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.

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Tuesday, December 17, 2019, 4:00 pm ET

Attending: Steve Ela (SE), NOSB Chair; Harriet Behar (HB), NOSB Chair Emeritus; Scott Rice (SR), NOSB Vice Chair

& CACS Chair; Jesse Buie (JB), NOSB Secretary & Crops Chair; Dave Mortensen (DM), Materials Chair; Rick

Greenwood (RG), PDS Chair; Sue Baird (SB), LS Chair; 

Absent: Asa Bradman (AB), Handling Chair

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

Agenda

• Approve notes of November 19, 2019

• Chairs Report - SE

o New members

o Spring 2020 new member training

o CR expiration?

o EPA List 4 inert sunset reviews

o SOE/OOL status

• NOP news and update - JT/PL

• Advisory Board Specialist (ABS) update - MA

o Final recommendations from Fall 2019

o Spring deadlines

• Subcommittee Reports/Updates (5 minutes each)

o Compliance, Accreditation, & Certification (CACS) - SR.

o Crops (CS) - JB. 

o Livestock (LS) - SB.

o Handling (HS) - SE.

o Materials/GMO ad hoc (MS/GMO) - DM.

o Policy Development (PDS) - RG.

• Additional Items

• Adjourn

Discussion

• Notes of November 19, 2019 approved with no changes.

• Chairs Report – SE

o New members. The Chair and Vice Chair have spoken with the new members and are working 

on Subcommittee assignments. 

o Spring 2020 new member training. The training is scheduled for the end of February, and in 

addition to the new members, will include the NOSB Chair and Vice Chair. 

o Expiration of continuing resolution (CR). The NOP indicated that the funding bill was moving 

through the approval process on the Hill, and will contact the NOSB with an update later this 

week if needed.

o EPA List 4 inert sunset reviews. The NOSB is challenged by reviewing the List 4 Inerts listing,

which is due to sunset in 2022. EPA does not maintain this list anymore and it has been 
outdated for about eight years. The NOP suggested that the NOSB work on a pragmatic solution 

to this issue as part of its review. The Crops and Livestock Subcommittees will develop

justification for why the NOP should move forward with this project.

• NOP news and update - JT/PL. 

o Strengthening Organic Enforcement (SOE)/Origin of Livestock (OOL) status. These two projects 

are top priorities for NOP. Public comment for OOL closed Dec 2, and the NOP received ~700 

comments. The majority of the commenters were supportive of moving to a final rule. The NOP 

elaborated that if a project is added to the USDA regulatory agenda, it indicates that it is a 

priority and the administration supports it. 

o Paul Lewis, Director of the Standards Division, announced that he will be stepping away from 

the NOP for a year beginning in January 2020 to serve as a Congressional Fellow on Capitol Hill. 

Shannon Nally Yanessa, Assistant Director, and Jennifer Tucker, NOP Deputy Administrator, will 

take on Paul’s role with the NOSB. 

o A certifier in China, ODFC, has surrendered its organic accreditation. 

o A multi-country working group that works on harmonizing organic standards and systems 

globally recently met in Canada. Supply chain oversight was a large part of the conversation. 

o The American National Standards Institute (ANSI) just concluded its peer review of the NOP. The 

NOP anticipates receiving the report in January and will report out at the Spring NOSB meeting. 

The feedback was very positive.

o The NOP will publish several job announcements soon, including an announcement for a

National List Manager, which is a top priority. The NOP asked that the NOSB spread the word. 

o The pending budget making its way through Congress includes additional funding for the 

Organic Program. NOP anticipates that spending priorities will likely be for enforcement and will 

have more information for the next Executive call. The NOP noted two potential focus areas for 

enforcement - domestic grain fraud and dairy.

• Advisory Board Specialist (ABS) update - MA

o The final recommendations from the Fall 2019 meeting are being finalized and should be posted

soon. 

o New member training is scheduled for Feb 25 - 26, 2020 in DC.

o Spring deadlines. See table below. 

• Subcommittee Reports/Updates (5 minutes each)

o Compliance, Accreditation, & Certification (CACS) - SR. The CACS did not meet this month. The 

Subcommittee is looking forward to the publication of SOE and any forthcoming work related to 

it. The Accredited Certifiers Association (ACA) and International Organic Inspectors Association 

(IOIA) training is upcoming, and the CACS Chair will be attending. The NOSB Chair noted that 

one of the new NOSB members worked for a certifier and may be added to the CACS.

o Crops (CS) - JB. The Subcommittee has discussed various work agenda items, including sunset 

reviews, petitions, and the report from Michigan State University on Biodegradable Biobased 

Mulch Film (BBMF). The CS is seeking feedback from stakeholders to determine the best path 

forward for the BBMF project. The CS received a re-petition for calcium acetate and after several 

discussions has determined the petition does not contain new information. They have sent it 

back to the NOP to communicate that to the petitioner. 

o Livestock (LS) - SB. The LS met this week and discussed the fenbendazole petition. In addition to 

the petition the LS is working on a number of sunset reviews.

o Handling (HS) - (SE). Handling is actively working on its sunset reviews. The HS has 35 sunsets, 

eighteen of which are colors. The Chair indicated that some of the substances are complex and 

not as straight forward as others. For example, inulin oligofructose (IOF) was recommended for 

removal at its last sunset review, but based on additional public comment the NOP chose not to
remove it. The Subcommittee discussed reaching out to NOAA to discuss the annotation for fish 

oil. 

o Materials/GMO ad hoc (MS/GMO) - DM.

 The Materials Subcommittee met last week and discussed research priorities. After the 

last NOSB meeting, the NOSB decided to put forth the research priorities at the Spring 

meeting to solicit feedback from stakeholders, which will then be incorporated into the 

Fall proposal. Each of the other Subcommittees will be sending the MS its research 

priorities this January, so the document will be ready for the Spring meeting. 

 The MS is hosting a panel on sanitizers at the Spring meeting. There is a wide range of 

issues with regard to sanitizers, and the MS is discussing the scope and charge for the 

panel.

 The MS resumed discussions about contamination of farm inputs. MS members have 

reached out to stakeholders to discuss issues including contaminated manures, water 

contamination from fracking, and others. This project was added to the hold list by the 

NOP, and it is not currently a priority. 

o Policy Development (PDS) - RG. The PDS met last week and three new NOSB members joined to 

observe. Currently the PDS is working on updates to the Member guide with a focus on aligning 

it with the changes that were made to the PPM a couple of years ago. 

• Additional Items. None.

• The meeting was adjourned.

Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 4:00 ET/1:00 PT 3rd Tuesday

November 19, 2019 

December 17, 2019

January 21, 2020

February 18, 2020

March 17, 2020

April 21, 2020

May 19, 2020

June 16, 2020

July 21, 2020

August 18, 2020

September 15, 2020

October 20, 2020

November 17, 2020

December 15, 2020
Spring 2020 Milestones Target dates (tentative)

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

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

New NOSB member training Feb 25 - 26, 2020

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

NOP - Post proposals Mar 5, 2020

Public comment closes Apr 3, 2020

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

Public comment webinars Apr 21 & 23, 2020

Spring 2020 NOSB meeting – Crystal City, VA Apr 28 - May 1, 2020
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

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

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

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

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities 

Tuesday, November 19, 2019, 4:00 pm ET 

Attending: Steve Ela (SE), NOSB Chair, Crops Chair; Harriet Behar (HB), NOSB Chair Emeritus; Scott Rice (SR), 

NOSB Vice Chair, CACS Chair; Jesse Buie (JB), NOSB Secretary; Emily Oakley (EO), Materials Chair; Rick 

Greenwood (RG), PDS Chair; 

Absent: Asa Bradman (AB), Handling Chair; Sue Baird (SB), LS Chair; Michelle Arsenault (MA); Jennifer Tucker (JT)

Staff: Paul Lewis (PL); Devon Pattillo (DP)

Agenda

• Approve notes of October 8, 2019

• Chairs Report - SE

o Fall 2019 NOSB meeting feedback

o New NOSB appointments

o Spring 2020 milestone schedule (see below)

o New member training

o New Subcommittee assignments (attached)

o Research Priorities timeline

o Discuss scheduling of NOSB meetings. Follow up from question at NOSB meeting.

• NOP news and update - JT/PL

• Advisory Board Specialist (ABS) update - DP

o Final recommendations from Fall 2019 due by November 25

• Subcommittee Reports/Updates (5 minutes each)

o Policy Development (PDS) - RG.

o Compliance, Accreditation, & Certification (CACS) - SR.

 Clarify with NOP the suggestion of working on a module for the Integrity Learning

Center about the Energy Infrastructure.

o Crops (CS) - SE.

o Livestock (LS) - HB (for SB).

o Handling (HS) - SE (for AB).

o Materials/GMO ad hoc (MS/GMO) - EO.

• Additional Items

• Adjourn

Discussion

• Notes of October 8, 2019 were accepted as is.

• Chairs Report - SE

o Fall 2019 NOSB meeting feedback. The Chair noted that a member expressed concern about the

limited time during meetings to make decisions on complex topics, especially for members that

are not members of the Subcommittee leading the topic. Members discussed how

Subcommittees could better share information leading up to NOSB meetings, especially around

contentious topics. The Program reminded the Executive Committee members that full Board

deliberations must occur at public NOSB meetings. SE noted that the Executive Committee

meeting could be a venue to bring up those issues.
o New NOSB appointments. The NOP noted that the Department is still reviewing nominations. 

o Spring 2020 milestone schedule (see table below). The NOSB Chair noted that the extra/full 

comment period leading up to the meeting was appreciated by stakeholders. 

o New member training. The NOSB Chair and Vice Chair are planning to attend new member 

training scheduled for February 2020. 

o New Subcommittee assignments have been finalized. 

o Research priorities timeline. The NOSB Chair discussed a timing issue with the research priorities 

document. This document is published prior to the Fall meeting after which it is finalized

without substantive changes, and the NOSB has not had the chance to incorporate feedback 

from stakeholders. Going forward, the NOSB will publish the document in the Spring and finalize 

it in Fall, to better accommodate and incorporate public feedback. The NOP noted that it could 

be beneficial to invite USDA National Institute of Food and Agriculture (NIFA) to an NOSB 

meeting or Subcommittee call to solicit feedback and share information. 

o Scheduling of NOSB meetings (follow-up from question at NOSB meeting). The NOSB Chair 

summarized the timing issue brought up by some stakeholders during the fall meeting and 

invited feedback from the NOP. It was noted that shifting dates could be problematic for several 

reasons (winter travel challenges, overlap with other winter meetings, signed contracts for 

upcoming meetings, etc.) and that no dates would work for everyone. The NOP also noted that 

the public comment webinars offer the opportunity to provide comments for those who cannot 

travel to the public face-to-face meetings. 

• NOP news and update - PL. 

o Strengthening Organic Enforcement proposed rule is making its way through review and is now 

with the Office of Management and Budget (OMB).

o Origin of Livestock comment period will close Dec. 2.

o Staff recruitment efforts are underway, with postings likely after Thanksgiving, including the 

National List Manager recruitment.

o A certifier in China (OFDC) has surrendered their accreditation following identification of issues 

by NOP, and is now exiting the organic market. Approximately 40 organic operations will either 

surrender their organic certification or apply with other certifiers. 

o The Materials Chairperson asked about greenhouses and the 3-year transition requirement. 

Specifically, about how best to ensure consistency between certifiers and producers. The NOP 

noted that the complaint process is a venue to address specific operations/circumstances. A 

member asked about the complaint process for certifiers. Another member noted ambiguity in 

the information published by NOP and indicated that greenhouse standards (i.e., plants on 

tables) can differ between certifiers. The NOSB Chair asked if certifier training could be a venue 

to address inconsistencies. 

• Advisory Board Specialist (ABS) update - DP

o Final recommendations from Fall 2019 are due by November 25

• Subcommittee Reports/Updates (5 minutes each)

o Policy Development (PDS) - RG. PDS has been working to update the Member Guide to reflect 

the recent updates to the Policy and Procedures Manual (PPM). MA will review the Member 

Guide to make sure the travel section includes current information. Revisions are expected to be 

completed by mid-December. 

o Compliance, Accreditation, & Certification (CACS) - SR. The CACS Chair sought clarification about 

whether the NOP would support work on energy infrastructure development (impacts to 

organic farms) if incorporated into the Organic Integrity Learning Center. PL noted he would 

discuss further with the Program and report back to NOSB. The CACS Chair noted that the 

certifier community (outside of NOSB’s work) continues to discuss the topic. 

Additional discussions were had about addressing energy infrastructure issues. 
o Crops (CS) - SE. Sunset reviews were assigned. The CS is reviewing the re-petition for calcium 

acetate, and also conducting ongoing discussions about fish used in fish products. 

o Livestock (LS) - HB provided an update in SB’s absence. The LS is discussing questions for a 

technical report on fenbendazole (for treatment of laying hens) to assist in its review of a 

petition. The Subcommittee is finalizing documents from the Pittsburgh meeting. 

o Handling (HS) - SE (for AB). The NOSB Chair provided an update in AB’s absence. Timeline for 

sunsets has been established. Retiring members will work on sunsets until January and then 

pass them to new members to present at the Spring meeting (as with other Subcommittees). 

The Handling Subcommittee has reviewed both the red jalapeño peppers petition (205.606) and 

the low-acyl gellan gum petition and will seek additional information for both prior to 

determining petition sufficiency. A member asked about criteria for 205.606 petitions, and the 

NOP directed her to the Petition Guidelines, which describes the required information. 

o Materials/GMO ad hoc (MS/GMO) - EO. The Subcommittee has been discussing the sanitizer 

panel, and the questions developed previously for the technical report will be used as a

foundation for discussion topics. The MS will discuss next steps for the excluded methods 

document. A proposal on the topic of marine materials is planned for spring 2020 and is under 

development. 

• Additional Items. The NOSB Chair asked the Subcommittee chairs to flag any hot topics. HB noted that 

the fenbendazole petition was likely to provoke discussion. 

• The meeting was adjourned.

Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 4:00 ET/1:00 PT 3rd Tuesday

October 8, 2019 

November 19, 2019 

December 17, 2019

January 21, 2020

February 18, 2020

March 17, 2020

April 21, 2020

May 19, 2020

June 16, 2020

July 21, 2020

August 18, 2020

September 15, 2020

October 20, 2020

November 17, 2020

December 15, 2020

Spring 2020 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 1, 2019

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

New NOSB member training Feb 25 - 26, 2020

NOP - Draft Spring 2020 NOSB meeting tentative agenda Mar 2, 2020
NOP - Post proposals Mar 5, 2020

Public comment closes Apr 3, 2020

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

Public comment webinars Apr 21 & 23, 2020

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

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Tuesday, October 8, 2019, 4:00 pm ET

Attending: Harriet Behar (HB), NOSB Chair; Steve Ela (SE), NOSB Vice Chair, Crops Chair; Scott Rice (SR), NOSB 

Secretary, CACS Chair; Emily Oakley (EO), Materials Chair; Rick Greenwood (RG), PDS Chair; 

Absent: Asa Bradman (AB), Handling Chair; Sue Baird (SB), LS Chair

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

Agenda

• Approve notes of September 17, 2019

• Chairs Report - HB

o Public comments

o Pre-meeting/meeting logistics

o New appointments

o Spring 2020 milestone schedule (see below)

o Fatty alcohols. Additional comments outside of comment docket?

• NOP news and update - JT/PL

• Advisory Board Specialist (ABS) update - MA

o Travel

o Future NOSB meetings

o COI/DOI forms

• Subcommittee Reports/Updates (5 minutes each)

o Materials/GMO ad hoc (MS/GMO) - EO.

o Policy Development (PDS) - RG.

o Compliance, Accreditation, & Certification (CACS) - SR.

o Crops (CS) - SE. 

o Livestock (LS) - SB.

o Handling (HS) - AB. 

• Additional Items

• Adjourn

Discussion

• Notes of September 17, 2019 were approved as written.

• Chairs Report - HB

o Public comments. The NOSB received 12,000 comments. More than 10,000 were a letter writing 

campaign that focused on concerns about gene editing. NOP will speak to this during the NOP 

update at the Pittsburgh meeting. The Materials Subcommittee may also make a statement at 

the meeting about gene editing. Both the NOP and NOSB will emphasize that GMOs are not 

allowed in organic. 

o Pre-meeting/meeting logistics. The Chair indicated that the Board members and stakeholders 

are looking forward to Pittsburgh.

o Peer review. The NOP published an executive summary of the peer review and will provide an

update in Pittsburgh.

o New appointments. There are no new updates at this time. 
o Spring 2020 milestone schedule. The proposed schedule is pasted at the bottom of these notes, 

and can be found in each set of Subcommittee notes. Feedback welcome. 

o Fatty alcohols. The Chair asked if there were additional comments submitted to the USDA 

outside of the NOSB comment docket. NOP was not aware of such a campaign. 

• NOP news and update - JT/PL

o Strengthening Organic Enforcement (SOE) rulemaking is in progress. NOP is reaching out to 

engage stakeholders outside of the organic community, such as importers. 

o Dairy compliance training is being launched in the Organic Integrity Database tomorrow. The 

Learning Center is open to all. It currently has 1400+ users, and more than 200 people have 

completed every lesson. All users who have an account will be enrolled automatically in the 

dairy compliance training. After completing a course, there is an evaluation form that people 

can use to send in feedback. 

o There are 250 operations in the Turkey region that will be surrendering organic certification.

o The comment period for the origin of livestock proposed rule, originally published in 2015, was 

reopened. The comment period closes on December 2, 2019. Comments previously submitted 

need not be resubmitted, as they are already incorporated into the public record and will be 

fully considered in any future final rule.

o The study to evaluate policy and scientific issues with biobased mulch film, via a cooperative 

agreement between Dr. Narayan from Michigan State University and NOP, is near completion

the NOP will share the report with the NOSB soon. 

o National List rules. Two National List rules that address several NOSB recommendations are 

undergoing final review. 

• Advisory Board Specialist (ABS) update - MA

o Travel arrangements for the Fall meeting are in progress. 

o The locations for the next two NOSB meetings have been posted on the AMS website. Spring 

2020 will be held in Crystal City, VA and Fall 2020 in Cedar Rapids, IA.

o The declarations of interest forms are due to NOP at the end of week.

• Subcommittee Reports/Updates (5 minutes each)

o Materials/GMO ad hoc (MS/GMO) - EO. The MS is working on preliminary plans for a sanitizer

panel at the Spring 2020 meeting. Policy Development (PDS) - RG. The PDS is working on

updates for the member guide in anticipation of the February training of new NOSB members. 

The NOSB has received a couple of comments in support of the policy and procedures manual 

(PPM) updates. 

o Compliance, Accreditation, & Certification (CACS) - SR. During the last Subcommittee call, the 

CACS talked about energy infrastructure and the possibility of adding a training component to 

the Organic Integrity Learning Center. The Subcommittee feels this would be a good first step, 

but would not entirely address all the issues. The CACS is anticipating the publishing of the SOE

proposed rule.

o Crops (CS) - SE. The Crops Subcommittee received a petition for sodium carbonate lignin and 

found it sufficient. The Subcommittee will work on the liquid fish document after the fall NOSB

meeting. 

o Livestock (LS) - SB. The LS will request a technical report on fenbendazole for use in poultry. The 

plan is to follow the Fall 2019 discussion document with a proposal for Spring.

o Handling (HS) - AB. The HS discussed products of fermentation and how to move forward with 

this project. The Subcommittee will revisit this on a future call. Handling also has two new 

petitions: One for low-acyl gellan gum, and one for red jalapeño pepper.

• Additional Items. None.

• The meeting was adjourned
Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 4:00 ET/1:00 PT 3rd Tuesday

September 17, 2019

October 8, 2019 

November 19, 2019 

December 17, 2019

Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018

NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019

Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019

Spring 2020 Milestones Target dates (tentative)

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

NOSB - Spring 2020 proposals due to NOP Feb 20, 2019

NOP - Draft Spring 2020 NOSB meeting tentative agenda Mar 2, 2019

NOP - Post proposals Mar 5, 2019

Public comment closes Apr 3, 2019

NOP - Send compiled public comments to NOSB Apr 7, 2019

Public comment webinars Apr 21 & 23, 2020

Spring 2020 NOSB meeting – Crystal City, VA Apr 28 - May 1, 2020
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

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

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

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

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Tuesday, September 17, 2019, 4:00 pm ET

Attending: Harriet Behar (HB), NOSB Chair; Steve Ela (SE), NOSB Vice Chair, Crops Chair; Scott Rice (SR), NOSB 

Secretary, CACS Chair; Emily Oakley (EO), Materials Chair; Rick Greenwood (RG), PDS Chair; 

Absent: Asa Bradman (AB), Handling Chair; Sue Baird (SB), LS Chair

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

Agenda

• Approve notes of August 20, 2019

• Chairs Report - HB

• NOP news and update - JT/PL

o Update on Energy Infrastructure work agenda request

• Advisory Board Specialist (ABS) update - MA

o DOI declarations

o Travel arrangements for Fall NOSB meeting

• Subcommittee Reports/Updates (5 minutes each)

o Handling (HS) - SE. 

o Materials/GMO ad hoc (MS/GMO) - EO.

o Policy Development (PDS) - RG.

o Compliance, Accreditation, & Certification (CACS) - SR.

 Potential work agenda items for supply chain traceability (e.g. next gen technology). 

o Crops (CS) - SE. 

 Contamination of farm inputs

o Livestock (LS) - SB.

• Additional Items

• Adjourn

Discussion

• Notes of August 20, 2019 were approved with a correction to the Crops update

• Chairs Report - HB

o The NOSB Chair participated in a panel at Expo East in Baltimore and noted that there was lots 

of discussion about the upcoming NOSB meeting.

o The Chair thanked NOP for updating the NOSB Subcommittee notes on the website.

o The Fall 2019 meeting materials were distributed to members. 

• NOP news and update - JT/PL

o Update on Energy Infrastructure work agenda request. The NOP discussed this work agenda 

request and recommended the NOSB provide recommendations for certifier training that could 

potentially be added to the Integrity Learning Center for broad distribution. The NOSB asked 

that the NOP collaborate with the CACS to discuss the content for the training module. 

Additionally, the CACS is interested in developing a discussion document to solicit public 

comments in order to inform the content for the modules. Several NOSB members as well as 
stakeholder groups indicated that the goal is to mitigate impacts, and while certifier training is a 

good first step it is not a solution. 

o NOP is hiring and there are a number of positions open, including the National List Manager.

o There are two National List (NL) rules in clearance that include NOSB recommendations from 

2018: Sulfur, Polyoxin D zinc salt, magnesium chloride, natamycin, and tamarind seed gum. 

o The NOP Deputy Administrator gave a presentation at Expo East in Baltimore last week on 

International Oversight. 

o The NOP anticipates publishing the strengthening organic enforcement proposed rule later this 

year. 

o The study on biodegradable biobased mulch film (BBMF) conducted via a cooperative 

agreement with NOP and Michigan State University is under review by NOP and will be posted 

on the NOP website and shared with the NOSB upon completion .

o 2018 NOP Peer review. Members asked why an executive summary, and not the full report, was 

posted on the website. NOP will follow up with a response on the next Executive call. 

o Applications for the NOSB nominations are still under review by the Secretary. 

• Advisory Board Specialist (ABS) update - MA

o DOI declarations. Due to NOP Friday, October 11

o Travel arrangements for Fall NOSB meeting are underway. Members were asked to delay 

making flight arrangements until the new fiscal year begins, unless there are circumstances that 

prohibit them from waiting. 

o The NOP will be using a new platform for the Comment Webinars: Zoom. There are two practice

opportunities on the calendar. 

o The comment docket is open and there are many comments at this time. 

• Subcommittee Reports/Updates (5 minutes each)

o Handling (HS) - SE. 

 The Handling Subcommittee had one call since the last ES call, today, and discussed the

L-malic acid reclassification, the TR for ion exchange filtration, and a summary of the 

review history and issues around nutrient vitamins and minerals (NVM). The HS is in 

early discussions about products of fermentation, which is an ongoing topic that needs 

to be addressed because it is not clear in the decision tree. 

o Materials/GMO ad hoc (MS/GMO) - EO.

 The MS discussed products of fermentation and potential overlap between the HS and 

MS, and determined that the overwhelming majority of issues fall under Handling. The 

Crops Chair noted that there are fermentation products in Crops as well. 

 The Subcommittee will begin organizing a panel on sanitizers for the Spring 2020 

meeting once the NOP approves it. The NOP is supportive of a panel instead of a 

technical report (TR) .

 Contamination of farm inputs. The lead reviewer indicated that this topic was originally 

on the Crops work agenda and moved to the Materials Subcommittee work agenda in 

early 2018. The MS will begin work on this after the Fall 2019 meeting.

 The Materials Subcommittee is hosting a panel on marine materials at the Fall 2019 

NOSB meeting with four panelists. The panelists were asked to review the TR and the 

MS Chair will reach out to the group soon to discuss this further. The NOP will ask the 

panelists for short bios and to see if they want to set up a pre-meeting call to review

meeting logistics. 

o Policy Development (PDS) - RG.

 The PDS is reviewing the NOSB member guide in anticipation of the onboarding of the 

new members. 

o Compliance, Accreditation, & Certification (CACS) - SR.
 Work agenda options for supply chain traceability (e.g. next gen technology). The NOSB 

is interested in looking to the future for the next generation technology that the organic 

community could use/adapt/employ. NOP noted that supply chain traceability is a 

component of the strengthening organic enforcement proposed rule. A member noted 

that the Organic Trade Association (OTA) has a newly formed group and training to look 

at fraud and traceability.

 The energy infrastructure work agenda request was addressed by NOP above and the 

CACS will wait for feedback. 

o Crops (CS) - SE. 

 The Crops Subcommittee received a new petition for the addition of sodium carbonate 

lignin. The CS will request a limited scope TR. 

 Liquid fish annotation. The CS will develop a proposal for the Spring 2020 meeting. It is 

still unclear as to whether whole fish are being used for fertilizer, and the CS is seeking 

feedback and clarification from stakeholders. 

 The CS is anticipating the report on Biodegradable biobased mulch film (BBMF) from 

Michigan State University. 

o Livestock (LS) - HB. The Subcommittee changed the fenbendazole review from a proposal to 

discussion document for the Fall 2019 meeting so they can consider additional research and 

solicit stakeholder feedback. 

• Additional Items. None. 

• Adjourn

Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 4:00 ET/1:00 PT 3rd Tuesday

July 16, 2019

August 20, 2019

September 17, 2019

October 15, 2019 

November 19, 2019 

December 17, 2019

Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018

NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019
Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019

Spring 2020 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 1, 2019

NOSB - Spring 2020 proposals due to NOP Feb 20, 2019

NOP - Draft Spring 2020 NOSB meeting tentative agenda Mar 2, 2019

NOP - Post proposals Mar 5, 2019

Public comment closes Apr 3, 2019

NOP - Send compiled public comments to NOSB Apr 7, 2019

Public comment webinars Apr 21 & 23, 2019

Spring 2020 NOSB meeting – Crystal City, VA Apr 28 - May 1, 2020
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or removal from the 

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

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

and status of substances used in organic production and handling.

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Tuesday, August 20, 2019, 4:00 pm ET

Attending: Harriet Behar (HB), NOSB Chair; Steve Ela (SE), NOSB Vice Chair, Crops Chair; Scott Rice (SR), NOSB 

Secretary, CACS Chair; Emily Oakley (EO), Materials Chair; Rick Greenwood (RG), PDS Chair; 

Absent: Asa Bradman (AB), Handling Chair; Sue Baird (SB), LS Chair

Staff: Jennifer Tucker (JT); Michelle Arsenault (MA); Devon Pattillo (DP)

Agenda

• Approve notes of July 16, 2019

• Chairs Report - HB

o NOSB meeting - Pittsburgh, PA

o Final proposals. 

o Marine materials panel. 

• NOP news and update - JT/PL

o Update on Origin of Livestock Rule. 

o Summary of Congressional hearing (re: questions on gene editing and fraud). 

o Update on NOSB nominations.

o Status of work agenda request on Energy Infrastructure (submitted to NOP December 2018)

• Advisory Board Specialist (ABS) update - MA

o Travel arrangements for Fall NOSB meeting

o Motions with OFPA citations

• Subcommittee Reports/Updates (5 minutes each)

o Livestock (LS) - HB.

o Handling (HS) - SE. 

o Materials/GMO ad hoc (MS/GMO) - EO.

o Policy Development (PDS) - RG.

o Compliance, Accreditation, & Certification (CACS) - SR.

o Crops (CS) - SE. 

• Additional Items

• Adjourn

Discussion

• Notes of July 16, 2019 were approved with no changes.

• Chairs Report - HB

o Reminder of upcoming NOSB meeting in Pittsburgh, PA

o The NOSB Chair thanked the members for their hard work and for submitting final proposals on 

time. 

o Marine materials panel preparations are under way, and the Materials’ Subcommittee Chair will 

discuss it more in the Subcommittee section below.

• NOP news and update - JT/PL
o Two organic fraud cases in Nebraska and Iowa were recently published in the news. The 

completion of these cases highlights the successful partnership between NOP and other 

government agencies.

o The NOP has suspended Basin and Range Organic (BARO), who certified ~30 operations in the 

Western US. These operations will have 60 days to locate a new certifier.

o Control Union (Turkey). Control Union was suspended and of the ~200 operations it certified, 

approximately 1/3 have surrendered organic certification. 

o Strengthening Organic Enforcement (SOE) proposed rulemaking. NOP anticipates a Fall, 2019 

publication. The rule is under review at USDA and will also go through interagency review.

o NOP staffing. NOP has hired eight new staff members, including several auditors who will be 

remote workers. The National List manager position has not yet been filled. 

o Origin of Livestock Rule. The Administration remains interested in this topic, which was addressed 

at a recent hearing of the House Agricultural Committee. With support from the Under Secretary 

of Marketing and Regulatory Programs (MRP), AMS is seeking a way to move this forward this Fall. 

o Summary of House Agricultural Committee discussion on gene editing and fraud. Gene editing is 

prohibited under organic regulations as an excluded method. Under Secretary Ibach (MRP) is 

interested in fostering conversations and also understands that gene editing is prohibited in 

organic. The NOSB can help the conversation by clearly noting which methods are already 

prohibited under the regulations and how new proposals fit under the current regulations. 

o Update on NOSB nominations. Review process is underway. The USDA would like to make 

announcements at the Fall NOSB meeting. 

o Status of work agenda request on Energy Infrastructure (submitted to NOP December 2018). No 

update on this work agenda item. 

• Advisory Board Specialist (ABS) update - MA

o Travel arrangements for Fall NOSB meeting are underway.

o Motions with OFPA citations. NOP will update the template so the citations to OFPA and the 

regulations are not included in the motion. The NOSB will review the criteria for proper citations. 

• Subcommittee Reports/Updates (5 minutes each)

o Livestock (LS) - HB. Livestock has finished its sunset reviews and has two other documents; a 

proposal on the use of excluded method vaccines in organic livestock production, and a discussion 

document on fenbendazole (petitioned). The LS will be requesting a limited TR on fenbendazole. 

o Handling (HS) - SE. Handling has many sunset reviews for the Fall 2019 meeting. The 

Subcommittee has requested to work on an annotation for fish oil, and will coordinate with Crops 

on liquid fish fertilizer, since Crops recently received a TR for liquid fish that may be helpful. 

Handling is also working on reclassification of L-Malic acid. There are two materials to note for the 

fall meeting: The Subcommittee voted to remove orange pulp and dairy cultures. The listing for 

dairy cultures was found to be redundant with the listing for microorganisms. 

o Materials/GMO ad hoc (MS/GMO) - EO. Materials has three proposals for the Fall meeting:

Excluded methods, marine materials and research priorities. The Subcommittee is hosting a panel 

on marine materials consisting of four experts with a breadth of expertise, as well as regional 

diversity. For a future agenda the group is discussing work on contamination of farm inputs, a 

project on fermentation products, and a panel on sanitizers. 

o Policy Development (PDS) - RG. The PDS will be discussing updates to the policy and procedures 

manual at the Fall meeting. After the Fall meeting the Subcommittee will update the member 

guide which is an internal document that is provided to new members during orientation and 

training. 

o Compliance, Accreditation, & Certification (CACS) - SR. The CACS will provide a verbal update on 

integrity of the supply chain/oversight improvements to deter fraud. The NOSB is anticipating the 
rule on strengthening organic enforcement (SOE) to determine if there is additional work the CACS 

could undertake. 

o Crops (CS) - SE. The Crops Subcommittee will be discussing several documents at the Fall 2019 

meeting: Twelve sunset reviews, a discussion document on paper pots, a proposal on fatty 

alcohols (C6, C8, C10, C12 Naturally Derived) (petitioned), and a proposal on potassium 

hypochlorite (petitioned). The CS has been discussing the question of synthetic fibers in paper 

pots, and is looking forward to receiving public comments. Other projects Crops is working on 

include a new petition on sodium carbonate lignin, and an annotation change on liquid fish, for 

which the Subcommittee just received a TR. 

• Additional Items. The NOSB Chair reviewed the voting process, since there are many items to be voted on 

at the NOSB meeting.

• The meeting was adjourned

Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 4:00 ET/1:00 PT 3rd Tuesday

July 16, 2019

August 20, 2019

September 17, 2019

October 15, 2019 

November 19, 2019 

December 17, 2019

Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018

NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019

Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019
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.

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Tuesday, July 16, 2019, 4:00 pm ET

Attending: Harriet Behar (HB), NOSB Chair; Steve Ela (SE), NOSB Vice Chair, Crops Chair; Scott Rice (SR), NOSB 

Secretary, Livestock Chair; Emily Oakley (EO), Materials Chair; Rick Greenwood (RG), PDS Chair; Asa Bradman 

(AB), Handling Chair; Ashley Swaffar (AS)

Absent: Sue Baird (SB), CACS Chair

Staff: Jennifer Tucker (JT); Paul Lewis (PL); Michelle Arsenault (MA)

Agenda

• Approve notes of June 10, 2019

• Chairs Report - HB

o New Executive call dates below

o August proposal deadline

• NOP news and update - JT/PL

o Work agenda requests - update

 Fish oil annotation

 Energy infrastructure

• Advisory Board Specialist (ABS) update - MA

o Updated Subcommittee roster and schedule 

• Subcommittee Reports/Updates (5 minutes each)

o Crops (CS) - SE. 

o Livestock (LS) - SR.

o Handling (HS) - AB. 

o Materials/GMO ad hoc (MS/GMO) - EO.

 Marine materials panel

o Policy Development (PDS) – RG.

o Compliance, Accreditation, & Certification (CACS) – SR.

• Additional Items

• Adjourn

Discussion

• Notes of June 10, 2019 were approved without changes.

• Chairs Report - HB

o New Exec call dates below

o Proposal deadline is August 16. Please submit completed proposals to NOP as soon as they are 

ready. 

• NOP news and update - JT/PL

o Work agenda requests:

 Fish oil annotation. NOP discussed the Handling Subcommittee’s (HS) request to add a 

work agenda item to annotate fish oil. The NOP asked if this overlaps with the liquid fish 

annotation that the Crops Subcommittee is working on. Members felt that there might

be some overlap, but cannot determine that until the TR is returned. The HS would like 
to move forward with this project, and is seeking a commitment by the NOP in the next 

week or two to add it to the work agenda. 

o Energy infrastructure. The work agenda request is still under review by AMS and NOP does not 

have a timeline for approval. The lead indicated that this project was initially very broad, and 

through extensive collaboration between stakeholders, NOP, and NOSB, it was narrowed down 

to something concrete and discreet, focusing on how infrastructure can effect organic 

certification. 

o Nominations are currently under review. Members expressed hope that the new NOSB 

members would be announced by the Fall NOSB meeting.

o House Agriculture Committee hearing. Mr. Ibach, Under Secretary, Marketing and Regulatory 

Programs, is testifying at the hearing tomorrow accompanied by Jennifer Tucker, AMS Deputy 

Administrator. Topics for discussion are related to compliance and enforcement, and farm bill 

implementation. 

o An NOSB member indicated that there is ongoing confusion in the community about the NOP 

container memo and asked if the NOP will address it. NOP noted that the memo articulated 

existing requirements, and any operations with questions should contact their certifiers. 

o NOP recently provided training in Kansas City on organic standards and enforcement for agents 

of the Office of the Inspector General. 

o NOP is continuing work on import fraud. As an example, NOP continues their work in 

developing the proposed rule on strengthening organic enforcement, which the program 

anticipates publishing in the fall of 2019.

o NOP is closely monitoring operations that were certified by Control Union in Turkey, whose 

certification was recently revoked. 

o L-Malic Acid work agenda request. The Handling Subcommittee is interested in making a 

technical clarification to reclassify L-Malic acid. Based on information from the recent technical 

review and public comment, it appears that L-Malic acid may be misclassified on the National 

List as nonsynthetic (205.605(a) instead of 205.605(b)). NOP indicated approval of this work 

agenda request.

o The NOP will be hiring a number of new staff members, primarily auditors and compliance 

officers.

• Advisory Board Specialist (ABS) update - MA

o The Subcommittee roster and schedule was updated to reflect the change in day and time of the 

Executive call, and the change in Chairs for the CACS and LS. The ES call was rescheduled for the

third Tuesday of each month. 

• Subcommittee Reports/Updates (5 minutes each)

o Policy Development (PDS) - RG. PDS has finalized the proposal for revisions to the PPM, and will 

send it to the NOP for posting for the Fall meeting. The PDS will review the member guide 

(internal document) over the summer and fall and may have some changes/updates.

o Crops (CS) - SE. Crops has completed all 2021 sunset reviews, and is working on two proposals: 

Potassium hypochlorite petition and fatty alcohols petition. The Subcommittee is waiting for 

two TRs. One for paper pots and one for liquid fish products. 

o Livestock (LS) - SR. Livestock has completed almost all sunset reviews and started work on a new 

petition for fenbendazole for use in poultry. 

o Handling (HS) - AB. The Handling Subcommittee is completing a long list of sunset reviews, and 

has a few outstanding topics scheduled for discussion in August. The HS will finalize the fish oil 

sunset review predicated on the NOP response to the fish oil annotation work agenda request. 

The HS also discussed writing a summary of the previous work on nutrient vitamins and minerals 

(NVM) that recommended removal of some vitamins, which had implications for organic infant 

formula. This summary is intended to capture the institutional knowledge for future boards. 
o Materials/GMO ad hoc (MS/GMO) - EO. The Materials Subcommittee has had several 

discussions about sanitizers and hosted a guest speaker to provide feedback and advice about 

the TR request. The MS Chair commented there is support within the community for this work. 

The MS also hosted a guest speaker to talk about marine materials, and is working on the details 

for a marine materials panel at the Fall meeting. The panel will be 1.5 hours long, include four 

experts with a breadth of expertise, and include short presentations and Q & A with the NOSB. 

The MS and NOP are discussing potential panelists. The MS will have proposals on excluded 

methods, genetic integrity of seed, and research priorities for the Fall meeting. The MS Chair 

asked the NOP to provide an update on the status of the NOSB research priorities at the Spring 

2020 meeting in Crystal City, VA. 

o Compliance, Accreditation, & Certification (CACS) - SR. The CACS is exploring work projects on 

grain and fresh produce supply chains. The CACS would also like to address inconsistencies 

between certifiers. 

• Additional Items. None

• Adjourn

Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 4:00 ET/1:00 PT 3rd Tuesday

July 16, 2019

August 20, 2019

September 17, 2019

October 15, 2019 

November 19, 2019 

December 17, 2019

Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018

NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019

Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019
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.

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Monday, June 10, 2019, 1:00 pm ET

Attending: Harriet Behar (HB), NOSB Chair; Steve Ela (SE), NOSB Vice Chair, Crops Chair; Scott Rice (SR), NOSB 

Secretary, Livestock Chair; Emily Oakley (EO), Materials Chair; Rick Greenwood (RG), PDS Chair; 

Absent: Sue Baird (SB), CACS Chair; Asa Bradman (AB), Handling Chair

Staff: Paul Lewis (PL); Michelle Arsenault (MA)

Agenda

• Approve notes of May 13, 2019

• Chairs Report - HB

• NOP news and update - PL

• Advisory Board Specialist (ABS) update - MA

o TR determinations due June 18

o Proposals due August 16

• Subcommittee Reports/Updates (5 minutes each)

o Compliance, Accreditation, & Certification (CACS) - SR.

 Energy Infrastructure work agenda request?

o Crops (CS) - SE. 

 Sunset review - sodium nitrate. Invalid listing? Paths forward? Notice to certifying 

agents 12-1.

o Livestock (LS) - SR.

o Handling (HS) - SE. 

 Microorganisms - Dairy cultures listing. Exploring the possibility of letting dairy cultures 

expire if the two listings are indeed redundant. 

o Materials/GMO ad hoc (MS/GMO) - EO.

o Policy Development (PDS) - RG.

• Additional Items

• Adjourn

Discussion

• Notes of May 13, 2019 approved with no changes

• Chairs Report - HB

o Rescheduling of Executive call. The NOSB Chair is seeking an alternate day and time so all the 

Subcommittee Chairs can attend. 

o Chairs of CACS/Livestock were swapped. Sue Baird will chair Livestock and Scott Rice will chair 

CACS. A CACS Vice Chair will be chosen soon. 

o Final proposals for Fall 2019 are due to NOP in mid-August to allow more time for posting and to 

assure a 30-day comment period.
• NOP news and update - JT/PL

o NOSB call for nominations. Nominations closed May 20 and the NOP is in the midst of review. 

USDA received a large, well-qualified pool of applicants. Members discussed the needs and gaps 

on the Board which includes expertise in livestock and grain/seed. 

o Open docket process. The Policy Development Subcommittee is discussing the governance of 

the open-docket process. NOP will participate on the next PDS call. 

o ANSI peer audit. The NOP response to the 2018 ANSI audit was posted May 30. ANSI provided 

very helpful feedback and the NOP is working on corrective actions.

o Container systems. The NOP recently sent a memo to certifiers clarifying the eligibility and 

compliance of container systems for organic crop certification. The Executive team members 

expressed their gratitude to the NOP for addressing this issue quickly, and noted that the memo 

was somewhat unclear and has created confusion and questions in the stakeholder and 

certification communities. Specific questions were raised such as how greenhouses are 

addressed via the memo, what types of structures and floors (i.e. concrete, dirt, etc.) are 

included/exempt, and when does a certifier need a land-use history. Several certifiers have 

reached out to NOP/AIA for clarification. 

o Spring 2019 NOSB recommendations. The NOP is reviewing the Spring 2019 recommendations.

o National List (NL) Manager. The NOP is currently recruiting a new National List Manager. 

• Advisory Board Specialist (ABS) update - MA

o TR determinations for the 2022 sunset substances are due June 18. 

o Fall 2019 proposals due to NOP August 16, so they can be posted by early September for public 

comment. 

• Subcommittee Reports/Updates (5 minutes each)

o Compliance, Accreditation, & Certification (CACS) - SR. 

 The CACS is scoping a possible project on fraud but is unsure whether it will be ready for 

the Fall 2019 meeting. There has been a lot of focus on grain and non-perishables, and 

the NOSB heard from stakeholders that the focus should also include fresh produce and 

traceability. 

 Energy Infrastructure work agenda request is still under consideration by NOP. 

Stakeholders are interested in having the NOSB working on this. 

o Crops (CS) - SE. 

 Dr. Ramani Narayan of Michigan State University joined the last CS call to talk about 

biodegradable biomulch film. The NOP entered into a cooperative agreement with 

Michigan State University to review biodegradable biobased biomulch film, and the 

report should be available later this summer. The Crops Subcommittee would like to 

invite him to talk with them again. 

 Sunset reviews are underway, and Crops is also reviewing a re-petition for fatty 

alcohols. 

 The Crops Subcommittee is seeking further clarification on sodium nitrate. A previous 

Board recommended to list sodium nitrate without its annotation, which would prohibit 

it entirely. The NOP did not implement the recommendation and under the sunset 

provision in OFPA the listing is expired although it still appears on the published 

National List. Members indicated that it is possibly unclear to stakeholders that it is 

invalid, and asked if the NOSB should be reviewing it during its sunset review. A notice 

to stakeholders (Notice 12-1) was published and outlines the use of sodium nitrate and 

compliance with the USDA organic regulations. The group discussed possible actions

which could include a petition as a means to revisit the sodium nitrate issue. A member 

noted that sodium nitrate is still in use and that operations are adhering to the 20% 

figure as original noted on the National List . 
o Livestock (LS) - SR. 

 The Livestock Subcommittee is reviewing its 2021 sunset substances, and does not 

currently have any petitions. 

 There is one work agenda item request under discussion for dairy goats and dry matter 

intake, and challenges around using feed calculations for other ruminants. Initial 

feedback from commenters indicated this was an issue, and the lead is investigating the 

need. So far it appears that it is not something dairy goat operations are concerned 

with. 

 The Subcommittee emphasized the need for NOP to consider new members of the 

NOSB who have livestock expertise. 

o Handling (HS) - SE. 

 The HS is actively reviewing sunset substances. TR requests for 2022 sunsets will be 

determined next week. 

 Microorganisms & dairy cultures listing. The HS is exploring the possibility of letting the 

listing for dairy cultures expire because it was identified by public commenters as 

redundant. Several commenters suggested this change, and one group who previously 

opposed it, has indicated that they’ve changed their view and now support the removal 

of dairy cultures. The simplest route would be for the NOSB to vote to remove it, as long 

as the NOP feels that the listings are redundant. Public comments at the Fall meeting 

may provide further insight . 

o Materials/GMO ad hoc (MS/GMO) - EO. 

 The MS Chair thanked the Subcommittee Chairs for adding discussion time to the 

agendas for the research priorities, and for submitting them to the MS by mid - July so 

the MS has time to review and vote on them. 

 The MS has several other projects underway including excluded methods, seed Integrity, 

and marine materials. The group held a preliminary discussion about panel questions

and panelists for a marine materials panel at the Fall meeting. 

 The sanitizers TR request was revised and has been submitted to the NOP for further 

refinement. The Chair noted that the NOSB received a range of comments, most 

supportive, on the work agenda item. 

o Policy Development (PDS) - RG. 

 The PDS began meeting again to work on minor updates to the PPM. The PDS will add to 

the list of NOSB Secretary duties, review the wording of motions to clarify what is being 

petitioned, and make other modifications as needed. 

• Additional Items - None

• The meeting was adjourned

Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 1:00 ET/10:00 PT 2nd Monday

June 10, 2019

July 8, 2019

August 12, 2019

September 9, 2019

October 14, 2019 Columbus day 

November 18, 2019 

December 9, 2019
Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018

NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019

Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019
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.

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Monday, May 13, 2019, 1:00 pm ET

Attending: Harriet Behar (HB), NOSB Chair; Steve Ela (SE), NOSB Vice Chair, Crops Chair; Scott Rice (SR), NOSB 

Secretary, Livestock Chair; Asa Bradman (AB), Handling Chair; Emily Oakley (EO), Materials Chair; Rick 

Greenwood (RG), PDS Chair

Absent: Sue Baird (SB), CACS Chair

Staff: Jennifer Tucker (JT); Paul Lewis (PL); Michelle Arsenault (MA); Clarissa Mathews (CM)

Agenda

• Approve notes of April 8, 2019

• Chairs Report - HB

o Debrief - Spring 2019 NOSB meeting 

o Motion language - “as petitioned” 

o Sunset reorganization/Updates from rulemaking

o Coversheets for final recommendations (sent in separate email)

o Work agenda requests (see Subcommittee discussion section below)

• NOP news and update - JT/PL

• Advisory Board Specialist (ABS) update - MA

o Fall milestones/timeline (see below)

o Travel reimbursement vouchers

• Subcommittee Reports/Updates (5 minutes each)

o Policy Development (PDS) - RG.

o Compliance, Accreditation, & Certification (CACS) - SB.

o Crops (CS) - SE.

 Work agenda request - seed guidance/vegetation from plants

 Sunset review - sodium nitrate

 Biodegradable biobased mulch film cooperative agreement

o Livestock (LS) - SR.

 Work agenda request - dairy goats

 MET follow up

o Handling (HS) - AB.

 Celery powder panel follow up

 Work agenda request - Reclassification of L-Malic acid 

 Work agenda request - Dairy cultures/microorganisms 

 Work agenda request - Annotation for fish oil 

 Work agenda request - Fermentation products 

o Materials/GMO ad hoc (MS/GMO) - EO.

• Additional Items

• Adjourn
Discussion

• Notes of April 8, 2019 were approved with no changes

• Chairs Report - HB

o Debrief - Spring 2019 NOSB meeting. Members noted that they received a lot of useful 

information and questions from the panels and public commenters. 

o Language used in motions “as petitioned”. The NOSB had discussion at the Seattle meeting 

about using this language in the motion and would like to discuss this further to determine if 

this is clear or if the Subcommittees should include more specific language. This would reduce 

the amount of searching the NOP and stakeholders would have to do, to determine the 

petitioned use and would clarify what a substance has been approved for. 

o Sunset reorganization/Updates from rulemaking. Several materials that are currently under 

review by the NOSB may have had the sunset date reset with the publishing of the final rule 

AMS-NOP-14-05. NOP is reviewing the issue and plans to provide further direction soon. 

o Coversheets for final recommendations from the April 2019 meeting are due to NOP May 31.

o Work agenda requests (see Subcommittee discussion section below)

• NOP news and update - JT/PL

o The NOP suspended Control Union’s satellite office in Turkey. Control Union is a large certifier in 

Europe. The suspension notice was posted today, and impacted clients will need to seek another 

certifier. The NOP is granting a 60-day transition period, so the affected operations can find a 

new certifier. Certifiers will be responsible for vetting the clients and notifying the NOP if they 

adopt any of the displaced clients. Operations certified by Control Union that were certified 

under a different office (that wasn’t the Turkey office), and those operations are not impacted. 

o NOP will publish its annual enforcement update in the next week or two announcing import 

oversight initiatives thus far. 

o The Organic Integrity Learning Center had garnered a lot of interest. ~ 500 groups have asked 

for access/login.

o NOP recently hired a trade systems oversight director, Jon Veley, who came from Customs and 

Border Protection. Jon’s role will include managing the AMS-wide portfolio of trade 

management and international oversight systems. And will develop an international organic 

oversight system for NOP. 

o Biobased mulch film panel. The NOP has entered into a cooperative agreement with Dr. Ramani 

Narayan to review biodegradable biobased mulch film. The scope of the agreement includes 

looking at how the currently available products align with the organic regulations. His final 

report should be available sometime in July. The Crops Subcommittee would like to extend an 

invitation to Dr. Narayan to sit in on a Subcommittee call to talk further. 

o Sunset dates. The members discussed the outcome of the rule that was published in December 

2018, which included ~36 changes to the National List. Currently it is unclear how this rule 

impacts the sunset dates for materials that had annotations or classifications changed by the 

rule, some of which are currently under review in 2019, such as DL-methionine. A potential 

consequence could be a change in the sunset review schedule. NOP will discuss this further and 

let the NOSB know how to proceed. 

• Advisory Board Specialist (ABS) update - MA

o Fall milestones/timeline (see below)

o Debrief from meeting. Members offered some feedback about what went well, and provided 

suggestions for processes they would like to include next time. They encourage more time for 

panel discussion for bigger issues which would come at the expense of public comment time. 

Having time for a full-Board discussion is very helpful for the proposal-development process. 

Subcommittees will discuss this further on calls. 
• Subcommittee Reports/Updates (5 minutes each)

o Policy Development (PDS) - RG. 

 PDS is meeting this week. The PDS agenda includes some minor edits and additions to 

the PPM, including a discussion of the phrasing of motions. 

o Compliance, Accreditation, & Certification (CACS) - SB. 

 There’s an outstanding work agenda request on energy infrastructure that is under 

review by the NOP. NOP will be tasking the CACS with more work on fraud and the CACS 

is waiting to hear more specifics. 

o Crops (CS) - SE. 

 The Subcommittee met last week and assigned leads for the next round of sunset 

reviews (for review in 2020). 

 Dr. Narayan will join a Crops call in June to talk with the Subcommittee about 

Biodegradable biobased biomulch film.

 Work agenda request - seed guidance/vegetation from plants. The group discussed 

whether or not they are required to submit a work agenda request or if they can 

continue to work on this without a formal request. The proposed changes to the seed 

guidance would likely require a rule change. Stakeholders and the Board members feel 

this is an issue that needs to be resolved noting that it is a concern.

 Sunset review - sodium nitrate. A previous NOSB submitted a recommendation to 

remove the annotation, which would have prohibited sodium nitrate, and the NOP did 

not complete rulemaking to implement it. The NOP indicated since no action was taken 

by the program, the substance expired, however, sodium nitrate continues to be listed

on the National List at 205.602 with an annotation. The NOP issued a policy memo (12-

1) indicating this status. The NOSB seeks to fix this listing as it is a grey area, and has not 

re-reviewed it as mandated by OFPA since 2011. NOP indicated that the only way to 

move forward would be to receive a petition. This could come from stakeholders or the 

NOSB. The Crops Subcommittee will discuss this further on a future call. The NOP 

supported the idea of bringing forth a petition. 

o Livestock (LS) - SR.

 Work agenda request - dairy goats. The LS is considering whether to submit a request to 

work on dairy goat pasture requirements. The LS is also working on excluded methods. 

o Handling (HS) - AB. 

 During the last call, the HS discussed sunset reviews for the Fall 2019 meeting and 

schedule dates for discussion. 

 There are two TR pending sufficiency review: L-Malic acid and ascorbic acid. 

 The project on BPA is on old but there is interest among the NOP and HS to continue 

work on this. 

 Celery powder panel follow up. The Subcommittee Chair found the panel helpful and 

will seek more information to incorporate into the sunset review for the Fall 2019 

meeting. The HS Chair encouraged USDA to support some of the ongoing research. 

 Work agenda request - Reclassification of L-Malic acid. The HS may work on a 

reclassification and move L-Malic Acid to 205.605(b) 

 Work agenda request - Dairy cultures/microorganisms. Several public commenters 

indicated that dairy cultures/microorganisms be consolidated on the National List as 

they are redundant. Alternatively, if the microorganisms listing encompasses dairy 

cultures, the HS could allow the dairy cultures listing to sunset. HS is considering this 

work agenda project and is seeking feedback from the NOP to ensure that is accurate. 
 Work agenda request - Annotation for fish oil. The HS is exploring an annotation change 

to address potential environmental impacts. This project overlaps with marine 

materials. 

 Work agenda request - Fermentation products. The group discussed placing this on the 

work agenda for the Materials Subcommittee. The NOSB doesn’t have a good decision 

tree about fermentation products, and will continue to discuss this in Subcommittee. 

o Materials/GMO ad hoc (MS/GMO) - EO. 

 The MS chair and HS Chair will discuss fermentation products to flesh it out better, to 

determine which Subcommittee is better situated to work on it. 

 The MS is working on a couple of proposals for Fall 2019 including research priorities, 

sanitizers, and contamination of farm inputs. The Chair asked that the Subcommittee 

Chairs add the research priorities to their discussion schedule, so they can add any new 

topics and submit the document to the MS for the Fall meeting. 

 Ancillary ingredients/sanitizers. The MS addressed concerns that were brought up at the 

Spring 2019 NOSB meeting and have since revised the TR request. 

 Marine materials work is ongoing, and the MS is interested in convening a panel at the 

fall meeting. 

• Additional Items. The NOSB Chair reminded members to submit travel documents. 

Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 1:00 ET/10:00 PT 2nd Monday

March 11, 2019

April 8, 2019

May 13, 2019

June 10, 2019

July 8, 2019

August 12, 2019

September 9, 2019

October 14, 2019 Columbus day 

November 18, 2019 

December 9, 2019

Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018
NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019

Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019
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.

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Monday, April 8, 2019, 1:00 pm ET

Attending: Harriet Behar (HB), NOSB Chair; Steve Ela (SE), NOSB Vice Chair, Crops Chair; Scott Rice (SR), NOSB 

Secretary, Livestock Chair; Asa Bradman (AB), Handling Chair; Emily Oakley (EO), Materials Chair; Sue Baird (SB), 

CACS Chair; Jesse Buie (JB) - observer

Absent: Rick Greenwood (RG), PDS Chair

Staff: Jenny Tucker (JT); Michelle Arsenault (MA); Clarissa Mathews (CM); Devon Pattillo (DP)

Agenda

• Approve notes of March 11, 2019

• Chairs Report - HB

o Spring 2019 NOSB meeting (Celery Powder Panel, MET speakers, BioMulch speakers)

o Webinar practice reminder April 16 & 18

• NOP news and update - JT/PL

o Update on Organic Integrity Learning Center. 

• Advisory Board Specialist (ABS) update - MA

o Preparations for April meeting

o Fall milestones/timeline (see below)

• Subcommittee Reports/Updates (5 minutes each)

o Policy Development (PDS) - RG.

o Compliance, Accreditation, & Certification (CACS) - SB.

o Crops (CS) - SE.

o Livestock (LS) - SR.

o Handling (HS) - AB.

o Materials/GMO ad hoc (MS/GMO) - EO.

• Additional Items

• Adjourn

Discussion

• Notes of March 11, 2019 were approved with no changes 

• Chairs Report - HB

o Nominations have been advertised and NOP has gotten a lot of interest. The NOSB Chair has 

received several inquiries about Board service. 

o The Spring 2019 NOSB meeting docket is full and the Board has received approximately 870 

comments. 

o The Chair asked that in the future the NOP and NOSB work together to develop the April 

meeting agenda. 

• NOP news and update - JT/PL

o The call for nominations closes May 20, 2019.

o The National List rule for two Fall 2017 NOSB recommendations is in final clearance. This rule 

adds elemental sulfur for use in organic livestock production and reclassifies potassium acid 
tartrate from a non-agricultural substance to an agricultural substance and requires the organic 

form of the ingredient when commercially available. 

o NOP is focusing on enforcement and oversight actions. The Compliance & Enforcement (C&E) 

division just launched C&E database.

o The NOP recently completed the pilot phase of the Organic Integrity Learning Center. NOSB 

members were invited to be part of the beta test to provide feedback.

o NOP is continuing investigations related to imports.

o Strengthening Organic Enforcement (SOE) proposed rule is in progress and on track for a fall 

publication date. 

o Farm bill implementation. NOP has initiated communication with Customs and Border 

Protection (CBP) to work on: (1) the programming to generate organic import certificates in 

CBP’s import system, and (2) establishing the inter-agency organic work group to work on 

import oversight activities. 

• Advisory Board Specialist (ABS) update - MA

o Preparations for April meeting are underway

o Fall milestones/timeline (see below)

o NOP verified that opening the oral comment registration when the proposals post is a useful

process.

o The meeting agenda for the in-person meeting full, as we have a panel and several speakers: 

Celery powder panel, MET (methionine) speakers, and biodegradable biobased mulch film

speakers) 

o Webinar practice is on April 15 and the webinars are scheduled for April 16 & 18. 

• Subcommittee Reports/Updates (5 minutes each)

o Policy Development (PDS) - RG. No update as PDS has not met. 

o Compliance, Accreditation, & Certification (CACS) - SB. The CACS has not met since the last Exec 

call. The Subcommittee will have one document on fraud and imports for the spring meeting. 

The CACS is waiting to hear from the NOP about the energy infrastructure work agenda item. 

Asa Bradman volunteered to take the lead on this item. 

o Crops (CS) - SE. Crops recently received the TR for horticultural oil. On the last call the CS found 

the potassium chlorite petition insufficient and is seeking additional information from the 

petitioner. 

o Livestock (LS) - SR. The LS has one item that they would like to add to the work agenda - grazing 

requirements for goats. The lead has reached out to several veterinarians and dairy goat 

producers and is developing the work agenda request to submit to the Executive team and the 

NOP. The Subcommittee has one proposal on oxalic acid, and one discussion document on the 

use of excluded methods in vaccines for the Spring 2019 meeting. 

o Handling (HS) - AB. The HS Chair has had a number of communications with the celery powder 

panel members. Handling has received the L-malic acid and ascorbic acid TRs and will reassign

them as the original lead is no longer on the NOSB. The HS has several petition reviews in 

progress, and the Silver dihydrogen citrate (SDC) proposal has garnered lots of comments and 

interest. 

o Materials/GMO ad hoc (MS/GMO) - EO. The MS has several materials for the Spring 2019 

meeting. The TR request for sanitizers is under revision by both the MS and NOP to narrow the 

scope so the contractor can better respond to the request. The MS work agenda item on 

contamination issues in farm inputs is a topic that will be discussed at the National Organic 

Coalition meeting just prior to the NOSB meeting. The intent is to aid the NOSB in its review. 
Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 1:00 ET/10:00 PT 2nd Monday

March 11, 2019

April 8, 2019

May 13, 2019

June 10, 2019

July 8, 2019

August 12, 2019

September 9, 2019

October 14, 2019 Columbus day 

November 18, 2019 

December 9, 2019

Spring 2019 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 26, 2018

NOSB – Spring 2019 proposals due to NOP Feb 21, 2019

NOP - Draft Spring 2019 NOSB meeting tentative agenda Mar 4, 2019

NOP - Post proposals Mar 6, 2019

Public comment closes Apr 4, 2019

Discuss/finalize work agendas on ES call Apr 13, 2019

NOP - Send compiled public comments to NOSB Apr 8, 2019

Public comment webinars Apr 16 & 18, 2019

Spring 2019 NOSB meeting - Seattle, WA Apr 24 - 26, 2019

Fall 2019 Milestones Target dates (tentative)

New NOSB member training TBD Feb/Mar 2020

NOP - Publish FRN, Open public comment May 3, 2019

NOSB Request for TRs for 2022 sunset materials Jun 12, 2019

NOP - Draft Fall 2019 NOSB meeting tentative agenda Aug 5, 2018

NOSB - Fall 2019 proposals due to NOP Aug 15, 2018

NOP - Post proposals On or before Sep 4, 2018

Public comment closes Oct 3, 2019

NOP - Send compiled public comments to NOSB Oct 7, 2019
Discuss/finalize work agendas on ES call Oct 14, 2019

Public comment webinars Oct 15 & 17, 2019

Fall 2019 NOSB meeting - Pittsburgh, PA Oct 23-25, 2019
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.

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Monday, March 11, 2019, 1:00 pm ET

Attending: Harriet Behar (HB), NOSB Chair; Steve Ela (SE), NOSB Vice Chair, Crops Chair; Scott Rice (SR), NOSB 

Secretary, Livestock Chair; Asa Bradman (AB), Handling Chair; Rick Greenwood (RG), PDS Chair; Emily Oakley 

(EO), Materials Chair; Sue Baird (SB), CACS Chair; Jesse Buie (JB) - observer

Absent: Tom Chapman (TC), NOSB Chair emeritus

Staff: Jennifer Tucker (JT); Michelle Arsenault (MA); Clarissa Mathews (CM); Devon Pattillo (DP)

Agenda

• Approve notes of February 11, 2019

• Chairs Report - HB

o Nominations 

o Finalization of Spring proposals

• NOP news and update - JT/PL

• Advisory Board Specialist (ABS) update - MA

o Preparations for April meeting

• Subcommittee Reports/Updates (5 minutes each)

o Materials/GMO ad hoc (MS/GMO) - EO.

o Policy Development (PDS) - RG.

o Compliance, Accreditation, & Certification (CACS) - SB.

o Crops (CS) - SE.

o Livestock (LS) - SR.

o Handling (HS) - AB.

• Additional Items

• Adjourn

Discussion

• Approve notes of February 11, 2019

• Chairs Report - HB

o Nominations. The opening created by the recent resignation of one of the Board members is 

being advertised as part of the next round of nominations and the seat will be filled in January 

2020. Therefore, there will be 14 NOSB members at each of the 2019 NOSB meetings. The NOSB 

Chair emphasized the need to be able to fill unexpected vacancies quickly if possible. She also 

noted the gaps in expertise in dairy, livestock, and grain farmers that currently exist, and hopes

that the USDA can address this with the 5 new appointments. 

o Finalization of Spring proposals. The Chair thanked the members for working hard and 

submitting the final proposals to the NOP on time. 

• NOP news and update - JT. 

o Nominations. The NOP noted that there is a process in place for filling unexpected vacancies 

quickly, which has been used in the past. In this instance, timing was such that it was more 
efficient to advertise the vacancy along with the upcoming 2020 vacancies. Members provided 

feedback and asked questions about the nominations process. The group also discussed the use 

of alternate members, which some other USDA Boards use. The Chair of the Policy Development 

Subcommittee suggested they discuss it during the next PDS call, in case they choose to put 

procedures or concepts in place. A member noted that it is beneficial to find folks that focus on 

organic as opposed to split operations. The nominations flyer will be available soon for 

distribution.

o Meeting Agenda. Adam Cline of the National Agricultural Statistics Service (NASS) was invited to 

speak at the NOSB meeting regarding data quality and the organic survey, which was a topic of 

interest discussed at the last NOSB meeting. 

o The NOP invited an additional researcher to speak at the NOSB meeting about biodegradable

biobased mulch film. NOP is working to develop a cooperative agreement with the researcher to 

seek information about the substance, including a review of the regulatory history, recent 

research, and availability of products. Members were supportive of having both speakers. 

o The docket announcing the Spring NOSB meeting is in clearance. Before the next Executive 

Committee call, NOP will send an invitation to the NOSB members to login to the Organic 

Integrity Learning Center, so they can be part of the beta test group. Initially there will be five 

courses available. The NOP is seeking feedback before the NOSB meeting.

o The NOP is moving forward with a cloud-based internal database for enforcement and 

compliance work. The cloud-based database will be more robust and efficient than the current.

The farm bill contained provisions for several projects focusing on compliance. 

o The new Associate Deputy Administrator, Dave Glasgow, will be attending the Spring NOSB 

meeting. The associate deputy has taken over operational, budgeting, and administrative duties. 

o The NOP will not likely send a response before the Spring NOSB meeting to the work agenda 

request on energy infrastructure. 

• Advisory Board Specialist (ABS) update - MA

o Preparations for April meeting are underway, including travel and document preparation.

• Subcommittee Reports/Updates (5 minutes each)

o Materials/GMO ad hoc (MS/GMO) - EO. The MS has a full docket for the Spring meeting: Four 

discussion documents and one proposal. The MS Chair summarized the documents and noted 

the intention for each of them going forward to the Fall meeting. The MS anticipates that all 

four of the discussion docs will be proposals up for votes in the fall. The Chair also asked about 

the TR for sanitizers. 

o Policy Development (PDS) - RG. The PDS has not met. There are some minor projects to update 

the Policy and Procedures manual (PPM) that will likely be ready for the fall 2019 meeting. 

o Compliance, Accreditation, & Certification (CACS) - SB. The CACS put forth one document for the 

Spring meeting - a summary of oversight improvements to deter fraud. 

o Crops (CS) - SE. Crops has a full agenda for the Spring meeting. The CS is bringing forth five 

proposals (Allyl Isothiocyanate (AITC), ammonium citrate , ammonium glycinate, calcium 

acetate, and strengthening organic seed guidance), and two discussion documents (paper pots 

and fatty alcohols). The CS also has several sunset reviews for the first posting. Crops also has a 

new petition for potassium hypochlorite, which falls into the realm of sanitizers, a work agenda 

project for the Materials Subcommittee. 

o Livestock (LS) - SR. Livestock is developing a work agenda request for pasture requirements for 

dairy goats that they may bring forward on the April 2 LS call. For the Spring meeting the LS has 

one proposal for oxalic acid and one discussion document on excluded methods vaccines used in 

livestock production.

o Handling (HS) - AB. The Handling Subcommittee has three proposals for the Spring meeting -

silver dihydrogen citrate (SDC), pullulan, and collagen gel. The HS also has 30 sunset reviews. 
The HS Chair noted that there is great interest in BPA although it’s not on the agenda for the 

spring meeting. 

• Additional Items. 

o The NOP noted that the final rule that was recently published (NOP-14-05) reset the sunset 

dates for several substances (listed below) and some of those substances are currently being rereviewed. The Board could choose to suspend the current review or continue. A member noted 

that they preferred to continue with the review, as work was already underway. The five 

affected substances are:

 Fenbendazole - § 205.603(a)(23)(i) milk or milk products from a treated animal cannot 

be labeled as provided for in subpart D of this part for: 2 days following treatment of 

cattle; 36 days following treatment of goats, sheep and other dairy species.

 Moxidectin - § 205.603(a)(23)(iii) milk or milk products from a treated animal cannot be 

labeled as provided for in subpart D of this part for: 2 days following treatment of cattle; 

36 days following treatment of goats, sheep and other dairy species.

 Xylazine - § 205.603(a) removed the limitation “The existence of an emergency” on use 

of this substance.

 DL-methionine - § 205.603(d) required that maximum methionine levels in feed be 

calculated as averages over the lifespan of organic poultry rather than as a constant 

percentage of the feed.

 Alginic acid - reclassified alginic acid from a non-synthetic substance included in 

§ 205.605(a) to a synthetic substance included in § 205.605(b), for use in organic 

handling.

o Carnauba wax implementation date. This substance was inadvertently omitted from the 

preamble statement listing substances with a delayed implementation date in the final rule

published December 27, 2018). For clarification, carnauba wax should have an implementation 

date of December 27, 2019. 

o The NOSB inquired about the status of Chilean nitrate. A previous Board recommended 

prohibition, and although the recommendation was never implemented, the NOSB has not rereviewed the substance for sunset. The NOSB requested placing this substance in the queue for 

sunset review because it has neither been removed from the National List nor reviewed within 5 

years. 

• The NOSB Chair is currently in DC attending the Organic Farmers Association meeting. 

• The meeting was adjourned

Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 1:00 ET/10:00 PT 2nd Monday

January 14, 2019 - cancelled due to shutdown

February 11, 2019

March 11, 2019

April 8, 2019

May 13, 2019

June 10, 2019

July 8, 2019

August 12, 2019

September 9, 2019
October 14, 2019 Columbus day 

November 18, 2019 

December 9, 2019

Spring 2019 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 26, 2018

NOSB – Spring 2019 proposals due to NOP Feb 21, 2019

NOP - Draft Spring 2019 NOSB meeting tentative agenda Mar 4, 2019

NOP - Post proposals Mar 6, 2019

Public comment closes Apr 4, 2019

Discuss/finalize work agendas on ES call Apr 13, 2019

NOP - Send compiled public comments to NOSB Apr 8, 2019

Public comment webinars Apr 16 & 18, 2019

Spring 2019 NOSB meeting - Seattle, WA Apr 24 - 26, 2019
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.

National Organic Standards Board (NOSB) 

Executive Committee (ES) Meeting notes and

summary of NOSB Subcommittee activities

Monday, February 11, 2019, 1:00 pm ET

Attending: Harriet Behar (HB), NOSB Chair; Steve Ela (SE), NOSB Vice Chair, Crops Chair; Scott Rice (SR), NOSB 

Secretary, Livestock Chair; Asa Bradman (AB), Handling Chair; Rick Greenwood (RG), PDS Chair; Tom Chapman 

(TC), NOSB Chair emeritus; Jesse Buie (JB) - observer; Sue Baird (SB) - observer

Absent: Emily Oakley (EO), Materials Chair; Eric Schwartz (ES), CACS Chair

Staff: Jenny Tucker (JT); Paul Lewis (PL); Michelle Arsenault (MA); Clarissa Mathews (CM); Devon Pattillo (DP)

Agenda

• Approve notes of December 14, 2018

• Chairs Report - HB

o NOSB membership

o Celery powder panel status

o Biodegradable biobased mulch film update at April meeting 

o Methionine task force update at the April meeting

o Update on open docket/Posting of document

• NOP news and update - JT/PL

o Biodegradable mulch update 

• Advisory Board Specialist (ABS) update – MA

o Nominations 

o Preparation for April meeting

• Subcommittee Reports/Updates (5 minutes each)

o Handling (HS) - AB.

o Materials/GMO ad hoc (MS/GMO) - HB.

o Policy Development (PDS) - RG.

o Compliance, Accreditation, & Certification (CACS) - ES.

o Crops (CS) - SE.

o Livestock (LS) - SR.

• Additional Items

• Adjourn

Discussion

• Approve notes of December 14, 2018

• Chairs Report - HB

o NOSB membership. Eric Schwartz will be resigning as of Feb 11 due to his acceptance of a new 

position at a company that does not have an organic component. Sue Baird will take on the role 

of CACS Chair in his place. The NOSB Chair discussed her succession plan that includes having 

the vice chair positions be filled by someone who is not in their last year on the Board. This will 

aid the work flow and continuity. 
o Celery powder panel status. The Handling Subcommittee will host a panel on celery powder at 

the Spring NOSB meeting, and has chosen three of the four panelists. The members discussed 

the needed expertise for the fourth person, and would like to have someone who can speak to 

the human health aspects of nitrates and nitrites. The HS Chair has spoken to several possible 

panelists and the HS will make its final recommendations in the next day or two. The panel will 

be 1.5 hours on the first day of the meeting. 

o Biodegradable biobased mulch film update. The NOSB Chair reached out to a researcher who is 

currently working on biodegradable biobased mulch film and asked her to provide an update at 

the April NOSB meeting. 

o Methionine task force update at the April meeting. The NOSB Chair has asked a couple of 

members of the methionine task force to give an update at the April meeting, since they will be 

in attendance. 

o Update on open docket/posting of documents. The NOSB received approximately 17 comments 

about the two seed documents that were reposted in the open docket: genetic integrity 

transparency of seed grown on organic land and strengthening the organic seed guidance. The

NOSB found the open docket to be a useful tool as it revised the Fall 2018 documents. The NOP 

and NOSB discussed the need for a procedure for posting documents and notifying the public of 

their availability. 

• NOP news and update - JT/PL

o Open docket. While the NOP has had an open docket for some time, there are no procedures 

for releasing documents for comment. The NOP will continue to explore steps for utilizing the 

open docket system. 

o Biodegradable biobased mulch film update. NOP has been in early conversations with a 

University researcher to commission a study about biodegradable biobased mulch film, 

including a comparison of the regulatory text and NOP policy memo to see if they are aligned. 

Members were supportive of this approach. 

o Post shutdown activities. NOP is catching up with work delayed due to the shutdown, and 

anticipates the NOSB meeting in April will proceed as planned. 

o Inerts. The Handling Chair has been getting a lot of comments and questions about inerts. The 

NOP noted that this is not on its current work agenda and will be focusing on other National List

recommendations. and the Strengthening Organic Enforcement rulemaking to enhance organic 

integrity.

o Fatty alcohols for tobacco use. The Crops Chair has been contacted about the status of the repetition for fatty alcohols and expects public comment at future NOSB meetings. There are 

disparities between certifiers and the approval of this material. Three certifiers had incorrectly 

approved this substance, and the NOP has sent notices of non-compliance. The NOP allowed a 

grace period for the operations who were affected. The re-petition will be sent to NOSB and 

posted on the website soon. 

• Advisory Board Specialist (ABS) update - MA

o Invitations to panelists. MA will confer with the NOSB Chair to get the contact information for 

the panelists, and will initiate the invitations. 

o Nominations. The call for nominations for the January 2020 vacancies is almost complete and 

should be posted this spring. The NOP is seeking to fill five (5) seats, including the Handler seat 

that was held by Eric Schwartz. Since there are only two years left in the Handling term, the NOP 

will seek to fill the seat for a 5-year term for continuity, rather than for the remaining 2 years. 

There will be 14 NOSB members at each of the 2019 NOSB meetings. 

o Preparation for the April meeting is underway, including travel, agenda, and meeting materials. 
• Subcommittee Reports/Updates (5 minutes each)

o Handling (HS) - AB. The HS is on-track to get its sunset reviews for Spring 2019 completed soon.

They are also working on celery powder panel logistics. 

o Materials/GMO ad hoc (MS/GMO) - HB. The MS is meeting tomorrow to discuss genetic 

integrity transparency of seed. The Subcommittee may produce a discussion document, rather 

than a proposal, to give the community more time to provide feedback. The MS is also moving 

forward with a proposal on excluded methods determinations, and three discussion documents 

- Excluded methods: Induced mutagenesis and embryo, marine materials in organic crop 

production, and Assessing cleaning and sanitation materials used in organic crop, livestock and 

handling. 

o Policy Development (PDS) - RG. There are a couple of minor items in the PPM that need to be 

updated. The NOP will send out a draft document with suggested edits and will add calls as 

needed. It will likely be a project for the Fall 2019 meeting. 

o Compliance, Accreditation, & Certification (CACS) - SR. The CACS is not bringing forward any 

projects for the Spring meeting. There is great interest in moving forward with the origin of 

livestock rule, and the CACS asked about the correspondence that the USDA had received in 

support of this. The Subcommittee may develop a summary of the import panels and work to 

date. 

o Crops (CS) - SE. The Crops Subcommittee has a busy work agenda for the Spring 2019 NOSB 

meeting. The CS will discuss: five proposals (allyl isothiocyanate (AITC), ammonium citrate, 

ammonium glycinate, calcium acetate, and strengthening the organic seed guidance); two 

discussion documents (paper pots and fatty alcohols), and several preliminary sunset reviews. 

The CS decided to not request a TR for paper pots, for now, but may choose to do so at a later 

date. 

The NOP provided feedback to a question from the NOSB, and a certifier/Material Review 

Organization (MRO) regarding liquid fish pH. The NOP agrees with the NOSB that as long as the 

final product pH (at sale) is 3.5 or higher, lower pH during production does not matter. At this 

time the NOP will not send an official response to the NOSB. If questions arise in the future, the 

NOP may revisit that. The NOP may relay this information during an upcoming certifier training. 

o Livestock (LS) - SR. The sunset reviews are nearly complete. The LS just received TRs for two of 

the three remaining sunsets. Oxalic acid was completed on the last call. The Subcommittee is 

interested in reviewing standards for goats, and will discuss a possible work agenda request. 

• Additional Items. None

• The meeting was adjourned

Previous ES Notes

NOSB Work Agenda

Future call schedule: All calls 1:00 ET/10:00 PT 2nd Monday

December 14, 2018 

January 14, 2019 - cancelled due to shutdown

February 11, 2019

March 11, 2019

April 8, 2019

May 13, 2019

June 10, 2019

July 8, 2019

August 12, 2019
September 9, 2019

October 14, 2019 Columbus day 

November 18, 2019 

December 9, 2019

Spring 2019 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Nov 26, 2018

NOSB – Spring 2019 proposals due to NOP Feb 21, 2019

NOP - Draft Spring 2019 NOSB meeting tentative agenda Mar 4, 2019

NOP - Post proposals Mar 6, 2019

Public comment closes Apr 4, 2019

Discuss/finalize work agendas on ES call Apr 13, 2019

NOP - Send compiled public comments to NOSB Apr 8, 2019

Public comment webinars Apr 16 & 18, 2019

Spring 2019 NOSB meeting - Seattle, WA Apr 24 - 26, 2019