Note: Committee notes may include preliminary discussions regarding substances considered 

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

Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, 

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

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Committee Notes

Tuesday, February 14, 2011, 3:00 pm ET

Attending: Joe Dickson (Chair), Barry Flamm, Carmela Beck, Harold Austin and Mac Stone

Absent: John Foster and Jean Richardson

Staff: Lorraine Coke 

Project Point 

Person

Status Target Meeting 

Pesticide residue 

testing

? On hold; perhaps provide 

feedback at a later point

?

Retail certification JD On hold, lower priority ?

Processing aids in 

100% products

JFo Discussion document Spring 2012

Review Criteria and 

Procedures for 

Material Review 

Organizations

JD and HA Proposed recommendation Spring 2012

Monitoring 

Practices and 

procedures for 

205.201(a)

MS and BF Proposed recommendation Spring 2012

Calculating 

percentage of 

organic

? Spring 2012?

Agenda

Discuss and confirm work plan items for spring meeting. Assign leader and deadlines for each. 

The draft work plan from Savannah is as follows:

• Processing aids in 100% organic products

• Calculating percentage of organic

• Monitoring Practices and procedures for 205.201(a) – the construction and composition 

of the organic system plan. 

• Review Criteria and Procedures for Material Review Organizations – 2nd part of the 

recommendation from the fall, which requires us to hunker down and specifically give our 

guidance on the specific procedures to be followed by certifiers and non-certifiers in evaluating 

specific substances.

Discussion

Review criteria and procedures for MROs – Joe and Harold

This will be a continuation of the recommendation from

Monitoring practices and procedures for 205.201(a) – Mac and Barry

This issue may have come from certifiers or from certifiers via John Foster. There is 

inconsistency in 

Processing aids in “100% organic” products – John 
Started out with inert gasses as processing aids (to prevent spoilage), then moved on to 

diatomaceous earth, and other materials of concern. This was a previous issue on the Board. 

Can the final product be labeled 100% organic even though it has non-agricultural, non-organic 

products? The committee will broaden this topic a little more and look more specifically.

Calculating percentage of organic – no assigned CACC member at this time

When you have an ingredient that is not 100% organic, but it is in a 100% organic product – 

how to calculate?

Another area of consideration:

Review of materials/inputs for use on individual operation

-certifiers often review and approve materials for use on individual operations, there is no set of 

criteria and there are varying degrees of consistency

-this area should be revisited in the MRO recommendation to ensure that some level of 

oversight

Future CACC Calls

February 28 – rough draft of MRO procedures/review criteria document, review old 

recommendation on calculating percentage of organic, draft/outline of 205.201(a), draft of 

processing aids in 100% products

March 13 – final draft of MRO document, vote?

March 27 – 

Milestone Deadline

Finalize Spring 2012 Agenda March 23, 2012

Committee Proposals April 2, 2012

Spring 2012 NOSB Meeting May 21 – 24 
Note: Committee notes may include preliminary discussions regarding substances considered 

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

Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, 

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

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Committee Notes

Tuesday, February 28, 2011, 3:00 pm ET

Attending: Joe Dickson (Chair), Barry Flamm, Carmela Beck, Harold Austin, Mac Stone, John 

Foster and Jean Richardson

Absent: none

Staff: Lorraine Coke 

Project Point 

Person

Status Target Meeting 

Pesticide residue 

testing

? On hold; perhaps provide 

feedback at a later point

?

Retail certification JD On hold, lower priority ?

Processing aids in 

100% products

JFo Discussion document Spring 2012

Review Criteria and 

Procedures for 

Material Review 

Organizations

JD and HA Proposed recommendation Spring 2012

Monitoring 

Practices and 

procedures for 

205.201(a)

MS and BF Proposed recommendation Spring 2012

Calculating 

percentage of 

organic

? Spring 2012?

Agenda

• Discuss MRO Recommendation (Joe), 

• Processing aids in “100% organic” products (John), 

• Monitoring practices/procedures for 205.201 (Mac) 

• Review/discuss old Board recommendations on calculating percentage of organic.

Discussion

Review minutes from last call, minutes were approved

Review/discuss old Board recommendation on calculating percentage of organic

-this has been a discussion point, not really a recommendation

-a variation in the way ingredients/percentages are calculated from certifier to certifier

-basic products, with minimal ingredients are fairly straightforward, but it becomes more 

complicated when multiple/compound ingredients are added

-certifiers’ ability to understand issues really varies – many ACAs have trouble verifying the 

organic content in ingredients
-use of additives, lack of consistent process in calculating, using weight vs. volume

-how you calculate and what the percentages are – these become real issue for producers and 

certifiers

-opportunity for this committee to flush out the tasks that certifiers will need to do on regular 

basis and formulate a list of materials (should this be a list of application questions? Or other?)

-big issue of variability among certifiers

Questions:

Where would the recommendation go? How would it be presented? What is content?

this is more of a training issue for certifiers and their staff, this is more applicable to processed 

products, should be able to demonstrate to auditor that they have these competencies

How do ACAs get this training? Who provides? 

doesn’t matter who provides it, but the certifier should have staff that can perform these 

calculations, if a certifier is accredited for certifying handling operations they should have these 

skills

Are their issues with proprietary information?

What tools do certifiers use to calculate the percentages in these types of materials?

Next steps:

-engage with the ACA groups about these issues and have a discussion

-create list of questions for public input – to be presented at spring 2012 meeting

-this proposal/recommendation will be developed for spring 2012

Monitoring practices/procedures for 205.201(a)(3)

-basic outline/background – this came from public comment at former meeting, regarding the 

organic system plan (variability in how ACAs are monitoring how producers are managing OSPs 

and meeting compliance)

-relatively rare for inspectors to find no changes on an operation from year to year, but how the 

producer is monitoring this and verifying that the OSP is followed and updated

-inspectors’ role is to verify OSP, if producer has changes then it is grounds for noncompliance

-need mechanism in place to verify compliance with OSP

Next steps:

-develop proposal with mechanism to monitor/verify OSP what does this look like?

-is this restricted to 205.201(a)(3) or are their other parts of the regulation that are applicable? 

general feeling from committee members that this section is the focus of the proposal

-develop draft for discussion and further development of proposal for spring 2012 meeting

Discuss MRO Recommendation

-general outline/skeleton of document was sent out to committee members

-the rec put forth in Savannah was well developed, but the initial question of how the MROs 

would be monitored was not fully explored, synthetic vs. non-synthetic

Processing aids in 100% organic products

-this document is still in progress

-initially this was brought up by previous Board members

-processing aids vs. sanitizer and how contact with these materials effects 100% claim
Future CACC Calls

March 13 – final draft of MRO document, vote?, review list of questions regarding percentage 

organic calculation, review monitoring practices/procedures

March 29 (1pm) – 

Milestone Deadline

Finalize Spring 2012 Agenda March 23, 2012

Committee Proposals April 2, 2012

Spring 2012 NOSB Meeting May 21 – 24, 2012
Note: Committee notes may include preliminary discussions regarding substances considered 

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

Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, 

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

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Committee Notes

Tuesday, March 13, 2011, 3:00 pm ET

Attending: Joe Dickson (Chair), Barry Flamm, Carmela Beck, Harold Austin, Mac Stone, John 

Foster and Jean Richardson

Absent: none

Staff: Lorraine Coke and Michelle Arsenault

Project Point 

Person

Status Target Meeting 

Pesticide residue 

testing

? On hold; perhaps provide 

feedback at a later point

?

Retail certification JD On hold, lower priority ?

Sanitizers in 100% 

organic products

JFo Discussion document Spring 2012

Review Criteria and 

Procedures for 

Material Review 

Organizations

JD and HA Proposed recommendation Spring 2012

Monitoring 

Practices and 

procedures for 

205.201(a)

MS and BF Discussion document; in 

progress

Spring 2012

Calculating 

percentage of 

organic

MS Fall 2012?

Agenda

• Approve 2/28 Minutes 

• Discuss MRO recommendation

• Discuss % of organic content (Mac)

• Discuss OSP monitoring (Mac and Barry)

• Discuss processing aids in 100% organic products recommendation (John)

Discussion

• Minutes reviewed – approved with no changes

• Discussion - status and feedback on OSP monitoring and % of organic content

-there is some hesitation on moving the OSP monitoring document forward, some initial 

feedback from ACAs has been more defensive

-suggestion to put out some specific questions for the ACAs and get feedback

-should this be a discussion document for spring?
-this could really be beneficial for ACAs and committee – the feedback so far has 

demonstrated the importance of this topic 

-will provide update/document on the 29th

• Discuss processing aids in 100% organic products recommendation

-in context of discussing 100% organic – does the CACC want to spend time on 

sanitizers in “100% organic” products?

-there seems to be variation on how ACAs approach this

-developing a discussion document on eliminating (or changing) 100% organic claim 

within two weeks could be difficult – may need to focus this topic on sanitizers

-are handlers/processors dealing with this issue often? How are ACAs dealing with this?

-the “100% organic” claim is a unique labeling category – this is a discussion that should 

be addressed/reviewed more thoroughly

-for this particular document we will draw the line when it is a “sanitizer” that is used – 

food contact cleaning materials (they also carry their own restrictions and instructions for 

use) – these typically include chlorine, peracetic acid, and hydrogen peroxide

-committee members supported the idea of developing a discussion document more 

focused on sanitizers and contact with 

• Calculating percentage of organic

-this was not a high priority on the committee

-will take this issue to the ACA group for additional feedback and discussion

-will develop this further over summer and present something (discussion document?) at 

the fall meeting

• Discuss MRO recommendation

-what are the specific criteria that ACAs should use for reviewing materials?

-at the fall 2011 meeting there was a fair amount of feedback from the public 

-this recommendation should provide guidance on direction that the NOP should go with 

this

-balance with too little vs. too much detail

-question regarding the recommendation portion and suggestion for MROs to become 

accredited – this could be more clear

 -some areas could be more specific or more targeted

 -some additional edits will be added and then sent 

Future CACC Calls

March 27 – no call

March 29 (1pm EDT) - wrap up documents for spring meeting, final votes on any proposals, 

etc.

Milestone Deadline

Finalize Spring 2012 Agenda March 23, 2012

Committee Proposals April 2, 2012

Spring 2012 NOSB Meeting May 21 – 24, 2012
Note: Committee notes may include preliminary discussions regarding substances considered 

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

Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, 

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

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Committee Notes

Thursday, March 29, 2011, 3:00 pm ET

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

John Foster (JFo) and Calvin Walker (CW)

Absent: Carmela Beck (CB), Jean Richardson (JR)

Staff: Michelle Arsenault (MA)

Work Plan

Project Point 

Person

Status Target Meeting 

Pesticide residue 

testing

? On hold; perhaps provide 

feedback at a later point

?

Retail certification JD On hold, lower priority ?

Sanitizers in 100% 

organic products

JFo Discussion document Spring 2012

Review Criteria and 

Procedures for 

Material Review 

Organizations

(MRO)

JD and HA Proposed recommendation Spring 2012

Monitoring 

Practices and 

procedures for

Organic System 

Plan (OSP)

205.201(a)

MS and BF Discussion document Spring 2012

Calculating 

percentage of 

organic

MS Fall 2012?

Agenda

• Approve minutes from March 13 meeting

• MROs: Updated recommendation based on discussion with Organic Materials Review 

Institute (OMRI) and other stakeholders.

• Sanitizers in 100% organic products discussion doc: (JF) 

• Organic System Plan (OSP)/205.201(a) Monitoring discussion doc (MS)

Discussion

• Minutes reviewed-approved without objections
• MROs: An updated recommendation document was sent to members, including some 

new ideas that resulted from a discussion the Chair had with Organic Materials Review 

Institute (OMRI) and other stakeholders. Would like to clarify when NOP makes decision 

about un-allowed material; what happens when a material review organization already 

has listed a product? Is “act upon” too generic a phrase? Committee edited doc to 

clarify, and agreed that the doc is ready to go forth. JD moved to accept 

recommendation. Seconded by BF. No discussion. Yes: 6 No: 0 Abstain: 0 Absent: 2 

Recuse: 0 

• Monitoring Practices and Procedures for 205.201(a) OSP. Committee has removed 

this from the agenda for the spring 2012 meeting while they collect more information. 

Felt that they should not rush this, and would rather seek more information about the 

2010 public comment and response. MS will forward public comments to BF. 

• Sanitizers: Discussed document which will be submitted as discussion doc at spring

meeting. Clarified some language and formatting. According to FDA, “sanitizers” and 

“processing agents” are distinct. 

Motion to accept discussion document made by JF: Second: CW Yes: 7 No: 0 

Abstain: 0 Absent: 1 Recuse: 0

Future CACC Calls

April 10 (3pm EDT)

April 24 (3pm EDT). JD might not be able to make this call. 

Milestone Deadline

Public Comment Period April 9 - May 3, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Committee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Committee Notes

Thursday, May 1, 2012, 4:00 pm ET

Attending: Joe Dickson (Chair)(JD), Barry Flamm (BF), Harold Austin (HA), Jean Richardson (JR)

Absent: Mac Stone (MS) Vice Chair, John Foster (JFo) and Calvin Walker (CW), Carmela Beck (CB)

Staff: Michelle Arsenault (MA)

Work Plan

Project Point Person Status Target Meeting 

Pesticide residue 

testing

? On hold; perhaps provide 

feedback at a later point

?

Retail certification JD On hold, lower priority ?

Sanitizers in 100% 

organic products

JFo Discussion document Spring 2012

Review Criteria and 

Procedures for 

Material Review 

Organizations (MRO)

JD and HA Proposed recommendation Spring 2012

Monitoring Practices 

and procedures for

Organic System Plan 

(OSP) 205.201(a)

MS and BF Discussion document Fall 2012?

Calculating 

percentage of organic

MS Fall 2012?

Agenda

Approve minutes from March 29th

Discussion

• Approved minutes from March 29th

• Would like to ask Miles McEvoy about retail certification as JD feels he might have a COI with 

this since he works for one of the only large scale retailers who does this 

• Follow up on CACC/CC biodiversity document. Need to be revisited and tightened? BF is the only 

NOSB member still on Board who was present during the original Biodiversity recommendation 

from spring 2009. (Discussion document in fall 2008 and recommendation in 2009). MA will 

circulate this to all. 

• Sanitizers could become recommendation for fall. (§205.201). 

Future CACC Calls

May 8 (3pm EDT)

June 12 (3pm EDT) 
Milestone Deadline

Public Comment Period April 9 - May 3, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, May 8, 2012, 3:00 pm EDT 

Attending: Joe Dickson (Chair)(JD), Barry Flamm (BF), Harold Austin (HA), Jean Richardson (JR), John 

Foster (JFo) and, Carmela Beck (CB)

Absent: Mac Stone (MS) Vice Chair, Calvin Walker (CW)

Staff: Michelle Arsenault (MA)

Work Plan

Project Point Person Status Target Meeting 

Pesticide residue 

testing

? On hold; perhaps provide 

feedback at a later point

?

Retail certification JD On hold, lower priority ?

Sanitizers in 100% 

organic products

JFo Discussion document Spring 2012

Review Criteria and 

Procedures for 

Material Review 

Organizations (MRO)

JD and HA Proposed recommendation Spring 2012

Monitoring Practices 

and procedures for

Organic System Plan 

(OSP) 205.201(a)

MS and BF Discussion document Fall 2012?

Calculating 

percentage of organic

MS Fall 2012?

Agenda

• Approve minutes from May 1, 2012 (not sent yet)

• Discuss the CACC's input to the GMO ad hoc Committee 

• Public comment received to date.

Discussion

• Approval of minutes deferred until next meeting

• Discuss the CACC's input to the GMO Ad Hoc Committee 

o JD led discussion in Mac’s absence. JR offered that GMO waste-corn as compost could 

be a potential intersection. This is an issue because GMOs weren’t as pervasive when 

the legislation was written, and perhaps things need to be refreshed. Would like to add 

this to workplan: i.e. How certifiers evaluate various items that are used as feedstock, 

compost, etc. Another potential topic could be the issue of how far back in the chain 

one must look to determine what is considered GMO. i.e. When does something stop 

being what it is, and when does it start becoming something else? These questions are 

at the root of the problem. Residue levels and thresholds may also be another issue that 
CACC could address. A member asked if the OMRI model of a decision tree is something 

that NOP would adopt, and would like CACC to discuss this. 

• Public comment received to date.

o Heard from major stakeholders about MROs and it seems to be well received. 

o Received a lot of comments about food contact sanitizers and whether or not they are 

food additives. USDA does not define separately but FDA does. There were some useful 

comments and committee would like to make sure this is on the fall workplan

o Discussed details of language surrounding the “100% organic claim”. It is difficult to 

determine the percentage, and a member suggested that better training might help. 

Doing away with the 100% claim would work, but committee feels that would not

garner public support. Short of that the NOP has several options - OTA comments 

address this - Only ingredients should be listed on 605, and all other materials should be 

under processing aids, and sanitizers are not part of that. This can be confusing to 

certifiers so perhaps NOP needs to clarify this and provide some training to certifiers.

o Will include a brief summary of the comments at the meeting and a statement that this 

will potentially be on the fall workplan. A member asked whether or not this should be a 

proposal for the fall meeting, but others felt it would be more useful as a discussion 

document.

Future CACC Calls

June 12 (3pm EDT)

June 26 (3pm EDT)

Milestone Deadline

Public Comment Period April 9 - May 3, 2012

Spring 2012 NOSB Meeting

 

May 21 – 24, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Friday, June 15, 2012, 12:00 pm EDT 

Attending: Joe Dickson (Chair)(JD), Barry Flamm (BF), Harold Austin (HA), Jean Richardson (JR), John 

Foster (JFo) and, Mac Stone (MS) Vice Chair 

Absent: Carmela Beck (CB), Calvin Walker (CW)

Staff: Michelle Arsenault (MA), Matthew Michael (MMi), Lorraine Coke (LC)

Work Plan

Project Point Person Status Target Meeting 

Pesticide residue 

testing

MS/JFo Discussion doc. NOP will send 

formal request in mid-June

fall 2012

Sanitizers in milk 

trucks

JR Discussion doc or rec? NOP will 

send formal request at end June

fall 2012

Sanitizers in 100% 

organic products

JFo Discussion doc. NOP will provide 

overview to CACS of food contact 

substances and processing aids

spring 2012

Retail certification JD Discussion doc spring 2013

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

MS and BF? Discussion doc fall 2012?

Calculating percentage 

of organic

MS Discussion doc. NOP is interested 

in how formulated “organic” 

products should be calculated

spring 2012?

Biodiversity BF? Update fall 2012?

Agenda

• Approve minutes from May 1, 2012 and May 8

• Talk through the fall work plan and assign projects and timelines.

Discussion

• Matthew Michael (NOP) introduced himself and indicated he will be designating someone from 

his staff to act as the technical rep for the CACS, or he might take that role. 

• Approved minutes from May 1 and May 8

• Two agenda items tentatively scheduled for fall 2012 meeting: Pesticide residue testing and 

sanitizers in milk trucks

• NOP indicated that the final rule for residue testing is in clearance and should be out this 

summer. NOP will have a letter to committee in mid-June. 
• A member asked for clarification about the Subcommittee role in light of the fact that the final 

rule on residues is coming out soon. MS offered to captain this topic with JFo. 

• Milk trucks/sanitizers -JR offered to take this topic.

o FDA mandate vs NOP mandate is the crux of the OIG’s audit. Perhaps the only solution is to 

petition the specific substances. Need to get feedback from Standards division. 

o NOP had requested extra info during ABQ meeting about this topic. JFo prepared a 

paragraph and will resend it to group for consideration. 

o With regard to biodiversity BF offered that it is an overarching topic in Organic. NOSB put 

out guidance in 2004, 2005, 2008 and 2009, via a joint committee between Crops and LS. BF 

would like to see discussion on this topic continue. NOP said they are working on 

implementation of 2009 recommendation and chair felt that perhaps an update on this 

topic would be valuable. The 2009 recommendation did not include regulatory change - just 

an update to the checklist, therefore it was guidance. BF will work on this for next call (June 

26). And asked that others look at 2009 recommendation. 

• The Subcommittee requested that MBailey and MMcEvoy be on next call to answer questions 

about standards and workplan. 

• Calculating percentage of organic: JR will circulate a doc from Oregon Tilth about how they 

calculate the % organic. (Product formulation sheet). 

Future Scheduled Subcommittee Calls:

June 26, 2012 3:00pm EDT – 

Biodiversity (BF)

 Summary paragraph about sanitizers in milk trucks (JFo?)

July 10, 2012 3:00pm EDT 

July 24, 2012 3:00pm EDT

August 14, 2012 3:00pm EDT

August 28, 2012 3:00pm EDT

September 11, 2012 3:00pm EDT

September 25, 2012 3:00pm EDT

October 9, 2012 3:00pm EDT

Milestone Deadline

NOP - “Finalize” agenda August 13, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, June 26, 2012, 3:00 pm EDT 

Attending: Joe Dickson (Chair)(JD), Mac Stone (MS) Vice Chair, Barry Flamm (BF), Harold Austin (HA), 

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

Absent: Jean Richardson (JR)

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

Work Plan

Project Point Person Status Target Meeting 

Calculating percentage 

of organic

MS Discussion doc. NOP is interested 

in how formulated “organic” 

products should be calculated

fall 2012

Biodiversity BF? Update fall 2012?

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc spring 2013?

Sanitizers in 100% 

organic products

JFo Discussion doc. NOP will provide 

overview to CACS of food contact 

substances and processing aids

spring 2013

Retail certification JD Discussion doc spring 2013

Agenda

• Approve minutes from June 15, 2012

• Discuss NOP’s latest changes to work plan (Emily) 

• Biodiversity – Barry (discuss next steps, and whether this item is satisfactory to NOP) 

• Calculating Percentage Organic – JFo (see Emily’s memo) 

• Monitoring Practices – JFo (see JFo’s summary, and whether this item is satisfactory to NOP)

Discussion

• Minutes from June 15, 2012 approved with no changes

• Workplan: Timeline for response to OIG/sanitizers in milk trucks and GMO residues in feed is by 

Feb 2013, so NOP is going to work on these issues internally. CACS asked about putting forth a 

recommendation on sanitizers instead of a discussion document at the fall 2012 meeting, 

recognizing that there may be time constraints. EBR is working on guidance and will consult with 

CACS if there are specific questions. Residue testing as pertains to livestock feed and GMOs is 

more complicated and NOP is handling internally in order to respond to OIG by February. 

• Biodiversity (BF) - Discuss next steps. 
o BF sent draft discussion document to Subcommittee to frame the subject. The purpose 

of the discussion document is twofold: 1) To review progress in implementing the 

Board’s recommendations on biodiversity conservation, made on May 6, 2009, and to 

identify other aspects of implementation of the NOP biodiversity standards that may 

require attention; and 2) To draw attention to the value of biodiversity to organic 

production systems and the importance of implementing conservation practices.

• Calculating Percentage Organic – Discussion doc for fall 2012. MS 

o Certifiers are not using uniform standards to calculate percentages. Would like CACS to 

check with several certifiers for templates currently in use. NOP is seeking overarching 

principles and would like more information. Team would welcome public input and will 

continue this conversation on next call. 

• Monitoring Practices (JFo) 

Organic Systems Plans (OSPs) are supposed to include description of monitoring practices 

and procedures (205.201(a)(3)). A public commenter indicated that groups that had internal 

audits and formal employee training are more likely to have a robust system. The group

chose to defer this workplan item until next spring, and evaluate the need. 

Future Scheduled Subcommittee Calls:

June 26, 2012 3:00pm EDT – 

Biodiversity (BF)

 Summary paragraph about sanitizers in milk trucks (JFo)

July 10, 2012 3:00pm EDT 

July 24, 2012 3:00pm EDT

Calculating Percentage Organic

August 14, 2012 3:00pm EDT – 

August 28, 2012 3:00pm EDT

September 11, 2012 3:00pm EDT

September 25, 2012 3:00pm EDT

October 9, 2012 3:00pm EDT

Milestone Deadline

NOP - “Finalize” agenda August 13, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Tuesday, July 10, 2012, 3:00 pm EDT 

Attending: Joe Dickson (Chair)(JD), Mac Stone (MS) Vice Chair, Barry Flamm (BF), Harold Austin (HA), 

John Foster (JFo) and, Calvin Walker (CW), Carmela Beck (CB), Jean Richardson (JR)

Absent: 

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

Work Plan

Project Point Person Status Target Meeting 

Calculating percentage 

of organic

MS Discussion doc. NOP is interested 

in how formulated “organic” 

products should be calculated

fall 2012

Biodiversity BF Update fall 2012

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc spring 2013?

Sanitizers in 100% 

organic products

JFo Discussion doc. NOP will provide 

overview to CACS of food contact 

substances and processing aids

spring 2013

Retail certification JD Discussion doc spring 2013

Agenda

• Approve minutes from June 26, 2012 call

• Biodiversity (Barry)

• Quick check-in on Percentage progress (Mac)

• Also note on the agenda for July 24 is a discussion and vote on Calculating Percentage of Organic 

(Mac).

Discussion

• Minutes from June 26, 2012 call approved with no changes

• MS is conducting discussions about “Calculating percentage of organic” with several other 

entities and JR offered to send him additional information prior to his meetings. 

• Biodiversity document: BF requested comments and received one from JR. NOP has no 

objection to an NOSB update on biodiversity at fall meeting. NOP noted that the following 

additions: 

o To checklist for petition review: Is the substance harmful to the environment and 

biodiversity? [§6517c(1)(A)(i);6517(c)(2)(A)i]
o To the TR template provided to contractors: 

Evaluation Question #8: Describe any effects of the petitioned substance on biological 

or chemical interactions in the agro-ecosystem, including physiological effects on soil 

organisms (including the salt index and solubility of the soil), crops, and livestock (7 

U.S.C. § 6518 (m) (5)). .... In addition, the response should describe the potential or 

actual impacts of the substances upon endangered species, population, viability or 

reproduction of non-target organisms and the potential for measurable reductions in 

genetic, species or eco-system biodiversity, if possible

• Group reviewed some parts of the document. Perhaps any discussion of “high value 

conservation land” should be highlighted not as an update but as new item. 

• Discussion regarding applicability of biodiversity: general feeling is this is not applicable to 

handling operations unless it’s associated with a farm. Processing area would be covered under 

processing facilities. BF asked if this question should be posed or if it should be eliminated 

altogether. BF requested that other members submit comments so he can further edit the doc

• JR asked that members test out some of the programs/spreadsheets for calculating percentorganic, to see how they work. 

Future Scheduled Subcommittee Calls:

July 24, 2012 3:00pm EDT

Calculating Percentage Organic

August 14, 2012 3:00pm EDT 

Finalize Biodiversity update document

August 28, 2012 3:00pm EDT

September 11, 2012 3:00pm EDT

September 25, 2012 3:00pm EDT

October 9, 2012 3:00pm EDT

Milestone Deadline

NOP - “Finalize” tentative agenda August 13, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, July 26, 2012, 1:00 pm EDT 

Attending: Joe Dickson (Chair)(JD), Mac Stone (MS) Vice Chair, Barry Flamm (BF), John Foster (JFo), 

Carmela Beck (CB), Jean Richardson (JR), Harold Austin (HA)

Absent: Calvin Walker (CW)

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

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of 

organic ingredients

MS/JFo Discussion doc. NOP is interested in 

how formulated “organic” products 

should be calculated

Fall 2012

Biodiversity BF Update. 07 26 12 Fall 2012

Monitoring 

Practices and 

procedures for 

Organic System 

Plan (OSP) 

205.201(a)

JFo Discussion doc Spring 2013?

Sanitizers in 100% 

organic products

JFo Discussion doc. NOP will provide 

overview to CACS of food contact 

substances and processing aids

Spring 2013

Retail certification JD Discussion doc Spring 2013

Agenda

• Approve minutes from July 10, 2012 call

• Biodiversity update

• Calculating % of organic materials

Discussion

• Minutes from July 10, 2012 call approved with no changes

• Vote on Biodiversity Update document. 

Motion to accept Biodiversity document as presented: 

Motion made by: JR

Seconded by: MS
Additional discussion: minor changes to some language re: EBR, otherwise, document is 

approved by NOP. BF asked EBR to forward the new language. One vote was cast via email postcall

Yes: 8 No: 0 Abstain: 0 Absent: 0 Recuse: 0

• Calculating % of organic ingredients

o Written as a discussion document in order to solicit feedback from stakeholders. Group 

discussed the various formats and templates that are used to calculate percentages. JR 

is going to take the lead on this with support from MS and JFo. The group discussed 

processing aids and the fact that they are being included in the calculation in some of 

the templates, but not others. NOP and group agreed that they are not ingredients and

should not be included. The definition of a processing aid is clear in the regulation 

(205.2). NOP indicated that it would be helpful to include broad ideas for certifiers: 1) 

Certifiers must review all sub-ingredients or else only attribute content as 95% for 

ingredients labeled “organic”, 2) Clarify that processing aids are not part of percentage 

calculation 3) Revisit language of 205.302 as per the 2001 NOSB recommendation. JR

and JFo will work together on doc via email, and MS will then assimilate and finalize doc. 

JR asked that EBR also weigh in while the document is in process. With regard to public 

comment on this topic, the group felt that they might get a lot of written comments, but

not many at meeting in Providence. If group structures questions right, then they feel 

they will glean the most useful information. 

o A discussion about salt ensued. MS asked if salt is considered to be NaCl, or does it also 

include KCL. It was noted that salt is not on National List. And that there was a CODEX

definition, though no NOP definition. It is a non-agricultural mined mineral. The Chair 

asked about keeping these issues separate, which may be a future topic. [NOP note: FDA 

regulations at 21CFR 101.22(a) (4) - “Any salt (sodium chloride) used as an ingredient in 

food shall be declared by its common or usual name “salt.””]

Future Scheduled Subcommittee Calls:

July 26, 2012 1:00pm EDT

• Biodiversity update-done

Calculating Percentage Organic Ingredients

August 14, 2012 3:00pm EDT 

Vote/Calculating Percentage of Organic Ingredients

August 28, 2012 3:00pm EDT

September 11, 2012 3:00pm EDT

September 25, 2012 3:00pm EDT

October 9, 2012 3:00pm EDT

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 
Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Subcommittee prep meetings October 14, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, August 14, 2012, 3:00 pm EDT 

Attending: Joe Dickson (Chair)(JD), Mac Stone (MS) Vice Chair, Barry Flamm (BF), Carmela Beck (CB), 

Jean Richardson (JR), Harold Austin (HA), Calvin Walker (CW) 

Absent: John Foster (JFo)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK) 

Work Plan

Project Point Person Status Vote Target Meeting 

Calculating 

percentage of 

organic ingredients

MS/JR/JFo Discussion doc. NOP is interested 

in how formulated “organic” 

products should be calculated

08 17 12 Fall 2012

Biodiversity BF Update. 07 26 12 Fall 2012

Monitoring 

Practices and 

procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc Spring 2013?

Sanitizers in 100% 

organic products

JFo Discussion doc. NOP will provide 

overview to CACS of food contact 

substances and processing aids

Spring 2013

Retail certification JD Discussion doc Spring 2013

Agenda

• Approve minutes from July 26, 2012

• Vote on calculating % of organic materials discussion document

Discussion

• Minutes from July 26, 2012 call approved with no changes

• Calculating % of organic ingredients

o Group discussed language in proposal and made edits. Will continue to make edits via 

email and will vote when final document is ready. 

DFO note: Vote taken via email Friday August 17, 2012

Motion: To put forth the “Calculating % of organic ingredients” discussion document as edited during 

the August 14th conference call

Motion made: JR

Seconded: CW

Yes: 8 No: 0 Absent: 0 Abstain: 0 Recusals: 0
Future Scheduled Subcommittee Calls:

July 26, 2012 1:00pm EDT

• Biodiversity update-done

Calculating Percentage Organic Ingredients

August 14, 2012 3:00pm EDT 

Vote/Calculating Percentage of Organic Ingredients

August 28, 2012 3:00pm EDT

September 11, 2012 3:00pm EDT

September 25, 2012 3:00pm EDT

October 9, 2012 3:00pm EDT

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Subcommittee prep meetings October 14, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, August 28, 2012, 3:00 pm EDT 

Attending: Joe Dickson (Chair)(JD), Mac Stone (MS) Vice Chair, Barry Flamm (BF), Carmela Beck (CB), 

Jean Richardson (JR), Harold Austin (HA), Calvin Walker (CW) 

Absent: John Foster (JFo)

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

Work Plan

Project Point Person Status Vote Target Meeting 

Calculating 

percentage of 

organic ingredients

MS/JR/JFo Discussion doc. NOP is interested 

in how formulated “organic” 

products should be calculated

08 17 12 Fall 2012

Biodiversity BF Discussion documents/update 07 26 12 Fall 2012

Monitoring 

Practices and 

procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc Spring 2013?

Sanitizers in 100% 

organic products

JFo Discussion doc. NOP will provide 

overview to CACS of food contact 

substances and processing aids

Spring 2013

Retail certification JD Discussion doc Spring 2013

Agenda

• Approve notes from August 14, 2012

• Follow up questions from MS on the calculating % document

Discussion

• Notes from August 14, 2012 approved with no changes

• Group has received some informal comments from colleagues and certifiers about Calculating 

percentage of organic ingredients. The group discussed the complexity of this issue and the plan 

moving forward with a discussion document and gathering formal public comment. 

• EBR will provide background info to group about...? 

• Chair suggested discussing this on a future call before the fall 2012 meeting

Future Scheduled Subcommittee Calls:

July 26, 2012 1:00pm EDT

• Biodiversity update-done

Calculating Percentage Organic Ingredients

August 14, 2012 3:00pm EDT 
Vote/Calculating Percentage of Organic Ingredients

August 28, 2012 3:00pm EDT

September 11, 2012 3:00pm EDT-cancelled

September 25, 2012 3:00pm EDT

October 9, 2012 3:00pm EDT

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Subcommittee prep meetings October 14, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, September 25, 2012, 3:00 pm EDT 

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

Absent: Barry Flamm (BF), Harold Austin (HA), Carmela Beck (CB), Calvin Walker (CW) 

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

Work Plan

Project Point Person Status Vote Target Meeting 

Calculating 

percentage of 

organic ingredients

MS/JR/JFo Discussion doc. NOP is interested 

in how formulated “organic” 

products should be calculated

08 17 12 Fall 2012

Biodiversity BF Discussion documents/update 07 26 12 Fall 2012

Monitoring 

Practices and 

procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc Spring 2013

Sanitizers in 100% 

organic products

JFo Discussion doc. NOP will provide 

overview to CACS of food contact 

substances and processing aids

Spring 2013

Retail certification JD Discussion doc Spring 2013

Agenda

• Review the notes from the August 28 call 

• Discuss Workplan post - Providence

• Discuss any comments received to date

Discussion

• Notes from August 28, 2012 not approved due to lack of quorum

• Comments with regard to % calculation: MS will compile info so the group can have a 

meaningful conversation about this. 

• A member suggested clarifying some language in the % calculation discussion document when 

presenting it at the meeting. This document could potentially be turned into a proposal based 

on the outcome from the fall 2012 meeting. 

• The group will discuss the comments further on the October 9 call. 

• Workplan: 

o Monitoring Practices and procedures for Organic System Plan (OSP) 205.201(a): the 

group feels this is ready to be a discussion document for spring 2013. NOP asked for 

clarification about what problem the group is trying to solve with this document.

Methods are supposed to be in the OSP and should be up-to-date, and in practice 
changes are sometimes made that are not reflected in OSP. When this occurs, certifiers 

often issue a non–compliance after the fact, so perhaps looking at the root cause would 

be more effective. A member added that a good OSP provides rule references, to help 

give reason for the requirements.

o Sanitizers in 100% organic products, NOP will provide overview/guidance before group 

works on this item.

o Retail certification: JD feels there are many topics needing clarification or guidance in 

this area but did not think it appropriate for him to be the lead on this issue. The group 

discussed the language in the regulation at 205.101(a)(2): Retail exemption, and staff 

provided a link to the Nov 2009 NOSB recommendation on Voluntary Retail 

Certification. 

• A member asked about training for inspectors. 

Future Scheduled Subcommittee Calls:

September 11, 2012 3:00pm EDT-cancelled

September 25, 2012 3:00pm EDT

October 9, 2012 3:00pm EDT

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Subcommittee prep meetings October 14, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, October 9, 2012, 3:00 pm EDT 

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

Barry Flamm (BF), Harold Austin (HA), Carmela Beck (CB)

Absent: Calvin Walker (CW) 

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

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of organic

ingredients

MS/JR/JFo Discussion doc. NOP is interested 

in how formulated “organic” 

products should be calculated

08 17 12 Fall 2012

Biodiversity BF Discussion documents/update 07 26 12 Fall 2012

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc Spring 2013

Sanitizers in 100% 

organic products

JFo Discussion doc. NOP will provide 

overview to CACS of food contact 

substances and processing aids

Spring 2013

Retail certification JD Discussion doc Spring 2013

Agenda

• Review the notes from the August 28 and September 25 calls

• Discuss Workplan for Spring 2013

Discussion

• Notes from the August 28 and September 25 calls were approved without changes. 

• The group discussed the workplan item entitled ”Monitoring Practices and Procedures for 

Organic System Plan (OSP) 205.201(a)” and the fact that the NOP does not support this item. 

Group would like to discuss this further with the NOP after the Providence meeting. 

• The group discussed how to streamline certification and reduce paperwork, and would like to 

discuss this issue further. There is a perceived connection between the pasture rule and the 

increased paperwork burden for farmers. Another member added that this was an issue that 

was predicted and eventually the Board will need to address it. 

• Comments on Biodiversity: Comments are overwhelmingly supportive. JR also received positive 

feedback from colleagues about this topic. 
Future Scheduled Subcommittee Calls:

October 9, 2012 3pm EDT

October 23, 2012 3pm EDT

November 13, 2012 3pm EST

November 27, 2012 3pm EST

December 11, 2012 3pm EST

Milestone Deadline

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012

Public comment closes September 24, 2012

NOP - Send compiled public comments to NOSB October 1, 2012

Subcommittee prep meetings October 14, 2012

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, November 13, 2012, 3:00 pm EST draft

Attending: Joe Dickson (Chair) (JD), Mac Stone (MS) (2012-Vice Chair), Jean Richardson (JR) (2013-Vice

Chair), John Foster (JFo), Harold Austin (HA), Calvin Walker (CW) 

Absent: Barry Flamm (BF), Carmela Beck (CB)

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

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of organic

ingredients

MS/JR/JFo Proposal NOP is interested in 

how formulated “organic” 

products should be calculated

Spr 2013

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc. NOP requested

additional information. 

TBD

Sanitizers in 100% 

organic products

JFo On hold. NOP will provide 

overview to CACS of food contact 

substances and processing aids

in ~January 2013

TBD

Retail certification ?/JD (not 

lead) 

Discussion doc. Will look at 

previous NOSB recommendation 

and current conditions, and see 

if an additional recommendation 

would be helpful.

JD will 

recuse 

from vote

Spring 2013

Agenda

• Approve notes from October 9 call

• Plan work plan items and timelines for Spring meeting:

o Calculating Percentage of Organic Ingredients 

o Retail Certification (see August 2009 recommendation as background)

• Discuss:

o Monitoring Practices and procedures for Organic System Plan (OSP) 205.201(a)

o Sanitizers in 100% organic products

Discussion 

• Notes from the October 9 call approved with no changes. 

• Plan work plan items and timelines for Spring meeting:

o Monitoring practices and procedures for Organic System Plan (OSP) 205.201(a). There is a 

concern that delayed updating of the OSP to reflect changes (e.g. use of sanitizers not listed 
on the OSP), is resulting in issuance of non-compliances (NONCs) and that perhaps changing 

the policies around issuance of non-compliance might be the solution. Issuing and following 

through on non-compliance paperwork is burdensome and the group and NOP are 

interested in simplifying the process. The NOP is working on another project related to 

streamlining of certification, which will involve certifier training and dialog, then will be 

vetted through the NOSB and the Public. May want to hold off on the monitoring project in 

view of this streamlining project. JFo indicated that the Deputy Administrator requested a 

written summary from the CACS on the monitoring project. JFo will discuss further with 

Deputy Administrator and the group would like to extend an invitation to him to participate 

in a future call. (MA will check schedule)

o Sanitizers in 100% organic products. EBR is working on guidance that overlaps with this 

topic. Once the guidance is further along she will brief the subcommittee (likely in January) 

so they can move forward. 

o Calculating percentage of organic ingredients. JR, JFo and MS are all working on this, and 

will gather more information before proceeding with a public document. For the 

purposes of calculating percentages, 100% composition vs. 100% for labeling purposes, 

is not the same thing. It was suggested that perhaps the NOP needs to hold the handling

certifiers accountable for this. MS asked that JFo write an initial document as a starting 

point for a discussion on the next call, and a recommendation. JR noted that there was 

some useful language in the public comments that they might want to incorporate. JFo 

will begin document and others can add language as needed. 

o Retail certification – in 2009 the NOSB made a recommendation to the NOP to clarify

this issue although NOP did not issue guidance. The recommendation articulated 3 areas

seen as problematic. JD felt that he might have a perceived Conflict of Interest, so 

although he will provide useful input, he will not take the lead on this or participate in 

the vote. 

Future Scheduled Subcommittee Calls:

November 27, 2012 3:00 pm EST

 Calculating percentage of organic ingredients

Retail certification 

December 11, 2012 3:00 pm EST 

December 19, 2012 3:00 pm EST

January 8, 2013 3:00 pm EST

January 22, 2013 3:00 pm EST

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

February 26, 2013 3:00 pm EST

March 12, 2013 3:00 pm EST

March 26, 2013 3:00 pm EST

MILESTONE

 

Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013
NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Public comment closes March 19, 2013

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

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

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, November 27, 2012, 3:00 pm EST

Attending: Joe Dickson (Chair) (JD), Mac Stone (MS) (2012-Vice Chair), Jean Richardson (JR) (2013-Vice

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

Absent: Barry Flamm (BF) 

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

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of organic

ingredients

MS/JR/JFo Proposal. NOP is interested in 

how formulated “organic” 

products should be calculated

Spr 2013

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc. NOP requested

additional information. 

TBD

Sanitizers in 100% 

organic products

JFo On hold. NOP will provide 

overview to CACS of food contact 

substances and processing aids

in ~January 2013

TBD

Fall 2009 Guidance 

doc Retail 

certification

HA/JD (not 

lead)

Discussion doc. Will look at 

previous NOSB recommendation 

and current conditions, and see 

if an additional recommendation 

would be helpful.

JD will 

recuse 

from vote

Spr 2013

Agenda: 

• Review and approve notes from the November 13 call.

• Strict but Sensible (SbS) discussion (JTu). Relevance to the “Monitoring Practices and procedures 

for Organic System Plan (OSP) 205.201(a)” (JFo) 

• Discuss background and discussion sections of the % Organic recommendation (JR and MS)

• Discuss background and discussion sections of the Retail Organic Certification recommendation 

(JD) 

Discussion: 

• Notes from the November 13 call approved with no changes.

• Strict but Sensible (JTu). Relevance to the “Monitoring Practices and procedures for Organic 

System Plan (OSP) 205.201(a)” (JFo) – 
o The idea for the “Monitoring Practices and Procedures for Organic System Plans” was 

borne out of public comments from past NOSB meetings regarding interpretation of 

§205.201(a)(3), which is related to concerns about issuance of non-compliance notices. 

The group feeling is that preventative action is preferable to corrective action, and that 

perhaps this can be addressed with scale appropriate guidance. . JTu briefed the 

Subcommittee about the NOP initiative to re-evaluate the certification process, which is 

called Strict but Sensible (SbS). The goal is to streamline the certification process while 

lowering the paperwork burden, and although the initiative is broader than this one 

topic, Monitoring Practices and Procedures for Organic System Plans is a component. A 

member asked about reclassifying past non-compliances based on this new guidance, if 

the issues were not significant and didn’t affect the integrity of the process. A member 

added that no part of the OSP should be less important than another, since Organic is 

based on this OSP. 

MS will be participating in the Accredited Certifiers Association (ACA) training in January 

in Florida, and will discuss this issue and the SbS project with them. Based on outcomes 

of this meeting and further updates on the SbS project, the CACS will consider the need 

to move forward on this topic. JFo indicated that in light of this discussion he has 

changed his outlook on this item, and JTu asked that he submit a(n) example(s) of a 

problem under the current system, which would help the NOP shape the initiative on 

SbS. CACS members plan to collect examples about where the process is breaking down

or is redundant, to contribute to the SbS effort to strengthen and streamline. JD asked 

JFo to rewrite his articulation of problem and recirculate it the group and the NOP. 

• Calculating Percentage of Organic ingredients recommendation (JR and MS). JFo will write the 

background and discussions section and JR will summarize the public comment and add to the 

initial document, noting the distinction between labeling and formulation calculation. A member 

added that the ACA has a working group addressing this and they may discuss it at the January

training. 

 

• Retail Certification recommendation (JD) – JD forwarded some notes about this topic and 

reiterated that HA will be the lead on this and he will assist. JD will do some outreach in the 

retail community to get initial reaction about this item. When the questions in the document are 

more fleshed out, staff will check to see if someone in the NOP Compliance Division can provide

feedback. 

Future Scheduled Subcommittee Calls:

November 27, 2012 3:00 pm EST

Calculating percentage of organic ingredients

Retail certification 

December 11, 2012 3:00 pm EST

Discuss “Calculating percentage of organic ingredients” (JFo)
December 19, 2012 3:00 pm EST

January 8, 2013 3:00 pm EST

January 22, 2013 3:00 pm EST

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

February 26, 2013 3:00 pm EST

March 12, 2013 3:00 pm EST

March 26, 2013 3:00 pm EST

MILESTONE

 

Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

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

Public comment closes March 19, 2013

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

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

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, December 11, 2012, 3:00 pm EST 

Attending: Mac Stone (MS), Jean Richardson (JR) (Vice Chair), John Foster (JFo), Harold Austin (HA), 

Barry Flamm (BF), Carmela Beck (CB), Calvin Walker (CW) 

Absent: Joe Dickson (Chair) (JD) 

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

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of organic

ingredients

MS/JR/JFo Proposal. NOP is interested in 

how formulated “organic” 

products should be calculated

Spr 2013

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc. On hold until 

Strict but Sensible is flushed out

TBD

Sanitizers in 100% 

organic products

JFo On hold. NOP will provide 

overview to CACS of food contact 

substances and processing aids

in ~January 2013

TBD

Fall 2009 Guidance 

doc Retail 

Certification

HA/JD (not 

lead)

Discussion doc. Will look at 

previous NOSB recommendation 

and current conditions, and see 

if an additional recommendation 

would be helpful.

JD will 

recuse 

from vote

Spr 2013

Agenda: 

• Approve minutes from November 27

• Discuss Calculating % of organic ingredients (MS/JR/JFo) 

• Discuss the OSP monitoring issue ("Monitoring Organic Concepts" )

Discussion: 

• Notes from the November 27 call approved with no changes

• Calculating percentages (%) of organic ingredients. JFo will frame the issue and provide some 

background, which he will then send to JR for inclusion in the document. Sanitizers are part of this 

discussion and although the NOP didn’t ask that the NOSB address this, the group feels it’s 

difficult to decouple it. JR highlighted ten items to include in the proposal to clarify the language 

for certifiers and processers. The members discussed several other components, including the 

issue of water in the calculation, for which MS offered to engage the Accredited Certifiers 

Association; the difference between the labeling of a product in the organic category (95%) and 
the percentage of organic content for calculation purposes; and impediments to commerce 

which needs to be addressed. JR will compile the document and forward it to the group.

• OSP monitoring issue ("Monitoring Organic Concepts"). The group discussed this workplan item in 

light of the “Strict but Sensible” (SbS) document and the comments made on the last call by the NOP. 

A member asked for some clarification about SbS and how it will address the issue of what qualifies 

as “not impacting the integrity of the process.” The group also discussed the changes that will be 

implemented, and decided that since this is such a large, longer term project, they will put the OSP 

monitoring issue on hold for now. 

Future Scheduled Subcommittee Calls:

November 27, 2012 3:00 pm EST

Calculating percentage of organic ingredients

Retail certification 

December 11, 2012 3:00 pm EST

Discuss “Calculating percentage of organic ingredients” (JFo) 

December 19, 2012 3:00 pm EST

Discuss Calculating % of organic ingredients (JR).

January 8, 2013 3:00 pm EST

January 22, 2013 3:00 pm EST

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

February 26, 2013 3:00 pm EST

March 12, 2013 3:00 pm EST

March 26, 2013 3:00 pm EST

MILESTONE

 

Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

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

Public comment closes March 19, 2013

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

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

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

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

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Compliance, Accreditation & Certification Subcommittee Notes

Thursday, December 19, 2012, 3:00 pm EST

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

Harold Austin (HA), Calvin Walker (CW)

Absent: Barry Flamm (BF), Carmela Beck (CB)

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

Work Plan

Project Point 

Person

Status Vote Target Meeting 

Calculating 

percentage of organic

ingredients

MS/JR/JFo Proposal. NOP is interested in 

how formulated “organic” 

products should be calculated

Spr 2013

Monitoring Practices 

and procedures for 

Organic System Plan 

(OSP) 205.201(a)

JFo Discussion doc. On hold until 

Strict but Sensible is flushed out

TBD

Sanitizers in 100% 

organic products

JFo On hold. NOP will provide 

overview to CACS of food contact 

substances and processing aids

in ~January 2013

TBD

Fall 2009 Guidance 

doc Retail 

Certification

HA/JD (not 

lead)

Discussion doc. Will look at 

previous NOSB recommendation 

and current conditions, and see 

if an additional recommendation 

would be helpful.

JD will 

recuse 

from vote

Fall 2013

Agenda:

• Approve minutes from December 11

• Discuss Calculating % of organic ingredients (JR).

Discussion:

• Notes from the December 11 call approved with no changes

• Calculating percent (%) of organic ingredients (JR). The group discussed various components of the draft 

proposal and JR asked for feedback about a couple of line items, including the issue of the inclusion of 

water (#4) and raw crop ingredients calculations (#5). 

JFo shared the following perspectives on several of the line items. There is a definite need for the

language change (#1) and that the NOSB might be asked to separate this out as a separate proposal 

because it changes the regulation. NOP staff suggested they divide the proposal into two sections, one 

for proposed rule change and the rest as guidance. Self-calculating forms (#2), salt excluded (#3) and 

water excluded (#4), shouldn’t be complicated, but they often are for certifiers. Certifiers have said
that they do not want to just cite the FDA, but would prefer that the NOP codify this. With regard to 

raw agricultural ingredients (# 5) and non-organic processing aids (# 8), he noted his agreement. As 

for sanitizers(# 9), § 205.2 doesn’t specify sanitizers and processing aids, and he feels that sanitizers 

and processing aids should be defined separately, and further, that sanitizers shouldn’t affect the 

100% organic claim. JFo noted that he does not support including this item in the proposal. JR asked 

how the group felt about the structure of the document and whether or not she should keep the 11 

recommendations short or should include more detail and examples under each of them. The group 

and the NOP suggested the latter. The group discussed the fact that this proposal, which would 

serve to standardize the process of calculating organic percentages, is going to be controversial. JR 

asked that the group send her examples of processing aids. A member noted that juice concentrates

is a perfect example. JFo will send JR information about apple juice, which is clarified with enzymes

(a processing aid).. It is generally understood that most of this is removed in the final product, but 

the exact amount is not known. JR asked EBR for examples as well, especially with regard to water. A 

member added that the Accredited Certifiers Association (ACA) was going to provide comments 

about the water and sanitizers items, and give the NOSB their recommendations after the January 

certifier training. NOP suggested that the proposal mention the need for training for both certifiers 

and auditors. .

Future Scheduled Subcommittee Calls

December 19, 2012 3:00 pm EST

Discuss Calculating % of organic ingredients (JR)

January 8, 2013 3:00 pm EST

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

Discuss Retail Certification (delayed until Fall 2013)

January 22, 2013 3:00 pm EST

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

February 26, 2013 3:00 pm EST

March 12, 2013 3:00 pm EST

March 26, 2013 3:00 pm EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

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

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

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

Public comment closes March 19, 2013
NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013