Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB recommendations. Proposals 

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, December 14, 2021 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Steve Ela (SE); Nate 

Powell-Palm (NPP); Kyla Smith (KS); Mindee Jeffery (MJ) - observer; Logan Petrey (LP) - observer

Absent: 

Staff: Laura Gallagher (LG); Andrea Holm (AH)

Agenda

• November 9th, 2021 notes

• Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB/NPP)

• Finalize Potential Work Agenda Topics (AB)

o (1) Organic Links

o (2) Human Capital NOSB support (CD/NPP)

o (3) Equity and (4) Climate Change (CD)

o (5) Universal Bill of Lading and (6) Mass Balance/Traceback

o (7) Auditor Math Qualifications - Calculating Nitrogen

o (8) Native Eco-Systems

• Additional Items

• Adjourn

Discussion

• November 9th, 2021 notes were accepted as written

• Oversight improvements to deter fraud: Modernization of organic traceability infrastructure 

(ADB/NPP) - Members discussed block chain technology.

• Finalize Potential Work Agenda Topics (ADB) - For the suggested agenda items below, members 

discussed possible next steps, open docket options, and their capacity to complete documents before 

the next NOSB meeting. Members anticipate that the NOP Priorities Federal Register Notice may guide 

future conversation.

o (1) Organic Links - The CACS Chair discussed opportunities for receiving feedback from 

stakeholder communities.

o (2) Human Capital NOSB Support (CD/NPP) - Members discussed requesting support with the 

international acceptance portion of sunset reviews.

o (3) Equity and (4) Climate Change (CD) - The lead will bring these topics back to CACS on a later 

call.

o (5) Universal Bill of Lading and (6) Mass Balance/Traceback - Members discussed mass 

balance/traceback and the possibility of developing guidance or requirements for bills of lading 

to contain specific information. Members discussed organic recordkeeping requirements versus 

Food Safety Modernization Act (FSMA) recordkeeping requirements. CACS may develop a 

discussion document on this topic.

o (7) Auditor Math Qualifications - Calculating Nitrogen - This potential NOSB Work Agenda topic 

was not discussed during the call.

o (8) Native Eco-Systems - Members discussed the relationship between native eco-systems, 

organic wild crop regulations, and the Organic Foods Production Act (OFPA) language on the 

transition of land.

• Additional Items - None

• The meeting was adjourned
Previous CACS Notes

Future call schedule (2nd Tuesday 2:00 PM ET | 11:00 AM PT, except where noted.) 

November 9, 2021

Debrief of Fall 2021 NOSB Meeting

December 14, 2021

Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB/NPP)

Finalize Potential Work Agenda Topics (AB)

(1) Organic Links

(2) Human Capital NOSB support (CD/NPP)

(3) Equity and (4) Climate Change (CD)

(5) Universal Bill of Lading and (6) Mass Balance/Traceback

(7) Auditor Math Qualifications - Calculating Nitrogen

(8) Native Eco-Systems 

January 11, 2022

February 08, 2022

March 08, 2022

April 12, 2022

May 10, 2022

June 14, 2022

July 12, 2022

August 09, 2022

September 13, 2022

October 11, 2022

November 08, 2022

December 13, 2022

Work Agenda

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

and/or vote.

Project Contact Doc Type Notes* 

Scheduled, 

Discussed, 

Voted

Target

meeting 

Oversight improvements to 

deter fraud: Modernization of 

organic traceability 

infrastructure

ADB/NPP Discussion 

Document

08.10.17 NOP Memo to CACS 11.9.21

12.14.21

TBD

Spr 2022

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal 

TBD TBD 07.31.20 NOP Memo to CACS. 

Proposal passed at April 2021 

NOSB meeting. Will remain 

an active agenda item for 

future work

TBD TBD

Human Capital Management:

NOSB support

CD/NPP Proposal 07.31.20 NOP Memo to CACS 11.9.21

12.14.21

TBD

Spr 2022
Milestones 

Spring 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~Nov 12, 2021

NOSB - Spring 2022 proposals due to NOP Feb 16, 2022

New NOSB member training TBD

NOP - Draft Spring 2022 NOSB meeting tentative agenda Feb 2, 2022

NOP - Post proposals Mar 3, 2022

Public comment closes Apr 1, 2022

NOP - Send compiled public comments to NOSB Apr 4, 2022

Public comment webinars Apr 20 & 21, 2022

Spring 2022 NOSB meeting - Crystal City, VA Apr 26 - 28, 2022

Final recommendations due May 27, 2022
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB recommendations. Proposals 

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, November 9, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Amy Bruch (ADB); Steve Ela (SE); Kyla Smith (KS); Carolyn Dimitri (CD); 

Sue Baird (SB)

Absent: Rick Greenwood (RG), Vice Chair

Staff: Michelle Arsenault (MA); Laura Gallagher (LG); Jenny Tucker (JT); Andrea Holm (AH)

Agenda

• October 12th, 2021 notes

• Debrief of Fall 2021 NOSB Meeting

• Additional items

• Adjourn

Discussion

• October 12th, 2021 notes were accepted as written.

• Debrief of Fall 2021 NOSB Meeting/Additional items.

o The group discussed the proposal on Human Capital Management: NOSB support and will

postpone work until the NOP writes a statement of work to solicit proposals. The CACS will

review the statement of work before it is posted and may post it to the open docket early, for 

the Spring 2022 meeting. 

o The CACS discussed the next steps for the discussion document on Oversight Improvements to 

Deter Fraud: Modernization of Organic Traceability Infrastructure presented at the October

2021 meeting. The lead indicated that given public comments they will write another discussion 

document for the Spring 2022 meeting. 

o Climate change letter proposal presented at October 2021 meeting. The lead expressed her 

appreciation for comments on organic’s relationship with social justice and racial equity, and 

also recognized OFPA limitations with regard to this.

o The NOSB Chair announced Amy Bruch as the new CACS Chair. The new Subcommittee rosters 

are under development and will be sent to the NOSB members soon. 

o The final proposals for the Spring 2022 meeting are due to the NOP by February 16, 2022.

A member mentioned the public comments regarding a revision to the organic handling 

standards (§205.270-272). Since this is not a work agenda item, if the NOSB would like to work 

on this, they would have to go through the formal work agenda process to request it. 

o CACS discussed takeaways from the October 2021 NOSB meeting and possible future work 

agenda items. A member suggested a potential work agenda item to strengthen the oversight of 

NOP’s accreditation process related to fraud, and the group will discuss it further. Another 

member suggested a discussion document on social justice in organic agriculture.

• The meeting was adjourned. 

Previous CACS Notes

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

October 12, 2021

November 9, 2021

December 14, 2021 

January 11, 2022

February 08, 2022
March 08, 2022

April 12, 2022

May 10, 2022

June 14, 2022

July 12, 2022

August 09, 2022

September 13, 2022

October 11, 2022

November 08, 2022

December 13, 2022

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion,

Voted

Target

meeting

Oversight improvements to deter 

fraud: Modernization of organic 

traceability infrastructure.

ADB/NPP Discussion document 11.9.21

12.14.21

Spr 2022

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal. 

TBD Proposal passed at April 2021 NOSB 

meeting. Will remain an active agenda 

item for future work. 

TBD TBD

Human Capital Management:

NOSB support - Proposal

CD/NPP NOP sent memo to CACS 07.31.20 11.9.21

12.14.21

Spr 2022

Spring 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~Nov 12, 2021

NOSB - Spring 2022 proposals due to NOP Feb 16, 2022

New NOSB member training TBD

NOP - Draft Spring 2022 NOSB meeting tentative agenda Feb 2, 2022

NOP - Post proposals Mar 3, 2022

Public comment closes Apr 1, 2022

NOP - Send compiled public comments to NOSB Apr 4, 2022

Public comment webinars Apr 20 & 21, 2022

Spring 2022 NOSB meeting - Crystal City, VA Apr 26 - 28, 2022

Final recommendations due May 27, 2022
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB recommendations. Proposals 

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, October 12, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Rick Greenwood (RG), Vice Chair; Amy Bruch (ADB) 

Absent: Steve Ela (SE) ; Kyla Smith (KS); Carolyn Dimitri (CD); Sue Baird (SB)

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

Agenda

• August 10 notes were approved via email

• Additional items

• Adjourn

Discussion

• August 10 notes were approved via email

• Additional items.

o Modernization of organic traceability infrastructure. The Chair noted that the comments were 

supportive of this document and had helpful feedback

o Climate Change Letter. The Chair noted that commenters were supportive, and people seemed 

pleased with the letter and intent. 

o The NOP awarded nine projects for the Human Capital Management: Inspector mentorship/ 

apprenticeship/consistency call for proposals. The NOP has a communications rollout plan and 

plans to inform the community and NOSB as the project deliverables are completed. 

o The CACS Chair asked about NOP thoughts or guidance for the future status of remote 

inspections and will discuss this further on the Executive Team call.

• The meeting was adjourned. 

Previous CACS Notes

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

August 10, 2021

Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) -

Discussion Doc - Discuss/Vote 

Human Capital Management: NOSB support (CD) - Discuss/Vote

Proposal: Letter to Sec re: climate change initiatives (CD) - Discuss/Vote

September 14, 2021 - cancelled

October 12, 2021

November 9, 2021

December 14, 2021 
Work Agenda

*Discussed. *Voted

Project Contact Status Discussion, Voted

Target

meeting

Oversight improvements to deter 

fraud: Modernization of organic 

traceability infrastructure.

NPP/ADB Discussion document 6.8.21

7.13.21

7.27.21

8.10.21

Fall 2021

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal. 

TBD Proposal passed at April 2021 NOSB 

meeting. Will remain an active agenda 

item for future work. 

TBD TBD

Human Capital Management:

NOSB support - Proposal

CD/NPP NOP sent memo to CACS 07.31.20 5.11.21

6.8.21

7.13.21

8.10.21

Spr 2022

Proposal: Letter to Secretary re 

Climate Change initiatives 

CD NOP approved work agenda item 6.8.21 6.8.21

7.13.21

8.10.21

Fall 2021

Fall 2021 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Jun 3, 2021

NOSB Request for TRs for 2024 sunset materials Jun 18, 2021

NOP - Draft Fall 2020 NOSB meeting tentative agenda Jul 30, 2021

NOSB - Fall 2021 proposals due to NOP Aug 13, 2021

NOP - Post proposals On or before Sep 1, 2021

Discuss/finalize work agendas on ES call Sep 21, 2021

Public comment closes Sep 30, 2021

NOP - Send compiled public comments to NOSB ~Oct 4, 2021

Public comment webinars Oct 12 & 14, 2021

Fall 2021 NOSB meeting - Sacramento, CA Oct 19 - 21, 2021
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB recommendations. Proposals 

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, August 10, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Rick Greenwood (RG), Vice Chair; Steve Ela (SE); Amy Bruch (ADB); Kyla 

Smith (KS); Carolyn Dimitri (CD); Sue Baird (SB)

Absent: None

Staff: Michelle Arsenault (MA)

Agenda

• Review July 27 notes

• Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) -

Discussion Doc - Discuss/Vote

• Human Capital Management: NOSB support (CD) - Discuss/Vote

• Proposal: Letter to Sec re: climate change initiatives (CD) - Discuss/Vote

• Additional items

• Adjourn

Discussion

• The July 27 notes were accepted as written.

• Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) -

discussion document. The CACS discussed the draft document that is meant to build on the

Strengthening Organic Enforcement (SOE) rule. Members discussed aspects of the document such as

certificates and transparency, the usefulness and maintenance of a database.

Motion to accept the discussion document on oversight improvements to deter fraud: Modernization of

organic traceability infrastructure.

Motion by: ADB

Seconded by: NPP

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

• Proposal: Human Capital Management: NOSB support (CD). The CACS indicated that the feedback they

received from commenters at the Spring 2021 meeting was helpful and was incorporated into the draft

proposal. The CACS will provide a verbal update at the Fall 2021 meeting, and gather feedback from the

rest of the Board, before proceeding to a proposal for the Spring 2022 meeting.

Proposal: Letter to Sec re: climate change initiatives (CD). The CACS posted the draft letter in the open

docket and received comments from several stakeholder groups. The group made some minor revisions

to the document before moving to a vote. A member asked about the USDA initiative and funding for

transitioning and if the funding has to be spent by the end of the 2021 fiscal year.

Motion to accept the proposal/letter to the Secretary re: climate change initiatives

Motion by: NPP

Seconded by: KS

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

• Additional items. None.

• The meeting was adjourned.
Previous CACS Notes

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

July 27, 2021 - Additional call

Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) - 

Discuss 

August 10, 2021

Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) - 

Discussion Doc - Discuss/Vote 

Human Capital Management: NOSB support (CD) - Discuss/Vote 

Proposal: Letter to Sec re: climate change initiatives (CD) - Discuss/Vote 

September 14, 2021 - cancelled

October 12, 2021

November 9, 2021

December 14, 2021 

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion,

Voted

Target

meeting

Oversight improvements to deter 

fraud: Modernization of organic 

traceability infrastructure.

NPP/ADB Discussion document 6.8.21

7.13.21

7.27.21

8.10.21

Fall 2021

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal. 

TBD Proposal passed at April 2021 NOSB 

meeting. Will remain an active agenda 

item for future work. 

TBD TBD

Human Capital Management:

NOSB support - Proposal

CD/NPP NOP sent memo to CACS 07.31.20 5.11.21

6.8.21

7.13.21

8.10.21

Spr 2022

Proposal: Letter to Secretary re 

Climate Change initiatives

CD NOP approved work agenda item 6.8.21 6.8.21

7.13.21

8.10.21

Fall 2021

Fall 2021 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Jun 3, 2021

NOSB Request for TRs for 2024 sunset materials Jun 18, 2021

NOP - Draft Fall 2020 NOSB meeting tentative agenda Jul 30, 2021

NOSB - Fall 2021 proposals due to NOP Aug 13, 2021

NOP - Post proposals On or before Sep 1, 2021
Discuss/finalize work agendas on ES call Sep 21, 2021

Public comment closes Sep 30, 2021

NOP - Send compiled public comments to NOSB ~Oct 4, 2021

Public comment webinars Oct 12 & 14, 2021

Fall 2021 NOSB meeting - Sacramento, CA Oct 19 - 21, 2021
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB recommendations. Proposals 

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, July 27, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Steve Ela (SE); Amy Bruch (ADB); Kyla Smith (KS); Carolyn Dimitri (CD); ; 

Sue Baird (SB)

Absent: Rick Greenwood (RG), Vice Chair

Staff: Michelle Arsenault (MA); Jennifer Tucker (JT)

Agenda

• Review July 13 notes

• Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) -

Discuss. 

• Additional items

• Adjourn

Discussion

• The July 13 notes were accepted as written.

• Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB). 

With this discussion document, the CACS intends to advance the work that has already been included in 

the strengthening organic enforcement rule (SOE). The CACS will focus its efforts on four areas: 

readdressing the topic of transaction certificates; introducing additional considerations for improved 

tools for human capital assessments; USDA interagency partnerships; and lastly, nitrogen

balancing. Members discussed cost of certification, and possible ways to support smaller farmers. A 

member indicated that integrity is paramount among small producers, and that cost can be an issue. The 

NOP noted that the cost associated with transaction certificates was one reason it was not included in 

the SOE rule and noted that an industry-led blockchain could be a possible solution that could be 

discussed. 

• Additional items. None. 

• The meeting was adjourned. 

Previous CACS Notes

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

July 13, 2021

Proposal: Letter to Sec re: climate change initiatives (CD) - Discuss

Human Capital Management: NOSB support (CD) - Discuss

Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) -

Discuss

July 27, 2021 - Additional call

Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) -

Discuss

August 10, 2021

Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) -

Discussion Doc - Discuss/Vote 

Human Capital Management: NOSB support (CD) - Discuss/Vote

Proposal: Letter to Sec re: climate change initiatives (CD) - Discuss/Vote
September 14, 2021

October 12, 2021

November 9, 2021

December 14, 2021 

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion,

Voted

Target

meeting

Oversight improvements to deter 

fraud: Modernization of organic 

traceability infrastructure.

NPP/ADB Discussion document 6.8.21

7.13.21

7.27.21

8.10.21

Fall 2021

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal. 

TBD Proposal passed at April 2021 NOSB 

meeting. Will remain an active agenda 

item for future work. 

TBD TBD

Human Capital Management:

NOSB support - Proposal

CD/NPP NOP sent memo to CACS 07.31.20 5.11.21

6.8.21

7.13.21

8.10.21

Fall 2021

Proposal: Letter to Secretary re 

Climate Change initiatives

CD NOP approved work agenda item 6.8.21 6.8.21

7.13.21

8.10.21

Fall 2021

Fall 2021 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Jun 3, 2021

NOSB Request for TRs for 2024 sunset materials Jun 18, 2021

NOP - Draft Fall 2020 NOSB meeting tentative agenda Jul 30, 2021

NOSB - Fall 2021 proposals due to NOP Aug 13, 2021

NOP - Post proposals On or before Sep 1, 2021

Discuss/finalize work agendas on ES call Sep 21, 2021

Public comment closes Sep 30, 2021

NOP - Send compiled public comments to NOSB ~Oct 4, 2021

Public comment webinars Oct 12 & 14, 2021

Fall 2021 NOSB meeting - Sacramento, CA Oct 19 - 21, 2021
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB recommendations. Proposals 

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, July 13, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Rick Greenwood (RG), Vice Chair; Steve Ela (SE); Sue Baird (SB); Amy 

Bruch (ADB); Kyla Smith (KS); Carolyn Dimitri (CD); Mindee Jeffery (MJ) - observer

Absent: None

Staff: Michelle Arsenault (MA); Jennifer Tucker (JT)

Agenda

• Review June 8 notes

• Proposal: Letter to Sec re: climate change initiatives (CD) - Discuss

• Human Capital Management: NOSB support (CD) - Discuss 

• Oversight improvements to deter fraud: Modernization of organic traceability infrastructure - Discuss

• Additional items

• Adjourn

Discussion

• The June 8 notes were accepted as written with no additional contributions or amendments. 

• Proposal: Letter to the Secretary re: climate change initiatives (CD). The CACS members discussed the 

draft document. The lead highlighted the gaps in research, and members contributed ideas for 

modifications, such as adding language about mandates from OFPA, and a discussion of transition 

grants. The lead will modify the draft document and the CACS will post it in the open comment docket in 

Regulations.gov to get some early feedback from stakeholders before they vote on the document during 

the next call. 

• Human Capital Management: NOSB support (JT). The NOP received a number of responses for its 

request for proposals for Human Capital Management, but none included providing support for the 

NOSB. The CACS is working on a draft proposal that includes a list of possible projects, and will prioritize 

them for discussion and vote on the next Subcommittee call. After the Fall meeting, if the NOSB passes 

the proposal, the NOP will put out a call for proposals. 

• Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB).

The lead described the current draft document and after additional discussion by the group will modify 

and recirculate it for discussion on the next call. 

• Additional items. The CACS added an extra call on July 27. 

• The meeting was adjourned. 

Previous CACS Notes

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

June 8, 2021

July 13, 2021

Proposal: Letter to Sec re: climate change initiatives (CD) - Discuss

Human Capital Management: NOSB support (CD) - Discuss

Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) -

Discuss

July 27, 2021 - Additional call

Oversight improvements to deter fraud: Modernization of organic traceability infrastructure (ADB) -

Discuss/Vote
Human Capital Management: NOSB support (CD) - Discuss

August 10, 2021

Human Capital Management: NOSB support (CD) - Discuss/Vote 

Proposal: Letter to Sec re: climate change initiatives (CD) - Discuss/Vote 

September 14, 2021

October 12, 2021

November 9, 2021

December 14, 2021 

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion,

Voted

Target

meeting

Oversight improvements to deter 

fraud: Modernization of organic 

traceability infrastructure.

NPP/ADB Discussion document 6.8.21

7.13.21

7.27.21

Fall 2021

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal. 

TBD Proposal passed at April 2021 NOSB 

meeting. Will remain an active agenda 

item for future work. 

TBD TBD

Human Capital Management:

NOSB support - Proposal

CD/NPP NOP sent memo to CACS 07.31.20 5.11.21

6.8.21

7.13.21

7.27.21

8.10.21

Fall 2021

Proposal: Letter to Secretary re 

Climate Change initiatives

CD NOP approved work agenda item 6.8.21 6.8.21

7.13.21

8.10.21

Fall 2021

Fall 2021 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Jun 3, 2021

NOSB Request for TRs for 2024 sunset materials Jun 18, 2021

NOP - Draft Fall 2020 NOSB meeting tentative agenda Jul 30, 2021

NOSB - Fall 2021 proposals due to NOP Aug 13, 2021

NOP - Post proposals On or before Sep 1, 2021

Discuss/finalize work agendas on ES call Sep 21, 2021

Public comment closes Sep 30, 2021

NOP - Send compiled public comments to NOSB ~Oct 4, 2021

Public comment webinars Oct 12 & 14, 2021

Fall 2021 NOSB meeting - Sacramento, CA Oct 19 - 21, 2021
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB recommendations. Proposals 

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, June 8, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Steve Ela (SE); Amy Bruch (ADB); Kyla Smith (KS); Carolyn Dimitri (CD); 

Rick Greenwood (RG), Vice Chair

Absent: Sue Baird (SB)

Staff: Michelle Arsenault (MA); Jennifer Tucker (JT); Laura Gallagher (LG)

Agenda

• Review May 11 notes

• Human Capital Management: NOSB support (CD). 

• Discuss drafting a discussion document on climate change (CD)

• Fraud prevention/enforcement in grain supply chain (ADB)

• Additional items

• Adjourn

Discussion

• May 11 notes were accepted as written. 

• Human Capital Management: NOSB support (CD). The Subcommittee discussed the project to enlist 

support for the NOSB and proposed a list of tasks or activities that could be performed by the support 

project team. The NOP is considering entering into a cooperative agreement with a non-profit 

organization or University if one is identified through the current Request for Applications or a future 

call for proposals. The organization would determine who to hire for the project. NOP has included in 

the RFP the tasks the NOSB is seeking help with. Members discussed broadening the scope beyond 

agriculture schools, to such things as schools of public health. One member offered that his University 

has an Institute of Environment and Sustainability and students would be interested and engaged in 

organic-related work. 

• Discussion document on climate change (CD). The group discussed writing a letter to USDA Secretary 

Vilsack regarding the Biden Administrations priorities on climate change. The NOSB would like to express 

its support and highlight the existing USDA resources, including Organic, that perhaps are being 

underutilized. The CACS will write a proposal for the Fall meeting, which would be posted for public 

comment and voted on by the NOSB at the Fall meeting. If the proposal passes, the output would be a 

proposal/recommendation that would include a letter that the NOP would forward to the Secretary. 

• Fraud prevention/enforcement in the grain supply chain (ADB). A member drafted a presentation on 

the modernization of organic enforcement and oversight, and the group discussed various components

in anticipation of the rule on Strengthening Organic Enforcement (SOE). NOP provided some feedback 

and encouraged the group to continue to discuss the topic. Although the CACS is not working on a 

specific document at the moment, it may provide an update at the Fall NOSB meeting. 

• Additional items. None.

• The meeting was adjourned. 

Previous CACS Notes

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

May 11, 2021
June 8, 2021

July 13, 2021

Proposal: Letter to Sec re: climate change initiatives (CD) - Discuss

Human Capital Management: NOSB support (CD) - Discuss

August 10, 2021

September 14, 2021

October 12, 2021

November 9, 2021

December 14, 2021 

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion,

Voted

Target

meeting

Oversight improvements to deter 

fraud 

TBD On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

6.8.21 TBD

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal. 

TBD Proposal passed at April 2021 NOSB 

meeting. Will remain an active agenda 

item for future work. 

TBD TBD

Human Capital Management:

NOSB support - Proposal

CD/NPP NOP sent memo to CACS 07.31.20 5.11.21

6.8.21

7.13.21

Fall 2021

Proposal: Letter to Secretary re 

Climate Chang initiatives

CD NOP approved work agenda item 6.8.21 6.8.21

7.13.21

Fall 2021

Fall 2021 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~Jun 3, 2021

NOSB Request for TRs for 2024 sunset materials Jun 18, 2021

NOP - Draft Fall 2020 NOSB meeting tentative agenda Jul 30, 2021

NOSB - Fall 2021 proposals due to NOP Aug 13, 2021

NOP - Post proposals On or before Sep 1, 2021

Discuss/finalize work agendas on ES call Sep 21, 2021

Public comment closes Sep 30, 2021

NOP - Send compiled public comments to NOSB ~Oct 4, 2021

Public comment webinars Oct 12 & 14, 2021

Fall 2021 NOSB meeting - Sacramento, CA Oct 19 - 21, 2021
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB recommendations. Proposals 

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, May 11, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Sue Baird (SB); Steve Ela (SE); Amy Bruch (ADB); Kyla Smith (KS); Carolyn 

Dimitri (CD)

Absent: Rick Greenwood (RG), Vice Chair

Staff: Michelle Arsenault (MA); Jennifer Tucker (JT); Laura Gallagher (LG)

Agenda

• Review April 13 notes

• Debrief from April 2021 NOSB meeting

• Assign discussion dates for work agenda items

• Human Capital Management: NOSB support - Discuss 

• Additional items

o Outcome: Human Capital Management: Inspector mentorship/ apprenticeship/consistency 

proposal 

• Adjourn

Discussion

• April 13 notes were accepted as written.

• Debrief from April 2021 NOSB meeting.

o The CACS Chair indicated that the organic community is excited by the request for proposals 

(RFP) seeking applicants to work on the human capital projects. The RFP identified 6 projects 

including one on NOSB support.

• Human Capital Management: NOSB support. 

o The group discussed the second Human Capital Management project for NOSB support and is 

looking forward to receiving proposals. The NOSB Chair noted the importance of Board 

members maintaining independence and ownership of their work while allowing for support.

The group discussed possible areas for support staff to contribute including literature searches, 

synthesis of background and historical NOSB data, compiling background information to review 

substances that are due to sunset for the first time, international use information, etc. The lead 

volunteered to synthesize and interpret the comments from the Spring meeting. The CACS 

members also discussed values to consider such as biases and organic experience. The NOP 

noted that the application deadline is July 2 and the program will have a better idea of the path 

forward once it assesses the proposals. 

• Assign discussion dates for work agenda items

o Human Capital Management will continue to be an open work agenda item until the CACS 

determines it is completed.

• Additional items.

o The group discussed the revocation of India’s organic certification and the timeline involved. 

• The meeting was adjourned. 

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

April 13, 2021

May 11, 2021

June 8, 2021

July 13, 2021

August 10, 2021

September 14, 2021

October 12, 2021

November 9, 2021

December 14, 2021 

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion,

Voted

Target

meeting

Oversight improvements to deter 

fraud 

TBD On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

TBD TBD

Human Capital Management: 

Inspector mentorship/ 

apprenticeship/consistency 

proposal. 

TBD Proposal passed at April 2021 NOSB 

meeting. Will remain an active agenda 

item for future work. 

TBD TBD

Human Capital Management:

NOSB support - Proposal

CD/NPP NOP sent memo to CACS 07.31.20 5.11.21

6.8.21

Fall 2021

Fall 2021 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~May 14, 2021

NOSB Request for TRs for 2024 sunset materials Jun 18, 2021

NOP - Draft Fall 2020 NOSB meeting tentative agenda Jul 30, 2021

NOSB - Fall 2021 proposals due to NOP Aug 13, 2021

NOP - Post proposals On or before Sep 1, 2021

Discuss/finalize work agendas on ES call Sep 21, 2021

Public comment closes Sep 30, 2021

NOP - Send compiled public comments to NOSB ~Oct 4, 2021

Public comment webinars Oct 12 & 14, 2021

Fall 2021 NOSB meeting - Sacramento, CA Oct 19 - 21, 2021
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB recommendations. Proposals 

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, April 13, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Rick Greenwood (RG), Vice Chair; Sue Baird (SB); Steve Ela (SE); Amy 

Bruch (ADB); Kyla Smith (KS); Carolyn Dimitri (CD) 

Absent: None

Staff: Michelle Arsenault (MA); Jennifer Tucker (JT); Laura Gallagher (LG)

Agenda

• Discuss Public Comments

• Prep for Spring 2021 NOSB Meeting

• Additional items

• Adjourn

Discussion 

• Discuss Public Comments/Prep for Spring 2021 NOSB Meeting. 

o Members discussed the public comments for the human capital documents, as well as the 

general process for summarizing and presenting comments. A member noted that there was 

general support and agreement about the human capital documents. 

• Additional items. 

o The request for applications regarding the human capital project cooperative agreement is in 

progress and should be published soon. There will be a 60-day application period.

• The meeting was adjourned. 

Previous CACS Notes

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

March 9, 2021 - cancelled

April 13, 2021

May 11, 2021

June 8, 2021

July 13, 2021

August 10, 2021

September 14, 2021

October 12, 2021

November 9, 2021

December 14, 2021 
Work Agenda

*Discussed. *Voted

Project Contact Status Discussion, Voted

Target

meeting

Oversight improvements to deter 

fraud 

TBD On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

TBD TBD

Human Capital Management:

Inspector mentorship/ 

apprenticeship/consistency

(SB/NPP) - Proposal

SB NOP sent memo to CACS 07.31.20 11.10.20

12.08.20

01.12.20

2.9.21

Spr 2021

Human Capital Management:

NOSB support - Discussion Doc.

SE/NPP NOP sent memo to CACS 07.31.20 11.10.20

12.08.20

01.12.20

Spr 2021

Spring 2021 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Feb 18, 2021

NOSB - Spring 2021 proposals due to NOP Feb 18, 2021

New NOSB member training Feb 3-5, 2021

NOP - Draft Spring 2021 NOSB meeting tentative agenda Feb 2, 2021

NOP - Post proposals Mar 3, 2021

Public comment closes Apr 1, 2021

NOP - Send compiled public comments to NOSB Apr 6, 2021

Public comment webinars Apr 20 & 22, 2021

Spring 2021 NOSB meeting - Virtual Apr 28 - 30, 2021
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 9, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Sue Baird (SB); Steve Ela (SE); Amy Bruch (ADB); Kyla Smith (KS); Carolyn 

Dimitri (CD)

Absent: Rick Greenwood (RG), Vice Chair

Staff: Michelle Arsenault (MA); Jennifer Tucker (JT); Laura Gallagher (LG)

Agenda

• Review January 12 notes

• Human Capital Management (SR): Proposal - inspector mentorship/apprenticeship/consistency (SB/NPP)

- discuss/vote

• Additional items

• Adjourn

Discussion

• January 12 notes were accepted as written.

• Human Capital Management: Proposal - inspector mentorship/apprenticeship/consistency (SB/NPP). 

Members discussed the draft document and several key issues such as potential added costs for 

operations. The NOP is hoping to support the Human Capital Management project by publishing a call 

for proposals for cooperative agreements. Due to the government contracting process the NOSB and 

NOP will move at a slightly different pace, and the NOP hopes to publish the call for proposals after the 

spring NOSB meeting. This is a positive, as it will allow the NOSB to introduce the idea and hear 

stakeholder feedback. The CACS members discussed minor modifications to the proposal and moved to 

a vote. 

Motion to accept the proposal on Human Capital Management: Inspector 

mentorship/apprenticeship/consistency

Motion by: SB

Seconded by: KS

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

• Additional items. The group cancelled the March 9 call. 

• The meeting was adjourned. 

Previous CACS Notes

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

January 12, 2021

February 9, 2021

Inspector mentorship/apprenticeship/consistency (SB/NPP) - Discuss/vote

March 9, 2021 - cancelled

April 13, 2021

May 11, 2021

June 8, 2021

July 13, 2021
August 10, 2021

September 14, 2021

October 12, 2021

November 9, 2021

December 14, 2021 

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion,

Voted

Target

meeting

Oversight improvements to deter 

fraud 

TBD On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

TBD TBD

Human Capital Management:

Inspector mentorship/ 

apprenticeship/consistency

(SB/NPP) - Proposal

SB NOP sent memo to CACS 07.31.20 11.10.20

12.08.20

01.12.20

2.9.21

Spr 2021

Human Capital Management:

NOSB support - Discussion Doc.

SB/NPP NOP sent memo to CACS 07.31.20 11.10.20

12.08.20

01.12.20

Spr 2021

Spring 2021 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 15, 2020

NOSB - Spring 2021 proposals due to NOP Feb 18, 2021

New NOSB member training TBD

NOP - Draft Spring 2021 NOSB meeting tentative agenda Feb 2, 2021

NOP - Post proposals Mar 3, 2021

Public comment closes Apr 1, 2021

NOP - Send compiled public comments to NOSB Apr 6, 2021

Public comment webinars Apr 20 & 22, 2021

Spring 2021 NOSB meeting - Crystal City, VA Apr 28 - 30, 2021
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 12, 2021 2:00 pm ET

Present: Nate Powell-Palm (NPP), Chair; Rick Greenwood (RG), Vice Chair; Sue Baird (SB); Emily Oakley (EO);

Scott Rice (SR), Chair; Steve Ela (SE); Amy Bruch (ADB) - observer; Kyla Smith (KS) - observer; Carolyn Dimitri (CD) 

- observer

Absent: A-dae Romero-Briones (ARB)

Staff: Michelle Arsenault (MA); Jennifer Tucker (JT); Laura Gallagher (LG)

Agenda

• Review December 8 notes

• Human Capital Management (SR)

• Additional items

• Adjourn

Discussion

• December 8 notes were accepted as written.

• Human Capital Management (EO, NPP): Supporting the Work of the NOSB. The lead circulated a draft 

discussion document, which includes questions for public comment. Stakeholders have expressed strong

support for the idea of engaging assistance for the NOSB. The goal is to provide support with the 

technical and rule writing. The NOP added that if this is approved and moves forward, the program 

would use a contractual cooperative agreement and would manage the contract. As such, it would not 

create an extra burden for NOSB members who are volunteers. A member added that the idea of 

potentially engaging graduate students was well received by his University. The CACS will reassign the 

project when the current lead completes her term on the Board.

Motion to accept the discussion document on Supporting the Work of the NOSB

Motion by: EO

Seconded by: SR 

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

• Human Capital Management: Inspector mentorship/apprenticeship/consistency (SB/NPP). The lead 

reached out to several members of the inspector community, including current inspectors, and 

inspectors who have left the industry, to glean feedback about issues and problems that the NOSB could 

possibly address. Several areas were identified such as time constraints due to travel, the perception 

that organic inspectors are not professional, and the lack of consistency between certifiers and 

inspection reports. Members suggested some minor edits to the questions in the draft document. The 

lead will incorporate the suggestions and the CACS will vote on the document on the next call. 

• Additional items. None.

• The meeting was adjourned. 

Previous CACS Notes

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

December 8, 2020

January 12, 2021
February 9, 2021

Inspector mentorship/apprenticeship/consistency (SB/NPP) - Discuss/vote

March 9, 2021

April 13, 2021

May 11, 2021

June 8, 2021

July 13, 2021

August 10, 2021

September 14, 2021

October 12, 2021

November 9, 2021

December 14, 2021 

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion, Voted

Target

meeting

Oversight improvements to deter 

fraud 

SR On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

TBD TBD

Human Capital Management:

Inspector mentorship/ 

apprenticeship/consistency 

(SB/NPP) - Proposal

EO/SB NOP sent memo to CACS 07.31.20 11.10.20

12.08.20

01.12.20

2.9.21

Spr 2021

Human Capital Management:

NOSB support (EO) - Discussion 

Doc.

EO/SB NOP sent memo to CACS 07.31.20 11.10.20

12.08.20

01.12.20

Spr 2021

Spring 2021 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 15, 2020

NOSB - Spring 2021 proposals due to NOP Feb 18, 2021

New NOSB member training TBD

NOP - Draft Spring 2021 NOSB meeting tentative agenda Feb 2, 2021

NOP - Post proposals Mar 3, 2021

Public comment closes Apr 1, 2021

NOP - Send compiled public comments to NOSB Apr 6, 2021

Public comment webinars Apr 20 & 22, 2021

Spring 2021 NOSB meeting - Crystal City, VA Apr 28 - 30, 2021