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 8, 2020 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) - observer; Kyla Smith (KS) - observer; Jesse Buie (JB) - observer

Absent: A-dae Romero-Briones (ARB)

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

Agenda

• Review November 10 notes

• Human Capital Management (SR)

• Additional items

• Adjourn

Discussion

• November 10 notes were accepted as written.

• Human Capital Management (SR). 

o Members discussed two focus areas: Consistency and integrity of inspections, and

apprenticeships. A member added that there are many pressures on inspectors including 

lack of training, retention, benefits, etc. The NOSB, along with the NOP and the inspector 

community, will explore ways to improve the experience and the pool of inspectors. Laura 

Gallagher, NOP staff, will be joining the CACS calls to assist with the human capital 

document, as she is working on similar initiatives for AMS as well as related training projects 

for the Organic Integrity Learning Center.

o NOP added that there may be funding available to develop an apprenticeship program. The 

CACS previously discussed two different apprenticeship programs: one for inspectors, and 

one for NOSB support, and will work on both. The group discussed whether to develop a 

proposal or discussion document for the Spring 2021 meeting and may add extra calls to 

complete the work. 

o EO will initiate a document to solicit comments from organic stakeholders regarding an

NOSB internship program. Members discussed possible formats and questions, and 

suggested reaching out to former NOSB members for feedback. 

o SB will draft a document discussing inspector apprenticeships, for discussion on the next 

CACS call. The NOSB Chair offered to present the document on behalf of the Board at the 

Spring 2021 NOSB meeting. A CACS member offered to summarize the comments from the 

Fall 2020 meeting.

• Additional items. None.

• The meeting was adjourned. 

Previous CACS Notes

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

November 10, 2020

December 8, 2020

January 12, 2021

February 9, 2021
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)

NOSB support (EO)

EO/SB NOP sent memo to CACS 07.31.20 11.10.20

12.08.20

01.12.20

TBD

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, November 10, 2020 2:00 pm ET

Present: Scott Rice (SR), Chair; Sue Baird (SB), Vice Chair; Emily Oakley (EO); Rick Greenwood (RG); Nate PowellPalm (NPP); Steve Ela (SE) - observer 

Absent: A-dae Romero-Briones (ARB) 

Staff: Michelle Arsenault (MA); Jenny Tucker (JT); Jared Clark (JC)

Agenda

• Human Capital Management

• Other items

• Adjourn

Discussion

• Human Capital Management (SR). 

o The NOP and NOSB discussed feedback received at the Fall 2020 meeting and possible steps to 

move this project forward. Key components include partnership building, diversity, curriculum 

models, and career development in organic. Members discussed possible areas on which to work, 

such as regional variation in compensation and consistency for inspectors/inspections, insurance 

for independent inspectors, code of conduct for employers, apprenticeships/mentorship, and 

internships. Members highlighted two topics they felt would be the most valuable to start with: 

consistency and apprenticeships. 

o A member noted an educational opportunity for organic. The environmental health sciences is a 

field that is closely aligned with organic principles, but many folks who are engaged in this field

don’t necessarily know what organic means. 

o Next steps: NPP and SB will each work on one of the two topics identified and come to the next call 

with ideas for discussion. The CACS could have discussion documents posted for the Spring 

meeting. 

o NOP is working on a project plan within the program as well, because human capital is a priority 

across AMS. The NOP hopes to have something ready for the end of the year. 

• The meeting was adjourned. 

Previous CACS Notes

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

October 13, 2020

November 10, 2020

December 8, 2020
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 NOP sent memo to CACS 07.31.20 11.10.20

12.08.20

TBD

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, October 13, 2020 2:00 pm ET

Present: Scott Rice (SR), Chair; Sue Baird (SB), Vice Chair; Emily Oakley (EO); Rick Greenwood (RG) 

Absent: Nate Powell-Palm (NPP); A-dae Romero-Briones (ARB) 

Staff: Michelle Arsenault (MA); Jenny Tucker (JT); Jared Clark (JC)

Agenda

• Human Capital Management

• Other items

• Adjourn

Discussion

• Human Capital Management (SR). 

o The lead summarized the public comments, noting that the community is engaged in this topic, 

and that most comments were positive and detailed. The group discussed possible directions 

and timelines. The NOP added that there are many possible directions and that this is a 

challenge that is not unique to the Organic Program; other USDA organizations have similar 

challenges with human capital. 

o Members also noted several ideas to assist the NOSB, such as hiring a third party entity to help 

the Board write documents. A member shared an experience with another Board(s), that had a 

writing support structure in place. The group also discussed assistance with comment analysis 

and summary.

o A member offered to help with the presentation of the discussion document for the Fall 

meeting. 

• Other items. The group reviewed the CACS work agenda below and updated the status of projects. A 

module addressing the Energy System Infrastructure on Organic Farms is in development, and will be 

added to the Integrity Learning Center, therefore, it will be removed it from the CACS work agenda 

below. 

• The meeting was adjourned. 

Previous CACS Notes

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

September 8, 2020

October 13, 2020

November 10, 2020

December 8, 2020
Work Agenda

*Discussed. *Voted

Project Contact Status Discussion,

Voted

Target

meeting

Energy system infrastructure on 

organic farms.

CACS requested addition to work 

agenda 12 14 18. NOP suggested 

working on a module for the Integrity 

Learning Center. A module for the 

Learning Center is in progress.

11.12.19

10.13.20

TBD

Oversight improvements to deter 

fraud 

SR On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

TBD TBD

Human Capital Management NOP sent memo to CACS 07.31.20 07.14.20

08.11.20

TBD

Fall 2020 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Sep 1, 2020

NOSB Request for TRs for 2023 sunset materials Jul 23, 2020

NOP - Draft Fall 2020 NOSB meeting tentative agenda Aug 1, 2020

NOSB - Fall 2020 proposals due to NOP Aug 13, 2020

NOP - Post proposals On or before Sep 2, 2020

Public comment closes Oct 1, 2020

NOP - Send compiled public comments to NOSB ~Oct 9, 2020

Discuss/finalize work agendas on ES call Sep 15, 2020

Public comment webinars Oct 20 & 22, 2020

Fall 2020 NOSB meeting - Virtual Oct 28 - 30, 2020
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

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

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, August 11, 2020 2:00 pm ET

Present: Scott Rice (SR), Chair; Sue Baird (SB), Vice Chair; Emily Oakley (EO); Rick Greenwood (RG); Nate PowellPalm (NPP); Steve Ela (SE) - observer

Absent: A-dae Romero-Briones (ARB)

Staff: Michelle Arsenault (MA); Jenny Tucker (JT); Jared Clark (JC)

Agenda

• Review July 14 notes

• Human Capital Management

• SOE

• Other items

• Adjourn

Discussion

• July 14, 2020 notes were accepted as written

• Human Capital Management (All). The group discussed the request from the NOP to engage the 

community in a conversation about human capital management. At this time the NOP is not looking for 

a recommendation for a rule, guidance, or instruction, but is seeking to start a conversation to solicit 

feedback from stakeholders. The hope is to improve and strengthen inspector qualifications, and not to 

eliminate staff. Members discussed inspector training, which is often comprehensive for certifier staff, 

but less so for contract or independent inspectors. These non-staff inspectors don’t necessarily have 

access to mentors or a formal framework or support network, and that is an area the CACS would like to 

address. Members discussed comments they have received from their stakeholder communities

regarding auditors, inspections, and compensation. Two members drew distinctions between industry 

and food safety inspections versus organic inspections. 

The CACS will post a brief summary for the Fall NOSB meeting pointing to the NOP memo to solicit 

feedback. The CACS Chair volunteered to lead this project and to synthesize the comments for the Fall 

meeting.

• Strengthening Organic Enforcement Rule (SOE). The CACS discussed the SOE rule, which was recently 

published in the Federal Register. The comment docket is open and closes October 5, 2020.

• Other items. The USDA announced changes to the organic cost share program which supports the 

community by paying a portion of certification costs. CACS members relayed feedback from 

stakeholders indicating that they were surprised, frustrated, and alarmed that the subsidy was reduced 

from 75% to 50% per scope.

• The meeting was adjourned. 

Previous CACS Notes

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

July 14, 2020
August 11, 2020

September 8, 2020

October 13, 2020

November 10, 2020

December 8, 2020

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion, Voted

Target

meeting

Energy system infrastructure on 

organic farms.

CACS requested addition to work 

agenda 12 14 18. NOP suggested 

working on a module for the Integrity 

Learning Center.

11.12.19 TBD

Oversight improvements to deter 

fraud 

SR On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

TBD TBD

Human Capital Management NOP sent memo to CACS 07.31.20 07.14.20

08.11.20

TBD

Fall 2020 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment May 21, 2020

NOSB Request for TRs for 2023 sunset materials Jul 23, 2020

NOP - Draft Fall 2020 NOSB meeting tentative agenda Aug 1, 2020

NOSB - Fall 2020 proposals due to NOP Aug 13, 2020

NOP - Post proposals On or before Sep 2, 2020

Public comment closes Oct 1, 2020

NOP - Send compiled public comments to NOSB ~Oct 9, 2020

Discuss/finalize work agendas on ES call Sep 15, 2020

Public comment webinars Oct 20 & 22, 2020

Fall 2020 NOSB meeting - Virtual Oct 28 - 30, 2020
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

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

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, July 14, 2020 2:00 pm ET

Present: Scott Rice (SR), Chair; Emily Oakley (EO); Rick Greenwood (RG); Nate Powell-Palm (NPP); Jesse Buie (JB); 

Steve Ela (SE) - observer

Absent: A-dae Romero-Briones (ARB); Sue Baird (SB), Vice Chair

Staff: Michelle Arsenault (MA); Jenny Tucker (JT); Jared Clark (JC)

Agenda

• Review June 9 notes

• SOE Proposed Rule - discuss

• Other items

• Adjourn

Discussion

• June 9, 2020 notes were accepted as written.

• Human Capital draft request. The NOP drafted a document for the CACS on a project to lay out a 

framework/strategic plan around human capital management, focusing specifically on organic 

inspectors and reviewers. The NOP is seeking feedback from the CACS/NOSB about what this project 

could entail. The group discussed a gap analysis, pipeline development, and retention of reviewers and 

inspectors. A member mentioned that there could be a role for academic institutions (specifically 

agricultural colleges) to provide online courses. The NOP noted that there will be a new course in the 

Organic Integrity Learning Center developed by a university, which could be used as a case study for this. 

The CACS also asked about ways to increase diversity in the inspector community. Next steps: the CACS 

will provide feedback to the NOP (by July 23), the NOP will continue to work on the document, and the 

CACS may develop a discussion document for the Fall meeting to solicit public comment. 

• Strengthening Organic Enforcement (SOE) Proposed Rule. The NOP held a webinar last week to 

announce the impending proposed rule on SOE. More than 900 members of the community attended. 

The CACS Chair summarized the path to the rule which was the culmination of 10+ years of work by the 

NOP, the NOSB, and the organic community. The draft rule is posted on the AMS website along with 

several document resources, including a side-by-side comparison of the original regulation and the 

proposed changes. Once the rule is published in Regulations.gov the public will have 60 days to 

comment. 

• Other Items. 

o Members shared experiences about virtual and hybrid inspections. The community continues to 

perform inspections and audits virtually or using a hybrid model to limit in-person visits to 

promote safety. Some organizations are restricting in-person inspections altogether and 

prohibiting air travel. Other practices include employment of local inspectors, which helps 

minimize travel. A member noted that she has an inspection scheduled and it will be conducted 

in person, but outside and physically distanced. 

• The meeting was adjourned. 

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

June 9, 2020

July 14, 2020

August 11, 2020

September 8, 2020

October 13, 2020

November 10, 2020

December 8, 2020

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion, Voted

Target

meeting

Energy system infrastructure on 

organic farms.

CACS requested addition to work 

agenda 12 14 18. NOP suggested 

working on a module for the Integrity 

Learning Center.

11.12.19 TBD

Oversight improvements to deter 

fraud 

SR On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

TBD TBD

Human Capital Management Pending receipt of request from NOP 07.14.20 TBD

Fall 2020 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment May 21, 2020

NOSB Request for TRs for 2023 sunset materials Jul 23, 2020

NOP - Draft Fall 2020 NOSB meeting tentative agenda Aug 1, 2020

NOSB - Fall 2020 proposals due to NOP Aug 13, 2020

NOP - Post proposals On or before Sep 2, 2020

Public comment closes Oct 1, 2020

NOP - Send compiled public comments to NOSB ~Oct 9, 2020

Discuss/finalize work agendas on ES call Sep 15, 2020

Public comment webinars Oct 20 & 22, 2020

Fall 2020 NOSB meeting - Cedar Rapids, IA Oct 27-29, 2020
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

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

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, June 9, 2020 2:00 pm ET

Present: Scott Rice (SR), Chair; Sue Baird (SB), Vice Chair; Emily Oakley (EO); Rick Greenwood (RG); A-dae 

Romero-Briones (ARB); Nate Powell-Palm (NPP); Steve Ela (SE) - observer

Absent: None

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

Agenda

• April 14 notes

• Inspector human capital

• Reduced contact inspections

• Other items

• Adjourn

Discussion

• April 14, 2020 notes were accepted as written

• Inspector human capital. NOP is developing a work agenda item for the CACS and anticipates that it will 

send a memo to the Board prior to the Fall meeting. Since there are only two calls between now and the 

proposal deadline it is not likely the CACS will have time to develop a document for the Fall meeting. 

• Reduced-contact inspections (ALL). Members shared their experiences conducting inspections and 

audits while continuing to limit contact and social distance. Several members indicated using a hybrid 

approach - part virtual and part field-based. The CACS Chair noted that WSDA has been doing limited 

contact inspections for about 1.5 - 2 months and things are going well, and they are receiving positive 

feedback. In the next phase they will be prioritizing inspections, and will continue to inspect new sites 

while distancing appropriately. 

A member shared that he began the season doing 100% virtual inspections but has moved to a hybrid 

approach that includes visiting a facility, riding around in separate vehicles, and then stopping and 

talking at a distance. Another member also noted a hybrid approach for Crop inspections. For 

processers, audits are virtual for now, and onsite physical inspections will be scheduled at a later date. 

She also shared that Handling operations are more challenging than other inspections, and they are 

working on ways to move forward. 

The group praised the best practices that were developed by the inspector community working group. 

These best practices also included the development of a registry of local inspectors so inspections can 

continue while minimizing travel. The CACS Chair noted that it’s working well so far, and the most 

difficult challenge is orienting inspectors to different forms and processes for each certifier. He also 

noted that there are some underserved regions that have a lack of inspectors. 

Other items. Members added personal experiences with inspections, farmers markets, and CSAs.

• The meeting was adjourned. 

Previous CACS Notes

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

May 12, 2020
June 9, 2020

July 14, 2020

August 11, 2020

September 8, 2020

October 13, 2020

November 10, 2020

December 8, 2020

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion, Voted

Target

meeting

Energy system infrastructure on 

organic farms.

CACS requested addition to work 

agenda 12 14 18. NOP suggested 

working on a module for the Integrity 

Learning Center.

11.12.19 TBD

Oversight improvements to deter 

fraud 

SR On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

TBD

Fall 2020 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment May 21, 2020

NOSB Request for TRs for 2023 sunset materials Jul 23, 2020

NOP - Draft Fall 2020 NOSB meeting tentative agenda Aug 1, 2020

NOSB - Fall 2020 proposals due to NOP Aug 13, 2020

NOP - Post proposals On or before Sep 2, 2020

Public comment closes Oct 1, 2020

NOP - Send compiled public comments to NOSB ~Oct 9, 2020

Discuss/finalize work agendas on ES call Sep 15, 2020

Public comment webinars Oct 20 & 22, 2020

Fall 2020 NOSB meeting - Cedar Rapids, IA Oct 27-29, 2020
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

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

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, May 12, 2020 2:00 pm ET

Present: Scott Rice (SR), Chair; Sue Baird (SB), Vice Chair; Emily Oakley (EO); Rick Greenwood (RG); Steve Ela (SE) 

- observer

Absent: A-dae Romero-Briones (ARB); Nate Powell-Palm (NPP)

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

Agenda

• April 14 notes

• Off-site inspection practices

• Spring meeting debrief

• Other items

• Adjourn

Discussion

• April 14, 2020 notes were accepted without changes.

• Off-site inspection practices. The group had a robust conversation about organic inspections and 

potential work agenda projects for the CACS. The CACS Chair mentioned several topics that have been 

discussed by the Accredited Certifiers Association (ACA), and NOP noted a project the International 

Organic Inspectors Association (IOIA) is currently working on looking broadly at education and

professional development for the inspector community. This project was funded by NOP for the 

Integrity Learning Center. Members discussed several potential work agenda ideas such as resource 

sharing of inspectors, identifying potential gaps in current services, and independent inspectors. The 

NOP will write a memo with some general thoughts for further discussion during the June CACS call. 

Once the topic and scope are established the NOP will write a memo framing the task for the Board. 

The intention would be to develop a discussion document for the Fall 2020 meeting to solicit feedback 

from the organic community

• Spring meeting debrief. The CACS Chair provided a verbal update at the NOSB meeting about the 

current activities of the Subcommittee. The CACS has no active work agenda items, as it waits for the 

publication of the Strengthening Organic Enforcement (SOE) rule. 

• Other items.

o Certifier best practices guidance. The CACS Chair circulated a fact sheet developed by the WSDA 

with best practices for inspections. NOP praised WSDA and the certifier community for working 

together and developing best practices for inspections while keeping safe and maintaining 

integrity. 

o The NOP shared some techniques and best practices for conducting inspector evaluations given 

social distancing protocols.

• The meeting was adjourned. 

Previous CACS Notes

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

April 14, 2020

May 12, 2020

June 9, 2020

July 14, 2020
August 11, 2020

September 8, 2020

October 13, 2020

November 10, 2020

December 8, 2020

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion, Voted

Target

meeting

Energy system infrastructure on 

organic farms.

CACS requested addition to work 

agenda 12 14 18. NOP suggested 

working on a module for the Integrity 

Learning Center.

11.12.19 TBD

Oversight improvements to deter 

fraud 

SR On hold, pending publication of 

proposed rule on Strengthening organic 

enforcement (SOE)

TBD

Fall 2020 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment May 21, 2020

NOSB Request for TRs for 2023 sunset materials Jul 23, 2020

NOP - Draft Fall 2020 NOSB meeting tentative agenda Aug 1, 2020

NOSB - Fall 2020 proposals due to NOP Aug 13, 2020

NOP - Post proposals On or before Sep 2, 2020

Public comment closes Oct 1, 2020

NOP - Send compiled public comments to NOSB ~Oct 9, 2020

Discuss/finalize work agendas on ES call Sep 15, 2020

Public comment webinars Oct 20 & 22, 2020

Fall 2020 NOSB meeting - Cedar Rapids, IA Oct 27-29, 2020
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

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

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

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

Compliance, Accreditation & Certification Subcommittee (CACS) Notes

Tuesday, April 14, 2020 2:00 pm ET

Present: Scott Rice (SR), Chair; Sue Baird (SB), Vice Chair; Emily Oakley (EO); A-dae Romero-Briones (ARB); Nate 

Powell-Palm (NPP); Steve Ela (SE) - observer

Absent: Rick Greenwood (RG)

Staff: Michelle Arsenault (MA)

Agenda

• Discuss public comments

• Certification during the COVID-19 pandemic: impacts? process adjustments? concerns?

• Strengthening organic enforcement (SOE) rule update

• Other items

• Adjourn

Discussion

• Discuss public comments. Members discussed public comments although the CACS does not have a

specific item on the agenda. There were a couple of comments about Converting Native Ecosystems to

Organic.

• Certification during the COVID-19 pandemic: impacts? process adjustments? concerns?

o Members discussed the move to virtual inspections, with lower risk clients, and the intention to

move to in-person inspections this fall. Some certifiers are using photographs which are added

to the client’s folder for future reference. Some certifiers continue to do in-person inspections.

For new producers, MT certifiers are conducting an modified initial inspection by visiting the

farm while social distancing. Members are participating in various community meetings to

discuss best practices. Other member offered that she has conducted 2 virtual inspections.

WSDA noted they are also modified inspections for new clients, and everyone has been very

understanding.

• Strengthening organic enforcement (SOE) rule update. Under review by OMB.

• Other items. CACS was interested in having an NOP staff member to expedite and provide regular

answers to certifier questions. SR spoke with NOP about this and suggested a contact person who could

direct questions to the appropriate staff member. The group discussed how to approach solutions when

discrepancies arise and when to involve NOP.

• The meeting was adjourned.

Previous CACS Notes

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

March 10, 2020 - cancelled

April 14, 2020

May 12, 2020

June 9, 2020

July 14, 2020

August 11, 2020

September 8, 2020

October 13, 2020

November 10, 2020
December 8, 2020

Work Agenda

*Discussed. *Voted

Project Contact Status Discussion, Voted

Target

meeting

Energy system infrastructure on 

organic farms.

CACS requested addition to work 

agenda 12 14 18. NOP suggested 

working on a module for the Integrity 

Learning Center.

11.12.19 TBD

Oversight improvements to deter 

fraud – Summary

HB/TC On hold, pending publication of 

proposed rule on Strengthening organic

enforcement (SOE)

1.14.20 TBD

Spring 2020 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Dec 9, 2019

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

New NOSB member training Feb 25 - 26, 2020

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

NOP - Post proposals Mar 5, 2020

Public comment closes Apr 3, 2020

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

Public comment webinars Apr 21 & 23, 2020

Spring 2020 NOSB meeting - Virtual Apr 29 - 30, 2020
 

 

 

 

 

 

 

 

 

 

 

 

 

 

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

removal from the National List. They do not represent official National Organic Program (NOP) policy/regulations or NOSB 

recommendations. Proposals must be voted on by the full Board, to become recommendations to the USDA. Please see 

the NOP website for official NOP policy, regulations, and status of substances used in organic production and handling. 

Compliance, Accreditation & Certification Subcommittee (CACS) Notes 

Tuesday January 14, 2020, 3:00 pm ET 

Attending: Scott Rice (SR), Chair; Sue Baird (SB), Vice Chair; Harriet Behar (HB); Rick Greenwood (RG); 

Lisa de Lima (LD); Emily Oakley (EO); Steve Ela (SE) - observer 

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

Staff: Michelle Arsenault (MA) 

Agenda 

• November 12 notes 

• Strengthening organic enforcement (SOE) Update 

• Other items 

o Report from quarterly IOIA inspector-certifier dialog call 

• Adjourn 

Discussion 

• November 12 notes were accepted as is. 

• Strengthening organic enforcement (SOE) rule update. Currently the proposed rule is under 

review at the Office of Management and Budget (OMB), and CACS is awaiting its publication 

before moving forward. 

• Other items: 

o The CACS Chair provided a summary from the quarterly IOIA inspector-certifier call, 

noting that the work of these two communities intersects often. 

o A member informed the CACS that once she rotates off the Board later this month she 

will be working with a certifier on energy infrastructure. She also indicated that she was 

recruited as an expert witness for a lawsuit for farmers who have a pipeline proposed 

on their land. 

o A member offered some thoughts about Strengthening Organic Enforcement (SOE) and 

enforcement in general. With regard to SOE she noted that addressing exclusions and 

exemptions in organic will create a more transparent supply chain and are considered 

significant steps. She also emphasized the need for the CACS and NOSB to continue to 

push for higher standards when it comes to enforcement and improvement, even in 

small increments. 

o The CACS Chair shared with the group that the NOP sent a notice to certifiers 

announcing a call for proposals/lessons for the Organic integrity Learning Center. Of 

particular note is the inclusion of "Addressing Energy Infrastructure Projects" Special 

Standards Topics section. The CACS Chair will discuss the use of the Organic Integrity 

Learning Center as a platform at the upcoming certifier training in San Antonio, TX. 

o The group also briefly discussed inspectors, and their designation as either an employee 

or contractor. 

• The meeting was adjourned 

Previous CACS Notes 
 

 

 

 

 

 

 

 

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

November 12, 2019 

December 10, 2019 - cancelled 

January 14, 2020 

February 11, 2020 - cancelled 

March 10, 2020 

April 14, 2020 

May 12, 2020 

June 9, 2020 

July 14, 2020 

August 11, 2020 

September 8, 2020 

October 13, 2020 

November 10, 2020 

December 8, 2020 

Work Agenda 

Project Contact Status Discussion, 

Vote 

Meeting 

Energy system infrastructure on organic 

farms. 

CACS requested addition to 

work agenda 12 14 18. NOP 

suggested working on a 

module for the Integrity 

Learning Center. 

11 12 19 TBD 

Oversight improvements to deter fraud 

- Summary 

HB/TC On hold, pending 

publication of proposed rule 

on Strengthening organic 

enforcement (SOE) 

1.14.20 TBD 

*Discussed *Voted 

Spring 2020 Milestones Target dates (tentative) 

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

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

New NOSB member training Feb 25 - 26, 2020 

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

NOP - Post proposals Mar 5, 2020 

Public comment closes Apr 3, 2020 

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

Public comment webinars Apr 21 & 23, 2020 

Spring 2020 NOSB meeting – Crystal City, VA Apr 28 - May 1, 2020