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

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, January 8, 2013, 3:00 pm EST 

Attending: Joe Dickson (Chair) (JD), Mac Stone (MS), John Foster (JFo), Harold Austin (HA), Barry Flamm

(BF), Carmela Beck (CB), Tracy Favre (TF)

Absent: Jean Richardson (JR) (Vice Chair), Calvin Walker (CW)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of organic

ingredients

MS/JR/JFo Proposal. NOP is interested in 

how formulated “organic” 

products should be calculated

Spr 2013

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc. On hold until 

Strict but Sensible is fleshed out

TBD

Sanitizers in 100% 

organic products

JFo On hold. NOP will provide 

overview to CACS of food contact 

substances and processing aids

in ~January 2013

TBD

Fall 2009 Guidance 

doc on Retail 

Certification

HA/JD (not 

lead)

Discussion doc. Will look at 

previous NOSB recommendation 

and current conditions, and see 

if an additional recommendation 

would be helpful.

JD will 

recuse 

from vote

Fall 2013

Agenda: 

• Approve minutes from December 19 

• Discuss next steps for “Calculating % of organic ingredients” (JR/JFo).

• Retail Certification – status check

Discussion: 

• Notes from the December 19 call were approved with no changes. 

• The chair indicated that the retail certification document will be delayed until the fall 2013 meeting, 

pending the work by the OIG on this topic. The delay will be discussed on the ES call this coming 

Friday. The workplan table above was updated to reflect this.

• Calculating percentage (%) of organic ingredients. MS noted that there is an hour long session on 

this topic at the Accredited Certifiers Association (ACA) meeting next week in Orlando, FL, and 

suggested that it might be a good place to network with various people. The NOP suggested some

edits and the chair noted those for JR, who is the lead person for this project. The members felt that 
the document was getting very long, and suggested separating some of the units, and in support of 

that will do some editing via email and prepare this document for a vote on next call (January 22). JD 

will make some edits and forward them to the group in the next couple days. A member 

paraphrased an adage from Deputy Secretary Merrigan: “Don’t let perfect be the enemy of the 

good.” 

• MS noted that the ACA training includes a discussion of the new initiative “Strict and Sensible” 

which he will debrief the group about on the January 22 call.

• A member asked about future workplan items for the CACS, and asked that MS keep an ear out for 

any ideas and feedback from the ACA training. The chair also asked that the group think about some 

ideas. 

Future Scheduled Subcommittee Calls

January 8, 2013 3:00 pm EST

Discuss/vote on Calculating % of organic ingredients (JR or JFo) 

 Discuss Retail Certification (delayed until fall 2013)

January 22, 2013 3:00 pm EST

Discuss/vote on Calculating % of organic ingredients

MS debrief about ACA training

February 12, 2013 3:00 pm EST - proposals due

February 26, 2013 3:00 pm EST

March 12, 2013 3:00 pm EST

March 26, 2013 3:00 pm EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, January 22, 2013, 3:00 pm EST 

Attending: Joe Dickson (Chair) (JD), Jean Richardson (JR) (Vice Chair), Mac Stone (MS), John Foster (JFo), 

Harold Austin (HA), Barry Flamm (BF), Tracy Favre (TF), Calvin Walker (CW)

Absent: Carmela Beck (CB)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of organic

ingredients in multiingredient products

MS/JR/JFo Proposal. NOP is interested in 

how formulated “organic” 

products should be calculated

Spr 2013

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc. On hold until 

Strict but Sensible is fleshed out

TBD

Sanitizers in 100% 

organic products

JFo On hold. NOP will provide 

overview to CACS of food contact 

substances and processing aids

in ~January 2013

TBD

Fall 2009 Guidance 

doc on Retail 

Certification

HA/JD (not 

lead)

Discussion doc. Will look at 

previous NOSB recommendation 

and current conditions, and see

if an additional recommendation 

would be helpful.

JD will 

recuse 

from vote

Fall 2013

Agenda: 

• Approve minutes from January 8

• Debriefing from of Accredited Certifiers Association (ACA) training

• Discuss next steps for “Calculating % of organic ingredients” (JR/JFo).

Discussion: 

• Notes from the January 8 call approved with no changes. 

• Note: ABS changed the title of “Calculating % of organic ingredients to Calculating % of organic 

ingredients in multi-ingredient products” based on input from one of the Subcommittee members

• Update on Sound but Sensible presentations from the ACA meeting in FL. MS summarized his 

experience at the ACA meeting which included session on outreach, education, user friendliness, 

Organic System Plans, and auditing, with a goal of streamlining paperwork. The ACA and NOP

discussed how to use the penalty matrix, and what distinguishes minor from major noncompliance, 
based on impact to organic integrity. A member asked if the topic of calculating percentage of 

ingredients was discussed and MS noted that it was, and it appears that the NOSB is on track with 

the proposal, especially with regard to water. 

• Calculating % of organic ingredients in multi-ingredient products: the group discussed edits to the 

document and feels that it is nearing completion and will be ready for voting during the next call 

(February 12). The group consensus is that although there isn’t a substantial problem, it does need 

to be documented. JR will incorporate the additional comments and circulate the document prior to 

the next call.

Future Scheduled Subcommittee Calls

January 22, 2013 3:00 pm EST

Discuss/vote on Calculating % of organic ingredients

MS debrief about ACA training

February 12, 2013 3:00 pm EST - proposals due

 Vote on Calculating % of organic ingredients in multi-ingredient products

February 26, 2013 3:00 pm EST

March 12, 2013 3:00 pm EST

March 26, 2013 3:00 pm EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, February 12, 2013, 3:00 pm ET 

Attending: Joe Dickson (Chair) (JD), Jean Richardson (JR) (Vice Chair), Mac Stone (MS), Harold Austin 

(HA), Tracy Favre (TF), Calvin Walker (CW), Carmela Beck (CB)

Absent: John Foster (JFo)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of organic

ingredients in multiingredient products

MS/JR/JFo Proposal. NOP is interested in 

how formulated “organic” 

products should be calculated

02 12 13 Spr 2013

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc. On hold until 

Sound and Sensible is fleshed out

TBD

Sanitizers in 100% 

organic products

JFo On hold. NOP will provide 

overview to CACS of food contact 

substances and processing aids

in ~January 2013 -delayed

TBD

Fall 2009 Guidance 

doc on Retail 

Certification

HA/JD (not 

lead) 

Discussion doc. On hold until OIG 

provides more info about this 

item

JD will 

recuse 

from vote

Fall 2013

Potential item: How 

certifiers apply 

205.206(e)

See JFo for 

more info

How certifiers apply 205.206(e) 

and judge the conditions 

appropriate to allow the use of a 

synthetic whatever

Agenda: 

• Review and approve notes from January 22 call

• Discuss and vote on Calculating % of organic ingredients in multi-ingredient products

• Discuss potential workplan items

Discussion: 

• Notes from the January 22 call were approved with no changes. 

• Calculating % of organic ingredients in multi-ingredient products. The members discussed some 

minor edits to the language in the document and proceeded to a vote. 
Vote on Calc % Organic Ingredients.

Motion to accept and forward to the full Board the proposal on Calculating % of organic 

ingredients in multi-ingredient products as amended 

Motion by: JR

Seconded by: JD

Additional discussion: none

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

The Chair will make the final edits and send to MA for posting. 

• Potential workplan items 

o The group discussed the retail certification guidance, which is currently on hold pending an 

OIG audit. JR noted that she recently attended a meeting where this was a major topic of 

discussion, where one of the areas of focus was the misrepresentation of the word organic 

at Farmers Markets. The members discussed the benefits of doing outreach and education 

as a means to prevent problems and asked if the USDA did outreach to conventional and 

other growers? The NOP provided a summary of some of the efforts that the USDA is 

making to reach out to farmers and connect farmers to USDA resources. MA will ask the 

Deputy Administrator about the OIG report status. (Update 02 13 13 - OIG has listed audit as 

a candidate audit for 2013, but it has not been initiated.).

o Sanitizers in 100% organic products. MA will ask about the status of this item and report 

back to the group. (Update 02 13 13: The NOP update re: Sanitizers in 100% Organic 

products is delayed).

o Members discussed Inspector training, and decided that this would be better suited for the

NOP than for the CACS. 

o The group also discussed seeking suggestions from various segments of the community

about potential workplan items. MS will ask ACA Board for suggestions. 

Future Scheduled Subcommittee Calls

February 12, 2013 3:00 pm EST - proposals due

Vote on Calculating % of organic ingredients in multi-ingredient products

February 26, 2013 3:00 pm EST-cancelled

March 12, 2013 3:00 pm EST

March 26, 2013 3:00 pm EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013
Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, March 12, 2013, 3:00 pm ET 

Attending: Joe Dickson (Chair) (JD), Jean Richardson (JR) (Vice Chair), Mac Stone (MS), Harold Austin 

(HA), Tracy Favre (TF), Calvin Walker (CW), John Foster (JFo)

Absent: Carmela Beck (CB)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of organic

ingredients in multiingredient products

MS/JR/JFo Proposal. NOP is interested in 

how formulated “organic” 

products should be calculated

02 12 13 Spr 2013

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc. On hold until 

Sound and Sensible is fleshed out

TBD

Sanitizers in 100% 

organic products

JR/JFo On hold. NOP will provide 

overview to CACS of food contact 

substances and processing aids

in ~January 2013 -delayed

TBD

Fall 2009 Guidance 

doc on Retail 

Certification

HA/JD (not 

lead) 

Discussion doc. JD will 

recuse 

from vote

Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

Fall 2013

Sound and Sensible MS

Agenda: 

• Review and approve notes from February 12 call

• Review comments on “Calculating percentage of organic ingredients...” 

Discussion: 

• Notes from the February 12 call approved with no changes

• Calculating percentage of organic ingredients- The Board hasn’t received any comments yet, but in 

personal communications, a member received positive feedback with some minor suggestions about 

language or reformatting. Other members have received verbal feedback ahead of people 

submitting written comments. 
• Workplan 

o Retail Certification - back on workplan because OIG will probably not take this up yet.

o Sound and Sensible - discussion about this continues and although most of it is internal to 

NOP, the CACS would be a good vehicle to get this into the public realm. The group is unsure 

as to whether or not a discussion document is the best vehicle for this.

o Sanitizers. The NOP indicated that there is consideration of development of a guidance 

document, but due to other priorities it will be delayed. Members felt that this is a topic 

that has profound implications to the community and the consensus was that it should be a 

workplan item. EBR asked what the group envisioned as the problem. Some members 

believe that sanitizers should not be considered processing aids (as NOP rule does) and 

believe that FDA does not consider them processing aids. [NOP notes that FDA does 

consider antimicrobials such as peracetic acid and sodium hypochlorite to be secondary 

direct food additives used for washing or peeling fruits or vegetables at 21 CFR173.315]. The 

group consensus is to keep it on the workplan so it does not drop off. 

o Potential item: How certifiers apply 205.206(e) – A member noted that often on Crops calls 

the bigger picture gets forgotten, and that these materials are not used in a vacuum. The 

feeling is that it would be useful to solicit comments from the certification community about

205.206(a-e) and how this applies to Crops Subcommittee materials. The NOP suggested 

that perhaps the questions can be phrased as “best practices”. A member added that this

should be viewed as a process based system – and not just materials use. The group 

consensus is that this is an important topic and they would like to move forward with this 

item for the workplan. The Chair asked about presenting this on the next ES call. The group 

will discuss this further on next call and flush out idea for NOP consideration. 

Future Scheduled Subcommittee Calls

February 26, 2013 3:00 pm EST- cancelled

March 12, 2013 3:00 pm EST

March 26, 2013 3:00 pm EST

Comments

Potential item: How certifiers apply 205.206(e)

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013
Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, May 10, 2013, 12:00 pm ET 

Attending: Jean Richardson (JR) (Vice Chair), Harold Austin (HA), Carmela Beck (CB), Mac Stone (MS),

John Foster (JFo), Calvin Walker (CW)

Absent: Joe Dickson (Chair) (JD), Tracy Favre (TF)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead) 

Discussion doc. JD will 

recuse 

from 

vote

Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

Fall 2013

Sound and Sensible JR/MS Discussion document? Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo On hold. NOP will provide 

overview to CACS of food 

contact substances and 

processing aids. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR/JFo Proposal. NOP is interested 

in how formulated “organic” 

products should be 

calculated

Fall 2014

Agenda: 

• Review and approve notes from March 26 call

• Review workplan

Discussion: 

• Notes from the March 26 call were approved with no changes

• Workplan: 
o Sound and sensible - The NOP would like the NOSB ultimately to produce a

recommendation, and the Subcommittee requested some written guidance from NOP 

before moving forward. EBR will let the Subcommittee know how to proceed. 

o The NOP is working on guidance based on the Board Recommendation for calculating 

percentage of organic ingredients in multi-ingredient products, and may include guidance 

about 100% label use as impacted by use of sanitizers/antimicrobials. NOP will provide 

feedback to the CACS when it is finished. 

o Exclusion of water in calculating percentage of organic ingredients - EBR will check with the 

program about this and let the group know how to proceed. 

o The members clarified that the Retail Certification discussion document is going forward for 

the fall meeting.

Future Scheduled Subcommittee Calls

May 28, 2013 3:00 pm ET 

JR out of office

How certifiers apply 205.206(e) (JFo)

Retail Certification (HA/JD)

June 11, 2013 3:00 pm ET 

JR out of office

June 25, 2013 3:00 pm ET

Sanitizers in 100% organic products (EBR/JFo)

July 9, 2013 3:00 pm ET

Sound and Sensible (EBR)

Exclusion of water (EBR/JR)

July 23, 2013 3:00 pm ET

August 13, 2013 3:00 pm ET

August 27, 2013 3:00 pm ET

September 10, 2013 3:00 pm ET

September 24, 2013 3:00 pm ET

October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB
Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, May 28, 2013, 3:00 pm ET

Attending: Joe Dickson (Chair) (JD), Harold Austin (HA), Carmela Beck (CB), Mac Stone (MS), John Foster 

(JFo)

Absent: Jean Richardson (JR) (Vice Chair), Tracy Favre (TF), Calvin Walker (CW)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead) 

Discussion doc JD will 

recuse 

from 

vote

Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

Fall 2013

Sound and Sensible JR/MS Discussion document Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo On hold. NOP will provide 

overview to CACS of food 

contact substances and 

processing aids. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR/JFo Proposal. NOP is interested 

in how formulated “organic” 

products should be 

calculated

Fall 2014

Agenda: 

• Review and approve notes from May 10 call

• Discuss status of workplan items

Discussion: 

• Notes from the May 10 call were approved with no changes. 

• The CACS is waiting for more info from the NOP about Sound & Sensible (S & S) and would like to 

know how to proceed and what the timeline is. If the target meeting is fall 2013, they need to start 
soon. MS indicated that the project is still a bit nebulous, but the plan is for the CACS to produce a 

discussion document with a general discussion about S & S and any other content they would like to 

include. MS will lead this project. 

• How certifiers apply 205.206(e) (JFo). JFo will write a rough draft with major questions and will 

circulate it prior to the group prior to the June 11 call. 

• Retail Certification – (HA). JD provided some background information. The Subcommittee was in 

unanimous support of this as he has vast knowledge of this area. JD had chosen to abstain from 

voting but may reevaluate that decision. MS noted that he too is involved in the retail market but 

doesn’t feel that he has a COI. The group discussed the potential perception of COI and chose to 

contact the NOP to ask for formal determination about this issue. The members discussed various 

aspects of retail certification that could be incorporated into this discussion document, including the 

issues of exemptions surrounding processing and packaging items in a retail facility and 

opportunities for use of the seal, etc. EBR suggested that the group might be thinking too broadly 

and it would be useful to narrow the parameters. JFo noted that processing is defined in §205.270, 

and the problem is the “onsite exclusion at 205.101(b)(2). The group discussed how to move 

forward since the NOP has not addressed the 2009 guidance, and now should determine the most 

useful products such as fact sheets, guidance and/or rule changes. EBR will check with NOP 

Compliance to see if there have been specific problems to date. Members discussed the Organic 

Trade Association proprietary training program called Good Organic Retail Practices (GORP) and 

whether or not it is current. A member asked about online retail sales and the potential of including 

that component in the discussion document. The retail establishment definition in the regulation

addresses brick and mortar operations, but is silent on internet sales. The NOP asked that the group 

compile a list of questions so it can determine if they’ve been addressed elsewhere. The group 

discussed the inclusion of examples and principles in the discussion document which is very helpful 

when relaying information to the public. Another component of this document could include 

sanitizers. The group feels that the fundamental question is who is checking on compliance with 

adherence to 205.272 (contamination with prohibited substances and commingling), and asked the 

NOP if this is important or if there are more important issues to address. A member noted that noncompliance issues at farmers markets and false claims about certification are potential items for this 

document. HA and JD will work together on a draft document to compile questions, and the NOP

will engage the Compliance Division to see if they have suggestions for other items to include. 

Future Scheduled Subcommittee Calls

May 28, 2013 3:00 pm ET 

JR out of office

How certifiers apply 205.206(e) (JFo)

Retail Certification (HA/JD)

June 11, 2013 3:00 pm ET 

How certifiers apply 205.206(e) (JFo)

MS - Exec summary on S & S

JR out of office

June 25, 2013 3:00 pm ET

Sanitizers in 100% organic products (EBR/JFo)

July 9, 2013 3:00 pm ET

Sound and Sensible (EBR)
Exclusion of water (EBR/JR)

July 23, 2013 3:00 pm ET

August 13, 2013 3:00 pm ET

August 27, 2013 3:00 pm ET

September 10, 2013 3:00 pm ET

September 24, 2013 3:00 pm ET

October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, June 11, 2013, 3:00 pm ET

Attending: Joe Dickson (Chair) (JD), Harold Austin (HA), Carmela Beck (CB), John Foster (JFo), Tracy Favre 

(TF), Calvin Walker (CW)

Absent: Jean Richardson (JR) (Vice Chair), Mac Stone (MS), Emily Brown Rosen (EBR)

Staff: Michelle Arsenault (MA)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead)

Discussion doc JD will 

recuse 

from 

vote?

Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

Fall 2013

Sound and Sensible JR/MS Discussion document Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo? JR? On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR/JFo Proposal. How formulated 

“organic” products should 

be calculated

Fall 2014

Agenda

• Review and approve notes from May 28 call

• How certifiers apply 205.206(e)

• Exec summary on S & S (MS)

• Retail Discussion Doc update (HA)

Discussion

• Notes from the May 28 call were approved with no changes.

• How certifiers apply 205.206(e): JFo circulated a draft document for the group to review and the 

group considered various aspects, including the goal for this document. Members discussed the 

usefulness of writing a discussion document first, with specific questions for certifiers, with the 
intent of providing the NOP with guidance not a rule change. A member noted that the general 

record keeping requirement should be adequate but it might not be specific enough, and the 

inclusion of overarching guidance would help to give the general public more confidence about 

NOSB review. Members also felt that this could operate as an education tool as well. The group was 

supportive of moving this forward as a discussion document. JFo will pose some questions for 

discussion on the July 23 call

• Exec summary on S & S (MS) - postponed until June 25

• Retail Discussion Doc update (HA) - rescheduled for July 23

• Sanitizers in 100% organic products- MA will verify who is leading this review. 

Future Scheduled Subcommittee Calls

June 11, 2013 3:00 pm ET

How certifiers apply 205.206(e) (JFo)

MS - Exec summary on S & S – postponed until June 25

JR out of office

June 25, 2013 3:00 pm ET

MS - Exec summary on S & S

Sanitizers in 100% organic products (EBR/JFo?)

July 9, 2013 3:00 pm ET

Sound and Sensible (EBR)

Exclusion of water (EBR/JR) 

July 23, 2013 3:00 pm ET

Retail Certification (HA)

How certifiers apply 205.206(e) - Discuss questions to include in DD

August 13, 2013 3:00 pm ET

August 27, 2013 3:00 pm ET

September 10, 2013 3:00 pm ET

September 24, 2013 3:00 pm ET

October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013
NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, June 25, 2013, 3:00 pm ET

Attending: Joe Dickson (Chair) (JD), Harold Austin (HA), Carmela Beck (CB), John Foster (JFo), Tracy Favre 

(TF), Calvin Walker (CW), Mac Stone (MS)

Absent: Jean Richardson (JR) (Vice Chair)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead)

Discussion doc JD will 

recuse 

from 

vote?

Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

Fall 2013

Sound and Sensible JR/MS Discussion document Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo? JR? On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR/JFo Proposal. How formulated 

“organic” products should 

be calculated

Fall 2014

Agenda

• Approve notes from June 11 call

• Sanitizers in 100% Organic Products (JFo)

• Quick 205.206(e) update, if necessary (JFo)

• Executive Summary on Sound and Sensible CACS participation (MS)

• Discussion

• Notes from the June 11, 2013 call were approved with no changes

• Sanitizers in 100% Organic Products (JFo) – The group reviewed the past NOSB discussion document 

(March 2012) and noted that it was very well written and comprehensive. Members discussed 
sanitizers and processing aids, including whether or not they are distinct. The NOP noted that they 

view microbial aids as processing aids, and that use on food for control of microorganisms is 

regulated differently than sanitizers used to clean equipment, which are considered food contact 

substances. Antimicrobials used in direct food contact are generally classed by FDA as secondary 

direct food additives. To that end, a member asked if oranges would be disqualified from the 100% 

organic claim if they were dropped in a sanitizing bath. The NOP noted that this was discussed in the 

document from the spring 2013 meeting entitled “Calculating % of organic ingredients in 100% 

organic products”. The HS has proposed that sanitizers (and antimicrobials ) be separated into their 

own section on the National List, which would clarify substance classification, and what was or 

wasn’t an ingredient. The NOP will provide some background references regarding FDA and EPA 

regulation. Members then discussed the need for this document, and there was wide support for 

moving forward. In support of that JFo will write up a discussion document highlighting the 

antimicrobial/sanitizer language differences and will present it on the next call. 

• Update on “How certifiers apply 205.206(e)”. The group discussed possible questions to include in 

the discussion document on this topic. The Subcommittee is seeking comments on this subject from 

the general public, and in particular the certification community on the following questions: 1. What 

do you require of applicants and certified operators in their OSP with respect to their compliance 

with §205.206(e)? 2. What verification from the operator do you require in support of their 

compliance with § 205.206(e), either during review of the OSP or at the inspection? 3. What 

information to do you require when an operator needs to amend their OSP on short notice when 

pest pressure unpredictably rises beyond their decision threshold? JFo asked the group to review 

the questions, and to add any others they thought would be helpful. 

• Executive Summary on Sound and Sensible. MS discussed his thoughts on Sound & Sensible, and 

how the CACS may be able to participate. There are various layers to this initiative, and while it is 

still not clear what the discussion document would include, one member suggested framing the 

challenges and difficulties in order to solicit feedback. This initiative seeks to remedy several 

difficulties, including making the system more user friendly, and reducing paperwork burdens 

without compromising the integrity of the process. 

Future Scheduled Subcommittee Calls

June 25, 2013 3:00 pm ET

MS - Exec summary on S & S

Sanitizers in 100% organic products (EBR/JFo?)

July 9, 2013 3:00 pm ET

Sound and Sensible (MM/SNY)

Exclusion of water (SNY/JR) 

July 23, 2013 3:00 pm ET

Retail Certification (HA)

How certifiers apply 205.206(e) - Discuss questions to include in DD

August 13, 2013 3:00 pm ET

August 27, 2013 3:00 pm ET

September 10, 2013 3:00 pm ET

September 24, 2013 3:00 pm ET
October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, July 9, 2013, 3:00 pm ET

Attending: Joe Dickson (Chair) (JD), Harold Austin (HA), John Foster (JFo), Tracy Favre (TF), Calvin Walker 

(CW), Mac Stone (MS), Jean Richardson (JR) (Vice Chair)

Absent: Carmela Beck (CB)

Staff: Michelle Arsenault (MA), Shannon Nally Yanessa (SNY)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead)

Discussion doc JD will 

recuse 

from 

vote?

Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

Fall 2013

Sound and Sensible JR/MS Discussion document Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR Proposal. How formulated 

“organic” products should 

be calculated. Waiting for 

guidance from NOP. 

Fall 2014

Agenda

• Approve notes from June 25 call

• Sound and Sensible (MS/SNY)

• Exclusion of water (SNY/JR)

• Discussion

• Notes from the June 25, 2013 call were approved with no changes. 

• Shannon Nally Yanessa, the new technical representative for the CACS, introduced herself and was 

welcome by the group. 

• Sound and Sensible (MS) – MS circulated a draft document to the group and discussed various 

components that are still being revised. MS noted that the Accredited Certifiers Association, Inc

(ACA) has a working group composing a document that potentially could be folded into this 
discussion document. The intent of the discussion doc is to lay out the process of Sound and 

Sensible (S & S) and includes many questions for public comment and feedback. MS asked that the 

members add or alter any of the questions. SNY added that the NOP sent an information collection 

notice via the insider asking for feedback about the paperwork burden, and the comments are due 

by August 27. The comment period is open on Regulations.gov and SNY will summarize and send any 

comments to the group so they can be incorporated. MS noted that the NOP had originally included 

a penalty matrix but it was not included in this document because it was not well received by the 

community. The S & S initiative is being embraced by the community and the group feels it is 

important that the CACS and NOSB promote it to keep the public alerted. CW added that it would 

be useful to add some more discussion points around streamlining record keeping. MS asked that 

members send in any comments or suggestions, and upon a recommendation from one of the 

members, include case studies or specific examples. Members emphasized the importance of 

including the appropriate level of detail in the guidance because certifiers often have variable levels 

of background knowledge and don’t necessarily know which questions to ask. As to bullet point 4 

under background, (Operators required to fill out redundant forms and documents), a member

noted that this is probably not the result of NOP policy but instead there seems to be a connection 

between excess paperwork and certifier qualifications. The same member asked that a reference or 

recognition for integrity of the product be included in the background section even though this is a 

process based document. The lead reviewer noted that although this initiative has a lot of support, 

they don’t want to give the impression that the certification process isn’t working now. This 

initiative is a means to improve and streamline the process. MS will continue to edit and revise the 

document and asked that members send in any comments. 

• Exclusion of water (SNY/JR) - JR noted that they were waiting for some guidance from the NOP 

because the topic is complex and there are many conflicting ways to calculate percent organic 

water. The problem they would like to see addressed is that currently there is no accessible single 

source for people to verify consistency in calculation methods. At the spring 2013 NOSB meeting, 

the NOSB asked that the NOP work on this guidance. SNY stated that the NOP had initially asked the 

NOSB to work on this, but reconsidered. SNY suggested that the NOP take the lead and address this 

issue when updating the NOP policy for calculating the percentage of organically produced 

ingredients. CACS opted to keep this on its workplan citing the informative public comments and the 

desire to work with NOP to provide input on this topic. 

Future Scheduled Subcommittee Calls

July 9, 2013 3:00 pm ET

Sound and Sensible (MS/SNY)

Exclusion of water (SNY/JR) 

July 23, 2013 3:00 pm ET

Retail Certification (HA) – discuss/vote?

How certifiers apply 205.206(e) - Discuss questions to include in DD

August 13, 2013 3:00 pm ET

S & S (discuss next draft)

August 27, 2013 3:00 pm ET

Sanitizers in 100% organic products - draft proposal
September 10, 2013 3:00 pm ET

September 24, 2013 3:00 pm ET

October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, July 23, 2013, 3:00 pm ET

Attending: Joe Dickson (Chair) (JD), Harold Austin (HA), John Foster (JFo), Tracy Favre (TF), Calvin Walker 

(CW), Jean Richardson (JR) (Vice Chair), Carmela Beck (CB)

Absent: Mac Stone (MS)

Staff: Michelle Arsenault (MA), Shannon Nally Yanessa (SNY)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead)

Discussion doc JD will 

recuse 

from 

vote?

Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

Fall 2013

Sound and Sensible JR/MS Discussion document Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR Proposal. How formulated 

“organic” products should 

be calculated. Waiting for 

guidance from NOP. 

Fall 2014

Agenda

• Approve notes from July 9 call 

• Retail Certification (HA) – discuss/vote? 

• How certifiers apply 205.206(e) (JFo) - Discuss questions to include in DD

Discussion

• Notes from the July 9, 2013 call accepted with no changes. 

• Retail Certification (HA) - discuss/vote? The members discussed the questions in the draft document 

and made minor revisions to the language, including the section on 205.201(b)(2) (exclusions). The 

group feels this topic needs clarification as there appears to be some inconsistency among certifiers 

with regard to the definition of “retail food establishment”. The group wanted to know how the 
NOP views this and how it is interpreted. Members also expressed an interest in identifying which 

Accredited Certifying Agents (ACAs) are collecting information about internet sales. Members 

discussed several other questions and how best to word them to solicit feedback from the public. 

They agreed that it would be helpful to include examples of different retail scenarios that have 

raised questions about certification requirements. The group reiterated that this document is not 

intended to prompt regulatory change, but for educational purposes to spread awareness of 

activities that should be certified. HA will incorporate the comments and suggestions into the 

document and send the revised version to the members prior to the next call, with the intention of 

voting on this on the August 13 call.

• How certifiers apply 205.206(e) (JFo) - postponed to next meeting

Future Scheduled Subcommittee Calls

July 23, 2013 3:00 pm ET

Retail Certification (HA) – discuss/vote?

How certifiers apply 205.206(e) - Discuss questions to include in DD

August 13, 2013 3:00 pm ET

Retail Certification (HA) - vote

How certifiers apply 205.206(e) (JFo)- Discuss latest draft/questions/vote? 

S & S (MS) - Discuss next draft/vote?

August 27, 2013 3:00 pm ET

Sanitizers in 100% organic products - draft proposal – on hold?

September 10, 2013 3:00 pm ET

September 24, 2013 3:00 pm ET

October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, August 13, 2013, 3:00 pm ET

Attending: Joe Dickson (Chair) (JD), John Foster (JFo), Tracy Favre (TF), Jean Richardson (JR) (Vice Chair), 

Carmela Beck (CB), Mac Stone (MS)

Absent: Harold Austin (HA), Calvin Walker (CW)

Staff: Michelle Arsenault (MA), Shannon Nally Yanessa (SNY)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead)

Discussion doc 08 13 13 Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

Fall 2013

Sound and Sensible JR/MS Discussion document Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR Proposal. How formulated 

“organic” products should 

be calculated. Waiting for 

guidance from NOP. 

Fall 2014

Agenda

• Approve notes from July 23 call 

• Retail Certification (HA) – vote

• How certifiers apply 205.206(e) (JFo) - Discuss latest draft/questions/vote?

• S & S (MS) - Discuss next draft/vote?

Discussion

• Notes from the July 23, 2013 call accepted with no changes. 

Retail Certification (HA) - vote. The group discussed the document and the language that was 

changed and recirculated since the last call. The language that was added was minor and meant to 
solicit public comment about consumer expectations. The members discussed the certification 

exception in light of on line retailers and the NOP noted that their stance is that businesses that 

operate exclusively on-line do not qualify for the retailer exemption or exclusion from certification.

Vote on Retail Certification 

Motion to approve the Retail Certification document as presented

Motion by: JR

Seconded by: JFo

Discussion: The Executive summary will state that consumers have confidence in the Organic 

logo and that the process currently in place is vigorous.

Yes: 7 No: 0 Abstain: 0 Absent: 1 Recuse: 0 . The Subcommittee will leave the vote open to 

allow absent member to vote via email. NOTE: HA voted via email and his vote was added 

above. 

• How certifiers apply 205.206(e) (JFo) - A new draft will be circulated this week so the group can 

discuss and perhaps vote on the August 27 call. JFo asked that the members send him any 

additional questions for the discussion document that pertain to the ACA community.

• S & S (MS) – MS discussed the framework and the intended content for the discussion document 

and will send the document to the group later this week. In preparation he has collected feedback 

from various entities, including the NOP and certifiers and identified areas that could improve 

efficiency of the certification process. JFo will send some language from 205.101b to the group 

(from 2010 recommendation) that he felt would be helpful to include in this document. A member 

felt that the intro was too long and that enforcing National List annotations should not be included, 

so she will make some edits and send it to MS for consideration. The members will discuss this 

further via email between now and the next call. Members agreed to an additional call next 

Tuesday, August 20, to go over this document

Future Scheduled Subcommittee Calls

August 13, 2013 3:00 pm ET

Retail Certification (HA) - vote

How certifiers apply 205.206(e) (JFo) - Discuss latest draft/questions/vote? 

S & S (MS) - Discuss next draft/vote?

August 20, 2013S & S (MS)

S & S (MS) - Discuss draft/vote?

August 27, 2013 3:00 pm ET

How certifiers apply 205.206(e) (JFo) - Finish discussion/vote 

S & S (MS) - Discuss draft/vote

September 10, 2013 3:00 pm ET

September 24, 2013 3:00 pm ET
October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, August 20, 2013, 4:00 pm ET

Attending: Joe Dickson (Chair) (JD), John Foster (JFo), Tracy Favre (TF), Mac Stone (MS), Harold Austin 

(HA)

Absent: Jean Richardson (JR) (Vice Chair), Calvin Walker (CW), Carmela Beck (CB)

Staff: Michelle Arsenault (MA), Shannon Nally Yanessa (SNY)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead)

Discussion doc 08 13 13 Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

08 20 13 Fall 2013

Sound and Sensible JR/MS Discussion document Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR Proposal. How formulated 

“organic” products should 

be calculated. Waiting for 

guidance from NOP. 

Fall 2014

Agenda

• Approve notes from August 13 call 

• How certifiers apply 205.206(e) (JFo) - Discuss latest draft/questions/vote?

• Sound & Sensible (S & S) (MS) - Discuss next draft/vote?

Discussion

• Notes from the August 13, 2013 call were not approved. Deferred to the August 27 call. 

• How certifiers apply 205.206(e) (JFo) – JFo circulated a new version of the document in which he

incorporated edits by other members of the Subcommittee. Members briefly discussed the edits 

and proceeded to vote. 
Vote on How certifiers apply 205.206(e) 

Motion to approve and forward to the NOSB the August 19th version of the discussion document 

on how certifiers apply 205.206(e). CW and JR cast their votes via email 08 20 13.

Motion by: JFo

Seconded by: JD

Discussion: none

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

• Sound & Sensible (S & S) (MS) – MS asked the NOP to provide data about the number of ACAs

worldwide and number of certified operations for inclusion in the document. Members discussed 

the document and made various edits to the formatting and language. MS will incorporate the 

suggested edits and send out a new document tomorrow for the group to review, and the members

will vote on the next CACS call (August 27). The NOP suggested the inclusion of specific examples, 

and clarification about what input the group is seeking.

Future Scheduled Subcommittee Calls

August 20, 2013 4:00 pm ET - additional call

How certifiers apply 205.206(e) (JFo) - Finish discussion?/vote? - done

S & S (MS) - Discuss draft

August 27, 2013 3:00 pm ET

S & S (MS) - Discuss final draft/vote

September 10, 2013 3:00 pm ET

September 24, 2013 3:00 pm ET

October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, August 27, 2013, 4:00 pm ET

Attending: Joe Dickson (Chair) (JD), Tracy Favre (TF), Mac Stone (MS), Harold Austin (HA), Carmela Beck 

(CB)

Absent: John Foster (JFo), Calvin Walker (CW), Jean Richardson (JR) (Vice Chair)

Staff: Michelle Arsenault (MA), Shannon Nally Yanessa (SNY)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead)

Discussion doc 08 13 13 Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

08 20 13 Fall 2013

Sound and Sensible JR/MS Discussion document 08 27 13 Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR Proposal. How formulated 

“organic” products should 

be calculated. Waiting for 

guidance from NOP. 

Fall 2014

Agenda

• Approve notes from August 13 & 20 call 

• Sound & Sensible (S & S) (MS) - Discuss next draft/vote?

Discussion

• Notes from the August 13, 2013 call approved with no changes

• Notes from the August 20, 2013 call approved with no changes

• Sound & Sensible (S & S) (MS) – MS discussed the purpose behind this document which is so the 

NOSB can inform the entire community about the conversation occurring around this initiative. The 

Subcommittee Chair asked if the Board’s role is as a conduit for information or to provide advice. 

Initially this was envisioned as a conduit, but with the addition of questions for the public 

commenters, it metamorphosed into advice. Ultimately, MS explained that this document is 

intended to generate input from various stakeholders that would be helpful to the NOP. MS 
discussed various sections of the document that were recently edited. The document had been 

revised to include the farmers’ perspective for each issue area covered. The group was supportive of 

the document and felt that it would garner useful and insightful feedback. 

Vote on Sound and Sensible

Motion: To accept the Sound and Sensible Initiative Discussion Document as presented on the 

August 27 call. 

Motion by: MS

Seconded by: HA

Discussion: none

Yes: 6 No: 0 Abstain: 0 Absent: 2 Recuse: 0 (JFo voted Y via email and vote tally was 

changed to reflect that)

Future Scheduled Subcommittee Calls

August 20, 2013 4:00 pm ET - additional call

How certifiers apply 205.206(e) (JFo) - Finish discussion?/vote? - done

S & S (MS) - Discuss draft

August 27, 2013 3:00 pm ET

S & S (MS) - Discuss final draft/vote - done

September 10, 2013 3:00 pm ET

Workplans

September 24, 2013 3:00 pm ET

October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, September 24, 2013, 3:00 pm ET

Attending: Joe Dickson (Chair) (JD), Jean Richardson (JR) (Vice Chair), Mac Stone (MS), Harold Austin 

(HA), Carmela Beck (CB), John Foster (JFo), Calvin Walker (CW)

Absent: Tracy Favre (TF) 

Staff: Michelle Arsenault (MA), Shannon Nally Yanessa (SNY)

Work Plan

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead)

Discussion doc 08 13 13 Fall 2013

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

08 20 13 Fall 2013

Sound and Sensible JR/MS Discussion document 08 27 13 Fall 2013

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR Proposal. How formulated 

“organic” products should 

be calculated. Waiting for 

guidance from NOP. 

Fall 2014

Agenda

• Approve notes from August 27 call 

• Discuss public comments

Discussion

• Notes from the August 27, 2013 call approved with no changes

• The group briefly discussed the lack of comments thus far, and will defer this conversation to the 

next call, October 8. 

• The Chair noted that he would be participating in a panel at the upcoming Natural Products Expo 

East conference in Baltimore, MD and would be talking about the Retail Certification Guidance 

document as a representative of the NOSB. 

• The meeting was adjourned
Future Scheduled Subcommittee Calls

September 10, 2013 3:00 pm ET - canceled

Workplans

September 24, 2013 3:00 pm ET

Public comment

October 8, 2013 3:00 pm ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Friday, November 15, 2013, 2:30:00 pm ET

Attending: Joe Dickson (Chair) (JD), Jean Richardson (JR) (Vice Chair), Mac Stone (MS), Harold Austin 

(HA), Carmela Beck (CB), John Foster (JFo), Tracy Favre (TF)

Absent: Calvin Walker (CW)

Staff: Michelle Arsenault (MA), Shannon Nally Yanessa (SNY)

Work Plan (Will be replaced with updated version after November Executive Call)

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on 

Retail Certification

HA/JD (not 

lead)

Proposal 08 13 13 Spring 2014

How certifiers apply 

205.206(e)

JFo Discussion doc with best 

practices and process view

08 20 13 Fall 2013

Meeting 

cancelled

Sound and Sensible JR/MS Discussion document 08 27 13 Fall 2013

Meeting 

cancelled

Monitoring Practices and 

procedures for Organic 

System Plan (OSP) 205.201(a)

JFo Discussion doc. On hold 

until Sound and Sensible is 

fleshed out

TBD

Sanitizers in 100% organic 

products

JFo On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in 

calculating percentage of 

organic ingredients 

JR Proposal. How formulated 

“organic” products should 

be calculated. Waiting for 

guidance from NOP. 

Fall 2014

Agenda

• Approve notes from September 24 call

• Fall 2013 documents: 

o Retail Certification discussion document.

o How certifiers apply 205.206(e)

• 2014 Workplan

Discussion

• Notes from the September 24, 2013 call were approved as is.

• Fall 2013 documents: 

o Discussion document on Retail Certification. Members discussed whether or not to go forth 

with a proposal based on the public comment that was already received. The members 
collectively chose to move it to a proposal for the spring 2014 meeting, and the NOP 

concurred. The status and meeting date were changed in the table above to reflect this 

decision. 

o How certifiers apply 205.206(e). The NOP asked about the goal of this document, if the 

Subcommittee chooses to move it to the proposal stage. The lead reviewer noted that the 

outcome is seen as non-regulatory, and that they are only seeking clarification or 

reemphasis from the program regarding this. The group decided to move this document to 

the proposal stage. 

• The CACS would like to invite Melissa Bailey, Director of Standards and/or the Deputy Administrator

to participate in the next CACS call to discuss the workplan items that were removed as they are not

entirely clear why the Sound & Sensible (S & S) and Calculating Percentage of Ingredients documents

were removed from the workplan. The NOP indicated that they are “working on guidance about the 

Calculating Percentage of Ingredients document and no additional work is needed from the Board at 

this time”, and the Subcommittee would like further conversation and clarification. MS noted that 

the S &S document feels incomplete and would like to discuss it further with the program. A 

member suggested an additional topic that might be addressed in S & S: the burden of certification 

is not always attributed to regulation, but in some cases, how certifiers carry out certification. The 

members agreed that there needs to be a summary or some sort of wrap-up in a public venue. MA 

will forward a meeting request to the Standards Director and the Deputy Administrator for the next 

CACS call.

• The CACS Chair asked if there were any other items that members would like to add to the workplan

or perhaps pursue in the future, and asked that people bring any suggestions to the next call. A 

member noted that since the near future will be subsumed with Sunset reviews, perhaps having 

discussions about broader scoped topics will be welcome and warranted, and that the CACS is well 

suited to think about such things. The workplan table has been updated with the 2014 workplan 

items and will replace the one above in the next set of notes. Additionally, a 2014 milestone timeline 

has been added below and will replace the fall 2013 milestones.

• HA noted that he would stay on the CACS and lead the presentation at the spring 2013 NOSB 

meeting on the Retail Document. 

• The meeting was adjourned

Future Scheduled Subcommittee Calls

October 8, 2013 3:00 pm ET (CANCELLED)

November 15, 2013 3:00 ET (rescheduled from the 12th)

November 26, 2013 3:00 ET

Suggestions for additional workplan items

December 10, 2013 3:00 ET
Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call CANCELLED

Fall 2013 NOSB Meeting – Louisville, KY CANCELLED

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014

Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, November 26, 2013, 3:00 pm ET

Attending: Joe Dickson (JD) (2013 Chair), Carmela Beck (CB) (2014 Chair), Jean Richardson (JR) (Vice 

Chair), Mac Stone (MS), Harold Austin (HA), John Foster (JFo), 

Transition members: Tracy Favre (TF) - Calvin Walker (CW) 

Absent: Wendy Fulwider (WF)

Staff: Michelle Arsenault (MA), Shannon Nally Yanessa (SNY)

Work Plan

Agenda

• Approve notes from November 15 call

• Discuss work plan changes (SYN)

• Spring Agenda Proposals: Retail and 205.206(e)

• Discuss additional ideas for longer term work plan items

Discussion

• Notes from the November 15 approved with no changes.

• Changes to work plan (SNY). 

o Sound & Sensible – The NOP indicated that this document was removed from the workplan 

because they thought the only intent was to generate public comment, which they have 

received, and it was not clear that there were further plans beyond that. The NOP would be 

interested in hearing the Subcommittee’s ideas for follow up work – such as a short white paper 

for the spring 2014 meeting as MS suggested. CACS will summarize the public comments (with 

assistance from MA and SNY) and provide a statement as to the status. MS offered to write a 

short summary document for the spring meeting. 

o A member reminded the NOP that the CACS is awaiting two responses from them: guidance 

about Exclusion of Water in Calculating Percentages of Organic Ingredients and guidance about 

Sanitizers in 100% Organic Products, for which the Processing and Handling communities are 

also eager. NOP indicated that they removed the Sanitizers in 100% Organic Products because 

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on Retail 

Certification

HA/JD (not 

lead)

Proposal 

Spring 2014

How certifiers apply 205.206(e) JFo Proposal 

Spring 2014

Monitoring Practices and procedures for 

Organic System Plan (OSP) 205.201(a)

JFo The NOP requests that the 

NOSB provide a briefing 

paper that summarizes the 

issue that the Subcommittee 

is proposing to work on. 

TBD
there are other NOP and NOSB priorities that supersede this project at this time, and the CACS 

Chair asked if the Deputy Administrator could provide some additional information about this. 

MA will invite her to the next CACS call. The NOP indicated that with regard to the Exclusion of 

Water in Calculating Percentages of Organic Ingredients they are trying to determine the scope

of the guidance before they can move forward. They are actively seeking advice and input from 

other USDA divisions and are trying to address and incorporate questions and complaints that 

the program has received. The CACS would like to keep it on the workplan so it doesn’t get 

discarded and the Subcommittee can continue to press the NOP to move forward with this. SNY

offered to update the group in mid-December and will provide periodic updates. 

• Spring Agenda Proposals:

o Retail Certification Guidance document. HA will maintain leadership for this work item, and will 

present it at the spring NOSB meeting. HA and JD will discuss the public comments and how to 

move forward. 

o 205.206(e) – The group discussed reviewing this discussion document in light of the decision by 

the NOP to conclude the Board’s Sound & Sensible work. MS will develop a synopsis and the 

group will consider options such as reassessing or finalizing.

• Additional ideas for longer term work plan items. Members discussed the need to keep items visible 

and on the workplan so they do not drop off, and suggested adding a separate table to the notes as a 

placeholder. The phrase “parking lot ideas” was used to represent a table for workplan items that are on 

hold, or will be worked on beyond the next NOSB meeting. A member noted that there was a past 

workplan item on the list about conducting oversight of the NOP. This was mentioned several times by 

public commenters in the Sound and Sensible comments, and is part of the Sound and Sensible initiative. 

The group discussed whether or not this oversight was mandated by OFPA, but MA was unable to locate 

such language with the exception of one reference on page 26 of the PPM. The NOP noted that the

program is currently undergoing a peer review by ANSI, which was mentioned briefly on the Executive 

call on November 15, and will update the CACS about the details. Additionally, there will be some 

information in the next NOP newsletter about this. The group may propose adding this as a future 

workplan item. 

• JD passed the Chairship of the CACS to the incoming Chair and thanked the members for their 

intelligence, collegiality, dedication and hard work. 

• The meeting was adjourned

Future Scheduled Subcommittee Calls

November 15, 2013 3:00 ET (rescheduled from the 12th)

November 26, 2013 3:00 ET

Suggestions for additional workplan items

December 10, 2013 3:00 ET

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014
NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014

Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, December 10, 2013, 3:00 pm ET

Attending: Carmela Beck, Chair (CB), Joe Dickson, (Vice Chair) (JD), Jean Richardson (JR) Mac Stone 

(MS), Harold Austin (HA), John Foster (JFo)

Absent: Wendy Fulwider (WF), Shannon Nally Yanessa (SNY) 

Staff: Michelle Arsenault (MA), Jenny Tucker (JTu)

Work Plan

Future potential projects

Project Contact Status Vote Meeting

Sanitizers in 100% organic products JFo On hold, pending draft NOP 

guidance. 

TBD

Exclusion of water in calculating 

percentage of organic ingredients 

JR Proposal. How formulated 

“organic” products should 

be calculated. Waiting for 

guidance from NOP. 

TBD

Agenda

• Approve notes from November 26 call

• Designate Vice Chair

• Discuss work plan (JTu)

• Discuss NOP Peer review (JTu)

Project Contact Status Vote Meeting

Fall 2009 Guidance doc on Retail 

Certification

HA/JD (not 

lead)

Disc doc or 

proposal?

Spring 2014

How certifiers apply 205.206(e) JFo Proposal Spring 2014

Monitoring Practices and procedures for 

Organic System Plan (OSP) 205.201(a)

JFo The NOP requests that the 

NOSB provide a briefing 

paper summarizing the issue 

that the Subcommittee is 

proposing to work on. 

TBD

Sound & Sensible (S & S) MS Summary/update from 

Subcommittee during 

meeting (no document for 

public comment)

NA Spring 2014
• Retail certification comment summary

Discussion

• The notes from the November 26 were approved with no changes.

• Vice Chair designation. Joe Dickson was appointed the CACS Vice Chair.

• Workplan tracking. The NOP responded positively to a request to add a second table to the notes to 

maintain “possible future projects” as long as it is kept separate from the active approved workplan 

table. CACS is interested in keeping track of mid- and long-term goals and feels this is a good 

organizational process. MA added the new table above.

• NOP peer review. JTu noted that a peer review of the NOP’s accreditation program is required as 

part of its quality system; one is currently underway and is currently being conducted by ANSI 

(American National Standards Institute). In 2011, NIST (National Institute of Standards and 

Technology) did a peer review of the NOP which resulted in a list of proposed corrective actions. The 

NOP took multiple actions as a result of the review, and the program evolved based on the 

feedback. ANSI’s 2013 peer review will involve document reviews, onsite interviews, and witness 

audits; and is scoped to cover the full accreditation management program. The NOP anticipates that 

the review will be complete in summer 2014 and will release a public document to summarize the 

review and next steps. 

• Sound & Sensible (S & S). MS noted that the Accredited Certifying Agents (ACAs) and the organic 

community are seeking some sort of finalization or summary about this topic. The NOP replied that 

there are many documents in the Handbook that are being updated to reflect sound and sensible 

principles. Sound and sensible will be also be incorporated into the spring certifier training, and this 

work will continue into the future. The NOP is aware that certifiers continue to seek clarity and 

specifics about the initiative and will continue to do outreach to support these needs. The group 

discussed having an update or brief summary document for the spring NOSB meeting, so that the 

Board can continue to support the importance of the sound and sensible model. 

• Retail certification document. The group discussed the fall 2013 public comments, noting that there 

was wide support for this idea. The overall sense is that the level of awareness and education about 

compliance issues is high for certified operations but not necessarily for uncertified operations. The

CACS would like to talk with the program about outreach efforts for volunteer certification for 

retailers to help bring people into the program and into compliance. The members also discussed 

the fact that because there is not a category for retail establishments, they are categorized as 

processors. The Subcommittee discussed revising the fall 2013 proposal based on the public 

comments and perhaps adding questions for the next posting to glean more information about the 

idea of having retailers get certified. They also noted that perhaps regulatory changes are the end 

goal after all. The group discussed the history of this decision, and a member thought it was based 

on the market and the possible exclusion of large retailers and the notion that perhaps large 

retailers would see certification as a barrier and would opt to not sell organic at all. A member asked 

if the landscape had changed since the 1990s when the rule was written, and asked if this would be 

worth revisiting. 

• The meeting was adjourned
Future Scheduled Subcommittee Calls

November 26, 2013 3:00 ET

Suggestions for additional workplan items

December 10, 2013 3:00 ET

January 14, 2014 3:00 ET

Retail certification –discuss questions for posting next disc doc or proposal

How certifiers apply 205.206(e) – discuss proposal for spring 2014

Discuss S & S update/summary

January 28, 2014 3:00 ET

February 11, 2014 3:00 ET

February 25, 2014 3:00 ET

March 11, 2014 3:00 ET

March 25, 2014 3:00 ET

April 8, 2014 3:00 ET

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014

Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014