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 13, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Kyla Smith (KS), Vice Chair; Jerry D’Amore (JD); Kim Huseman (KH); Allison 

Johnson (AJ); Nate Powell-Palm (NPP); Mindee Jeffery - observer

Absent: Logan Petrey (LP); Carolyn Dimitri (CD)

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

Agenda

• Review December 6, 2022 notes

• Organic and Climate-Smart Agriculture - Organic IS climate smart. Discuss proposal outline (NPP)

• Minimum reporting requirements. Discuss proposal outline (NPP/ADB). 

• Organic and Climate-Smart Agriculture - Climate induced farming risk and crop insurance (CD)

• Finalize work agenda

• Additional Items

• Adjourn

Discussion

• December 6, 2022 were accepted with edits to the bullet about Minimum Reporting Requirements.

• Current agenda:

o Organic and Climate-Smart Agriculture - Organic IS climate smart (NPP). The CACS will convert 

the discussion document to a proposal for Spring meeting. 

o Minimum Reporting Requirements (NPP/ADB). NOP is working on a course for the Learning 

Center on this topic and the CACS asked about augmenting the work that is already underway. 

The NOP suggested areas in which the Subcommittee/NOSB could help, including 

communicating to certifiers that the modules are available, and providing feedback about best 

practices or additional materials that should be included in the training. The NOP also asked the 

CACS for ideas about priority areas. The group talked about guidance, templates, and tracebackaudit aids to certifiers. The NOP noted that it’s likely too late to add anything prior to the 

January Accredited Certifier Association training, but welcomes ideas from the NOSB for future 

trainings. 

• Proposed additions to work agenda

o Organic and Climate-Smart Agriculture - discussion document on climate induced farming risk 

and crop insurance (CD). The lead compiled background, which will be circulated to the group 

soon. The CACS will send the request to add this to the work agenda to the Executive Committee 

ahead of the December 20 call. 

• Finalize work agenda

o There are four meetings left before the proposal deadline. The group discussed potential 

additions for the work agenda. The leading options are: Defining transition, Strengthening 

Organic Enforcement (SOE) implementation, What/Why Organic?, geo-referencing 

transition/organic parcels, and equivalency enforcement calibration

 Defining transition. Transition is undefined in the Transition to Organic Partnership 

Program (TOPP) program. A member mentioned ideas about potential areas on which 

the NOSB could provide help, noting that timing is critical. The group discussed 

providing clarity around requirements. AJ volunteered to write a white paper to 

circulate to the CACS . The NOP will send examples of other work agenda requests and 

suggested that people look at the guidance in the PPM about what to include. 

 Strengthening Organic Enforcement (SOE) Implementation. NOP will be developing 

training once SOE is published, and would welcome suggestions. 
 What/Why Organic? JD will develop a document and will include history and ideas about 

future directions. The CACS will talk more about this on the next call. 

• Additional Items 

o The group discussed potential areas/ideas where the NOSB could help the NOP such as the 

TOPPS program, which might be the best place to develop resources that are specific to farmers. 

A member asked about courses focusing on supply chain issues. Currently there isn’t anything 

specific, but once SOE is published, the CACS could address this. Another member added a

suggestion about transactions and how to provide a “mass balance”. 

• The meeting was adjourned

Previous CACS Notes

Future call schedule (1st & 2nd Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

December 6, 2022

Organic and Climate-Smart Agriculture (Climate/Equity) (NPP/CD)

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

December 13, 2022

January 3, 2023 

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

January 10, 2023

February 7, 2023

February 14, 2023

March 7, 2023

March 14, 2023

April 4, 2023

April 11, 2023

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 

- Minimum Reporting 

 Requirements (Prop)

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS

12.6.22

12.13.22

1.3.23

Spr 2023

Organic and Climate-Smart 

Agriculture (Climate/Equity)

- Organic IS climate smart

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22

11.8.22

12.6.22

12.13.22

Spr 2023
Milestones

Organic and Climate-Smart 

Agriculture (Climate/Equity)

- Climate induced farming 

 risk and crop Insurance

CD/NPP Discussion 

document

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22

11.8.22

12.6.22

12.13.22

Spr 2023

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

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment ~Nov 10, 2022

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks

New NOSB member training TBD

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023

NOP - Post proposals Mar 6, 2023 7.5

Public comment closes Apr 5, 2023 3.5

NOP - Send compiled public comments to NOSB Apr 7, 2023 3

Public comment webinars Apr 18 & 20, 2023 1 week

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023

Final recommendations due May 25, 2023
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 6, 2022 4:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Kyla Smith (KS); Kim 

Huseman (KH), Mindee Jeffery - observer

Absent: Allison Johnson (AJ); Logan Petrey (LP); Nate Powell-Palm (NPP)

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

Agenda

• Review October 11, 2022 notes

• November 8, 2022

• Additional Items

• Adjourn

Discussion

• October 11, 2022 were accepted as written.

• November 8, 2022 were accepted as written.

• Additional Items. The CACS discussed its work agenda and what projects will move ahead and in what 

format. The Chair described the projects they are considering, based on feedback from the Fall 2022 

NOSB meeting. 

• Oversight improvements to deter fraud: Modernization of organic traceability - Minimum Reporting 

Requirements. The CACS discussed public comments and NOSB discussion heard at the Fall meeting and 

will develop the previous discussion document into a proposal for the Spring 2023 meeting.

• Human Capital Management: Inspector mentorship/ apprenticeship/consistency proposal - Organic 

and Climate-Smart Agriculture (Climate/Equity). The CACS will continue to work on this to stress that 

Organic IS climate smart already.

• Organic and Climate-Smart Agriculture (Climate/Equity). The CACS proposed a new topic under this 

work agenda item on climate-induced farming risk and crop insurance

• NOSB tech support and the inspector qualifications. The NOP will provide an update to the 

Subcommittee on these two human capital projects. 

• Other potential topics for the work agenda 

o Clarify the definition of transition. 

o Strengthening Organic Enforcement (SOE) follow up. The CACS discussed the idea of producing

focused discussion documents about implementation. A member added that certifiers will have 

a year to implement SOE once it’s published, and it might be useful for the NOSB to prep an 

outline or framework on how the NOP and Certifiers can coordinate. The goal would be to have 

something for the Spring 2023 meeting in order to collect public feedback. 

o Why Organic? The Organic community and the NOSB discussed the idea of a marketing 

campaign during the last NOSB meeting, and the CACS has interest in this.

o A member suggested a potential work agenda topic on supply chain issues and organic

equivalency agreements, and would like to look at global coordination on enforcement. 

o The CACS discussed the potential of developing a proposal on geolocation of parcels. One 

member noted that the information is already publicly available, and it would be a matter of 

making it more accessible. Another member noted the existence of a similar system although 

some of the data is not consistent across certifiers. The CACS Chair expressed interest in 

coordinating across agencies. 

• The meeting was adjourned
Previous CACS Notes

Future call schedule (1st & 2nd Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

November 8, 2022

December 6, 2022

Organic and Climate-Smart Agriculture (Climate/Equity) (NPP/CD)

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

December 13, 2022

January 3, 2023 

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

January 10, 2023

February 7, 2023

February 14, 2023

March 7, 2023

March 14, 2023

April 4, 2023

April 11, 2023

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 

- Minimum Reporting 

 Requirements (Prop)

ADB/NPP Proposal 08.10.17 NOP Memo to 

CACS

12.6.22

1.04.23

Spr 2023

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

Organic and Climate-Smart 

Agriculture (Climate/Equity)

- Organic IS climate smart

NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22

11.8.22

12.6.22

Spr 2023

Organic and Climate-Smart 

Agriculture (Climate/Equity)

- Climate induced farming 

 risk and crop Insurance

CD/NPP Discussion 

document

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22

11.8.22

12.6.22

Spr 2023
Milestones

Spring 2023 Milestones Target dates (tentative) Weeks PTM (prior 

to meeting)

NOP - Publish FRN, Open public comment ~Nov 10, 2022

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks

New NOSB member training TBD

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023

NOP - Post proposals Mar 6, 2023 7.5

Public comment closes Apr 5, 2023 3.5

NOP - Send compiled public comments to NOSB Apr 7, 2023 3

Public comment webinars Apr 18 & 20, 2023 1 week

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023

Final recommendations due May 25, 2023
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 8, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Kyla Smith (KS); Nate 

Powell-Palm (NPP); Kim Huseman (KH), Mindee Jeffery - observer

Absent: None

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

Agenda

• Review October 11, 2022 notes

• Meeting Debrief

• Work agenda items

• Additional Items

• Adjourn

Discussion

• Acceptance of October 11, 2022 notes deferred to the next call.

• Meeting Debrief. Three documents at the Fall NOSB meeting passed and will be removed from the work 

agenda. A couple items will move from discussion documents to proposals.

• Climate change - A lot of ideas were included in the climate smart agriculture discussion document. 

Useful feedback was received in public comments. The NOSB chair asked for feedback from NOSB 

members on next steps. Crop insurance was a top interest and the subcommittee discussed moving 

ahead with a discussion document.

o Standardization of forms and better audits, better guidelines for inspectors. A subcommittee 

member noted that if organic is said to be climate smart, then what is holding back organic 

industry growth? Public comments noted crop insurance as higher risk. The subcommittee asks 

if crop insurance is a barrier, and if the NOSB can suggest changes to USDA programs to make 

crop insurance easier or less risky.

o A subcommittee member is looking at research into how many farmers are using the various 

farm bill programs and what barriers exist. The subcommittee member noted that these 

programs are geared for conventional agriculture and were slightly changed to include organic, 

rather than being designed for organic. The subcommittee member suggests using the open 

docket to ask for feedback.

o The subcommittee discussed how to move forward with a proposal. May include a specific 

request for crop insurance and why organic should be positioned, and eligible, for grants.

o A subcommittee member indicated that practical values should be identified for yields.

• NOSB tech support - Public comments universally support this idea. However, specifics identified varied. 

Such as, who provides help, and with what.

o The subcommittee discussed how this proposal may move forward with the NOP and if the 

NOSB will be informed. The NOSB will receive updates and support may be in year-to-year 

agreements with different USDA programs.

• Risk management project - The subcommittee discussed future steps with this topic, if any. Public 

comments suggested work on Conflict of Interest (COI), certifier selection, certifier inconsistencies, 

audits. The Subcommittee discussed the collaborative work of certification agencies, the growth of the 

NOP, and rules in process.

• Additional Items. The NOP will send coversheets for the final recommendations to the NOSB soon.

• The meeting was adjourned
Previous CACS Notes

Future call schedule (1st & 2nd Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

November 8, 2022

December 6, 2022

Organic and Climate-Smart Agriculture (Climate/Equity) (NPP/CD)

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

December 13, 2022

January 3, 2023 

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

January 10, 2023

February 7, 2023

February 14, 2023

March 7, 2023

March 14, 2023

April 4, 2023

April 11, 2023

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 Fall

2022 

- Minimum Reporting 

 Requirements (Prop)

- Grower Groups (DD)

ADB/NPP Proposal/ 

Discussion 

document

08.10.17 NOP Memo to 

CACS

12.6.22

1.04.23

Spr 2023

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

Organic and Climate-Smart 

Agriculture (Climate/Equity)

- 

CD/NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22

11.8.22

12.6.22

Spr 2023

Organic and Climate-Smart 

Agriculture (Climate/Equity)

- 

CD/NPP Discussion 

document

Approved by Exec 

Cmmte/NOP 1.18.22. 

Memo sent to CACS 

02.23.22

11.8.22

12.6.22

Spr 2023
Milestones

Spring 2023 Milestones Target dates (tentative) Weeks PTM 

(prior to 

NOP - Publish FRN, Open public comment ~Nov 10, 2022

NOSB - Spring 2023 proposals due to NOP Feb 14, 2023 10 weeks

New NOSB member training TBD

NOP - Draft Spring 2023 NOSB meeting tentative agenda Feb 3, 2023

NOP - Post proposals Mar 6, 2023 7.5

Public comment closes Apr 5, 2023 3.5

NOP - Send compiled public comments to NOSB Apr 7, 2023 3

Public comment webinars Apr 18 & 20, 2023 1 week

Spring 2023 NOSB meeting - Atlanta, GA Apr 25 - 27, 2023

Final recommendations due May 25, 2023
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 11, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Kyla Smith (KS); Nate 

Powell-Palm (NPP); Kim Huseman (KH)

Absent: None

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

Agenda

• Review September 13, 2022 notes

• Review Fall meeting logistics

• Review public comments

• Discuss additional ideas for potential work agenda topics

• Additional Items

• Adjourn

Discussion

• September 13, 2022 notes were accepted as written.

• Review Fall meeting logistics.

• Review public comments. The CACS received a good number of comments on the agenda items for the 

fall meeting.

o Organic and Climate-Smart Agriculture (Climate/Equity) - received good feedback and 

anticipating robust conversation as they move to the next iteration of the document. As a 

community, Organics is poised to inform and educate the rest of the USDA about the fact that it 

is already part of the solution to climate change. Organics already has a firm footing and would 

like to talk about scaling up and sharing ideas. Looking for consistency in messaging to make 

sure that Organics has a seat at the table.

o A subcommittee member said it would be helpful to know what the NOSB ask is, particularly if it 

includes a request for funding or new programs. The subcommittee anticipates that it will be 

able to answer this question after the fall meeting and will add it to the Spring proposal. The 

subcommittee plans to highlight other environmental benefits, not just carbon reduction. As 

well as tension between research, which is process based, and the research and data needed as 

system for sustainable agriculture.

o A subcommittee member offered a view to rebalancing, suggesting that food systems currently 

focus on food security, not environmentalism.

o The subcommittee would like to know how NOP will implement the recommendation for NOSB 

support. Public comments were for the most part supportive, and some comments mentioned 

specific items that the technical support person(s) would be able and should or should not do. 

NOP would likely write an MOU with other independent agencies to see who has the capacity to 

do this work. It may take some time for the NOP to find the appropriate agency and find the 

appropriate level of transparency. The NOSB would like to have input as the process moves 

forward. The process of implementing any proposal would be flexible and iterative and can be 

modify as needed. The subcommittee will seek intermittent updates on this project.

o Risk mitigation - the lead noted comments about risks not included on the table as they were 

considered out of scope.

o Acreage - Received quite a few comments with mixed support, ranging from strong to limited.

Some comments suggested the proposal go back to the subcommittee for additional work. The 

subcommittee discussed the process for implementation and whether it would require 
rulemaking, or guidance. The subcommittee also discussed the relationship of this proposal to 

the Strengthening Organic Enforcement rule that is in process. 

• Discuss additional ideas for potential work agenda topics

o A subcommittee member suggested impact of climate on organic farms rather than vice versa. 

Suggested a topic of how USDA programs could be improved to help organic farmers deal with 

climate change.

o A subcommittee member suggested picking up “conflict of interest” as a work agenda topic, 

similar to the work done on the current proposal on the NOP Risk Mitigation Table. Public 

comments may inform this topic.

o A subcommittee member suggested discussing the difference between organic certifiers and 

state programs. 

• Additional Items

• The meeting was adjourned

Previous CACS Notes

Future call schedule (2nd & 4th Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

October 4, 2022 - cancelled

October 11, 2022

Review Fall comments

November 1, 2022 - cancelled

November 8, 2022

Organic and Climate-Smart Agriculture (Climate/Equity) (NPP/CD)

December 6, 2022

Organic and Climate-Smart Agriculture (Climate/Equity) (NPP/CD)

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

December 13, 2022

January 4, 2022

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 
Work Agenda

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

and/or vote.

Milestones

Project Contact Doc Type Notes*

Scheduled, 

Discussed, 

Voted

Target

meeting

Oversight improvements to 

deter fraud: Modernization of 

organic traceability Fall 2022 

1. Acreage/mass balance 

 of yields (Prop) and 

2. Minimum Reporting 

 Requirements (DD)

ADB/NPP Proposal, 

Discussion Doc

08.10.17 NOP Memo to CACS 6.14.22

7.12.22

8.2.22

8.9.22

12.6.22

01.04.23

Fall 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 technical support

JD Proposal 07.31.20 NOP Memo to CACS 6.14.22

7.5.22

7.12.22

Fall 2022

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by Exec Cmte

6.14.22

7.5.22

7.12.22

8.9.22

Fall 2022

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

CD/NPP Discussion 

document

Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS 02.23.22

7.5.22

7.12.22

8.2.22

8.9.22

11.8.22

12.6.22

Fall 2022

Fall 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment June 23, 2022

NOP - Draft Fall 2022 NOSB meeting agenda Aug 5, 2022

NOSB - Fall 2022 proposals due to NOP Aug 11, 2022

NOP - Post proposals Aug 31, 2022

Public comment closes Sep 29, 2022

NOP - Send compiled public comments to NOSB ~Oct 3, 2022

Public comment webinars Oct 18 & 20, 2022

Fall 2022 NOSB meeting - Sacramento, CA Oct 25 - 27, 2022

Final recommendations due Nov 25, 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, September 13, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Kyla Smith (KS)

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

Staff: Michelle Arsenault (MA) 

Agenda

• Review August 9, 2022 notes

• Review New Meeting Structure

• Assign dates for SC review for our two potential proposals (1. climate memo 2. oversite to deter fraud: 

minimal reporting requirements)

• Brainstorm - Any additional topics to add to work agenda

• Comments / Discussion on Fall Meeting CACS work agenda

• Additional Items

• Adjourn

Discussion

• August 9, 2022 notes were accepted as written

• Review New Meeting Structure. The Chair proposed a timeline for reviewing documents to provide 

more time to discuss them before voting. The CACS has two potential proposals on the work agenda: 

Climate-Smart Ag and Oversite to deter fraud: Minimum reporting requirements, and assigned future 

discussion dates for them. See table below. 

• Additional topics to add to work agenda. Members discussed potential topics for future work agenda 

items. The group also discussed having a broader philosophical conversation at the Fall NOSB meeting to 

discuss the past, present, and future of the NOSB. 

• Additional Items. Members discussed organic certification and the potential challenges with marketing 

and add-on labels, and public perception. The CACS is interested in addressing big-picture topics and 

having full-board conversations. 

• The meeting was adjourned

Previous CACS Notes

Future call schedule (2nd & 4th Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

September 13, 2022

October 4, 2022

October 11, 2022

Review Fall comments

November 1, 2022 - cancelled 

November 8, 2022

Organic and Climate-Smart Agriculture (Climate/Equity) (NPP/CD)

December 6, 2022

Organic and Climate-Smart Agriculture (Climate/Equity) (NPP/CD)

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 

December 13, 2022

January 4, 2022

Oversight to Deter fraud: Minimum Reporting Requirements (ADB/NPP) 
Work Agenda

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

and/or vote.

Milestones

Project Contact Doc Type Notes*

Scheduled, 

Discussed, 

Voted

Target

meeting

Oversight improvements to 

deter fraud: Modernization of 

organic traceability Fall 2022 

1. Acreage/mass balance 

 of yields (Prop) and 

2. Minimum Reporting 

 Requirements (DD)

ADB/NPP Proposal, 

Discussion Doc

08.10.17 NOP Memo to CACS 6.14.22

7.12.22

8.2.22

8.9.22

12.6.22

01.04.23

Fall 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 technical support

JD Proposal 07.31.20 NOP Memo to CACS 6.14.22

7.5.22

7.12.22

Fall 2022

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by Exec Cmte

6.14.22

7.5.22

7.12.22

8.9.22

Fall 2022

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

CD/NPP Discussion 

document

Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS 02.23.22

7.5.22

7.12.22

8.2.22

8.9.22

11.8.22

12.6.22

Fall 2022

Fall 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment June 23, 2022

NOP - Draft Fall 2022 NOSB meeting agenda Aug 5, 2022

NOSB - Fall 2022 proposals due to NOP Aug 11, 2022

NOP - Post proposals Aug 31, 2022

Public comment closes Sep 29, 2022

NOP - Send compiled public comments to NOSB ~Oct 3, 2022

Public comment webinars Oct 18 & 20, 2022

Fall 2022 NOSB meeting - Sacramento, CA Oct 25 - 27, 2022

Final recommendations due Nov 25, 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, August 9, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Kyla Smith (KS); Kim 

Huseman (KH); Nate Powell-Palm (NPP); Mindee Jeffery (MJ) - observer

Absent: None

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

Agenda

• Review August 2, 2022 notes

• Oversight to Deter fraud: Acreage/mass balance of yields (ADB/NPP) - discuss proposal/vote

• Oversight to Deter fraud: Minimum Reporting Requirements/bills-of-lading (ADB/NPP) - discuss disc. 

doc/vote

• NOP Risk Mitigation Table review (KS) - discuss proposal/vote

• Organic and Climate-Smart Agriculture (Climate/Equity) (CD) - discuss discussion document/vote

• Additional Items

• Adjourn

Discussion

• August 2, 2022 notes were accepted as written, with one minor modification: The climate document will 

be a discussion document instead of a proposal, and the table below was updated. 

• NOP Risk Mitigation Table review (KS). The lead summarized the additions/changes she made since the 

last discussion, and noted the addition of modifications regarding impartiality. The group discussed the 

proposal and voted to move it forward to the NOSB. The CACS did not receive many comments at the 

Spring meeting, but did receive a few that were specific and comprehensive. 

Motion to accept the proposal on the NOP’s risk mitigation table 

Motion by: Kyla Smith

Seconded by: Nate Powell-Palm

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

• Oversight to deter fraud - Acreage/mass balance of yields proposal (ADB/NPP). The group discussed 

the proposal on acreage/mass balance of yields. The document focuses on two main aspects: how to 

avoid double counting acres, and small acres/parcels. The group also discussed the confidentiality and 

transparency of listing acreage on organic certificates, which would then be publicly available. The lead 

has some additional modifications to make based on feedback from members, and will add some 

background on taxonomy. One member felt they needed to do more research on some components of 

the proposal and therefore abstained from the vote. 

Motion to accept the proposal on acreage/mass balance of yields

Motion by: Amy Bruch

Seconded by: Nate Powell-Palm

Yes: 5 No: 0 Abstain: 1 Recuse: 0 Absent: 0 

• Oversight to deter fraud: Minimum reporting requirements/universal bills-of-lading (NPP). Community 

feedback indicated that universality is important, and so the CACS has broadened this topic to 

encompass more than just bills-of-lading. The group had a thoughtful conversation about making 

reporting requirements more uniform and consistent, resulting in better outcomes for inspectors, 
certifiers, and operations. If the forms that inspectors use were more similar it would eliminate 

inconsistencies, and also aid with better more robust trace-back and mass balance activities. 

Motion to accept the discussion document on minimum reporting requirements/universals bills-oflading

Motion by: Nate Powell-Palm 

Seconded by: Jerry D’Amore 

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

• Organic and Climate-Smart Agriculture (Climate/Equity) discussion document (NPP/CD). The NOSB 

Chair built upon the previous iteration of the document and incorporated answers to the questions 

posed in the NOP memo. The goal of the document is to illustrate the strong connection that already 

exists between organic and climate smart agricultural practices, to ensure that organic is part of the 

conversation as the USDA initiative on climate and equity progresses. The lead will finalize the 

document and recirculate to CACS members, who will vote via email. Voting will close Friday, August 12 

at 5:00 pm ET. 

Motion to accept the discussion document on Organic and Climate-Smart Agriculture 

Motion by: Nate Powell-Palm 

Seconded by: Kyla Smith 

Yes: 5 No: 0 Abstain: 1 Recuse: 0 Absent: 0

• Additional Items. None.

• The meeting was adjourned

Previous CACS Notes

Future call schedule (2nd & 4th Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

August 2, 2022

Oversight to Deter fraud: Acreage/mass balance of yields (ADB/NPP) - discuss proposal/vote

Oversight to Deter fraud: Minimum Reporting Requirements/bills-of-lading (ADB/NPP) - discuss disc. 

doc/vote

NOP Risk Mitigation Table review (KS) - discuss proposal/vote

Organic and Climate-Smart Agriculture (Climate/Equity) (CD) - discuss discussion document/vote

August 9, 2022

September 6, 2022

September 13, 2022

October 11, 2022

November 1, 2022

November 8, 2022

December 6, 2022

December 13, 2022

Work Agenda

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

and/or vote.
Milestones 

Project Contact Doc Type Notes* 

Scheduled, 

Discussed, 

Voted

Target

meeting 

Oversight improvements to 

deter fraud: Modernization of 

organic traceability Fall 2022 

1. Acreage/mass balance 

 of yields (Prop) and 

2. Minimum Reporting 

 Requirements (DD)

ADB/NPP Proposal, 

Discussion Doc

08.10.17 NOP Memo to CACS 6.14.22

7.12.22

8.2.22

8.9.22

Fall 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 technical support

JD Proposal 07.31.20 NOP Memo to CACS 6.14.22

7.5.22

7.12.22

Fall 2022

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by Exec Cmte

6.14.22

7.5.22

7.12.22

8.9.22

Fall 2022

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

CD/NPP Discussion 

document

Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS 02.23.22

7.5.22

7.12.22

8.2.22

8.9.22

Fall 2022

Fall 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment June 23, 2022

NOP - Draft Fall 2022 NOSB meeting agenda Aug 5, 2022

NOSB - Fall 2022 proposals due to NOP Aug 11, 2022

NOP - Post proposals Aug 31, 2022

Public comment closes Sep 29, 2022

NOP - Send compiled public comments to NOSB ~Oct 3, 2022

Public comment webinars Oct 18 & 20, 2022

Fall 2022 NOSB meeting - Sacramento, CA Oct 25 - 27, 2022

Final recommendations due Nov 25, 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, August 2, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Kyla Smith (KS); Kim 

Huseman (KH); Nate Powell-Palm (NPP); Mindee Jeffery (MJ) - observer

Absent: None

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

Agenda

• Review July 12, 2022 notes

• Oversight to Deter fraud: Acreage/mass balance of yields (ADB/NPP) - discuss proposal/vote

• Oversight to Deter fraud: Minimum Reporting Requirements/bills-of-lading (ADB/NPP) - discuss disc. 

doc/vote

• Organic and Climate-Smart Agriculture (Climate/Equity) (CD) - discuss proposal/vote

• Additional Items

• Adjourn

Discussion

• July 12, 2022 notes were accepted as written

• Oversight to Deter fraud proposal (ADB/NPP). The CACS discussed the two components of this work 

agenda item: 1. A proposal on acreage/mass balance of yields and 2. A discussion document on 

minimum reporting requirements (formerly bills-of-lading).

o Acreage/mass balance of yields (ADB). The CACS is proposing that acreage information be 

reported on organic certificates, which would aid in calculating approximate yields. The group 

discussed the taxonomy used to describe categories (livestock/crops/vegetables/fruits) and 

commodities and existing platforms that could be leveraged. NOP noted that the Organic 

Integrity Database (OID) includes a taxonomy that NOP invested significant work and resources 

in developing and that has been widely adopted by certifiers and data consumers. NOP noted 

that certifier reporting of acreage also decouples total acreage from commodity acreage. The 

lead will make some minor modifications to the draft document and the CACS will vote on the 

next call. 

o Minimum reporting requirements (formerly bills-of-lading) (NPP). The CACS briefly discussed 

this project, which has been rescoped to encompass more than just bills-of-lading. NPP will 

develop and circulate a draft later this week for discussion on the August 9 call. 

• Organic and Climate-Smart Agriculture (Climate/Equity) proposal (CD). The lead sought feedback from 

NOSB members on a previous call and incorporated their comments into a draft document. The group 

had a robust conversation about the intent of the document, as emphasized in the NOP memo that 

tasked them with exploring “how organic can advance in tandem with climate-smart agriculture to 

support our planet and our farmers.” Members suggested a proposal rather than a discussion 

document, and will include information demonstrating that organic farming is already climate-smart. 

A member also suggested making a connection between organic and other sectors of the food system. 

The audience for the proposal is the USDA and the organic community and trade. NPP will consult with 

the lead and will revise and recirculate the document before the next CACS call.

• Additional Items. None.

• The meeting was adjourned
Previous CACS Notes

Future call schedule (2nd & 4th Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

July 12, 2022

Oversight to Deter fraud (ADB/NPP). Discuss acreage/mass balance of yields

NOSB Tech Support (JD). Discuss proposal/vote

Organic and Climate-Smart Agriculture (Climate/Equity). Discuss discussion document

August 2, 2022

Oversight to Deter fraud: Acreage/mass balance of yields (ADB/NPP) - discuss proposal

Oversight to Deter fraud: Minimum Reporting Requirements/bills-of-lading (ADB/NPP) - discuss disc. doc

Organic and Climate-Smart Agriculture (Climate/Equity) (CD) - discuss proposal

August 9, 2022

Oversight to Deter fraud: Acreage/mass balance of yields (ADB/NPP) - discuss proposal/vote

Oversight to Deter fraud: Minimum Reporting Requirements/bills-of-lading (ADB/NPP) - discuss disc. 

doc/vote

NOP Risk Mitigation Table review (KS) - discuss proposal/vote

Organic and Climate-Smart Agriculture (Climate/Equity) (CD) - discuss proposal/vote

September 6, 2022

September 13, 2022

October 11, 2022

November 1, 2022

November 8, 2022

December 6, 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 Fall 2022 

1. Acreage/mass balance 

 of yields (Prop) and 

2. Minimum Reporting 

 Requirements (DD)

ADB/NPP Proposal, 

Discussion Doc

08.10.17 NOP Memo to CACS 6.14.22

7.12.22

8.2.22

8.9.22

Fall 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 technical support

JD Proposal 07.31.20 NOP Memo to CACS 6.14.22

7.5.22

7.12.22

Fall 2022
Milestones

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by Exec Cmte

6.14.22

7.5.22

7.12.22

8.9.22

Fall 2022

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

CD/NPP Proposal Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS 02.23.22

7.5.22

7.12.22

8.2.22

8.9.22

Fall 2022

Fall 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment June 23, 2022

NOP - Draft Fall 2022 NOSB meeting agenda Aug 5, 2022

NOSB - Fall 2022 proposals due to NOP Aug 11, 2022

NOP - Post proposals Aug 31, 2022

Public comment closes Sep 29, 2022

NOP - Send compiled public comments to NOSB ~Oct 3, 2022

Public comment webinars Oct 18 & 20, 2022

Fall 2022 NOSB meeting - Sacramento, CA Oct 25 - 27, 2022

Final recommendations due Nov 25, 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, July 12, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Kyla Smith (KS); Kim 

Huseman (KH)

Absent: Nate Powell-Palm (NPP)

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

Agenda

• Review July 5, 2022 notes

• NOSB Tech Support (JD). Discuss proposal/vote

• Oversight to Deter Fraud (ADB/NPP). Discuss acreage/mass balance of yields

• Risk Mitigation Table (KS). Discuss

• Organic and Climate-Smart Agriculture (Climate/Equity). Discuss discussion document

• Additional Items

• Adjourn

Discussion

• July 5, 2022 notes were accepted as written

• NOSB Tech Support (JD). The lead summarized the draft proposal, noting that there is overwhelming 

support among the community, NOSB, and NOP staff. The NOSB is putting forth suggestions for what 

could be completed by the technical support person/people, and will work with the NOP to refine the 

task list as needed. A member suggested some minor edits to the document for clarity, and the CACS 

moved to a vote. The proposal will be posted for public comment and will be on the agenda for the Fall 

2022 NOSB meeting. 

Motion to accept the proposal on NOSB technical support 

Motion by: JD

Seconded by: KH 

Yes: 5 No: 0 Abstain: 0 Absent: 1 Recuse: 0 

• Oversight to Deter Fraud (ADB/NPP). The lead summarized the work to date on the acreage/mass 

balance of yields project. Several CACS members met with staff from the California Department of Food 

and Agriculture (CDFA) to talk about best practices, since CDFA already has well-established processes 

and guidelines. The Subcommittee discussed reporting structure and challenges with flexibility as 

conditions change. The CACS noted a recent press release from the Department of Justice regarding 

organic grain fraud, and briefly discussed this in the context of organic certificates and inspections. The 

lead also mentioned potential difficulties with international oversight, although the Strengthening 

Organic Enforcement rule (SOE) will likely help. 

• Risk Mitigation Table (KS). The lead will draft a proposal based on feedback from NOP and CACS 

member and the Subcommittee will discuss it on the August 2 call. 

• Organic and Climate-Smart Agriculture (Climate/Equity) (CD). The lead is working on a draft document 

and asked for feedback from members by July 22. NOP highlighted two resources that the CACS may 

find helpful as they develop the document: the memo that NOP sent to the CACS in February, which 

contains specific guidance, and the USDA-wide climate change activities. Members highlighted the 

benefits of the organic label as a multifaceted, systems-based approach, which positions it well in the 

climate-smart ag conversation. Such things as carbon capture, soil health, and the lack of pesticides and 
chemicals, all factor into the issue. A member emphasized the importance of viewing it as a system, 

since it’s much broader than just soil. The CACS will discuss the draft document on the August 2 call.

• Additional Items. None. 

• The meeting was adjourned

Previous CACS Notes

Future call schedule (2nd & 4th Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

July 12, 2022

Oversight to Deter fraud (ADB/NPP). Discuss acreage/mass balance of yields

NOSB Tech Support (JD). Discuss proposal/vote

Organic and Climate-Smart Agriculture (Climate/Equity). Discuss discussion document

August 2, 2022

Oversight to Deter fraud (ADB/NPP). Discuss acreage/mass balance of yields; Bills-of-lading

NOP Risk Mitigation Table review. Discuss proposal/vote

Organic and Climate-Smart Agriculture (Climate/Equity) - discuss

August 9, 2022

September 6, 2022

September 13, 2022

October 11, 2022

November 1, 2022

November 8, 2022

December 6, 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 Fall 2022 

1. Acreage/mass balance 

 of yields and 

2. Bills-of-lading

ADB/NPP Proposal 08.10.17 NOP Memo to CACS 6.14.22

7.12.22

8.2.22

Fall 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 technical support

JD Proposal 07.31.20 NOP Memo to CACS 6.14.22

7.5.22

7.12.22

Fall 2022
Milestones

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by Exec Cmte

6.14.22

7.5.22

7.12.22

8.2.22

Fall 2022

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

CD Discussion 

Document

Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS 02.23.22

7.5.22

7.12.22

8.2.22

Fall 2022

Fall 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment June 23, 2022

NOP - Draft Fall 2022 NOSB meeting agenda Aug 5, 2022

NOSB - Fall 2022 proposals due to NOP Aug 11, 2022

NOP - Post proposals Aug 31, 2022

Public comment closes Sep 29, 2022

NOP - Send compiled public comments to NOSB ~Oct 3, 2022

Public comment webinars Oct 18 & 20, 2022

Fall 2022 NOSB meeting - Sacramento, CA Oct 25 - 27, 2022

Final recommendations due Nov 25, 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, July 5, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Kyla Smith (KS); Nate 

Powell-Palm (NPP)

Absent: Kim Huseman (KH)

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

Agenda

• Review June 14, 2022 notes

• Risk Mitigation Table (KS) - discuss in-scope/out-of-scope public comments from spring and finalize next 

steps

• Tech Support (JD) - review draft proposal

• Climate Memo (CD) - review framework

• Oversite to Deter fraud (ADB/NPP) - review best practices

• Additional Items

• Adjourn

Discussion

• June 14, 2022 notes were accepted as written. 

• Risk Mitigation Table (KS). The lead summarized the discussion from the last CACS call, and the group 

reviewed the current list of items under consideration for the next iteration of the proposal. The CACS 

would like to invite Rebecca Claypool of NOP to the next CACS call as they finalize the list. The CACS will 

include items that it is not sure about, and let the NOP determine if they are appropriate and in-scope. 

• NOSB Tech Support Proposal (JD). The lead circulated a draft document, which includes public comment 

the NOSB received on the Spring 2022 discussion document. The group discussed outstanding questions, 

including the potential source of technical support and Board autonomy. Members discussed the 

independence of using another department within USDA versus an outside entity. Although it seems 

counterintuitive, if NOP contracts with an outside entity, then it (NOP) would oversee the contract, 

scope of work, and deliverables. 

• Organic and Climate-Smart Agriculture (Climate/Equity) (CD). The lead has had discussions with 

stakeholders and is reviewing literature, and will work on a draft document to bring to a future call. She 

views this project as iterative and incremental. The NOSB Chair added that the initial memo from NOP

contained a lot of information, and it may be helpful to revisit it as they move forward. The CACS is 

aiming for a document that frames the issue to seek public comment and to facilitate conversations. 

• Oversite to Deter fraud (ADB/NPP). Deferred to next call due to lack of time. 

• Additional Items. The NOSB Vice chair has engaged in conversations with CDFA to discuss the current 

best practices on acreage reporting. 

• The meeting was adjourned

Previous CACS Notes

Future call schedule (2nd & 4th Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

July 5, 2022

July 12, 2022

Oversight to Deter fraud (ADB/NPP). Discuss acreage/mass balance of yields

NOSB Tech Support (JD). Discuss proposal/vote

Organic and Climate-Smart Agriculture (Climate/Equity). Discuss discussion document
August 2, 2022

NOP Risk Mitigation Table review. Discuss proposal/vote

August 9, 2022

September 6, 2022

September 13, 2022

October 11, 2022

November 1, 2022

November 8, 2022

December 6, 2022

December 13, 2022

Work Agenda

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

and/or vote.

Milestones

Project Contact Doc Type Notes*

Scheduled, 

Discussed, 

Voted

Target

meeting

Oversight improvements to 

deter fraud: Modernization of 

organic traceability Fall 2022 

1. Acreage/mass balance 

 of yields and 

2. Bills-of-lading

ADB/NPP Proposal 08.10.17 NOP Memo to CACS 6.14.22

7.12.22

Fall 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 technical support

JD Proposal 07.31.20 NOP Memo to CACS 6.14.22

7.5.22

7.12.22

Fall 2022

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by Exec Cmte

6.14.22

7.5.22

8.2.22

Fall 2022

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

CD Discussion 

Document

Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS 02.23.22

7.5.22

7.12.22

Fall 2022

Fall 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~May 20, 2022

NOP - Draft Fall 2022 NOSB meeting agenda Aug 5, 2022

NOSB - Fall 2022 proposals due to NOP Aug 11, 2022

NOP - Post proposals Aug 31, 2022

Public comment closes Sep 29, 2022
NOP - Send compiled public comments to NOSB ~Oct 3, 2022

Public comment webinars Oct 18 & 20, 2022

Fall 2022 NOSB meeting - Sacramento, CA Oct 25 - 27, 2022

Final recommendations due Nov 25, 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, June 14, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Mindee Jeffery (MJ); Kim 

Huseman (KH); Kyla Smith (KS); Nate Powell-Palm (NPP)

Absent: None

Staff: Michelle Arsenault (MA); Rebecca Claypool (RC); David Glasgow (DG) 

Agenda

• Review May 10, 2022 notes

• NOP Risk Mitigation Table review (KS)

• NOSB tech support proposal (JD)

• Climate Memo framework discussion

• Acres on Certificates - Define boundaries of confidential business information

• Additional Items

• Adjourn

Discussion

• May 10, 2022 notes were accepted as written.

• NOP Risk Mitigation Table review (KS). Rebecca Claypool and David Glasgow joined the call to discuss 

the NOP Risk Mitigation Table proposal. The NOP asked the NOSB to review the table because there was 

an update to the ISO standards, which changed how accreditation bodies manage risk for impartiality. 

The CACS presented a document to the full NOSB at the Spring 2022 meeting, which was sent back to 

the Subcommittee for additional work. The document is intended for accreditation bodies, and some of 

the comments the NOSB received were outside of scope. The CACS is going to work on a document for 

the Fall meeting and will acknowledge concerns they heard from commenters. The NOP added that this 

is a living document and can be updated as needed. 

• NOSB tech support proposal (JD). The NOP and organic stakeholders are supportive of this work agenda

item. The lead will have a draft document ready for the next call. Outstanding questions for discussion 

include the following: 

o Where should support come from? Internal or external?

o Would NOSB lose autonomy seeking outside help?

o What are the costs involved and are ? Is this an issue? DG provided some feedback about 

possible issues. 

• Climate Memo framework discussion (CD). The CACS will work on this project during the next meeting. 

The group discussed the idea of inviting guests to future calls. A member offered to share a link to a 

hearing occurring tomorrow in which the OFRF is participating. 

• Acres on Certificates - Define boundaries of confidential business information (CBI) (ADB). The CACS 

discussed CBI and how organic could be more transparent. Members discussed data collection, which 

some agencies do, and the need for data collection for the purposes of enforcement and identifying risk.

NOP noted that it doesn’t collect acreage data unless it’s for enforcement activities. NOP also 

highlighted the risk management aspect, and reminded the group that organic is an opt-in standard. 

Members also discussed how this could impact different sectors of the organic community, and how it 

would apply to international equivalency agreements. The NOSB Vice Chair shared a link to a document 

from the California Department of Food and Ag (CDFA) as a reminder that CA has already done a lot of 

work on this realm. 
Additional Items. The CACS added an extra call each month, and discussed moving it from the 4th Tuesday to a 

different week and day. NOP will search for a couple of options and let the group know. 

The meeting was adjourned

Previous CACS Notes

Future call schedule (2nd & 4th Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

June 14, 2022

NOSB tech support proposal

June 28, 2022 

July 12, 2022

July 26, 2022

August 9, 2022

August 23, 2022

September 13, 2022

September 27, 2022

October 11, 2022

November 8, 2022

November 22, 2022

December 13, 2022

December 27, 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 Fall 2022 

1. Acreage/mass balance 

 of yields and 

2. Bills-of-lading

ADB/NPP Proposal 08.10.17 NOP Memo to CACS 6.14.22

6.28.22

Fall 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 technical support

JD Proposal 07.31.20 NOP Memo to CACS 6.14.22

7.05.22

Fall 2022

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by Exec Cmte

6.14.22

6.28.22

Fall 2022

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

CD Discussion 

Document

Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS 02.23.22

6.28.22 Fall 2022
Milestones

Fall 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~May 20, 2022

NOP - Draft Fall 2022 NOSB meeting agenda Aug 5, 2022

NOSB - Fall 2022 proposals due to NOP Aug 11, 2022

NOP - Post proposals Aug 31, 2022

Public comment closes Sep 29, 2022

NOP - Send compiled public comments to NOSB ~Oct 3, 2022

Public comment webinars Oct 18 & 20, 2022

Fall 2022 NOSB meeting - Sacramento, CA Oct 25 - 27, 2022

Final recommendations due Nov 25, 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, May 10, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Nate Powell-Palm (NPP);

Mindee Jeffery (MJ); Kim Huseman (KH)

Absent: Kyla Smith (KS)

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

Agenda

• Review April 12, 2022 notes

• Debrief from Spring 2022 NOSB meeting.

• Discuss ideas for the framework for the climate work agenda item

• Brainstorm additional topics for work agenda for the upcoming semester

• Finalize CACS meeting schedule 

• Additional Items. June 14 or May 10 talk through RMT. 

• Adjourn

Discussion

• April 12, 2022 notes were accepted as written.

• Debrief from Spring 2022 NOSB meeting.

o The Chair thanked the group for their flexibility at the meeting to continue the discussion of the 

Modernization of organic traceability later in the meeting.

o Oversight improvements to deter fraud: Modernization of organic traceability Fall 2022: The 

CACS discussed decoupling two topics within this project: Acreage and universal bills-of-lading. 

The intent is to aggregate acreage information into the organic certificate, and with regard to 

the bills-of-lading piece, the intent is to improve usability and standardization. The lead will look 

more closely at the confidential business information (CBI) component, and NOP will seek 

feedback from within the USDA from personnel who can speak to CBI, such as technology and 

privacy officers. The group also discussed the idea of a universal Organic System Plan (OSP), 

which has mixed certifier support, crop insurance, and the cost share program. The NOSB Chair 

asked about inviting Natural Resources Conservation Service(NRCS) or Farm Service Agency 

(FSA) to a future call to discuss. 

o NOSB tech support (JD). The lead summarized the feedback from the Spring meeting, and laid 

out the possible paths forward. The two main questions/concerns are how to fund NOSB tech 

support, and how to protect the Board’s autonomy. The organic community was supportive of 

the project. 

o Risk Mitigation Table. NOP is reviewing the public comments to determine if the scope of the 

Risk Mitigation Table needs to be revised or updated. If so, the NOP may ask the CACS to 

continue work on this. 

• Climate work agenda item (CD). The CACS would like to reach out to the community seeking ideas for

what this project could and should look like. Given that climate change is a broad topic, the group will 

put some boundaries on it. The lead will sketch out some directions and present that to the CACS on a 

future call. 

• Additional topics for work agenda. The CACS has a full schedule and will not add any new topics at this 

time. 

• Finalize CACS meeting schedule. The CACS would like to add meeting time each month and discussed 

adding 30 minutes to the current call, which also requires swapping the CACS call with the Materials 

Subcommittee call. The NOP will work with the CACS to find a solution. 
• Additional Items. The CACS is interested in inviting guest speakers to the calls to provide feedback on 

the climate change discussion. A member reminded the group of an upcoming organic farming research 

day at USDA, being held in Beltsville, MD and virtually, and noted that Michel Cavigelli, a soil scientist 

with ARS, who is leading the field day, would be a valuable speaker. 

• The meeting was adjourned

Previous CACS Notes

Future call schedule (2nd & 4th Tuesdays 2:00 PM ET | 11:00 AM PT, except where noted.) 

April 12, 2022

May 10, 2022

June 14, 2022

NOSB tech support proposal

June 28, 2022

July 12, 2022

July 26, 2022

August 9, 2022

August 23, 2022

September 13, 2022

September 27, 2022

October 11, 2022

November 8, 2022

November 22, 2022

December 13, 2022

December 27, 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 Fall 2022

ADB/NPP Proposal 08.10.17 NOP Memo to CACS 5.10.22 Fall 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 technical support

JD Proposal 07.31.20 NOP Memo to CACS 5.10.22

6.14.22

Fall 2022

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by Exec Cmte

5.10.22 Fall 2022
Milestones

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

CD Discussion 

Document

Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS 02.23.22

6.14.22 Fall 2022

Fall 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment ~May 20, 2022

NOP - Draft Fall 2022 NOSB meeting agenda Aug 5, 2022

NOSB - Fall 2022 proposals due to NOP Aug 11, 2022

NOP - Post proposals Aug 31, 2022

Public comment closes Sep 29, 2022

NOP - Send compiled public comments to NOSB ~Oct 3, 2022

Public comment webinars Oct 18 & 20, 2022

Fall 2022 NOSB meeting - Sacramento, CA Oct 25 - 27, 2022

Final recommendations due Nov 25, 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, April 12, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Nate Powell-Palm (NPP); 

Kyla Smith (KS); Mindee Jeffery (MJ)

Absent: None

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

Agenda

• Review March 8, 2022 14, 2022 notes

• Review upcoming oral comments and board meeting agenda

• Discuss ideas for the framework for the climate work agenda item

• Brainstorm additional topics for work agenda for the upcoming semester

• Finalize updated CACS meeting schedule 

• Additional Items

• Adjourn

Discussion

• March 8, 2022 notes were accepted as written.

• Review written comments and board meeting agenda. 

o NOSB technical support: The CACS received a number of comments on the NOSB technical 

support document. Commenters addressed the topics thoughtfully, and the CACS is looking 

forward to further discussion at the NOSB meeting. The group discussed how other USDA 

agencies would factor into the decision if the Board were to choose to seek technical support 

from within the USDA. Members also discussed benefits and challenges of chooses external 

versus internal assistance. 

o Risk management table: The CACS received detailed comments and looks forward to discussing 

this more at the NOSB meeting. The CACS will summarize the comments and forward those 

along with the recommendation to NOP after the meeting. 

o Modernization of organic traceability: The lead posed questions to the group regarding the 

document and feedback from the community regarding acreage reporting, non-compliances, 

information sharing, etc.

• Framework for the climate work agenda item. The CACS received comments despite the fact that there 

is no document yet. The NOP sent a memo to the CACS in February asking them to work on a climate 

change project, and the CACS will discuss the topic on a future call. Members are supportive of making 

sure organic is at the forefront of the conversation. The group also discussed the possibility of holding 

an expert panel at a future NOSB meeting. NOP supports this idea. A member cautioned the group 

about gaps in research, and about difficulties when comparing the US to the EU. After the Spring 

meeting, the CACS will discuss the scope the project. 

• A member shared a link to an upcoming organic farming research event being held in Maryland (and 

virtually) by a soil scientist at the USDA Agricultural Research Service (ARS), which will include 

discussions on future organic research topics.

• Additional topics for work agenda for the upcoming semester. Deferred to later call.

• Finalize CACS meeting schedule. The CACS would like to either add an additional call each month or add 

30 minutes to its existing call. In order to add 30 extra minutes, it would require swapping the call time 

with the Materials Subcommittee and starting a half-hour earlier. Another option would be to hold an 

additional meeting on a different day of the week. NOP will check with the MS Chair and members. 

• 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.) 

March 8, 2022

April 12, 2022

May 10, 2022

June 14, 2022

July 12, 2022

August 9, 2022

September 13, 2022

October 11, 2022

November 8, 2022

December 13, 2022

Work Agenda

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

and/or vote.

Milestones

Project Contact Doc Type Notes*

Scheduled, 

Discussed, 

Voted

Target

meeting

Oversight improvements to 

deter fraud: Modernization of 

organic traceability Spring 

2022

ADB/NPP Discussion 

Document

08.10.17 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.14.22

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 technical support

JD Discussion 

Document

07.31.20 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.14.22

Spr 2022

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by EC

1.25.22

2.8.22

Spr 2022

Organic and Climate-Smart 

Agriculture (Climate/Equity) 

CD Discussion 

Document

Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS 02.23.22

1.11.22

1.25.22

Fall 2022

Spring 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Mar 3, 2022

NOSB - Spring 2022 proposals due to NOP Feb 16, 2022
New NOSB member training Mar 16 - 18, 2022

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 19 & 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, March 8, 2022 2:00 pm ET 

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Nate Powell-Palm (NPP) 

Absent: Kyla Smith (KS) 

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

Agenda

• Review February 14, 2022 notes

• Review spring meeting agenda

• Review climate letter - confirm that CACS committee will work on this

• Additional Items

• Adjourn

Discussion 

• February 14, 2022 notes were accepted as written.

• Review spring meeting agenda. The CACS discussed the three agenda items for the Spring meeting. 

They have one hour for two discussion documents and one proposal

• Review climate letter (CD). The NOSB Chair confirmed that the CACS committee will work on this topic 

for the upcoming semester. The lead has some upcoming meetings and will be discussing both climate 

change and equity and will bring that info back to the CACS. NOP added that the memo was based on a 

framework from the previous CACS work, similar to the import oversight and human capital projects, 

which are longer-term “umbrella” work agenda items. 

• Additional Items. 

o NOSB Current and Past, was a topic that a CACS member proposed, but for now they will table

it. The CACS may talk more about it when they meet in person, rather than virtually. 

o A member mentioned that crop insurance is an issue that needs to be addressed, even though it 

is not under the purview of NOSB or NOP, it is important to discuss its relationship to organic, 

and potential barriers. The member added that it could be a good fit with the climate-smart-ag 

initiative. Another member added that crop insurance is very complicated and important, and 

proposed a crop insurance panel or NOP-hosted educational webinars. 

o The CACS discussed a possible research priority on crop insurance to assess what is currently out 

there, what gaps exist, and what the barriers are. This may be a great question to ask NIFA at 

the spring NOSB meeting. Perhaps the Risk Management Agency (RMA) could guest speak on a 

future CACS call. The NOSB Chair will formulate question(s) for NIFA, and will also try to tie risk 

management into climate change and crop Insurance. 

o The CACS will discuss swapping call times with the PDS, in order to give the CACS more time to 

meet. If that does not work, they may add a second call each month. 

• The meeting was adjourned

Previous CACS Notes

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

February 14, 2022 (Monday - Additional call)

NOSB tech-support discussion doc (JD) - discuss/vote

Oversight improvements to deter fraud: Modernization of Supply Chain Traceability discussion doc 

(ADB/NP) - discuss/vote
NOSB Current and Past (CD) - discuss

March 8, 2022

April 12, 2022

May 10, 2022

June 14, 2022

July 12, 2022

August 9, 2022

September 13, 2022

October 11, 2022

November 8, 2022

December 13, 2022

Work Agenda

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

and/or vote.

Milestones 

Project Contact Doc Type Notes* 

Scheduled, 

Discussed, 

Voted

Target

meeting 

Oversight improvements to 

deter fraud: Modernization of 

organic traceability Spring 

2022

ADB/NPP Discussion 

Document

08.10.17 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.14.22

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 technical support

JD Discussion 

Document

07.31.20 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.14.22

Spr 2022

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by EC

1.25.22

2.8.22

Spr 2022

Climate/Equity CD Discussion 

Document

Approved by Exec 

Cmmte/NOP 1.18.22. Memo 

sent to CACS XX.XX.XX

1.11.22

1.25.22

Fall 2022

Spring 2022 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Mar 3, 2022

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

New NOSB member training Mar 16-18, 2022
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 19 & 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

Monday, February 14, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Nate Powell-Palm (NPP); 

Kyla Smith (KS) 

Absent: None

Staff: Michelle Arsenault (MA) 

Agenda

• Review February 8, 2022 notes

• NOSB tech-support discussion doc (JD) - discuss/vote

• Oversight improvements to deter fraud: Modernization of Supply Chain Traceability Spring 2022

discussion doc (ADB/NP) - discuss/vote

• NOSB Current and Past (CD) - discuss

• Adjourn

Discussion

• February 8, 2022 notes were accepted as written.

• NOSB tech-support discussion document (JD). The lead summarized the document, noting the

modifications made based on feedback since the last call. The CACS moved to a vote on the document

and will forward it to the NOP for posting at the Spring meeting.

Motion to accept the discussion document on NOSB technical support

Motion by: JD

Seconded by: KS

Additional Discussion: None

Yes: 5 No: 0 Abstain: 0 Absent: 0 Recuse: 0

• Oversight improvements to deter fraud: Modernization of Supply Chain Traceability Spring 2022

discussion document (ADB/NP). The group discussed the draft document, made some minor edits, and

moved to a vote. The CACS will post this document for the Spring meeting.

Motion to accept the discussion document on Oversight Improvements to Deter Fraud: Modernization

of Supply Chain Traceability Spring 2022

Motion by: ADB

Seconded by: NPP

Additional Discussion: None

Yes: 5 No: 0 Abstain: 0 Absent: 0 Recuse: 0

• NOSB Current and Past (CD). The lead explained the impetus behind the idea for this document, which

is two-fold: to inform new members and remind other members about the broader NOSB mandate; and

to seek historical information about the sunset process and what the resolution was after the lawsuit

and court ruling. The lead also noted the value in having the conversation as a full Board. The group

discussed how to move forward, if at all, and will discuss this on the next call.

• 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.) 

February 8, 2022

Review January 11, 2022 notes

Review January 25, 2022 notes

NOSB tech-support doc (JD) - discuss/vote 

Risk Management Table (KS) - discuss/vote 

Oversight improvements to deter fraud: Modernization of Supply Chain Traceability (ADB/NP) - 

discuss/vote 

Climate Change/Equity Update (CD) - discuss/vote

February 14, 2022 (Monday - Additional call)

NOSB tech-support discussion doc (JD) - discuss/vote

Oversight improvements to deter fraud: Modernization of Supply Chain Traceability discussion doc 

(ADB/NP) - discuss/vote

NOSB Current and Past (CD) - discuss

March 8, 2022

April 12, 2022

May 10, 2022

June 14, 2022

July 12, 2022

August 9, 2022

September 13, 2022

October 11, 2022

November 8, 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 Spring 2022

ADB/NPP Discussion 

Document

08.10.17 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.14.22

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 technical support

JD Discussion 

Document

07.31.20 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.14.22

Spr 2022
Milestones

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by EC

1.25.22

2.8.22

Spr 2022

Climate/Equity CD Discussion 

Document

Approved by Exec 

Cmmte/NOP 1.18.22

1.11.22

1.25.22

Fall 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 19 & 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, February 8, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Nate Powell-Palm (NPP); 

Kyla Smith (KS); Mindee Jeffery (MJ) - observer

Absent: None

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

Agenda

• Review January 11, 2022 notes

• Review January 25, 2022 notes

• NOSB tech-support discussion document (JD) - discuss/vote 

• Risk Management Table (KS) - discuss/vote

• Oversight improvements to deter fraud: Modernization of Supply Chain Traceability (ADB/NP) -

discuss/vote

• NOSB (CD) - discuss/vote

• Adjourn

Discussion

• January 11, 2022 notes were accepted as written.

• January 25, 2022 notes were accepted as written.

• NOSB tech-support discussion document (JD). The lead summarized the draft document noting the two 

tasks in front of the CACS and NOSB. First, to confirm that the NOSB does want technical assistance and

whether that assistance should come from the USDA or from the non-profit/university community. The

CACS will submit a discussion document for the Spring 2022 meeting. The lead will circulate a revised 

draft for vote on February 14.

• Risk Mitigation Table Review (KS). The lead thanked the members for feedback and the CACS moved to 

a vote on the proposal.

Motion to accept the proposal on NOP’s Risk Mitigation Table

Motion by: KS

Seconded by: NPP

Yes: 5 No: 0 Abstain: 0 Absent: 0 Recuse: 0 

• Oversight improvements to deter fraud: Modernization of Supply Chain Traceability Discussion 

Document (ADB/NP). The leads circulated a draft discussion document and the CACS discussed it. The 

CACS added an additional call on February 14 to complete the vote.

• NOSB Current and Past (CD). A member proposed a topic for conversation regarding the role of the 

NOSB, based on the initial intent of OFPA. The CACS discussed the idea and what the goal of this would 

be. A member noted that if the goal is to suggest changes to OFPA, that would require negotiations 

within the framework of the Farm Bill and Congress. The CACS will talk more about this on the February 

14 call.

• Additional Items. The CACS added a call on February 14 to complete two votes.

• The meeting was adjourned
Previous CACS Notes

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

January 25, 2022

NOP Risk Mitigation Table - Assign lead/Discuss

February 08, 2022

Review January 11, 2022 notes

Review January 25, 2022 notes

NOSB tech-support doc (JD) - discuss/vote 

Risk Management Table (KS) - discuss/vote

Oversight improvements to deter fraud: Modernization of Supply Chain Traceability (ADB/NP) - 

discuss/vote

Climate Change/Equity Update (CD) - discuss/vote

February 14, 2022 (Monday - Additional call) 

NOSB tech-support discussion doc (JD) - discuss/vote

Oversight improvements to deter fraud: Modernization of Supply Chain Traceability discussion doc 

(ADB/NP) - discuss/vote

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/Supply Chain 

Verification 

ADB/NPP Discussion 

Document

08.10.17 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.14.22

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

JD Discussion 

Document

07.31.20 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.14.22

Spr 2022
Milestones 

NOP Risk Mitigation Table

review

KS Proposal 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by EC

1.25.22

2.8.22

Spr 2022

Climate/Equity CD Discussion 

Document

Approved by Exec 

Cmmte/NOP 1.18.22

1.11.22

1.25.22

Fall 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 19 & 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, January 25, 2022 2:00 pm ET

Present: Amy Bruch (ADB), Chair; Jerry D’Amore (JD), Vice Chair; Carolyn Dimitri (CD); Nate Powell-Palm (NPP); 

Kyla Smith (KS)

Absent: None

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

Agenda

• NOSB tech-support doc review update (JD)

• Climate Change/Equity Update (CD)

• Risk Management Table (KS) NOP Memo to NOSB - Risk Mitigation Table (usda.gov)

• Supply Chain Verification Update (ADB/NP)

• Additional Items

• Adjourn

Discussion

• NOSB tech-support doc review update (JD). The lead expressed support for this work given the 

workload of the NOSB. Members discussed several facets of the project including barriers to finding the 

appropriate expertise, and the perception that the NOSB does not have autonomy from the NOP. The 

CACS is considering the pros and cons of seeking support from non-profits/universities, versus a 

department within the USDA, but outside of NOP. The discussion document will include an excerpt from 

the NOPs statement of work and the CACS will seek feedback from the organic stakeholders at the 

Spring 2022 NOSB Meeting. 

• NOP Risk Mitigation Table. KS will lead this project and is seeking feedback from the other 

Subcommittee members. The CACS intends on presenting a discussion document at the Spring 2022 

NOSB meeting to gather feedback from stakeholders before sending its response to the NOP. 

• Climate Change/Equity Update (CD). The lead indicated that this project is vast, and she is still working 

on scoping, but may produce a brief discussion document for the Spring NOSB meeting to introduce the 

topic and start a discussion. The NOP will be sending the CACS a work agenda item on this topic, which 

may initiate a document for the Fall 2022 meeting. 

• Supply Chain Verification Update (ADB/NPP). The leads indicated that this is a work in progress and the 

group had a robust conversation about best practices and next steps for aspects such as tech support for

the community and how enhanced data collection could possibly assist in identifying fraud. Members 

discussed the use of the Organic Integrity Database to input data, and the benefits and challenges 

associated with that. A member noted that the Strengthening Organic Enforcement (SOE) rule does have 

data requirements that may address this need, and it might be better to wait until it is published before 

they move forward. 

• 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.)

January 11, 2022

January 25, 2022

NOP Risk Mitigation Table - Assign lead/Discuss
February 08, 2022

Review January 11, 2022 notes

Review January 25, 2022 notes

NOSB tech-support doc (JD) - discuss/vote 

Risk Management Table (KS) - discuss/vote

Oversight improvements to deter fraud: Supply Chain Verification Update (ADB/NP) - discuss/vote

Climate Change/Equity Update (CD) - discuss/vote

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/Supply Chain 

Verification

ADB/NPP Discussion 

Document

08.10.17 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.8.22

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

JD Discussion 

Document

07.31.20 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

1.25.22

2.8.22

Spr 2022

NOP Risk Mitigation Table

review

KS Discussion 

Document

11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by EC

1.25.22

2.8.22

Spr 2022

Climate/Equity CD Discussion 

Document

Approved by Exec 

Cmmte/NOP 1.18.22

1.11.22

1.25.22

2.8.22

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 19 & 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, January 11, 2022 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.

Absent: None

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

Agenda

• Review December 14, 2021 notes

• Tech-Support for NOSB RFA (CD/NPP)

• Climate/Equity (CD)

• Oversight Improvements to deter fraud (ADB/NPP)

• NOP Risk Mitigation Table (Assigned to CACS 12.21.21) - Assign lead/Discuss

• Additional Items

• Adjourn

Discussion

• December 14, 2021 notes were accepted with a minor correction.

• Tech-Support for NOSB RFA (CD/NPP). The NOP drafted a proposal seeking assistance for the NOSB

members, and the CACS will review the draft and provide feedback. The group discussed whether to 

seek assistance from non-profits and outside organizations, or to solicit help from within the 

government/USDA, but outside of NOP/AMS. 

• Climate/Equity (CD). The lead introduced the issues that the Board proposes to address with this 

project and will write a request to add this to the CACS work agenda. The Chair will forward the request 

to the Executive team for discussion on the January 18 call. Members discussed possible topics and 

content for consideration. 

• Oversight Improvements to deter fraud (ADB/NPP). The lead summarized feedback from the 

community from the Fall meeting regarding goals, outstanding questions, and the focus going forward. 

The CACS discussed whether to produce a document for the Spring meeting or to wait until other 

external pieces move ahead, specifically the final rule for Strengthening Organic Enforcement (SOE). 

• NOP Risk Mitigation Table (Assigned to CACS 12.21.21). Deferred to January 25 call.

• 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.)

December 14, 2021

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

Finalize Potential Work Agenda Topics (AB)

January 11, 2022

January 25, 2022

NOP Risk Mitigation Table - Discuss

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.

Milestones 

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

1.11.22

2.8.22

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 DD/Proposal? 07.31.20 NOP Memo to CACS 11.9.21

12.14.21

1.11.22

2.8.22

Spr 2022

NOP Risk Mitigation Table

review

TBD TBD 11.18.21 NOP Memo to 

NOSB. Assigned to CACS on 

12.21.21 by EC

1.25.22 Spr 2022

Climate/Equity CD TBD Pending approval by Exec 

Cmmte/NOP. 

1.11.22

2.8.22

TBD

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 19 & 21, 2022

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

Final recommendations due May 27, 2022