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

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday January 12, 2016, 4:30 pm ET

Attending: Carmela Beck (CB), Chair; Jean Richardson (JR); Tom Chapman (TC); Jennifer Taylor (JT); Adae Romero-Briones (AR); Ashley Swaffar (AS)

Absent: Scott Rice (SR); Nick Maravell (NM) 

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

Work Agenda

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/LD On hold NA TBD

Future Potential Projects Contact Status Vote Meeting

Agenda

• Approve notes of August 11, 2015

• Assessment of Soil Conservation Practices (CBe)

• Worker welfare (JT)

• Adjourn

Discussion

• The notes from August 11, 2015 were approved with no changes

• Assessment of Soil Conservation Practices. The group discussed the status of this document 

and how to move it forward. Both the CACS and NOP feel this is an important topic, but at this 

time the NOP suggests delaying further work until it can provide more guidance and resources 

to the CACS. An alternative approach is for the NOP to work on this project in collaboration with 

the NRCS and to not have the CACS work on it. NOP suggested that the group consult with one 

of the new NOSB members as she has experience in this area and with the NRCS. The CACS will 

continue this discussion on the next call. 

• Worker welfare (JT). The group discussed the potential of adding to the work agenda a project 

on addressing organic farm worker health and welfare. Several members acknowledged that this 

is a weakness of the organic standards, but felt that it does not fit under OFPA and therefore the 

USDA does not have authority to regulate this. The member suggested that the group develop a 

way to address the health of organic farm workers, perhaps in terms of food safety or 

contamination. Members felt that this was addressed elsewhere and by other agencies. Another 
CACS member suggested a discussion document or position statement so the community knows 

that it is a topic of interest for the NOSB. 

• Calculating % organic in multi-ingredient products. A member asked about the status of the 

document that was sent to the NOP on April 11, 2013. The Subcommittee members urged the 

NOP to move this forward as they constantly receive feedback from stakeholders regarding this 

topic. The NOP indicated that the draft guidance should be sent back to the CACS soon. 

Additionally, the following documents are also near completion: Post harvest handling, 

biodiversity guidance, and classification of materials. 

• The meeting was adjourned

Previous CACS Notes

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

December 8, 2015 3:00 ET - cancelled

January 12, 2016

February 9, 2016

Assessment of Soil Conservation Practices. Discuss status of document

March 8, 2016 

April 12, 2016 

May 10, 2016 

June 14, 2016 

July 12 2016 

August 9, 2016 

September 13, 2016 

October 11, 2016 

November 8, 2016 

December 13, 2016 

Spring 2016 Milestones Target date

New NOSB member orientation Feb 4, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 8, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment webinars ??

Public comment closes Apr 6, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 11, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday February 9, 2016, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Tom Chapman (TC); Jean Richardson (JR); A-dae Romero-Briones 

(AR); Ashley Swaffar (AS); Scott Rice (SR)

Absent: none

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

Work Agenda

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/SR Verbal update NA Spr 2016

Future Potential Projects Contact Status Vote Meeting

Agenda

• Approve notes of January 12, 2016

• Assessment of Soil Conservation Practices (CBe)

• Calculating % organic in multi-ingredient products - NOP update

• Adjourn

Discussion

• The notes from January 12 were approved with no changes.

• Assessment of Soil Conservation Practices. Members discussed the relationship between NRCS 

and Oregon Tilth and opportunities with regard to soil conservation projects and organic

agriculture. The group discussed the role of the CACS in moving this document forward, and 

agreed that at this time it is limited. Therefore the group feels the best path forward would 

involve training and education for certifiers, inspectors and producers. The Subcommittee will 

provide a verbal update on the status at the spring NOSB meeting. 

• Calculating % organic in multi-ingredient products. The NOP updated the CACS about this 

project, noting that it is in progress, and should be sent through internal review soon. Members 

discussed the history and issues with the calculations of ingredients, and were encouraged that 

the project is making progress.

• Other projects. The group discussed other projects for potential addition to the CACS work 

agenda. Members will reach out to stakeholders and the NOP will review the status of the prior 

NOSB recommendation(s) regarding eligibility of products treated with sanitizers for the 100% 

organic label. 
• The meeting was adjourned

Previous CACS Notes

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

January 12, 2016

February 9, 2016

Assessment of Soil Conservation Practices. Discuss status of document

March 8, 2016 

Assessment of Soil Conservation Practices. Discuss verbal summary for spring meeting. 

Discuss 100% organic label 

April 12, 2016 

May 10, 2016 

June 14, 2016 

July 12 2016 

August 9, 2016 

September 13, 2016 

October 11, 2016 

November 8, 2016 

December 13, 2016 

Spring 2016 Milestones Target date

New NOSB member orientation Feb 29, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 8, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment closes Apr 6, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 11, 2016

Public comment webinars Apr 18, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday March 8, 2016, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; A-dae Romero-Briones, Vice Chair (AR); Tom Chapman (TC); Jean 

Richardson (JR); Ashley Swaffar (AS); Scott Rice (SR)

Absent: none

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

Work Agenda

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/SR Verbal update NA Spr 2016

Future Potential Projects Contact Status Vote Meeting

Agenda

• Approve notes of February 9, 2016

• Assessment of Soil Conservation Practices. Discuss verbal summary for spring meeting. 

• In-field, annual evaluations of inspectors

• Calculating percentage organic in multi-ingredient products

• Other items

• Adjourn

Discussion

• The notes from February 9 were approved with no changes.

• Assessment of Soil Conservation Practices (SR). The lead sent a draft summary document to the 

CACS members for review. The document included a comprehensive history of the work-to-date 

as well as suggestions for moving forward. The CACS will present a brief verbal overview at the 

spring 2016 NOSB meeting, and will enter the document into the official record during the 

meeting. 

• In-field, annual evaluations of inspectors (JR). A member suggested a topic for the CACS work 

agenda regarding the NOP Instruction 2027 dated August 3 2013 

(https://www.ams.usda.gov/sites/default/files/media/2027.pdf). As a longtime inspector, the 

member feels that the requirement for annual on-site inspector evaluations is not aligned with

Sound and Sensible principles and could have a negative impact on organic certification. She 

feels that it is logistically complex, very expensive for certifiers, and it does not appear to give 

discretion to certifiers. A member added information from a Certifiers perspective in support of 
this viewpoint. The CACS will submit a request to the NOP to add this to the work agenda as a 

discussion document for the fall 2016 NOSB meeting. 

• Calculating percentage organic in multi-ingredient products. The NOSB asked for an update on 

the status of the proposed guidance document, in response to the NOSB 2013 recommendation. 

Guidance is currently under development, and the NOP asked for examples of issues that may 

be of concern. Members expressed concern about lack of consistency in verification of 

percentages, particularly for single ingredient products, which may be over 95% organic but lack 

documentation to prove this. Members also noted continuing problems in calculating 

percentages for liquid products such as soups or almond beverages. 

• 100% organic label claim. The NOP will send some information and links to prior NOSB work on 

this topic. 

• Other items - none

• The meeting was adjourned

Previous CACS Notes

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

February 9, 2016

Assessment of Soil Conservation Practices. Discuss status of document

March 8, 2016 

Assessment of Soil Conservation Practices. Discuss verbal summary for spring meeting. 

Discuss 100% organic label 

April 12, 2016 

May 10, 2016 

June 14, 2016 

July 12 2016 

August 9, 2016 

September 13, 2016 

October 11, 2016 

November 8, 2016 

December 13, 2016 

Spring 2016 Milestones Target date

New NOSB member orientation Feb 29, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 8, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment closes Apr 6, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 11, 2016
Public comment webinars Apr 19, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday April 12, 2016, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Jean Richardson (JR); Ashley Swaffar (AS); Scott Rice (SR); A-dae 

Romero-Briones, Vice Chair (AR)

Absent: Tom Chapman (TC)

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

Work Agenda

Project Contact Status Vote Meeting

Assessment of Soil Conservation 

Practices

CBe/SR Verbal update NA Spr 2016

In-field, annual evaluations of inspectors 

update (NOP 2027)

JR Approved 04 21 16 Fall 2016

Agenda

• Approve March 8, 2016 notes 

• In-field, annual evaluations of inspectors update 

• Review public comment if applicable

• Peer review of NOP by ANSI

• Other items

Discussion

• The notes from March 8 were approved with no changes.

• In-field, annual evaluations of inspectors update (NOP 2027) (JR). The group discussed the 

issues and justification for why they are requesting this work agenda item regarding the 

requirement for yearly evaluations of inspectors. The NOP spoke with staff from the 

Accreditation and International Activities Division (AIA) briefly about the request from the CACS,

as they have just revised this guidance. A member noted that the 2011 NOSB recommendation 

included a three-year review timeline, and it is unclear why the NOP did not adopt that 

recommendation. AIA will discuss this and provide feedback. The NOP feels that the 

requirement for annual in-field inspector evaluations are a critical part of certification quality 

management. Certifiers are supportive of the concept of field audits, and agree it is improving 

the system. However, they want more flexibility, and for it to be risk-based so the logistics will

be less burdensome. Certifiers would appreciate more explanation of the specific problem this 

requirement is meant to address. . . The CACS feels strongly that it continue to explore this topic 

to glean feedback from the certification community. The CACS will draft a letter to NOP asking 

for clarification, and asked that someone from AIA to address their concerns on a future call. 

• Peer review of NOP by American National Standards Institute (ANSI). The NOSB put forth a 

recommendation in 2014 for a peer review process, and the audit is underway. Two current 
NOSB members have been approached about assisting with the audit, but are unsure if they will 

be selected. The audit is scheduled to be completed by August 2016, at which time ANSI will 

deliver a report to the NOP. 

• Other items. The CACS will discuss future work agenda topics on the May call. A member 

suggested adding calls to the schedule if they add work agenda items and need more discussion 

time.

• The meeting was adjourned

Previous CACS Notes

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

March 8, 2016 

Assessment of Soil Conservation Practices. Discuss verbal summary for spring meeting. 

Discuss 100% organic label

April 12, 2016 

May 10, 2016 

June 14, 2016 

July 12 2016 

August 9, 2016 

September 13, 2016 

October 11, 2016 

November 8, 2016 

December 13, 2016 

Spring 2016 Milestones Target date

New NOSB member orientation Feb 29, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 16, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment closes Apr 14, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 18, 2016

Public comment webinars Apr 19, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday May 10, 2016, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; A-dae Romero-Briones, Vice Chair (AR); Harriet Behar (HB); 

Tom Chapman (TC); Jean Richardson (JR); Scott Rice (SR); Tracy Favre (TF); Jesse Buie - observer

Absent: Ashley Swaffar (AS)

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

Guest: Cheri Courtney (CC), Director, Accreditation and International Activities (AIA)

Work Agenda

Project Contact Status Vote Meeting

In-field, annual evaluations of inspectors 

update (NOP 2027)

JR Approved 04 21 16 Fall 2016

Agenda

• Approve April 12, 2016 notes 

• Instruction 2027 In-Field, Annual Inspector Evaluations Overview (ALL)

• Notifying operators via their certifier of sunset materials that were not renewed at sunset (HB)

• Other items

Discussion

• The notes from April 12 were approved with no changes.

• Instruction 2027: In-Field, Annual Inspector Evaluations Overview (ALL). Cheri Courtney, 

director of the NOP’s Accreditation and International Activities (AIA), joined the call to discuss

the NOP 2027 Instruction, which is an instruction for personnel performance evaluations. NOP 

views the inspectors as extremely vital to organic integrity, and annual evaluations are both 

important and required. The group discussed the reasons and goals for yearly evaluations, and 

while all agree that in-field evaluations are critical, requiring them to be done yearly is seen by 

some as a burden to organic certifiers, both logistically and financially. The NOP is aware that 

reaching the goal of auditing 100% of inspectors each year is burdensome and is working with 

certifiers to attain this goal. During public comment at the April 2016 NOSB meeting, 

stakeholders suggested that evaluations be conducted using a risk-based method, as opposed to 

trying to reach a goal of 100 % evaluations every year. Members also discussed public 

comments, the need for data collection from the community, and consistency and uniformity

across certifiers. Members were welcomed to contact AIA for additional questions or discussion. 

The next step will include reaching out to the Accredited Certifiers Association (ACA) with a 

request for data. The leads will update the CACS on the next call. 

• Notifying operators via their certifier of sunset materials that were not renewed at sunset 

(HB). A member circulated a draft document with justification for adding this project to the 

CACS work agenda. The member feels there is a breakdown in communication between 

certifiers and organic stakeholders, and the message about sunset materials that are no longer 
allowed in organic is not being adequately or systematically relayed. The group discussed the 

idea and need for this project and will reach out to the Accredited Certifiers Association (ACA) 

and other groups to see if this is necessary or useful. A member suggested an informal process 

of communication via the ACAs, which could be implemented much quicker than having the 

NOSB develop a recommendation for guidance or instruction from the NOP. 

• The meeting was adjourned

Previous CACS Notes

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

April 12, 2016 

May 10, 2016 

June 14, 2016

Instruction 2027 In-Field, Annual Inspector Evaluations Overview (JR/SR)

Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB)

July 12 2016 

August 9, 2016 

September 13, 2016 

October 11, 2016 

November 8, 2016 

December 13, 2016 

Fall 2016 timeline chart coming soon.
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the National List. 

They do not represent official National Organic Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, 

and status of substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday June 14, 2016, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Harriet Behar (HB); Tom Chapman (TC); Jean Richardson (JR); Scott 

Rice (SR); Tracy Favre (TF); Ashley Swaffar (AS); 

Absent: A-dae Romero-Briones, Vice Chair (AR) 

Staff: Jessica Walden (JW), Michelle Arsenault (MA)

Work Agenda

Project Contact Status Vote Meeting

In-field, annual evaluations of inspectors 

update (NOP 2027)

JR Approved 04 21 16 Fall 2016

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production

HB Pending ES approval on 07 

12 16

TBD

Agenda

• Approve May 10, 2016 notes 

• Instruction 2027 In-Field, Annual Inspector Evaluations Overview (JR, SR)

• Notifying operators via their certifier of sunset materials that were not renewed at sunset (HB)

• Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB)

• Other items

Discussion

• The notes from May 10 approved with no changes.

• Instruction 2027: In-Field, Annual Inspector Evaluations Overview (JR, SR). The co-leads 

updated the group on the progress to date. They have received feedback and data from the 

Accredited Certifiers Association, Inc. (ACA) and continue to seek more data about inspectors 

and costs. The goal is to receive all data by mid-July so they can analyze it and draft a document 

to send to the NOP. A member indicated that the document will include an International 

perspective as well. Members discussed various other topics related to the inspector evaluation 

process, including the sharing of evaluations by certifiers, guidance on procedures and 

thoroughness of evaluations , considering whether the frequency could be reduced to once 

every 3 years, and templates currently in use for evaluations. Several members will seek 

additional information from the International Organic Inspectors Association (IOIA) and the 

Food Safety Community and will discuss this further on the next call. The CACS intends on 

presenting an oral report at the fall 2016 NOSB meeting.

• Notifying operators via their certifier of sunset materials that were not renewed at sunset 

(HB). The lead sought feedback from the certification community and received mixed opinions 

about the idea of operator notification. The intention behind this project was two-fold: to create 

consistency among certifiers, and to aid co-packers or larger operations by keeping them 

informed about changes to the National List. The lead feels that this would aid those who may 
face a loss of certification due to non-compliance. Based on feedback from the community and

other Subcommittee members, the group decided there was no support at this time to move 

ahead with this project and will not seek to add it to the work agenda. 

• Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB). The 

lead summarized the project idea for the members. The CACS discussed the complexity of the 

topic, and members were supportive of adding it to the work agenda as a discussion document. 

The CACS will request its addition during the next Executive call, July 8. 

• The meeting was adjourned

Previous CACS Notes

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

May 10, 2016 

June 14, 2016

Instruction 2027 In-Field, Annual Inspector Evaluations Overview (JR/SR)

Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB)

July 12 2016 

Instruction 2027 In-Field, Annual Inspector Evaluations Overview (JR/SR)

Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB)

August 9, 2016 

September 13, 2016 

October 11, 2016 

November 8, 2016 

December 13, 2016 

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment June/TBD

NOP - Complete fall 2016 NOSB meeting tentative agenda Sept 8, 2016

NOSB - Fall 2016 proposals due to NOP Sept 14, 2016

NOP - Post proposals On or before Sept 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the National List. 

They do not represent official National Organic Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, 

and status of substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday August 9, 2016, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Harriet Behar (HB); Tom Chapman (TC); Jean Richardson (JR); Scott 

Rice (SR)

Absent: A-dae Romero-Briones, Vice Chair (AR)

Staff: Jessica Walden (JW), Michelle Arsenault (MA)

Work Agenda

Project Contact Status Vote Meeting

In-field, annual evaluations of inspectors 

update (NOP 2027)

JR Approved for addition to 

work agenda 04 21 16

NA Verbal update 

Fall 2016

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production

HB Approved for addition to 

work agenda 07 15 16.

DD Fall 2016

Agenda

• Approve June 14, 2016 notes 

• Instruction 2027 In-Field, Annual Inspector Evaluations Overview (JR, SR)

• Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB)

• Other items

Discussion

• The notes from June 14 were approved with no changes

• Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB). The 

lead offered to develop a discussion document for the Fall 2016 meeting. Members discussed 

various components for the document which may include a definition of high value land, and 

questions for which they would like feedback from the public. The lead author will circulate a 

draft by September 5 and the group will provide feedback for the September 13 call. 

• Instruction 2027: In-Field, Annual Inspector Evaluations Overview (JR, SR). The co-leads have 

discussed the peer evaluation procedures gleaned from the Accredited Certifying Agents (ACAs)

and feel that the data is not as current or comprehensive as they would like, so they are 

proposing an oral report at the Fall 2016 meeting and a discussion document at the Spring 2017 

meeting. JR offered to draft a discussion document before her Board term ends as a foundation 

document for future work. 

• The meeting was adjourned

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

July 12 2016 

Instruction 2027 In-Field, Annual Inspector Evaluations Overview (JR/SR)

Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB)

August 9, 2016 

September 13, 2016

Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB). -

Discuss draft document, vote

October 11, 2016 

November 8, 2016 

December 13, 2016 

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016

NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the National List. 

They do not represent official National Organic Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, 

and status of substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday September 13, 2016, 3:00 pm ET 

Attending: Carmela Beck (CB), Chair; Tom Chapman (TC); Scott Rice (SR); A-dae Romero-Briones, Vice 

Chair (AR); Harriet Behar (HB)

Absent: Jean Richardson (JR)

Staff: Jessica Walden (JW), Michelle Arsenault (MA)

Work Agenda

Project Contact Status Vote Meeting

In-field, annual evaluations of inspectors 

update (NOP 2027)

JR Approved for addition to 

work agenda 04 21 16

09 12 Disc doc Fall 

2016

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production

HB Approved for addition to 

work agenda 07 15 16. 

09 12 Disc doc Fall 

2016

NOP operating plan suggestions ALL NA NA

Agenda

• Approve August 9, 2016 notes 

• In-field, annual evaluations of inspectors update (NOP 2027) (SR,JR) - Discuss and vote 

• Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB) -

Discuss and vote

• Other items

Discussion

• The notes from August 9 were approved as written.

• In-field, annual evaluations of inspectors disc doc (NOP 2027) (SR, JR). One of the co-leads 

summarized the document and the group discussed it. A member suggested the addition of a 

question pertaining to parallel systems that may be in use by other organizations. If such 

systems are in use, they could potentially be used as a model or for reference. For example, 

Global GAP has a robust global system in place, and perhaps could be a useful source for risk 

assessment. Another member suggested two additional questions for the document: 1) 

regarding a minimum threshold for evaluations. (E.g. inspectors who do less than 10 inspections 

a year) could be exempt from yearly field evaluations and instead be evaluated on a less 

frequent basis supplemented by paper evaluations); and 2) If certifiers would share evaluations, 

especially for those inspectors who inspect for multiple certifiers, it could streamline the process 

and be less burdensome. A member noted that both of these approaches have been considered 

and the NOP has not been supportive. After some discussion and feedback on these questions, 

the CACS chose to move forward with the document as a means to gather more information 

without proposing specific solutions. 
The lead will make some edits as discussed on the call and recirculate the document for review. 

The Chair will hold the vote will open to allow the absent member the opportunity to vote via 

email. 

Motion to accept the discussion document on In-field, annual evaluations of inspectors (NOP 

2027) with the addition of questions as discussed on today’s call.

Motion by: SR

Seconded by: HB

Additional discussion: none

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

ABS note: The absent member voted via email and the vote was adjusted to reflect that.

• Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB). 

The lead summarized the origination of this project. It was requested by various stakeholders, 

and was originally a separate piece in the NOSB biodiversity recommendation. Because it 

involved treatment of land before organic certification, the NOP felt it would require a rule 

change. The goal of the project would be to prevent these lands from being destroyed in favor 

of organic production. The lead noted that because it takes 3 years to convert land to organic, it 

tempts people to utilize “pristine” lands to convert to organic. Members offered suggestions for 

the document which were addressed before and on the call and the group moved to a vote. The 

vote will remain open for absent member to vote via email. Members will provide additional 

feedback to the lead and the document will be modified and recirculated.

Motion to accept the discussion document, as amended, on eliminating the incentive to convert 

native ecosystems into organic crop production. 

Motion by: HB

Seconded by: SR

Additional discussion: none

Yes: No: 0 Abstain: 0 Absent: Recuse: 0

ABS note: After the opening of the vote and the September 13 call, the CACS had further 

discussions via email and chose to provide a verbal update only, and will develop a discussion 

document for the spring 2017 meeting. The motion was therefore withdrawn and no vote was 

taken. 

• The meeting was adjourned

Previous CACS Notes

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

August 9, 2016 

September 13, 2016

Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB). - 

Discuss draft document, vote

In-field, annual evaluations of inspectors disc doc (NOP 2027) (SR, JR).
October 11, 2016 

November 8, 2016 

December 13, 2016 

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016

NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the National List. 

They do not represent official National Organic Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, 

and status of substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday November 8, 2016, 3:00 pm ET

Attending: Carmela Beck (CB), Chair; Scott Rice (SR); Harriet Behar (HB); Jean Richardson (JR); Tom 

Chapman (TC); Jesse Buie (JB) - observer

Absent: A-dae Romero-Briones, Vice Chair (AR) 

Staff: Jessica Walden (JW), Michelle Arsenault (MA)

Work Agenda

Project Contact Status Vote Meeting

In-field, annual evaluations of inspectors 

update (NOP 2027)

JR/SR Approved for addition to 

work agenda 04 21 16

09 12 Disc doc Fall 

2016

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production

HB Approved for addition to 

work agenda 07 15 16.

NA Verbal update

Fall 2016. DD 

Spring 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve September 13, 2016 notes 

• Discuss comments

• Other items

Discussion

• The notes from September 13 were approved with the addition of follow up notation about the 

outcome of the Eliminating the Incentive to Convert Native Ecosystems into Organic Crop 

Production vote. The Subcommittee withdrew the motion and will present a verbal update at 

the Fall meeting.

• Public Comments. Members discussed public comments, and noted the support and interest 

about the project on “Incentive to Convert Native Ecosystems into Organic Crop Production”. 

Comments regarding the In-field, annual evaluations of inspectors update (NOP 2027) are

overwhelmingly in favor of reducing the number of inspections and removing the requirement 

that they be conducted annually. The group discussed various aspects of the document 

including uniform checklists, definitions and the confusion between peer audits and evaluations, 

as well as processes that are currently in place. 

• The meeting was adjourned

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

September 13, 2016

Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production (HB). -

Discuss draft document, vote

In-field, annual evaluations of inspectors disc doc (NOP 2027) (SR, JR).

October 11, 2016 - cancelled

November 8, 2016

December 13, 2016 

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016

NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the National List. 

They do not represent official National Organic Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, 

and status of substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday December 13, 2016, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Harriet Behar (HB); Jean Richardson (JR); Tom Chapman (TC); Emily 

Oakley (EO); A-dae Romero-Briones (ARB)

Absent: Carmela Beck (CB)

Staff: Jessica Walden (JW), Michelle Arsenault (MA)

Work Agenda

Project Contact Status Vote Meeting

In-field, annual evaluations of inspectors 

update (NOP 2027) proposal

JR/SR Approved for addition to 

work agenda 04 21 16

12 13 16 Spr 2017

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production discussion doc

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017

12 13 16 Spr 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve November 8, 2016 notes 

• Discuss/vote on proposal:- In-field, annual evaluations of inspectors update (NOP 2027)

• Discuss/vote on discussion doc: Eliminating the Incentive to Convert Native Ecosystems into 

Organic Crop Production

• Other items

Discussion

• The notes from November 8 were approved with no changes

• Discuss/vote on proposal: In-field, annual evaluations of inspectors update (NOP 2027). The 

group discussed the draft document, and the edits and suggestions made by various 

Subcommittee members. A member suggested asking the Director of AIA to participate on a 

future call after she has read the latest document. The Subcommittee moved to a vote.

Motion to approve the five recommendations in the document as amended on the call.

Motion by: JR

Seconded by: EO 

Additional discussion: none

Yes: 6 No: 0 Abstain: 0 Absent: 1 Recuse: 0 
• Discuss document on eliminating the incentive to convert native ecosystems into organic crop 

production. The group discussed the draft document, and the edits and suggestions made by 

various Subcommittee members. The lead will modify the document accordingly and will 

recirculate it for review. The CACS will vote on the discussion document in January. 

• The meeting was adjourned

Previous CACS Notes

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

November 8, 2016

December 13, 2016 

January 10, 2017

Discuss/Vote on “Eliminating the Incentive to Convert Native Ecosystems into Organic Crop 

Production” discussion doc

February 14, 2017

March 14, 2017

April 11, 2017

May 9, 2017

June 13, 2017

July 11, 2017

August 8, 2017

September 12, 2017

October 10, 2017

November 14, 2017

December 12, 2017

January 9, 2018

Spring 2017 Milestones 2017 Target date

New NOSB member orientation Feb 8, 2017

NOP - Complete Spring 2017 NOSB meeting tentative agenda Feb 10, 2017

NOSB - Spring 2017 proposals due to NOP Feb 17, 2017

NOP - Post proposals, Publish FRN, Open public comment Mar 1, 2017

Discuss work agendas on ES call Mar 17, 2017 

Public comment closes Mar 30, 2017

NOP - Send compiled public comments to NOSB Apr 5, 2017
Work agendas finalized on ES call (last call before fall meeting) Apr 7, 2017

Public comment webinar Apr 13, 2017

Spring 2017 NOSB meeting – Denver, CO Apr 19-21, 2017 (W-F)