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 10, 2017, 3:00 pm ET

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

Chapman (TC); 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, 

01 10 17

Spr 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve December 13, 2016 notes 

• Eliminating the Incentive to Convert Native Ecosystems into Organic Crop Production discussion 

doc - discuss and vote

• Other items

Discussion

• The notes from December 13 were approved with no changes.

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

discussion doc (HB). The group discussed the draft document and the changes suggested by 

Subcommittee members, which were incorporated. The lead noted that some countries do not 

allow this type of conversion, and the group can likely expect helpful comments about this 

during the public comment process. The group proceeded to a vote and will leave the vote open 

for an absent member. 

Motion to accept the document on eliminating the incentive to convert native ecosystems into 

organic crop production. 

Motion by: JR

Seconded by: HB 

Additional discussion: 

Yes: 6 No: 0 Abstain: 0 Absent: 1 Recuse: 0 
• Other Items. The group discussed sustainability language with regard to NOSB projects in 

general, and feels that the CACS could undertake this as a work agenda item. A member noted 

that it is especially relevant to the marine materials proposal. Another member added that the 

perhaps sustainability is not the correct term, as it involves social and economic aspects as well, 

and the NOSB only has purview over ecological issues. The USDA does have a definition of 

sustainability, but it seems vague. 

• Other items. The CACS Chair informed the group about the upcoming annual certifier training, 

and asked for suggestions from the group about possible topics or ideas for discussion for 

potential work agenda items. 

• The meeting was adjourned

Previous CACS Notes

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

December 13, 2016

January 10, 2017

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 10, 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)
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 14, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Harriet Behar (HB); Emily Oakley (EO); A-dae Romero-Briones (ARB)

Absent: Tom Chapman (TC)

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, 

01 10 17

Spr 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve January 10, 2017 notes 

• Update on In-field evaluation of inspectors

• Fracking and groundwater comments

• Other items

Discussion

• The notes from January 10 were approved with no changes

• Additions to agenda. A member noted topics that were discussed in the Crops proposal on 

strengthening the organic seed requirements that could potentially become a work agenda item 

for the CACS. How to help certifies, inspectors, and operators understand the protocol for 

searching for commercial availability, and the idea of continuous improvement. 

• CACS Vice Chair - Emily Oakley will be the Vice Chair for the CACS.

• Update on the in-field evaluation of inspectors proposal. During the recent Accredited 

Certifiers Association (ACA) training the NOP provided an update about the in-field evaluation 

of inspectors proposal. The CACS Chair noted that there is wide support for audits, but not the 

requirement for the frequency of the audits: every inspector/every year. The NOP is open to 

receiving alternative plans from certifiers. The CACS will be discussing its proposal at the Spring 

2017 NOSB meeting. 

• Fracking and groundwater. Based on public comment during the last couple of NOSB meetings, 

it has become clear that there is concern in the organic community in various regions in the 

country about water use in organic. Neither the Regulations nor OFPA are very specific about 

water, although contamination is mentioned in a non-specific way. The CACS members have 

concerns, but at this time are unsure how the NOSB could address this. The CACS requested 
input from the NOP on water issues, and possibly having a speaker participate on a conference 

call. 

• Other items - none

• The meeting was adjourned

Previous CACS Notes

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

January 10, 2017

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 10, 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)

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 14, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO); A-dae Romero-Briones (ARB); Tom Chapman (TC); 

Harriet Behar (HB)

Absent: none

Staff: Matt Pavone (MP), Standards Division; 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, 

01 10 17

Spr 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve February 14, 2017 notes 

• Fracking and groundwater update (EO)

• Sustainable Harvesting of Marine Materials (EO)

• Import Certificates (HB/SR)

• Uncertified Brokers & Handlers (HB/SR)

• Brief Check in RE: Update of NOP 2027

• Other items

• Adjourn

Discussion

• The notes from February 14 were approved with no changes.

• Fracking and groundwater update (EO). A member has received several communications from 

stakeholders concerned about fracking water used in irrigation. The group discussed various 

options about how the NOSB can provide input into this issue, such as perhaps putting forth a 

position statement. MA and JW will check with NOP leadership about the “incidental” uses of 

water on organic farms, which is a grey area that is not specified in the regulations. For example, 

irrigation water and other water issues.

• Sustainable harvesting of marine materials (EO). The lead summarized the history of this 

project including some feedback from a stakeholder regarding sustainability and inputs. The 

stakeholder was directed to submit comments to the open docket. A member noted that wild 

harvest is a larger issue and the Organic Regulations don’t include much guidance. The groups 
discussed various factors associated with making recommendations about marine materials, 

including the authority constraints of the NOP. 

• Import Certificates (HB/SR). The CACS Chair shared feedback from various groups regarding the 

changes to the NOP import certificates. Since this is such new guidance, the CACS will wait to 

see if there are any areas where they can provide suggestions or guidance. 

• Uncertified Brokers & Handlers (HB/SR). The group discussed this issue also in relation to the 

import certificates. 

• Update of NOP 2027. The NOP updated its instruction 2027 on March 6, which addressed some 

of the issues that were proposed in the CACS proposal that they are scheduled to discuss at the 

Spring 2017 meeting.

• Other items. None

• The meeting was adjourned

Previous CACS Notes

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

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 10, 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)
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 11, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO); Tom Chapman (TC); Harriet Behar (HB)

Absent: A-dae Romero-Briones (ARB)

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

Work Agenda

Project Contact Status Vote Meeting

In-field, annual evaluations of inspectors 

update (NOP 2027) proposal

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, 

01 10 17

Spr 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve March 14, 2017 notes 

• Further discussion re: water on an organic farm (irrigation, groundwater, well water, flood 

water)

• Review public comment

• Adjourn

Discussion

• The notes from March 14 were approved with a small edit to the conversation regarding 

fracking and groundwater.

• Water on an organic farm (irrigation, groundwater, well water, flood water). The CACS 

discussed the best way to approach the evaluation of water sources, and possible paths 

forward. The NOP reviewed OFPA to determine if there is any guidance or language regarding 

contamination or irrigation water; noting the lack of specificity on this issue. The NOP also noted 

that in global organic standards there is an absence of regulations regarding these issues. The 

CACS discussed various opportunities for input into this problem. The challenge is that it must 

fall within the scope of the USDA’s authority. The CACS members will discuss this more with 

stakeholders to determine if there is a section in OFPA that could be addressed. 

• Public comment. Members discussed a public comment regarding the 5-year-long waiting time 

for conversion in the discussion document on conversion of native ecosystems to organic crop 

production. The commenter noted that OFPA says 3 years, and the discussion document 
suggests a 5-year conversion. The CACS discussed whether or not they could restrict the 

regulations further. The NOP will review the issue, and provide feedback to the Subcommittee. 

• Other items. Members discussed the proposal on in-field, annual evaluations of inspectors (NOP 

2027), since some of the issues in the proposal were addressed by the NOP in the convening 

months since the proposal was completed. 

• The meeting was adjourned

Previous CACS Notes

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

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 10, 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)
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 9, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO); Tom Chapman (TC); Harriet Behar (HB); Dave 

Mortensen (DM) - observer

Absent: A-dae Romero-Briones (ARB)

Staff: Jessica Walden (JW); Michelle Arsenault (MA); Devon Pattillo (DP) 

Work Agenda

Project Contact Status Vote Meeting

In-field, annual evaluations of inspectors 

update (NOP 2027) proposal. 

Inspector qualifications

SR Approved for addition to 

work agenda 04 21 16. 

Referred back to LS at Spr 

2017 meeting

Fall 2017

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production proposal

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017.

Fall 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve April 11, 2017 notes 

• Denver meeting debrief

• Discussion re: proposal referred back to SC: Eliminating the Incentive to Convert Native 

Ecosystems/High Value Conservation Land to Organic Production

• Discussion re: Inspector Qualifications (if time allows)

• Other items

• Adjourn

Discussion

• Personnel update. JW will be leaving NOP at the end of May, and DP will be the technical 

representative on the CACS calls. 

• The notes from April 11 were approved with no changes

• Denver meeting debrief. 

o Members discussed comments that were received at the Denver meeting regarding

exempt operations, and whether or not this is a topic they would add to the work 

agenda. Members were supportive of further work, and the CACS Chair will write a 

justification request for discussion on a future Executive call. 

o A member noted that she has had continuing conversations with stakeholders regarding 

fracking and the marine algae proposal. The docket for the next meeting has not yet 

opened, so the lead will ask that they provide any information to her directly, and then 
eventually submit comments to the public docket. This topic, while important to organic 

agriculture, is somewhat out of the scope of the NOSB and USDA, so the Subcommittee

is considering ideas on how to get involved. 

• Eliminating the Incentive to Convert Native Ecosystems/High Value Conservation Land to 

Organic Production. The group discussed the various issues surrounding this very complex topic, 

including the regulatory authority that the USDA has, and what role the NOSB could have. The 

CACS Chair discussed how to scope this topic and how to move forward. HB will continue to 

work on the document and the group will discuss on the next call. 

• Inspector Qualifications. The lead noted that the CACS received useful comments and feedback 

from the NOP at the Spring meeting in Denver on the in-field, annual evaluations of inspectors 

(NOP 2027) proposal. Since the NOP made changes prior to the meeting, the proposal was sent 

back to Subcommittee and will be re-scoped to focus on inspector qualifications. The CACS Chair

noted that there has been a lot of work done in this area already, and the CACS will build upon 

that work. 

• Other items. A member noted that for the next call they would like to discuss the recent news 

story about the certification of an organic dairy. 

• The meeting was adjourned

Previous CACS Notes

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

April 11, 2017

May 9, 2017

June 13, 2017

Eliminating the Incentive to Convert Native Ecosystems/High Value Conservation Land to 

Organic Production.

July 11, 2017

August 8, 2017

September 12, 2017

October 10, 2017

November 14, 2017

December 12, 2017

January 9, 2018

Fall 2017 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~May 5, 2017

NOSB Request for TRs for 2020 sunset materials July 17, 2017

NOP - Complete Fall 2017 NOSB meeting tentative agenda Aug 11, 2017

NOSB - Fall 2017 proposals due to NOP Aug 29, 2017

NOP - Post proposals On or before Sep 12, 2017

Public comment closes Oct 11, 2017

Discuss/finalize work agendas on ES call Oct 13, 2017
NOP - Send compiled public comments to NOSB Oct 16, 2017

Two Public comment webinars Oct 24, and if needed 26, 

2017

Fall 2017 NOSB meeting - Jacksonville, FL Oct 31- Nov 2, 2017
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 13, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO); Tom Chapman (TC); Harriet Behar (HB); A-dae 

Romero-Briones (ARB)

Absent: none

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

Work Agenda

Project Contact Status Vote Meeting

Inspector qualifications SR Approved for addition to 

work agenda 04 21 16. 

Referred back to CACS at Spr 

2017 meeting

Fall 2017

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production proposal

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017.

Fall 2017

Exempt/uncertified handlers and 

brokers

SR Discussion doc. NOP 

approved addition to the 

work agenda 05 19 17

Fall 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve May 9, 2017 notes 

• Eliminating the Incentive to Convert Native Ecosystems/High Value Conservation Land to 

Organic Production (HB).

• Exempt Operations in the Supply Chain (SR)

• Inspector Qualifications

• Other items

• Adjourn

Discussion

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

• Eliminating the Incentive to Convert Native Ecosystems/High Value Conservation Land to 

Organic Production (HB). The CACS members had a lengthy conversation about how to move 

forward with this project. Members discussed how to work within the scope of OFPA and the 

Organic regulations while preventing the conversion of native ecosystems for organic 

production. The group considered incentives, disincentives and the potential long-term 

implications under various options. 
• Exempt Operations in the Supply Chain (Exempt/uncertified handlers and brokers) (SR). The 

CACS Chair noted that the topic of fraud in the supply chain (based on the recent investigation 

into grain imports from Turkey) has the organic community concerned and engaged. The lead 

noted that certified operations, and not exempt operations, have been implicated in the 

investigation. The CACS is considering a rule change that removes some of the exemptions, as 

well as guidance for organic operations regarding exemptions. SR, with assistance from TC, will 

develop a draft document for the group to discuss on the next CACS call. 

• Inspector Qualifications (SR). The CACS is working on a proposal to address inspector 

qualifications. This project was initially part of a previous proposal on In-field, annual 

evaluations of inspectors (NOP 2027). To support this project work, the NOP provided the 

Subcommittee with a report prepared for the NOP by the International Organic Inspectors 

Association (IOIA) in 2011. The CACS will invite the Deputy Administrator to a future CACS call to 

discuss the report and provide further guidance. A member added that in addition to 

inspectors, reviewers are also a key component of the certification process, and should also be 

considered. 

• Other items. Water/Fracking (TC). The NOSB Chair recently reviewed the original congressional 

conference report on OFPA and noted that a section about water was eliminated from the 

Senate version of the bill in conference committee. The members shared various ideas about 

ways in which the NOSB could address water in organic agriculture while staying within the 

scope of OFPA. 

• The meeting was adjourned

Previous CACS Notes

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

May 9, 2017

June 13, 2017

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production.

July 11, 2017

Exempt operations in the supply chain (Exempt/uncertified handlers and brokers)

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production

Inspector qualifications

August 8, 2017

September 12, 2017

October 10, 2017

November 14, 2017

December 12, 2017

January 9, 2018

Fall 2017 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~Apr 27, 2017, May 30, 2017

NOSB Request for TRs for 2020 sunset materials July 18, 2017

NOP - Complete Fall 2017 NOSB meeting tentative agenda Aug 11, 2017
NOSB - Fall 2017 proposals due to NOP Aug 29, 2017

NOP - Post proposals On or before Sep 12, 2017

Public comment closes Oct 11, 2017

Discuss/finalize work agendas on ES call Oct 13, 2017

NOP - Send compiled public comments to NOSB Oct 16, 2017

Two Public comment webinars Oct 24, and if needed 26, 

2017

Fall 2017 NOSB meeting - Jacksonville, FL Oct 31- Nov 2, 2017
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the National List. 

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

and status of substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday July 11, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO); Tom Chapman (TC); Harriet Behar (HB)

Absent: A-dae Romero-Briones (ARB)

Staff: Michelle Arsenault (MA); Lisa Brines (LB); Miles McEvoy (MM)

Work Agenda

Project Contact Status Vote Meeting

Inspector qualifications proposal SR Approved for addition to 

work agenda 04 21 16. 

Referred back to CACS at Spr 

2017 meeting

Spr 2018

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production proposal

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017.

Fall 2017

Exempt/uncertified handlers and 

brokers. Discussion document.

SR/TC NOP approved addition to 

the work agenda 05 19 17

Fall 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve June 13, 2017 notes 

• Exempt operations in the supply chain (Exempt/uncertified handlers and brokers)

• Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production

• Inspector qualifications

• Other items

• Adjourn

Discussion

• The notes from June 13 were approved with no changes.

• Exempt operations in the supply chain (Exempt/uncertified handlers and brokers) (SR). No 

update or forward movement at this time. The CACS will revisit this topic on the next call. 

• Eliminating the incentive to convert native ecosystems/high value conservation land to 

organic production (HB). Several members have researched other international organic 

standards and how this topic is addressed. The group is working on developing language to 

address the most critical areas, so they can get support from the community while still working 

within OFPA. Members discussed various details and scope of the project. HB will develop ideas 

for discussion on the next call.
• Inspector qualifications (SR). The NOP offered some additional history and perspective on the 

2011 IOIA document that was provided to the CACS as they work on inspector qualifications. 

The NOP did not implement the 2011 guidance, and has asked that the CACS address one 

component of this topic: inspector qualifications. A member added that reviewers are also an 

important component in the process, and suggested that it be included in the review. The goal 

for this document would be a concise, succinct guidance document that could be used as part of 

a comprehensive training system. Currently IOIA, NOP and individual certifiers all do separate 

training. The NOP noted that the IOIA contains useful elements, such as the auditor 

qualifications and auditor-in-training documents, which also align with ISO requirements. The 

group discussed next steps and based on today’s conversation, may address this project at the 

Spring 2018 meeting. 

• Other Items. The CACS added an additional call on August 22. 

• The meeting was adjourned

Previous CACS Notes

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

June 13, 2017

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production.

July 11, 2017

Exempt operations in the supply chain (Exempt/uncertified handlers and brokers)

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production

Inspector qualifications

August 8, 2017

Exempt operations in the supply chain (Exempt/uncertified handlers and brokers) (SR).

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production

August 22, 2017 additional call.

September 12, 2017

October 10, 2017

November 14, 2017

December 12, 2017

January 9, 2018

Fall 2017 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~Apr 27, 2017, May 30, 2017

NOSB Request for TRs for 2020 sunset materials July 19, 2017

NOSB public teleconference Aug 14, 2017

NOP - Draft Fall 2017 NOSB meeting tentative agenda Aug 11, 2017

NOSB - Fall 2017 proposals due to NOP Aug 29, 2017

NOP - Post proposals On or before Sep 12, 2017
Public comment closes Oct 11, 2017

Discuss/finalize work agendas on ES call Oct 13, 2017

NOP - Send compiled public comments to NOSB Oct 16, 2017

Two Public comment webinars Oct 24, and if needed 26, 2017

Fall 2017 NOSB meeting - Jacksonville, FL Oct 31- Nov 2, 2017
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 8, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO); Tom Chapman (TC); Harriet Behar (HB); A-dae 

Romero-Briones (ARB)

Absent: none

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

Work Agenda

Project Contact Status Vote Meeting

Inspector qualifications proposal SR Approved for addition to 

work agenda 04 21 16. 

Referred back to CACS at Spr 

2017 meeting

Jul 11 Spr 2018

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production. Proposal

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017.

Aug 8, 

Aug 22

Fall 2017

Exempt/uncertified handlers and 

brokers. Discussion document.

SR/TC NOP approved addition to 

the work agenda 05 19 17

Aug 8, 

Aug 22

Fall 2017

NOP operating plan suggestions ALL NA NA

Agenda

• Approve July 11, 2017 notes 

• Exempt operations in the supply chain (Exempt/uncertified handlers and brokers) (SR).

• Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production

• Adjourn

Discussion

• The notes from July 11 were approved with no changes.

• Exempt operations in the supply chain (Exempt/uncertified handlers and brokers) (SR). The 

group discussed the draft document on exempt operations. With regard to the subject of 

fraudulent imports, the NOP and the community are addressing this issue, and the Board is 

considering ways in which it can address it as well. The current focus for the CACS is a document 

with a more limited scope - excluded operations. The group discussed the questions that they 

would like to ask of the public and discussed the various types of excluded operations such as

brokers and transit operations. A member offered to forward an opinion piece she wrote on this 

topic. The CACS will discuss and vote on the document on the next call. 

• Eliminating the incentive to convert native ecosystems/high value conservation land to 

organic production (HB). The lead summarized the draft document, and the group suggested 

some edits and additions. Members discussed various aspects such as definitions of high value, 

time restrictions, land requirements, and wild crops. The CACS will continue to discuss it on the 

next call, before bringing it to a vote. 
• The meeting was adjourned

Previous CACS Notes

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

July 11, 2017

Exempt operations in the supply chain (Exempt/uncertified handlers and brokers)

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production

Inspector qualifications

August 8, 2017

Exempt operations in the supply chain (Exempt/uncertified handlers and brokers) (SR).

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production

August 22, 2017 additional call

Exempt operations in the supply chain (Exempt/uncertified handlers and brokers) (SR). Discuss 

and vote

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production, Discuss and vote.

September 12, 2017

October 10, 2017

November 14, 2017

December 12, 2017

January 9, 2018

Fall 2017 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment May 30, 2017

NOSB Request for TRs for 2020 sunset materials July 19, 2017

NOSB public teleconference Aug 14, 2017

NOP - Draft Fall 2017 NOSB meeting tentative agenda Aug 11, 2017

NOSB - Fall 2017 proposals due to NOP Aug 29, 2017

NOP - Post proposals On or before Sep 12, 2017

Public comment closes Oct 11, 2017

Discuss/finalize work agendas on ES call Oct 13, 2017

NOP - Send compiled public comments to NOSB Oct 16, 2017

Two Public comment webinars Oct 24, and if needed 26, 2017

Fall 2017 NOSB meeting - Jacksonville, FL Oct 31- Nov 2, 2017
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 22, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO); Tom Chapman (TC); Harriet Behar (HB); A-dae 

Romero-Briones (ARB)

Absent: none

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

Work Agenda

Project Contact Status Vote Meeting

Inspector qualifications proposal SR Approved for addition to 

work agenda 04 21 16. 

Referred back to CACS at Spr 

2017 meeting

Jul 11 Spr 2018

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production. Proposal

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017.

Aug 8, 

Aug 22,

Aug 29

Fall 2017

Excluded/uncertified handlers. 

Discussion document

SR/TC NOP approved addition to 

the work agenda 05 19 17

Aug 8, 

Aug 22,

Aug 29

Fall 2017

Imports Memo sent to NOSB 08 10

17

TBD TBD

NOP operating plan suggestions ALL NA NA

Agenda

• Approve August 8, 2017 notes 

• Excluded operations in the supply chain (uncertified handlers) (SR).

• Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production

• Marine Materials for Handling - move this discussion to HS notes.

• Adjourn

Discussion

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

• Excluded operations in the supply chain (uncertified handlers) (SR). The CACS discussed the 

memo from the NOP requesting that the NOSB add a work agenda item regarding imports. The 

document on excluded operations overlaps with imports but does not address imports

specifically. The CACS discussed ways in which it could address this topic, perhaps without 

recommending a rule change. The CACS will continue the discussion and vote on the discussion 

document on exempt operations on the August 29 call. 
• Eliminating the incentive to convert native ecosystems/high value conservation land to 

organic production (HB). Members provided feedback and edits to the draft document. The 

group discussed the addition of language about economic impacts. Members asserted that 

converting land that has already been in agricultural production, as opposed to clearing native 

ecosystems for agricultural production, would be much less economically impactful. The NOP 

must consider economic impacts when conducting rulemaking. The CACS will continue the 

discussion and vote on the August 29 call. 

• Other items: The CACS will add another call on August 29.

• The meeting was adjourned

Previous CACS Notes

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

August 8, 2017

Exempt operations in the supply chain (Exempt/uncertified handlers and brokers) (SR).

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production

August 22, 2017 additional call

Exempt operations in the supply chain (Exempt/uncertified handlers and brokers) (SR). Discuss 

and vote

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production, Discuss and vote.

August 29, 2017 - Additional call

Excluded operations in the supply chain (uncertified handlers) disc doc (SR) - Discuss and vote

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production - Discuss and vote.

September 12, 2017

October 10, 2017

November 14, 2017

December 12, 2017

January 9, 2018

Fall 2017 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment May 30, 2017

NOSB Request for TRs for 2020 sunset materials July 19, 2017

NOSB public teleconference Aug 14, 2017

NOP - Draft Fall 2017 NOSB meeting tentative agenda Aug 11, 2017

NOSB - Fall 2017 proposals due to NOP Aug 29, 2017

NOP - Post proposals On or before Sep 12, 2017
Public comment closes Oct 11, 2017

Discuss/finalize work agendas on ES call Oct 13, 2017

NOP - Send compiled public comments to NOSB Oct 16, 2017

Two Public comment webinars Oct 24, and if needed 26, 2017

Fall 2017 NOSB meeting - Jacksonville, FL Oct 31- Nov 2, 2017
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 29, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO); Tom Chapman (TC); Harriet Behar (HB); Sue Baird 

(SB) - observer 

Absent: A-dae Romero-Briones (ARB)

Staff: Michelle Arsenault (MA); Devon Pattillo (DP); Paul Lewis (PL) 

Work Agenda

Project Contact Status Vote Meeting

Inspector qualifications proposal SR Approved for addition to 

work agenda 04 21 16. 

Referred back to CACS at Spr 

2017 meeting

Jul 11 Spr 2018

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production. Proposal

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017.

Aug 8, 

Aug 22,

Aug 29

Fall 2017

Excluded/uncertified handlers. Proposal SR/TC NOP approved addition to 

the work agenda 05 19 17

Aug 8, 

Aug 22,

Aug 29

Fall 2017

Imports Memo sent to NOSB 08 10

17

TBD TBD

NOP operating plan suggestions ALL NA NA

Agenda

• Approve August 22, 2017 notes 

• Excluded operations in the supply chain (uncertified handlers) disc doc (SR) - Discuss and vote

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production - Discuss and vote.

• Adjourn

Discussion

• The notes from August 22 were approved with no changes. 

• Eliminating the incentive to convert native ecosystems to organic production. The lead 

summarized the changes that were made since the last discussion and the members discussed

the current iteration of the document. The group made some modifications to the language and 

proceeded to a vote. The NOP asked about the choice of a 10-year wait period and also asked 

whether the Subcommittee had considered a recommendation for guidance (vs. rulemaking). 
The group noted that they considered addressing this issue via guidance but did not see a path 

forward.

Motion to accept the proposal on eliminating the incentive to convert native ecosystems to 

organic production. 

Motion by: HB

Seconded by: TC

Additional discussion: none

Yes: 4 No: 0 Abstain: 0 Absent: 1 Recuse: 0 

• Excluded operations in the supply chain (uncertified handlers) (SR). The group discussed the 

draft document and made minor edits to the language. Members chose to put this forth as a 

proposal rather than a discussion document. 

Motion to accept the proposal on excluded operations in the supply chain (uncertified handlers)

Motion by: TC

Seconded by: HB

Additional discussion: none

Yes: 4 No: 0 Abstain: 0 Absent: 1 Recuse: 0 

• Other items. The CACS cancelled the September 12 call.

• The meeting was adjourned

Previous CACS Notes

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

August 22, 2017 additional call

Exempt operations in the supply chain (Exempt/uncertified handlers and brokers) (SR). Discuss 

and vote

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production, Discuss and vote.

August 29, 2017 - Additional call

Excluded operations in the supply chain (uncertified handlers) disc doc (SR) - Discuss and vote

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production - Discuss and vote.

September 12, 2017 - cancelled

October 10, 2017

November 14, 2017

December 12, 2017

January 9, 2018
Fall 2017 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment May 30, 2017

NOSB Request for TRs for 2020 sunset materials July 19, 2017

NOSB public teleconference Aug 14, 2017

NOP - Draft Fall 2017 NOSB meeting tentative agenda Aug 11, 2017

NOSB - Fall 2017 proposals due to NOP Aug 29, 2017

NOP - Post proposals On or before Sep 12, 2017

Public comment closes Oct 11, 2017

Discuss/finalize work agendas on ES call Oct 13, 2017

NOP - Send compiled public comments to NOSB Oct 16, 2017

Two Public comment webinars Oct 24, and if needed 26, 2017

Fall 2017 NOSB meeting - Jacksonville, FL Oct 31- Nov 2, 2017
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 October 10, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO), Vice Chair; Tom Chapman (TC); Harriet Behar (HB);

A-dae Romero-Briones (ARB)

Absent: none 

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

Work Agenda

Project Contact Status Vote Meeting

Inspector qualifications proposal SR Approved for addition to 

work agenda 04 21 16. 

Referred back to CACS at Spr 

2017 meeting

Jul 11 Spr 2018

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production. Proposal

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017.

Aug 8, 

Aug 22,

Aug 29

Fall 2017

Excluded/uncertified handlers. Proposal SR/TC NOP approved addition to 

the work agenda 05 19 17

Aug 8, 

Aug 22,

Aug 29

Fall 2017

Imports Memo sent to NOSB 08 10

17

TBD TBD

NOP operating plan suggestions ALL NA NA

Agenda

• The notes from August 29 were approved via email after the call 

• Public comments. 

• Excluded/uncertified handlers. 

• Inspector Qualifications (SR)

• Fracking (EO, ABR)

• Imports (8/10/17 NOP memo)

• Other items

• Adjourn

Discussion

• The notes from August 29 were approved via email after the call 

• Public comments. The group discussed the comments briefly, specifically for the proposal on 

eliminating the incentive to convert native ecosystems into organic crop production. 
• Excluded/uncertified handlers. The group discussed comments received to date on the 

proposal. Some stakeholders have provided feedback that the CACS’s recommendations should 

be broader than the changes proposal in the document for the Fall 2017 meeting. Members 

acknowledged that further work will be needed and acknowledged that the direction of future 

work may be influenced by changes under the Farm Bill and interest in imports. 

• Inspector Qualifications (SR). Members discussed how to proceed with their proposal on 

inspector qualifications from the Spring 2017 meeting. Members discussed how inspector 

qualifications relate to the size and complexity of the organic operations they inspect. The CACS 

will continue work on this topic after the Fall meeting. 

• Imports (8/10/17 NOP memo). The NOP is holding a panel at the Fall NOSB meeting and there 

will be four government panelists: one each from NOP, APHIS, Specialty Crops, and Customs and 

Boarder Protection. The NOSB Chair asked that folks prepare possible questions for the panelists 

if they have any, and send those to him by Friday, October 13. 

• Fracking and Water Issues (EO, ABR). This issue was initially raised by the organic community, 

and the NOSB agrees that it is important to address. At the Denver meeting the CACS had asked 

the community to provide input about where within the regulation the CACS could address this 

issue. Members noted that several organizations are working on comments to the NOSB on this 

topic. The group discussed how best to move forward and will continue to discuss this issue 

before submitting a request to add it to the work agenda. 

• Other items. None

• The meeting was adjourned

Previous CACS Notes

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

August 29, 2017 - Additional call

Excluded operations in the supply chain (uncertified handlers) disc doc (SR) - Discuss and vote

Eliminating the incentive to convert native ecosystems/high value conservation land to organic 

production - Discuss and vote.

September 12, 2017 - cancelled

October 10, 2017

November 14, 2017

Imports - discussion (TC on travel)

December 12, 2017

Imports

Inspector qualifications

January 9, 2018

February 13, 2018

Fall 2017 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment May 30, 2017

NOSB Request for TRs for 2020 sunset materials July 19, 2017
NOSB public teleconference Aug 14, 2017

NOP - Draft Fall 2017 NOSB meeting tentative agenda Aug 11, 2017

NOSB - Fall 2017 proposals due to NOP Aug 29, 2017

NOP - Post proposals On or before Sep 12, 2017

Public comment closes Oct 11, 2017

Discuss/finalize work agendas on ES call Oct 13, 2017

NOP - Send compiled public comments to NOSB Oct 16, 2017

Two Public comment webinars Oct 24, and if needed 26, 2017

Fall 2017 NOSB meeting - Jacksonville, FL Oct 31- Nov 2, 2017
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 28, 2017, 3:00 pm ET

Attending: Emily Oakley (EO), vice chair; Tom Chapman (TC)

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

Staff: Michelle Arsenault (MA); Devon Pattillo (DP); Jenny Tucker (JT); Betsy Rakola (BR)

Work Agenda

Project Contact Status Vote Meeting

Inspector qualifications proposal SR Approved for addition to 

work agenda 04 21 16. 

Referred back to CACS at Spr 

2017 meeting

Jul 11 Spr 2018

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production. Proposal

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017. Proposal Fall 

2017. Referred back to CACS 

at Fall 2017 meeting

Spr 2018

Imports Memo sent to NOSB 08 10

17

TBD Spr 2018

Agenda

• Approve notes from October 10 

• Ecosystem/Inspector Qualifications next steps

• Imports next steps:

o Co-packer/Industry panel

o 4 Options from NOP as presented at the NOSB meeting

o Program feedback on supply chain integrity issues (JT, BR)

• Other items

• Adjourn

Discussion

• Approval of the notes from October 10 was deferred to the next call.

• Inspector Qualifications next steps. Deferred to next call. 

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

CACS is evaluating public comments and considering next steps for the proposal that was 

referred back to CACS at the fall meeting. The NOP noted that if the CACS wants to propose 
rulemaking the justification needs to be robust and the benefits need to outweigh costs and/or 

address a market failure.

• Imports. The group discussed next steps with regard to imports, which is of great interest to the 

NOP and USDA.

o Co-packer/Industry panel. The NOSB Chair noted the need for more dialogue with 

public, industry, and certifiers. The CACS would like to assemble a panel of industry and 

certifier representatives, and the NOP noted that the Spring 2018 meeting would be the 

best time to convene the panel. This will allow time for selection of panelists and for the 

Board to develop appropriate questions for the panel. Members discussed that it will 

likely be easier to tackle this broad topic by developing several smaller proposals to 

address specific problems. 

o Project topics, as presented by NOP at the NOSB meeting; Program feedback on 

supply chain integrity issues (JT, BR). The group discussed the best path forward, 

beginning with determining a scope for the projects. A primary issue is the complexity of 

the supply chains. Some specific challenges include the paper trail and documentation 

of organic status as product is bought and sold by multiple entities (sometimes 

uncertified brokers/traders) and as it passes through international borders. The NOSB is 

interested in finding resources about documentation required for imports, which is a 

complex problem in and of itself. As part of its review, the NOP is looking at document 

trails, including phytosanitary certificates, bills of lading, invoices, etc. Also of interest is 

what tools the industry is currently using. The NOP noted that part if the complexity lies 

in the distinction between product-level certification vs. process-based certification. The 

CACS would like to post questions to the open docket, and discussed how best to 

communicate the request for feedback on specific topics from stakeholders. The NOP 

will explore the options to coincide with the opening of the next meeting docket. JT will 

work with BR to refine the four suggested items, and possibly other ideas, and send 

them to the CACS. The NOSB Chair asked that the NOP provide the names of experts 

who can provide additional information to the CACS regarding the various potential 

topic areas. JT will develop a project plan and timeline for panel invitations.

• Other items. None

• The meeting was adjourned

Previous CACS Notes

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

October 10, 2017

November 14, 2017 - cancelled

November 28, 2017 - additional call

December 12, 2017

Imports

Inspector qualifications

December 26, 2017- additional call

January 9, 2018

January 23, 2018 - additional call

January 30, 2018 - additional call

February 13, 2018
February 27, 2018 - additional call

March 13, 2018

April 10, 2018

May 8, 2018

June 12, 2018

July 10, 2018

August 14, 2018

September 11, 2018

October 9, 2018

November 13, 2018

December 11, 2018

Spring 2018 Milestones Target dates (tentative)

New NOSB member orientation TBD

NOSB - Spring 2018 proposals due to NOP Feb 21, 2018

NOP - Complete Spring 2018 NOSB meeting tentative agenda Mar 6, 2018

NOP - Post proposals, “Open” public comment Mar 6, 2018

Discuss work agendas on ES call Mar 9, 2018

Public comment closes Apr 4, 2018

NOP - Send compiled public comments to NOSB Apr 9, 2018

Work agendas finalized on ES call (last call before fall meeting) Apr 13, 2018

Public comment webinar(s) Apr 17 & 19, 2018

Spring 2018 NOSB meeting – Tucson, AZ Apr 25-27, 2018
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 12, 2017, 3:00 pm ET

Attending: Scott Rice (SR), Chair; Emily Oakley (EO), vice chair; A-dae Romero-Briones (ARB); Tom 

Chapman (TC); Harriet Behar (HB)

Absent: Jenny Tucker (JT)

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

Work Agenda

Project Contact Status Discussion,

Vote

Meeting

Inspector qualifications proposal SR Approved for addition to 

work agenda 04 21 16. 

Referred back to CACS at 

Spr 2017 meeting

Dec 12 Spr 2018

Eliminating the Incentive to Convert 

Native Ecosystems into Organic Crop 

Production. Proposal

HB Approved for addition to 

work agenda 07 15 16.

Verbal update Fall 2016. DD 

Spr 2017. Proposal Fall 

2017. Referred back to CACS 

at Fall 2017 meeting

Nov 28 Spr 2018

Imports ALL Memo sent to NOSB 08 10

17

Nov 28 Spr 2018

*Discussed *Voted

Agenda

• Approve notes from October 10

• Approve notes from November 28 

• Inspector Qualifications next steps

• Imports

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

• Other items

• Adjourn

Discussion

• Notes from October 10 were approved with no changes. 

• Notes from November 28 notes were approved with a date correction under the imports topic.

• Inspector qualifications next steps (SR). The group discussed some ideas for the next iteration 

of the proposal on inspector qualifications. Members suggested such things as guidance and

best practices for inspectors about scale of operations. A member stressed the importance of 

such training, which can build stronger and more confident relationships between operations 

and inspectors. Another member mentioned several other standards, such as Global G.A.P.,
suggesting that it would be helpful to know how other certification schemes address inspector 

training and qualifications. The lead will develop an outline or draft for the next call.

• Imports. The group discussed the next steps with regard to imports. The NOP refined the four 

broader topics that were proposed at the Fall 2017 meeting to help focus in on areas where the 

CACS could develop a recommendation(s). Several questions came up during the conversation 

as the group tried to identify how to best address this broad topic. A member questioned how 

the EU verified organic certification for goods exported from countries that have been 

implicated in fraudulent behavior. Another member asked if there could be useful information 

from the recent meeting in Odessa, Ukraine, and HB agreed to reach out to participants of that 

meeting. 

As the discussion continued, there was some uncertainty as to how the NOSB could best provide 

feedback given the size and complexity of the topic. A member felt that the very idea that the 

USDA/NOSB is attempting to close the gaps could act as a deterrent to fraud. Another member 

discussed the implicit level of trust that exists within the organic community and suggested that

perhaps verification needs to be enhanced, which would also provide a deterrent. The NOSB 

Chair is reaching out to industry representatives who have experience in international trade in 

an effort to gather more information. The CACS would also like to invite experts to the 

Subcommittee calls to provide additional insight. There was a request that the program 

prioritize the bulleted list of possible topics, and provide additional input about other activities 

at the USDA regarding imports. 

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

lead discussed the feedback that the CACS received at the Fall 2017 NOSB meeting, and 

indicated she was developing ideas for the next iteration of the proposal to include some of

these suggestions. The lead invited feedback about the path forward. The group discussed the 

inclusion of a definition of native ecosystem. The NOSB Chair suggested looking at how this 

issue may be affecting domestic farmers economically as compared to international farmers

(given that most destruction of native ecosystems is international). A member urged the group 

to write the proposal they want to see go forth, with the acknowledgement that it likely won’t 

go forward as rulemaking in the near future. 

• Other items. None

• The meeting was adjourned

Previous CACS Notes

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

November 28, 2017 - additional call

December 12, 2017

Imports

Inspector qualifications

December 26, 2017- additional call

Imports discussion (ALL)

Inspector qualifications (SR)

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

January 9, 2018

January 23, 2018 - additional call

January 30, 2018 - additional call
February 13, 2018

February 27, 2018 - additional call

March 13, 2018

April 10, 2018

May 8, 2018

June 12, 2018

July 10, 2018

August 14, 2018

September 11, 2018

October 9, 2018

November 13, 2018

December 11, 2018

Spring 2018 Milestones Target dates (tentative)

New NOSB member orientation TBD

NOSB - Spring 2018 proposals due to NOP Feb 21, 2018

NOP - Complete Spring 2018 NOSB meeting tentative agenda Mar 6, 2018

NOP - Post proposals, “Open” public comment Mar 6, 2018

Discuss work agendas on ES call Mar 9, 2018

Public comment closes Apr 4, 2018

NOP - Send compiled public comments to NOSB Apr 9, 2018

Work agendas finalized on ES call (last call before fall meeting) Apr 13, 2018

Public comment webinar(s) Apr 17 & 19, 2018

Spring 2018 NOSB meeting – Tucson, AZ Apr 25-27, 2018