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 12, 2019, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Harriet Behar (HB); Ashley Swaffar (AS); Rick Greenwood (RG); Steve 

Ela (SE) - observer

Absent: Lisa de Lima (LD); A-dae Romero-Briones (ARB); Emily Oakley (EO)

Staff: Michelle Arsenault (MA)

Agenda

• Energy Infrastructure work agenda request

• Other items 

• Adjourn

Discussion

• Energy Infrastructure work agenda request. NOP denied the CACS’s work agenda request

during the Fall NOSB meeting. The CACS noted that the NOSB heard many comments from 

stakeholders that this is an issue that needs to be addressed and they are seeking support from 

the USDA. Members will continue to discuss possible solutions in other venues, such as the 

Accredited Certifiers Association (ACA) and International Organic Inspectors Association (IOIA). 

The CACS will clarify with the NOP if it should move forward on a module for the Integrity 

Learning Center, which was suggested previously. Members emphasized that information and 

education is key for farmers and others who are effected. 

• Other items 

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule (2nd Tuesday 3:00 ET)

October 8, 2019 - cancelled

November 12, 2019

December 10, 2019

January 14, 2020

February 11, 2020

March 10, 2020

April 14, 2020

May 12, 2020

June 9, 2020

July 14, 2020

August 11, 2020

September 8, 2020

October 13, 2020

November 10, 2020

December 8, 2020
Work Agenda

Project Contact Status Discussion,

Vote

Meeting

Energy system infrastructure on organic 

farms.

CACS requested addition to 

work agenda 12 14 18. NOP 

suggested working on a 

module for the Integrity 

Learning Center.

11 12 19 TBD

Oversight improvements to deter fraud 

- Summary

HB/TC On hold, pending 

publication of proposed rule 

on Strengthening organic 

enforcement (SOE)

TBD TBD

*Discussed *Voted

Spring 2020 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 15, 2019

NOSB - Spring 2020 proposals due to NOP Feb 20, 2020

New NOSB member training Feb 25 - 26, 2020

NOP - Draft Spring 2020 NOSB meeting tentative agenda Mar 2, 2020

NOP - Post proposals Mar 5, 2020

Public comment closes Apr 3, 2020

NOP - Send compiled public comments to NOSB Apr 7, 2020

Public comment webinars Apr 21 & 23, 2020

Spring 2020 NOSB meeting – Crystal City, VA Apr 28 - May 1, 2020
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 10, 2019, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Harriet Behar (HB); Emily Oakley (EO); Ashley Swaffar (AS)

Absent: Lisa de Lima (LD); A-dae Romero-Briones (ARB)

Staff: Michelle Arsenault (MA)

Agenda

• Discuss verbal update on integrity of the supply chain/oversight improvements to deter fraud at 

Fall 2019 NOSB meeting

• Fraud, traceability and the unique considerations of the fresh product trade.

• Energy infrastructure - status of work agenda request.

• Other items 

• Adjourn

Discussion

• Verbal update on Integrity of the Supply Chain/Oversight Improvements to Deter Fraud at Fall 

2019 NOSB meeting. The lead is reviewing transcripts and previous work to incorporate into the 

verbal update for the Fall 2019 meeting. A member mentioned that she also reviewed the 

transcripts and previous work and has sent that to the CACS members. The lead asked for 

feedback from members. 

• Fraud, traceability and the unique considerations of the fresh product trade. The CACS will 

defer this project until after the Strengthening the organic enforcement rule (SOE) is published, 

so they can determine what previous recommendations have already been incorporated. 

Members also discussed potential future technologies such as block chain, and will ask the NOP 

for an update at the Executive call. 

• Energy infrastructure - status of work agenda request. The CACS will request an update from 

the NOP about the status of this request. 

• Other items. A member asked about having a point-of-contact at the NOP who can address 

certifier questions. And if having guidance from the NOSB would help with that realm. 

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule (2nd Tuesday 3:00 ET)

July 9, 2019 - cancelled

August 13, 2019 -cancelled

September 10, 2019

Discuss verbal update on Integrity of the supply chain/Oversight improvements to deter fraud.

Fraud, traceability, and the unique considerations of the fresh product trade.

Energy infrastructure - status of work agenda request.

October 8, 2019

November 12, 2019

December 10, 2019
Work Agenda

Project Contact Status Discussion,

Vote

Meeting

Energy system infrastructure on organic 

farms.

CACS requested addition to 

work agenda 12 14 18. 

TBD

Oversight improvements to deter fraud 

- Summary

HB/TC Verbal update Fall 2019 Fall 2019

*Discussed *Voted

Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018

NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019

Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019
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

Monday June 17, 2019, 3:00 pm ET 

Attending: Scott Rice (SR), Chair; Harriet Behar (HB); Emily Oakley (EO); Lisa de Lima (LD); 

Absent: Sue Baird (SB); A-dae Romero-Briones (ARB); Ashley Swaffar (AS)

Staff: Michelle Arsenault (MA)

Agenda

• Notes from May 14, 2019

• NOP Memo to Certifiers re: Container Production

• Fraud, Traceability and the unique considerations of the fresh product trade

• Other items

• Adjourn

Discussion

• Notes from May 14, 2019 were accepted as is.

• NOP memo to certifiers re: container production. The group discussed the NOP memo

regarding certification of container growing systems. Subcommittee members noted the memo

raised a lot of questions and uncertainty in the certifier community. In addition to feedback

from the NOSB during the last Executive call, a member noted that the NOP has also heard from

several other stakeholder groups, such as certifiers, and the International Organic Inspectors

Association (IOIA).

• The group discussed the need for definitive and quick answers from the NOP to resolve certifier

questions and discrepancies. Members shared their perspectives that it can be problematic to

certifiers and the operations to not have a quick and decisive answer, and it ultimately stifles the

growth of the organic industry. A member added that the absence of an answer often results in

conflict and division in the community. There is great interest in continuous improvement and

accountability, and the CACS would like to explore how to get involved. The CACS discussed

several ways to engage and is considering a request for a work agenda item. SR will develop a

draft request.

• Fraud, Traceability and the unique considerations of the fresh product trade. Deferred to next

call due to lack of time.

• Other items.

o Energy infrastructure. The CACS is seeking feedback from NOP about the status of its

work agenda request of December 2018. MA will check with NOP leadership to see if

there is additional information needed. Members added that there is currently

inconsistent implementation, and the community is anxious to have the NOSB work on

it.

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule (2nd Tuesday 3:00 ET)

May 14, 2019
June 17, 2019

July 9, 2019

Fraud, traceability and the unique considerations of the fresh product trade.

Energy infrastructure – status of work agenda request.

August 13, 2019

September 10, 2019

October 8, 2019

November 12, 2019

December 10, 2019

Work Agenda

Project Contact Status Discussion,

Vote

Meeting

Energy system infrastructure on organic 

farms.

CACS requested addition to 

work agenda 12 14 18. 

TBD

Oversight improvements to deter fraud 

- Summary

HB/TC TBD

*Discussed *Voted

Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018

NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019

Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019
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 14, 2019, 3:00 pm ET

Attending: Sue Baird (SB), Chair; Scott Rice (SR), Vice Chair; Harriet Behar (HB); Emily Oakley (EO); 

Ashley Swaffar (AS)

Absent: Lisa de Lima (LD); A-dae Romero-Briones (ARB)

Staff: Michelle Arsenault (MA)

Agenda

• Debrief from Seattle meeting

• Energy system infrastructure on organic farms. 

• Other items 

• Adjourn

Discussion

• Debrief from Seattle meeting. 

o The CACS Chair summarized the top three topics from public comments: Stop-sale, for 

which the NOP doesn’t have authority; uncertified handlers, because there is no 

traceability; and acreage reporting. A member asked about areas where the NOSB could 

provide input while waiting for requests from the NOP.

o A member noted there are a couple of minor areas with regard to certification that 

could be useful. For example, tightening up certification systems which helps the 

accreditation aspect. A member noted that there is a gap - not in the system but in the 

implementation, adding that audits and accreditation oversight often involve checking 

boxes as apposed to assessing whether or not an operation made a good decision. 

o A member indicated the NOP is working on a project regarding fraud that they will ask 

the CACS to work on. MA will follow up with the Deputy Administrator and the 

Director/or Assistant director of AIA to see if they can provide additional information. 

The Subcommittee also discussed checklist-based oversight (as opposed to processbased decisions), which doesn’t offer much helpful feedback or oversight about decision 

making. The CACS Vice-Chair suggested they review the comments and use those to 

inform their work going forward. 

o Other potential work agenda items could include excluded operations and accreditation.

• Energy system infrastructure on organic farms. Waiting on approval from NOP about this work 

agenda request. 

• Other items. None

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule (2nd Tuesday 3:00 ET)

May 14, 2019

June 17, 2019, rescheduled from June 11

July 9, 2019
August 13, 2019

September 10, 2019

October 8, 2019

November 12, 2019

December 10, 2019

Work Agenda

Project Contact Status Discussion,

Vote

Meeting

Energy system infrastructure on organic 

farms.

CACS requested addition to 

work agenda 12 14 19. 

TBD

Oversight improvements to deter fraud 

- Summary

HB/TC TBD

*Discussed *Voted

Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018

NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019

Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019
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 12, 2019, 3:00 pm ET

Attending: Sue Baird (SB); Harriet Behar (HB); Emily Oakley (EO); Lisa de Lima (LD); A-dae RomeroBriones (ARB)

Absent: Ashley Swaffar (AS); Eric Schwartz, CACS Chair; Scott Rice (SR), Vice Chair

Staff: Michelle Arsenault (MA); Devon Pattillo (DP)

Agenda

• Summary of import panel

• Other items 

• Adjourn

Discussion

• Summary of import panel. The NOSB Chair intends on writing a discussion document with a 

summary of the import panels and any work to date on imports. The CACS will post a discussion 

document for the Spring NOSB meeting. Since the CACS does not have another call before the 

proposal deadline, the lead will send it to the members via email by the end of the week for 

review. 

• Other items.

o Grower groups. The members briefly discussed grower groups. NOP noted that grower 

groups are addressed in the Strengthening Organic Enforcement rulemaking, based on 

previous NOSB recommendations. NOP is in ex parté communication while rulemaking 

is underway, 

o Eric Schwartz resigned his position on the NOSB as he took a new position with a 

company that does not support organic. Sue Baird is now Chair of the CACS beginning 

with the March 12 call. 

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule (2nd Tuesday 3:00 ET)

January 29, 2019

February 12, 2019

March 12, 2019

April 9, 2019

May 14, 2019

June 11, 2019

July 9, 2019

August 13, 2019

September 10, 2019

October 8, 2019

November 12, 2019

December 10, 2019
Work Agenda

Project Contact Status Discussion,

Vote

Meeting

Integrity of the supply chain SR, HB, TC NOP Memo, requesting the 

CACS add a work agenda

item on Import Integrity, 

sent to NOSB 08 10 17.

01 29 19 Proposal

Spr 2019

Energy system infrastructure on organic 

farms.

CACS requested addition to 

work agenda 12 14 19

01 29 19 TBD

Summary of import panel TC 01 29 19

02 12 19

TBD

*Discussed *Voted

Spring 2019 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 26, 2018

NOSB – Spring 2019 proposals due to NOP Feb 21, 2019

NOP - Draft Spring 2019 NOSB meeting tentative agenda Mar 4, 2019

NOP - Post proposals Mar 6, 2019

Public comment closes Apr 4, 2019

Discuss/finalize work agendas on ES call Apr 13, 2019

NOP - Send compiled public comments to NOSB Apr 8, 2019

Public comment webinars Apr 16 & 18, 2019

Spring 2019 NOSB meeting - Seattle, WA Apr 24 - 26, 2019
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 29, 2019, 3:00 pm ET

Attending: Eric Schwartz, CACS Chair; Sue Baird (SB); Harriet Behar (HB); Emily Oakley (EO); Ashley 

Swaffar (AS); Lisa de Lima (LD)

Absent: Scott Rice (SR), Vice Chair; A-dae Romero-Briones (ARB)

Staff: Michelle Arsenault (MA); Devon Pattillo (DP)

Agenda

• Energy system infrastructure on organic farms. 

• Integrity in the supply chain - further work

• Other items 

• Adjourn

Discussion

• Energy system infrastructure on organic farms. The goal of this project is to develop guidance 

for certifiers and would address energy infrastructure, such as pipelines, fracking, utilities, etc., 

to protect integrity of organic land. The CACS is waiting for feedback from NOP approving the 

work agenda request, and about how best to move forward. 

• Integrity in the supply chain. The Subcommittee discussed various components of the project 

on integrity in the supply chain, including the development of a summary of the two import 

panels that addressed the NOSB, and domestic fraud. The CACS Chair will check with the lead 

author of the summary to determine if they will bring something forward to the Spring 2019 

NOSB meeting. The CACS is seeking advice from the NOP about what topics are priorities. 

• Other items. 

o Origin of Livestock. NOP received considerable public comment in support of this rule

and will determine how to move forward in the coming weeks. The NOSB expressed 

their support at the Fall 2018 meeting in the form of a resolution. 

o Guidance about goats. A member mentioned working on better, more species-specific 

guidance for goats. 

o Pasture rule. The CACS would like information from NOP about how it is moving 

forward with better oversight of implementation of the pasture regulations

• The meeting was adjourned

Previous CACS Notes

Future Call Schedule (2nd Tuesday 3:00 ET)

December 11, 2018

January 8, 2019 - cancelled due to shutdown

January 29, 2019

February 12, 2019

March 12, 2019

April 9, 2019
May 14, 2019

June 11, 2019

July 9, 2019

August 13, 2019

September 10, 2019

October 8, 2019

November 12, 2019

December 10, 2019

Work Agenda

Project Contact Status Discussion,

Vote

Meeting

Integrity of the supply chain SR, HB, TC NOP Memo, requesting the 

CACS add a work agenda

item on Import Integrity, 

sent to NOSB 08 10 17.

01 29 19 Proposal

Spr 2019

Energy system infrastructure on organic 

farms.

CACS requested addition to 

work agenda 12 14 19

01 29 19 TBD

Summary of import panel TC 01 29 19 TBD

*Discussed *Voted

Spring 2019 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 26, 2018

NOSB – Spring 2019 proposals due to NOP Feb 21, 2019

NOP - Draft Spring 2019 NOSB meeting tentative agenda Mar 4, 2019

NOP - Post proposals Mar 6, 2019

Public comment closes Apr 4, 2019

Discuss/finalize work agendas on ES call Apr 13, 2019

NOP - Send compiled public comments to NOSB Apr 8, 2019

Public comment webinars Apr 16 & 18, 2019

Spring 2019 NOSB meeting - Seattle, WA Apr 24 - 26, 2019