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 13, 2024 4:00 pm ET

Present: Amy Bruch (ADB), Chair; Allison Johnson (AJ), Vice Chair; Kyla Smith (KS); Nate Lewis (NL); Jerry

D’Amore (JD); Kim Huseman (KH); Nate Powell-Palm (NPP)

Absent: Carolyn Dimitri (CD)

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

Agenda

• Review February 6, 2024 notes

• 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

• Organic Food System Capacity and Constraints Disc doc (CD) - discuss/vote

• Additional Items

• Adjourn

Discussion

• February 6, 2024 notes were modified and approved by the Subcommittee.

• Climate Induced Farming Risk and Crop Insurance discussion document (ADB for CD/AJ). The CACS 

Chair recapped the recent conversations the Subcommittee members had, and the revisions to the 

original discussion document. The CACS moved to a vote and will present the discussion document to 

the full Board at the April 2024 meeting. 

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

Motion by: ADB

Seconded by: NL

Yes: 6 No: 0 Abstain: 1 Recuse: 0 Absent: 1

• Improving Support for Organic Transition proposal (AJ). The lead presented the draft document, 

noting the updates since the last CACS meeting. The NOP and CACS discussed various aspects such as 

the role of the NOSB, the ultimate goal for this document, who the audience(s) is/are, how NOP would 

implement the recommendations, what the best format would be, and how it could be successful. The 

lead noted that the document contains aspects that are already being carried out in the TOPP 

program, and highlighted that the Organic Transition Initiative (OTI) is a bigger umbrella. The CACS is 

seeking to collect public input, so it can convey stakeholder feedback to the USDA in an effort to 

improve the feedback loop among different agencies, such as NOP, NRCS, FSA, etc. This role would 

typically belong to the USDA Organic Policy Advisor, however, that position is currently vacant. The 

NOSB Chair asked if the document would be better framed as a letter to the Secretary? Members 

suggested minor edits, and the CACS moved to a vote.

Motion to accept the proposal on Improving Support for Organic Transition

Motion by: AJ

Seconded by: JD

Yes: 7 No: 0 Abstain: 0 Recuse: 0 Absent: 1
• Residue Testing for a Global Supply Chain discussion document (NL/ADB/NPP/KH). The lead 

provided a brief summary of the document and the CACS moved to a vote on the discussion 

document. The lead will finalize the document and send it to the NOP for the Spring meeting. 

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

Motion by: NL

Seconded by: KH 

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

• Organic Food System Capacity and Constraints discussion document (NPP for CD). The group 

discussed the current version of the document and questions to stakeholders, and made minor edits. 

The NOP reminded the group of the work agenda scoping request. The CACS moved to a vote and will 

finalize the document and send it to the NOP for the Spring meeting. 

Motion to accept the discussion document on Organic Food System Capacity and Constraints 

Motion by: NPP

Seconded by: ADB 

Yes: 6 No: 0 Abstain: 1 Recuse: 0 Absent: 1 

• 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 6, 2024

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

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

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

Organic Food System Capacity and Constraints Disc doc (CD) - discuss/vote

February 13, 2024

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

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

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

Organic Food System Capacity and Constraints Disc doc (CD) - discuss/vote

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.

Milestones 

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 Discussion 

Document

Approved by Exec 

Cmmte/NOP 4.17.23

11.14.23

1.23.24

2.13.24

Spr 2024

Organic and ClimateSmart 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

2.6.24

2.13.24

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

1.9.24

2.13.24

Spr 2024

Organic Food System 

Capacity and Constraints

CD Discussion 

Document

Approved by Exec 

Cmmte 12.19.23, and 

NOP 1.16.24

1.23.24

2.13.24

Spr 2024

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, February 6, 2024 4:00 pm ET

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

Kyla Smith (KS); Nate Lewis (NL); Jerry D’Amore (JD); Nate Powell-Palm (NPP); Kim Huseman (KH)

Absent: None

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

Agenda

• Review January 23, 2024 notes

• 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

• Organic Food System Capacity and Constraints Disc doc (CD) - discuss/vote

• Additional Items

• Adjourn

Discussion 

• The January 23, 2024 notes were approved with no changes. 

• Climate Induced Farming Risk and Crop Insurance discussion document (CD). The document was 

originally a proposal, and the CACS has decided to put it forth as a discussion document for the Spring 

meeting instead. The group spent the call discussing and debating the scope and goals of the crop 

insurance project. A representative from the Risk Management Agency (RMA) spoke at the Fall 2023 

NOSB meeting and noted that the current program is not well suited to assist organic producers, and 

the NOSB is in a better position to translate the needs of organic farmers specifically. Several members 

made suggestions for how to move this document forward. One member suggested splitting the 

document in two: one with the interview data, and one with recommendations to RMA. 

The CACS will review and vote on the documents on the next call. 

• Improving Support for Organic Transition (AJ). Deferred to next call. 

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

document will be a discussion document rather than a proposal.

• Organic Food System Capacity and Constraints Disc doc (CD). 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 23, 2024

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

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

Organic Food System Capacity and Constraints (CD) - discuss

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

Organic Food System Capacity and Constraints Disc doc (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.

Milestones 

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 Discussion 

Document

Approved by Exec 

Cmmte/NOP 4.17.23

11.14.23

1.23.24

2.13.24

Spr 2024

Organic and ClimateSmart 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

2.6.24

2.13.24

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

1.9.24

2.13.24

Spr 2024

Organic Food System 

Capacity and Constraints

CD Discussion 

Document

Approved by Exec 

Cmmte 12.19.23, and 

NOP 1.16.24

1.23.24

2.13.24

Spr 2024

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, January 23, 2024 4:00 pm ET

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

Lewis (NL); Jerry D’Amore (JD); Nate Powell-Palm (NPP); Kim Huseman (KH)

Absent: None

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

Agenda

• Review January 9, 2024 notes

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

• Organic Food System Capacity and Constraints (formerly Market Development) (CD) - discuss 

discussion document

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

• Additional Items

• Adjourn

Discussion 

• January 9, 2024 notes were accepted as written. 

• Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH). The lead summarized the current 

iteration of the document which focuses on residue testing as it relates to the rollout of the 

Strengthening Organic Enforcement (SOE) rule. The document proposes suggestions for sampling and 

testing, and the co-leads are seeking information about adverse actions, which they may incorporate 

into the document as appropriate. In this document, they are not proposing to change the regulations

or handbook. The co-leads are meeting with NOP staff from the Compliance and Enforcement Division 

next week at the Accredited Certifiers Association (ACA) training to talk about the proposal and 

explore ideas. Members discussed various aspects of the proposal and offered ideas for consideration. 

Topics included: Not making things unnecessarily complex for certifiers; potential unintended 

consequences; the possibility of adding a training module to the Organic Integrity Learning Center; the 

need to keep in mind that we have a global supply chain; and the need to be mindful and methodical; 

and that this dovetails with the Strengthening Organic Enforcement (SOE) and the Transition to

Organic Partnerships Program (TOPP). The CACS will finalize the proposal on the February 6 call. 

• Organic Food System Capacity and Constraints (formerly Market Development) (CD). The lead 

introduced the draft discussion document, in which the Subcommittee asks the community to provide 

feedback about infrastructure and marketplace challenges in the organic food system. The ultimate 

goal is to provide suggestions for areas of research to the Economic Research Service that would 

support and promote organic markets and future market development grants. 

• Climate Induced Farming Risk and Crop Insurance (CD). 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 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

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

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

Organic Food System Capacity and Constraints (CD) - discuss

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

Organic Food System Capacity and Constraints Disc doc (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.

Milestones 

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

1.23.24

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

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

1.9.24

2.6.24

Spr 2024

Organic Food System 

Capacity and Constraints

CD Discussion 

Document

Approved by Exec 

Cmmte 12.19.23, and 

NOP 1.16.24

1.23.24

2.6.24

Spr 2024

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, January 9, 2024 2:00 pm ET

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

Kyla Smith (KS); Nate Lewis (NL); Jerry D’Amore (JD); Mindee Jefferey (MJ) - observer

Absent: Nate Powell-Palm (NPP); Kim Huseman (KH)

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

Agenda

• Review December 12, 2023 notes

• Guest Speakers - Kate Mendenhall (OFA): Equity and Racial Justice in Organic Transition; Ryann

Monteiro (OFA)

• Improving Support for Organic Transition (AJ) - discuss

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

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

• Organic Food System Capacity and Constraints (formerly Market Development) (CD) - discuss updated 

work agenda request

• Additional Items

• Adjourn

Discussion

• December 12, 2023 notes were accepted as written.

• Guest Speaker - Kate Mendenhall (OFA): Equity and Racial Justice in Organic Transition; Ryann 

Monteiro (OFA). Kate and Ryann provided an update about the Transition to Organic Partnership 

Program (TOPP) program, and what the central tenants are for racial diversity, identifying systemic 

racism, and barriers to organic transition & certification, acknowledging geographic barriers, and a 

country that is culturally and regionally diverse. Ryann added that racial equity and BIPOC (black, 

indigenous, and other people of color) are not the same. The 2022 Organic Farmers Association (OFA)

report contains much of the information presented today, and the 2023 report will be available soon. 

https://organicfarmersassociation.org/dei/

Both Kate and Ryann fielded questions from the CACS members, and the group discussed topics such 

as how to improve the process for certification, and how to expand the tent while still maintaining the 

integrity of the organic certificate. A member asked about NOSB’s role, given that the OFPA directs the 

NOSB to engage with certified operations and operators, and they aren’t really positioned to solve 

issues with barriers to certification. A member suggested that giving voice to the issues could be 

helpful. Another member added that the organic industry and advocates, who are in a position to

influence legislation might be in a stronger position. The group also discussed availability of resources, 

looking at grower groups as a potential model for resource sharing, market risk, building institutional 

knowledge and expertise in technical support, and international models, such as Denmark, who uses

an integrated model for organic agriculture. 

• Improving Support for Organic Transition (AJ). The lead circulated a draft in December, and will 

integrate some of the information from today’s discussion into the next iteration, which will be 

discussed again in February. 

• Climate Induced Farming Risk and Crop Insurance (CD). Deferred to next call. 

• Residue Testing for a Global Supply Chain (ADB/NPP/NL/KH). Deferred to next call.
• Organic Food System Capacity and Constraints (formerly Market Development) (CD) updated work 

agenda request. The CACS Chair submitted the work agenda request to the NOP and is awaiting a 

response about whether it is approved. Given the timeline, the CACS may not have time to work on 

this for the Spring meeting. Members had a brief discussion about the goal of the document. A 

member feels that it is within the scope of the NOSB to identify important topics that the USDA and 

Economic Research Service could work on that would benefit organic stakeholders. 

• 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).

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

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

Improving Support for Organic Transition (AJ) - discuss 

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

Organic Food System Capacity and Constraints (CD) - discuss

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

Organic Food System Capacity and Constraints (CD) - discuss

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

2.6.24

Spr 2024
Milestones

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

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

1.9.24

2.6.24

Spr 2024

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