FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB)

TO THE NATIONAL ORGANIC PROGRAM (NOP)

Date: 

Subject: 

November 19, 2008

Chair:

Policy and Procedures Manual changes

Rigoberto I. Delgado

Recommendation

The NOSB hereby recommends to the NOP the following:

Rulemaking Action: _______

Guidance Statement: _______

Other: ___X___

Summary Statement of the Recommendation (including Recount of Vote):

The Policy Development Committee recommended six separate changes to the Policy and Procedures 

Manual as follows listed as they appear on the NOSB meeting agenda for November 18.

1) Technical corrections: This recommendation presents an approach to identify and correct or 

address discrepancies between Federal Register publication and NOSB recommendation wording. 

Committee vote - Moved: Barry Flamm, Second: Hue Karreman, Yes: 3 No: 0 Absent: 1

2) Public Comment at NOSB meetings: The intent of this update to the PPM is to obtain maximum 

benefit from public comment and to allow the most number of presenters the opportunity to speak. 

Committee vote - Moved: Barry Flamm, Second: Bea James, Yes: 4 No: 0 Absent: 0

3) Election of NOSB officers: The recommendation amends the section on Election of Officers in the 

PPM to clarify the election process. 

Committee vote - Moved: Barry Flamm, Second: Bea James, Yes: 4 No: 0 Absent: 0 

4) Committee Work Plans: This recommendation provides guidance on developing committee work 

plans. 

Committee vote- Moved: H. Karreman, Second: R. Delgado, Yes: 4 No: 0 Absent: 0

5) Sunset Procedures: This recommended update to the PPM provides background on the Sunset of 

materials requirements and provides a clear description of the review process. Committee voteMoved: Hue Karreman, Second: Rigo Delgado, Yes: 3 No: 0 Absent:1

6) Content and structure of Recommendation Documents: The purpose of this recommendation is to 

create more process and structure for writing committee recommendations. 

Committee vote- Moved: Barry Flamm, Second: Bea James, Yes: 3 No: 0 Absent: 1

NOSB Vote: Motion: Barry Flamm Second: Bea James

Board vote: Yes - 14 No- 0 Abstain- 0 Absent – 1

 

Summary Rationale Supporting Recommendation (including consistency with OFPA and NOP):

The recommendation strengthens and clarifies guidance to NOSB members and is consistent with 

OFPA. There has been no adverse comment from NOP.

Response by the NOP:
National Organic Standards Boaard

Policy Development Committee

Technical Corrections

September 18. 2008

Background: 

Technical Corrections are those actions needed to amend or slightly change the exact wording of 

an item placed into the Federal Register, as recommended by the NOSB and accepted (or 

rejected) by the Secretary. Changes in the wording of a recommendation (e.g., omitting a word, a 

place holder, or changing an annotation slightly), or finding unintended consequences of a 

recommendation (e.g., incomplete annotations allow inappropriate uses of a material) can obscure 

the intent of the NOSB, incorrectly convey a statement voted on by the NOSB, and/or create 

uncertainty among the public. Because other issues come forward as more urgent once the Board 

has taken action on an item, Technical Corrections may glaringly emerge and remain uncorrected. 

This recommendation presents an approach to identifying and correcting such discrepancies.

Discussion:

In order to minimize confusion in the organic community, the Board needs to have a way to deal 

with discrepancies between items which have been voted on and their subsequent insertion in the 

Federal Register. Some examples of the different types of Technical Corrections and the different 

levels of technical Corrections (NOSB level or NOP level) are:

Annotations different than what was originally recommended by NOSB and changed by the 

Program in order to fit the demands of other federal regulatory bodies (ex: livestock medications 

withholding times).

An unforeseen consequence of a recommendation voted by the Board could require additional 

annotations in order to fit the needs of the organic industry. The absence, for example, of a 

explicit description of what methods of extraction are allowed for specific materials could result 

in the unwanted use of materials extracted using prohibited extraction processes (ex: colors on 

606 – hexane and ethanol extraction not reviewed, but water, oil-extracted and dried were 

recommended) .

Recommendation:

Insert in the Policy and Procedures Manual a new section called “Handling Technical 

Errors after an Item Has Been Placed in the Federal Register”, to be included at the end of 

Section VIII, before the section “Appendices and Resources” of the NOSB Policy and 

Procedures Manual. 

The suggested text of the section is as follows:
HANDLING TECHNICAL ERRORS AFTER AN ITEM HAS BEEN PLACED IN THE 

FEDERAL REGISTER 

In order to minimize confusion in the organic community, the Board needs to monitor and correct 

discrepancies between items which have been voted on and their subsequent insertion in the 

Federal Register. Some examples of the different types of technical corrections needed are:

Annotations different than what was originally recommended by NOSB and changed by the 

Program in order to fit the demands of other federal regulatory bodies (ex: livestock medications 

withholding times).

An unforeseen consequence of a recommendation voted by the Board could require additional 

annotations in order to fit the needs of the organic industry. The absence, for example, of an 

explicit description of what methods of extraction are allowed for specific materials could result 

in the unwanted use of materials extracted using prohibited extraction processes.

The Board should follow these steps to monitor and correct technical discrepancies:

(1) The Secretary of the Board, with the assistance of the NOSB Executive Director, shall review 

all additions to the Federal Register and report to the Board any discrepancies between Board 

recommendation and those published in the Federal Register. 

(2) When the Program incorporates changes to a recommendation voted and presented by the 

Board, the Program is expected to communicate these changes prior to final action by the 

Program to the Board Chair, Vice Chair and Secretary. The Board Chair, Vice Chair and 

Secretary will report such activity to the Board and then work with the Program in order to assist 

the Program in stating the exact reasons for such deviations in the preamble to the Rule change 

posted. 

(3) In the cases of unintended consequences with a published recommendation, the Chair of the 

Board, with the approval of the Executive Committee, will assign committee to resolve the issue. 

Committee Vote:

Moved: Barry Flamm Second: Hue Karreman

Yes: 3 No:0 Absent: 1 Abstain:0
National Organic Standards Board

Policy Development Committee

Recommendation for amendments and additions to the NOSB Board Policy 

Manual

NOSB Policy for Public Comment at NOSB Meetings

September 10, 2008

Recommendation

The following recommendation amends the section called NOSB Policy for Public 

Comment at NOSB Meetings of the NOSB Policy and Procedures Manual (page 28). 

The intent of these updates is to obtain maximum benefit from public comment, and to 

allow the most number of presenters the opportunity to speak according to the allotted 

time. 

Proposed new language is presented in underlined text while deletions are indicated in 

strikethrough.

NOSB Policy for Public Comment at NOSB Meetings:

1. All persons wishing to comment at NOSB meetings during public comment periods 

must sign up in advance per the instructions in the Federal Register Notice for the 

Meeting. 

2. All presenters are encouraged to submit public comment in writing according to the 

Federal Register Notice. Advance submissions allow NOSB members the 

opportunity to read comments in advance electronically, and decrease the need for 

paper copies to be distributed during the meeting

3. Persons will be called upon to speak in the order they sign up. 

.

Persons called upon 

who are absent from the room could potentially miss their opportunity for public 

comment

4. Each person will be given 5 minutes to speak, unless otherwise indicated by the 

Chair each person will be given 5 minutes to speak.

.

5. Persons must give their names and affiliations for the record at the beginning of their 

public comment

6. A person may submit a written proxy to the NOP or NOSB requesting that another 

person speak on his or her behalf. 

.

7. No person will be allowed to speak during the public comment period for more than 

10 minutes, unless otherwise indicated by the Chair

8. Individuals providing public comment will refrain from any personal attacks and from 

remarks that otherwise impugn the character of any individual.

.
•

Other suggestions that would be appreciated by NOSB members:

The NOSB will attempt to accommodate all persons requesting public comment time, 

however, persons requesting time after the closing date in the Meeting Notice, or 

during last minute sign-up at the meeting, will be placed on a waiting list and will be 

considered at the discretion of the NOSB Chair depending on availability of time. 

Similarly, persons who have signed up to address the NOSB for their 5-minute slot 

and have also served as a proxy for another person will be placed on a waiting list if 

they wish to speak for a third time on the same topic, and will be considered at the 

discretion of the NOSB Chair depending on availability of time. This should allow 

more members of the public time to present.

•

•

Members of the public are asked to define clearly and succinctly the issues they wish 

to present before the Board. This will give NOSB members a comprehensible 

understanding of the speaker’s concerns. 

Adopted October 19, 2002

Members of the public should be considerate about - speaking more than once on 

the same topic - to allow more members of the public the opportunity to speak

Amended March 2, 2005

Amended September 10, 2008

Committee vote:

Moved: Barry Flamm Second: Bea James

Yes- 4 No- 0 Absent- 0
National Organic Standards Board

Policy Development Committee

Recommendation for amendments and additions to the NOSB Board Policy 

Manual

Election of NOSB Officers

September 18, 2008

Recommendation

The following recommendation amends the section called Election of Officers of 

the NOSB Policy and Procedures Manual (page 13-14). The intent of these 

updates is to clarify the process of the election of NOSB officers. 

Proposed new language is presented in blue text while deletions are indicated in 

strikethrough.

OFFICER RESPONSIBILITIES 

Three principal officers – Chair, Vice Chair and Secretary – guide the Board. Chair 

The Chair is responsible to assure the integrity of the Board process, including 

effectiveness of meetings and the board’s adherence to its own rules. The Chair shall: 

Schedule meetings of the Board and the Executive Committee; 

Draft meeting agendas in consultation with committee chairs and NOP staff; 

Convene and preside at meetings; 

Review committee work plans; and 

Review meeting minutes for accuracy, and

Assist with the annual election of NOSB officers.

Vice Chair 

The Vice Chair shall act in the absence of the Chair. The Vice Chair shall also be 

responsible for maintenance and upkeep of the Policy and Procedures Manual. 

Secretary 

The Secretary is responsible for the integrity of all legal and governing documents of the 

Board. It is the Secretary’s responsibility to: 

• Record and maintain the official Board proceedings; 

• Circulate draft minutes for approval of the Board; 

• Ensure that minutes of Board actions are available to members of the public; and 

• Transfer custody of the Board minutes to the Secretary’s successor, and

• Assist with the annual election of NOSB officers.

ELECTION OF SECTION III

Officers shall be elected for terms of one year by majority vote at the annual fall meeting 

of the Board. Candidates may be self-nominated or nominated by another member of the 

ELECTION OF OFFICERS
Board. Should an officer resign or fail to serve the full term, the Executive Committee 

shall appoint an interim officer. The interim officer shall serve in the capacity until the 

next regularly scheduled meeting of the Board, during which an election will be held to 

fill the remainder of the term.

A. NOMINATION

• All interested NOSB members are eligible for consideration for any officer position.

• Candidates may be self-nominated or nominated by another member of the Board. 

• Should the Vice Chair or Secretary resign or fail to serve the full term, the Executive 

Committee shall appoint an interim officer. 

• The interim officer shall serve in the capacity until the next regularly scheduled 

meeting of the Board, during which an election will be held to fill the remainder of 

the term.

• Members interested in serving more than one consecutive term in an officer position 

can if the Board is in favor, however it is recommended that an officer not serve for 

more than two consecutive terms.

B. VOTING SCHEDULE 

• Officers shall be elected for terms of one year by majority vote at the annual fall 

meeting of the Board. 

• Newly appointed officers will assume their positions at the conclusion of the fall 

Board meeting pursuant to the election.

• Acting Board officers will assist the new officers to transition into their new role.

C. ELIGIBILITY TO VOTE

• Only NOSB Board Members present are eligible to vote for nominated officers.

• Absent NOSB members will not be eligible to vote. 

• Board members shall be entitled to cast one vote per nomination.

D. COUNTING OF VOTES

• Voting will be by ballot immediately following nominations for each office.

• Ballots for officers will be cast in the following order:

1. Chair

2. Vice-Chair

3. Secretary

• The ballots will be counted for one office and the acting Chair will announce the tally 

before the next office is opened for nominations

• The acting Secretary will prepare and distribute the ballots and will gather the votes 

by secret ballot. 
• The acting Chair will tally the votes after each officer nomination and the acting 

Secretary will verify the vote results. 

• The candidate receiving the largest number of votes will be elected.

• In the event of a tie there will be a revote until a nominee obtains majority. All 

nominees will be included in the revote or may be given the opportunity the withdraw 

at their discretion. .

• Member vote counts will remain confidential. Other NOSB members will not be 

allowed to determine how the members voted.

• Votes will be disposed of by the Chair or Secretary.

• The acting Secretary will record newly elected officers into the NOSB Meeting 

Summary of Minutes.

Committee vote: Moved: Barry Flamm Second: Bea James Yes: 4 No: 0 

Absent: 0
National Organic Standards Board

Policy Development Committee

Recommendation for an addition to the NOSB Board Policy Manual:

Committee Work Plans

September 19, 2008

INTRODUCTION:

The Policy Development Committee is recommending a guideline on developing a committee 

work plan. The proposed guideline is to be included in Section VIII, immediately after the 

introductory subsection titled “Procedures of the NOSB, and before the subsection titled 

“National Organic Program Materials Review Process” of the NOSB Policy and Procedures 

Manual. Given that section VIII covers topics which relate to “how” the Board should manage its 

review process, a section on committee work plans should be a useful addition. 

The recommended text of the proposed section is as follows:

COMMITTEE WORK PLANS

At the end of every NOSB meeting, each committee chair is required to present the committee’s 

work plan. Given the nature, and number, of the issues the Board handles, it is important for a 

committee to follow a structured procedure for assigning priorities in the work plan. The 

following provides a guideline on how to develop a committee work plan. 

The committee chair, working with the committee, should follow three general steps in producing 

a work plan: 1) List all issues before the committee; 2) Prioritize each issue; 3) set a calendar; 

and 4) Obtain feedback from the Executive Committee and the Program.

Step 1: Identifying all issues

The committee work plan rises out of these main situations:

- Items committed, or assigned to a committee, by the Board during an official session. 

- Items that are reviewed by a committee on a regular basis such as materials sunset review 

or petitions submitted by members of the public. 

- Requests or suggestions from the National Organic Program such as clarifications on a 

particular issue or guidance on enforcement.

- Proposals stemming from the committee members’ contact with the organic community.

In many cases not all issues should be the responsibility of the committee. Selecting what the 

committee should be reviewing can be done based on the following criteria:

- Relevance to the organic community (Is this an important issues? vs. Is this an interesting 

issue?)

- Criticality regarding mandate (is the issue within the committee’s or the NOSB’s realm?)

- Feasibility in terms of the Rule (can a proposal by the committee be realistically enforced

by the NOP?)
Step 2: Prioritizing the issues

After listing the issues to review, the committee should prioritize its work plan items according to 

the following criteria:

- Preference given to petitioned materials

- Relevance to the organic community, public at large and the environment

- Size of the population affected by the issue

- Timeline since the issue/petition was submitted

The criteria are presented in order of importance and should be used to rank or prioritize each 

issue accordingly. For example, a petitioned material has priority over an issue that has been 

waiting to be reviewed for an extended period of time.

Step 3: Setting a calendar for reviews

Once the issues are prioritized, the committee chair should define a calendar for discussion of 

each issue. The calendar should allow committee members to understand specific deadlines and 

should reflect the posting/publication target dates mandated by the Program and the Federal 

Regulation.

Step 4: Incorporating Input from the Executive Committee

The committee chair must present the finalized work plan at the first Executive Committee 

conference call following a normal NOSB meeting. This event is not only an opportunity for the 

EC to provide guidance to the committee chair, but it is also an opportunity to obtain input from 

the NOP regarding the feasibility of implementing the committee’s recommendation. 

Committee vote:

Moved: H. Karreman Second: R. Delgado

Yes-4 No- 0 Abstain- 0 Absent- 0
National Organic Standards Board

Policy Develoment Committee

Policy and Procedures Manual Update: 

Sunset Procedures Section 

September 19, 2008

Introduction:

The Policy and Procedures Manual has a section on the Sunset Review process (pages 52-56). 

This content, however, does not provide enough background or explains clearly the unique 

characteristics of the review procedures followed by the NOSB. The proposed updates to the

section should address the current limitations and provide a clear description for the benefit of all 

Board members. 

Committee vote

Motion: Hue Karreman Second: Rigo Delgado

Yes: 3 No: 0 Abstain: 0 Absent:1

Recommendation:

The proposed text is presented in red font and deleted sections are marked with 

strikethrough 

SECTION VIII 

SUNSET REVIEW PROCESS 

Background 

Sunset is a regulatory process for determining the continued listing of a material already approved 

or prohibited on the National List for use in organic agriculture production and handling. It is not 

used to petition to add a new substance nor is it used to change an existing annotation. If the 

review and renewal process is not concluded by the expiration date, the use of the material will 

become prohibited.

Since sunset is defined as the reviewing of regulations to ensure the continued relevance and not 

the creation of new regulation, all substance must be renewed as listed. If there is a need to 

consider changing an annotation or moving a material from one list to another, this may be 

accomplished through the existing procedures for petition.

The Organic Foods Production Act of 1990 (OFPA) authorized a National List of Allowed and 

Prohibited Substances (Section 6517). Sections 6517 (e) mandates a Sunset Provision as follows:

“No exception or prohibition in the National list shall be valid unless the National Organic 

Standards Board has reviewed such exemption or prohibition as provided in this section within 5 
years of such exemption or prohibition being adopted and the Secretary has reviewed such 

exemption or prohibition”. 

The National List that was implemented in October 21, 2002 contained over 200 substances. The 

first sunset review of listed materials was completed in October, 2007. Decisions made through 

the Sunset review must be transparent, non-arbitrary, based on the best current information and in 

the interest of the organic community and public at large.

Steps followed in Sunset Process 

Not all listed materials reach sunset status at the same time, but the review process includes these 

steps:

1. A public notice is placed in the Federal Register (Advance Notice of Proposed Rule 

Making or ANPR) of the pending sunset of the listed materials. The public has 60 days 

after the publication date to provide written comment (see Chart 1 below). The committee 

may request a third party technical review in anticipation of scientific evidence and 

claims likely to be made during public comment to the ANPR.

2. Public comments are collected and forwarded to the NOSB (see Chart 2).

3. The appropriate NOSB committee begins review of the material with the intent of 

providing a recommendation to the entire Board for the material’s removal or renewal. 

The review is conducted based on “Force of Evidence” as presented by Board members,

public comments, and scientific data from other sources (see Chart 3). This includes the 

original recommendation from the Board to list.The committee may request a third party 

technical review, if needed, to verify scientific evidence and claims made during public 

comment to the ANPR.

4. The reviewing NOSB committee provides its recommendation to the full Board 60 days 

prior to the Board Meeting. At the same time, the committee recommendations are 

posted on the NOSB website and open to public comments.

5. At the public NOSB business meeting, the NOSB hears additional public comment, 

discusses the force of evidence, and votes on the committee’s recommendation.

6. The NOP reviews the NOSB recommendation and accompanying documentation and 

publishes a proposed rule to review the National List. The public has 90 days after the 

publication date to comment. All comments are made available on the NOP website.

7. NOP will review the comment and publish the final rule. The final rule process is 

illustrated in Chart 4 
Chart 1: Sunset Review – NOP Posts an ANPR

Chart 2: Sunset Review – NOP Collects and Forwards Public Comment to 

the NOSB

NOP Develops Regulatory Review work plan and drafts Advanced Notice of Public Rulemaking

(60 days)

OGC Review and Departmental Clearance

(60 days)

NOP publishes a FR notice for an Advanced Notice of Public Rulemaking

(Allow 60 days for public comment)

NOP receives comments, forwards to NOSB, and posts to the NOP Website

(All comments shall be in NOSB possession no later than 7 days after the closing date of public comment)

Committee Recommendations Posted on 

NOP Website

60 days prior to NOSB meeting

Additional Public Comments Received

NOSB Final Vote

NOP Receives Public Comments

Committee Reviews Evidence for Delisting

(See chart 3 for detail)

Complete Material Review Forms

NOSB Notified of Comments

(within 5 days of NOP receipt)

Notification to Materials Chair

Notification to Committee Chair

Comments Posted on NOP Website

(within 5 days of NOP receipt)

Posted by Category

Handling (H), Crops (C), Livestock (L)

Additional Comments Received

On Posted Materials

NOSB Notified of Additional Comments
Chart 3: Sunset Review – NOSB Committee Reviews Evidence for Delisting

NOSB submits 

recommendation 

to remove material

Does NOSB 

committee have 

evidence for 

removal?

Yes

No

No

NOP provides 

public 

announcement

Yes

Yes

Evidence for 

removal from the 

Public Input?

NOSB submits 

recommendation to 

continue listing material

NOSB Committee Receives Request to 

Review Sunset Material – plus copies of 

public input

Is a Technical 

Review needed to 

make decision?

No

Form a 

Technical 

Advisory Panel 

(TAP)

TAP completes 

technical review 

and submits 

findings to 

NOSB 

committee
Chart 4: Sunset Review - Final Rule Process

OVERVIEW OF THE SUNSET PROCESS-STEPS COMPLETED 

• FEDERAL REGISTER NOTICE 

• RECEIPT OF PUBLIC COMMENTS 

• COMMITTEES FORWARDED RECOMMENDED SUBSTANCES 

FOR FURTHER TECHNICAL REVIEW TO NOP

SUNSET PROCESS-IN PROGRESS 

• COMMITTEES REVIEWING SUBSTANCES UNDER SUNSET 

REVIEW 

• COMMITTEES REVIEWING PUBLIC COMMENTS 

• COMMITTEES DRAFTING RECOMMENDATIONS ON 

SUBSTANCES 

• COMMITTEES FORWARDING SUBSTANCES FOR 

ADDITIONAL TECHNICAL REVIEW BASED ON PUBLIC 

COMMENTS 

Committee substance Forms 

NOP Drafts Final Rule

(90 days)

OGC Review

(90 days)

Interagency Review

(90 days)

OMB Review

(90 days)

Congressional Review

(60 days)

Final rule is Final
• Sunset Review Committee Forms 

• Name of Substance 

• National List Section, use and annotation if applicable 

• Comment (s) code number (s) 

• Status (record number of comments) 

o Renewal ( ) 

o Removal ( ) 

• Summary of comment (s) 

• Committee recommendation

Committee Recommendations 

Committees will recommend to the full Board a determination on each substance 

for renewal, removal or deferral to seek specific technical information from the 

TAP contractors. TAP contractors shall be used to verify information provided by 

the commenters, research or seek additional information requested by the 

committee

Since sunset is defined as the reviewing of regulations to ensure the continued 

relevance and not the creation of new regulation, all substance must be renewed 

as listed. If there is a need to consider changing an annotation or moving a 

material from one list to another, this may be accomplished through the existing 

procedures for petition. 

Public Comment and Final NOSB Vote on Recommendations 

• Each committee will provide their recommendation to the board on each 

substance 60 days prior to the full Board meeting. The recommendation will 

be posted on the website and open to public comment. 

• NOSB Final Vote 

Rulemaking on NOSB Recommendations 

• NOP Rulemaking 

• Dockets of materials for renewal based on the assumption that deferred 

materials may take some additional time for review and a full board vote. 

After each NOSB meeting, the NOP would begin rulemaking on those 

substances that were voted for renewal. The materials committee anticipates 

at least two. 
Sunset Timeline

DELETE CHART 

Sunset Timeline

DELETE CHART 
National Organic Standards Board

Policy Development Committee

Recommendation for an addition to the NOSB Board Policy Manual:

Content and Structure of Recommendation Documents

September 18, 2008

INTRODUCTION:

The Policy Development Committee is recommending an improved outline for clarifying 

the process for writing committee recommendations. The following outline provides the 

suggested improvements and would be included in the Board Policy and Procedures 

Manual. The purpose of this recommendation is to create more process and structure for writing 

committee recommendations.

The following addition to the PPM includes eliminations of current text in the Policy Manual for 

Section V (page 21) in strike through, and additions in red font:

OUTLINE FOR WRITING COMMITTEE RECOMMENDATIONS 

This section provides an outline to be used by committees in writing a recommendation 

document. These guidelines not only allow consistency in the content of NOSB 

recommendations, but should also provide the NOSB, and the public, a fast manner to 

weigh the advantages and disadvantages of a proposal.

Recommendations not related to material petitions or sunset reviews, should include the 

following sections:

I. Introduction: 

This section consists of a brief summary of the recommendation, its main issues and 

its relevance to the organic community. This section should also mention the goals 

and intent of the proposed recommendation.

II. Background: 

This section should present the issues that justify the development of the 

recommendation as well as any relevant work done by the NOSB in the past.

III. Relevant areas in the Rule: 

This section should mention any areas of the Rule or OFPA which provide the basis 

for the recommendation.

IV. Discussion:

This section should be used to expand on the intent of the recommendation. It is 

also a place to emphasize the SWOT of the recommendation (strength, weaknesses, 

opportunities and threats). No recommendation is 100% perfect and this section can 

serve to clarify the tradeoffs and advantages of a recommendation. Thus, it is 

advisable to mention all major alternatives reviewed by the committee. If 
appropriate, different stakeholders groups should be identified indicating how each 

group’s needs are met or affected. 

V. Recommendation:

This is the core, or deliverable, of the recommendation.

VI. Committee Vote:

This section should present the names of the members who moved and second the 

motion to approve the recommendation. It should also list the votes including 

number of abstentions and absences. As a norm, a motion should always be 

presented in the affirmative. 

Minority opinion:

If applicable, the dissenting opinion(s) of committee or task force members shall 

be reported. A member of a committee can present a minority report to the 

committee recommendation. Such document should include reasons for 

opposing a proposed recommendation and cite where the opposition points are 

in the recommendation. In addition, the minority report could, provide alternative 

approaches or solutions from those given in the recommendation, or recommend 

an amendment to the recommendation. The minority opinion will be included as 

a separate document at the end of the recommendation.

PROCEDURES TO FOR PRESENTING COMMITTEE RECOMMENDATIONS 

NOSB committees and task forces will follow the outline presented below in order to 

present draft policy and/or material recommendations for consideration by the Board

at meetings of the Board: 

Introduction—A brief summary of the issue or statement of the problem. 

Background—An explanation with sufficient detail and rationale to support a 

proposed recommendation, including reasons why the recommendation 

should be adopted, historical context, and the regulatory framework pertinent 

to the issue. 

Recommendation—The concise text of the recommended action. 

Committee vote—The vote of the committee or task force shall be reported. 

Minority opinion – If applicable, the dissenting opinion(s) of committee or task 

force members shall be reported. 

Committee vote:

Moved: Barry Flamm Second: Bea James

Yes- 3 No- 0 Absent- 1