to Deter fraud: Parcel Identification discussion doc (ADB/NPP). The lead introduced the 

document and noted that she has incorporated some of the information from the newly published 

Strengthening Organic Enforcement (SOE) rule into the document. The group discussed the content, the 

goals for this project, and stakeholder feedback. The lead will make edits based on the conversation and 

the CACS will recirculate the document for discussion and vote on the February 14 call. 

• Organic and Climate-Smart Agriculture - Organic IS climate smart proposal (NPP). Deferred to next call. 

• Additional Items. None 

• The meeting was adjourned 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

January 10, 2023 

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? (JD) 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate induced farming risk and crop Insurance 

(CD/NPP) 

February 7, 2023 

Organic and Climate-Smart Agriculture discussion doc - What and Why Organic? (JD) - discuss/vote 

Oversight to Deter fraud: Parcel Identification discussion doc (ADB/NPP) - discuss/vote 
 

 

 

 

 

 

 

 

 

 

 

 

Organic and Climate-Smart Agriculture - Climate Induced Farming Risk and Crop Insurance 

discussion doc - discuss/vote 

Organic and Climate-Smart Agriculture - Organic IS climate smart proposal - discuss/vote 

February 14, 2023 

Oversight improvements to deter fraud: Parcel Identification - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - Organic IS climate smart - discuss/vote 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate Induced Farming Risk and Crop 

Insurance - discuss/vote 

March 7, 2023 

Oversight improvements to deter fraud: Minimum Reporting Requirements proposal 

March 14, 2023 

April 4, 2023 

April 11, 2023 

May 2, 2023 

May 9, 2023 

June 6, 2023 

June 13, 2023 

July 11, 2023 

August 1, 2023 

August 8, 2023 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements to 

deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

3.7.23 

Fall 2023 

Oversight improvements to 

deter fraud: 

- Parcel Identification 

ADB/NPP Discussion 

document 

08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Organic IS climate smart 

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

2.14.23 

Spr 2023 
 

 

 

 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Climate Induced Farming 

Risk and Crop Insurance 

CD/NPP Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.10.23 

2.7.23 

2.14.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

Fall 2023 

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal 

- Support for Transitioning 

Producers. 

TBD Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed at 

April 2021 NOSB 

meeting. Will remain an 

active agenda item for 

future work 

TBD Fall 2023 

Milestones 

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment ~Nov 10, 2022 

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks 

New NOSB member training TBD 

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023 

NOP - Post proposals Mar 6, 2023 7.5 

Public comment closes Apr 5, 2023 3.5 

NOP - Send compiled public comments to NOSB Apr 7, 2023 3 

Public comment webinars Apr 18 & 20, 2023 1 week 

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023 

Final recommendations due May 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, January 10, 2023 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Kim Huseman (KH); Allison Johnson (AJ); Nate 

Powell-Palm (NPP); Logan Petrey (LP); Carolyn Dimitri (CD); Mindee Jeffery - observer 

Absent: Jerry D’Amore (JD) 

Staff: Michelle Arsenault (MA); Laura Gallagher (LG) 

Agenda 

• Review January 3, 2023 notes 

• Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

• Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? (JD) 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Climate induced farming risk and crop 

Insurance (CD/NPP) 

• Meeting time 

• Additional Items 

• Adjourn 

Discussion 

• January 3, 2023 were accepted as written. 

• Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP). Deferred until the final rule 

for Strengthening Organic Enforcement (SOE) is published, and given the timeline, the CACS may push 

the proposal to the Fall 2023 meeting. 

• Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? (JD). The lead is 

working with other members as he develops this discussion document, and will add it to the agenda for 

the next CACS call. 

• Organic and Climate-Smart Agriculture (Climate/Equity) - Climate induced farming risk and crop 

Insurance (CD/NPP). The primary intent of this project is to lay out the state of research, address 

adoption of crop insurance by organic farmers, and to ask questions for public comment. The group 

discussed various issues with crop insurance for organic and transitioning farmers, including barriers, 

risk management, and areas for improvement. The lead would like to seek additional information from 

the National Agricultural Statistics Service (NASS) about the newest survey data. CACS members were 

supportive of this project, as it is of great interest to the entire community. A member noted that the 

timing is perfect with regard to the development of the farm bill, and having a document for the Spring 

NOSB meeting would be most helpful, although a Fall document would also be useful. The CACS would 

like to have a document that will assist stakeholders that do advocacy work. 

The CACS also discussed the connection to the TOPP program (Transition to Organic Partnership 

Program) and transition funding. 

• Meeting time. The CACS is seeking an alternate meeting time to replace the 2nd Tuesday meeting to 

accommodate everyone's schedules. The Chair asked that members look at their calendars and provide 

feedback about the best options. 

• Additional Items. None 

• The meeting was adjourned 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

January 3, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

January 10, 2023 

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? (JD) 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate induced farming risk and crop Insurance 

(CD/NPP) 

February 7, 2023 

Organic and Climate-Smart Agriculture discussion doc - What and Why Organic? (JD) - discuss/vote 

Oversight to Deter fraud: Parcel Identification discussion doc (ADB/NPP) - discuss/vote 

Organic and Climate-Smart Agriculture - Climate Induced Farming Risk and Crop Insurance 

discussion doc (CD/NPP) - discuss/vote 

Organic and Climate-Smart Agriculture - Organic IS climate smart proposal (NPP) - discuss/vote 

February 14, 2023 

March 7, 2023 

Oversight improvements to deter fraud: Minimum Reporting Requirements proposal 

March 14, 2023 

April 4, 2023 

April 11, 2023 

May 2, 2023 

May 9, 2023 

June 6, 2023 

June 13, 2023 

July 11, 2023 

August 1, 2023 

August 8, 2023 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements to 

deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

3.7.23 

Fall 2023 

Oversight improvements to 

deter fraud: 

- Parcel Identification 

ADB/NPP Discussion 

document 

08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

Spr 2023 
 

 

 

 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Organic IS climate smart 

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

2.7.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Climate Induced Farming 

Risk and Crop Insurance 

CD/NPP Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.10.23 

2.7.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- What and Why Organic? 

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.3.23 

2.7.23 

Spr 2023 

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal 

- Support for Transitioning 

Producers. 

TBD Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed at 

April 2021 NOSB 

meeting. Will remain an 

active agenda item for 

future work 

TBD Fall 2023 

Milestones 

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment ~Nov 10, 2022 

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks 

New NOSB member training TBD 

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023 

NOP - Post proposals Mar 6, 2023 7.5 

Public comment closes Apr 5, 2023 3.5 

NOP - Send compiled public comments to NOSB Apr 7, 2023 3 

Public comment webinars Apr 18 & 20, 2023 1 week 

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023 

Final recommendations due May 25, 2023 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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/regulations or NOSB recommendations. Proposals 

must be voted on by the full Board, to become recommendations to the USDA. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday, January 3, 2023 4:00 pm ET 

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Jerry D’Amore (JD); Kim Huseman (KH); Allison 

Johnson (AJ); Nate Powell-Palm (NPP); Logan Petrey (LP); Carolyn Dimitri (CD); Mindee Jeffery - observer 

Absent: None 

Staff: Michelle Arsenault (MA); Laura Gallagher (LG) 

Agenda 

• Review December 13, 2022 notes 

• Executive Meeting Recap 

• Oversight to Deter fraud: Parcel Identification (ADB/NPP) 

• Work Agenda Request: Overview of “Why organic” (JD) 

• Additional Items 

• Adjourn 

Discussion 

• December 13, 2022 were accepted as written 

• Executive Meeting Recap. The CACS Chair presented four work agenda items to the Executive 

Committee during the December call and all four were approved by both the Executive team and the 

NOP. See table below. 

• Oversight to Deter fraud: Parcel Identification (ADB/NPP). The lead presented background information 

about parcels and reporting such info to the Farm Service Agency (FSA). The group discussed collection 

and consistency in data, various existing processes, regulations, guidance, etc., and will discuss this more 

with the intention of bringing a discussion document to the Spring 2023 meeting. The NOP added that 

the word field is defined in § 205.2, and parcel is not, and for consistency it might be helpful to use the 

word field. 

• Work Agenda Request: Overview of “Why organic” (JD). The lead described the proposed project and 

members discussed the goals and the way forward. The NOSB and stakeholders are seeking a way to 

promote organic better. The CACS Chair added that the National Organic Program does not receive 

marketing dollars even though it is part of the Agricultural Marketing Service (AMS). The lead asked for 

feedback from each member, so he can incorporate it into the draft discussion document for the Spring 

2023 meeting. Tangential to the discussion about “why organic?”, the group discussed add-on labels, 

such as regenerative agriculture, and its relationship to the National Organic Program. 

• Additional Items. The leads for the following projects will circulate drafts before the weekend, and the 

CACS will discuss them during the January 10 call: Oversight improvements to deter fraud: Minimum 

Reporting Requirements; What and Why Organic?; and Climate Induced Farming Risk and Crop 

Insurance. 

• The meeting was adjourned 

Previous CACS Notes 

Future call schedule (1st & 2nd Tuesdays 4:00 PM & 2:00 PM ET, except where noted.) 

December 13, 2022 

January 3, 2023 

January 10, 2023 

Oversight to Deter fraud: Parcel Identification (ADB/NPP) 

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 
 

 

 

 

 

 

 

 

Organic and Climate-Smart Agriculture (Climate/Equity) - What and Why Organic? (JD) 

Organic and Climate-Smart Agriculture (Climate/Equity) - Climate induced farming risk and crop Insurance 

(CD/NPP) 

February 7, 2023 

Oversight to Deter fraud: Parcel Identification (ADB/NPP) 

Organic and Climate-Smart Agriculture (Climate/Equity) - Organic IS climate smart 

February 14, 2023 

March 7, 2023 

March 14, 2023 

April 4, 2023 

April 11, 2023 

May 2, 2023 

May 9, 2023 

June 6, 2023 

June 13, 2023 

July 11, 2023 

August 1, 2023 

August 8, 2023 

September 5, 2023 

September 12, 2023 

October 3, 2023 

October 10, 2023 

November 7, 2023 

November 14, 2023 

December 5, 2023 

December 12, 2023 

Work Agenda 

*Highlight indicates discussion. *Highlight indicates action needed. *Highlight indicates review completion 

and/or vote. 

Project Contact Doc Type Notes* Scheduled/ 

status 

Target

meeting 

Oversight improvements to 

deter fraud: 

- Minimum Reporting 

Requirements 

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS 

12.6.22 

12.13.22 

1.17.23 

Spr 2023 

Oversight improvements to 

deter fraud: 

- Parcel Identification 

ADB/NPP Discussion 

document 

08.10.17 NOP Memo to 

CACS. Approved by Exec 

Cmmte/NOP 12.20.22 

12.6.22 

12.13.22 

1.3.23 

1.17.23 

2.7.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Organic IS climate smart 

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

Spr 2023 
 

 

 

 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- Climate induced farming

risk and crop Insurance 

CD/NPP Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.17.23 

Spr 2023 

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

- What and Why Organic?

JD Discussion 

document 

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22 

11.8.22 

12.6.22 

12.13.22 

1.3.23 

1.17.23 

Spr 2023 

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal 

- Support for Transitioning

Producers

TBD Discussion 

document 

07.31.20 NOP Memo to 

CACS. Proposal passed at 

April 2021 NOSB 

meeting. Will remain an 

active agenda item for 

future work 

TBD Fall 2023 

Milestones 

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment ~Nov 10, 2022 

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks 

New NOSB member training TBD 

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023 

NOP - Post proposals Mar 6, 2023 7.5 

Public comment closes Apr 5, 2023 3.5 

NOP - Send compiled public comments to NOSB Apr 7, 2023 3 

Public comment webinars Apr 18 & 20, 2023 1 week 

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023 

Final recommendations due May 25, 2023