Updated June 17, 2010 

Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: April 29, 2011 

Subject: PPM Section V: Procedures for Completing Committee 

Recommendations

Chair: Tracy Miedema 

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action 

Guidance Statement 

Other X 

 

Statement of the Recommendation (Including Recount of Vote): 

 This recommendation revises Section V of the Policy and Procedures Manual 

(PPM); Procedures for Completing Committee Recommendations. The most 

significant change is the clarification of the policy for withdrawal of a committee 

recommendation. The complete text voted on at the Board Meeting is attached. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

 Standing Committees develop recommendations based on the best information 

available, including public comment and the Committee’s own expertise. However, 

at the Board Meeting additional information may be presented that may cause the 

Committee to reconsider its recommendation. The new information may be so 

complex, technical or controversial, that the Committee needs additional time or 

third party evaluation of the information. In such situations the Committee needs to 

be able to take back its recommendation. This recommendation clarifies 

procedures for handling this situation and other steps in developing 

recommendations. 

The recommendation is consistent with OFPA and NOP.OFPA provides the 

authority for the NOSB, but operating procedures were left to the Boards 

discretion. 

NOSB Vote: 

Moved: Barry Flamm Second: Steve DeMuri 

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recusal: 0 
National Organic Standards Board 

Policy Development Committee 

Final Recommendation 

Policy & Procedures Manual Section V: 

Procedures for Completing Committee Recommendations 

April 29, 2011 

Introduction 

 

The PPM is a guide to assist the Board in the conduct of its responsibilities and it is revised as 

necessary to improve the functioning of the Board. The development and proposed revisions 

are done with public input, following the same procedures used for all NOSB committee 

recommendations. 

Most of the Board’s work is done by the standing committees, constituted by members with 

expertise and experience in the subject area and thus should be allowed to reach an 

independent committee conclusion, which may include a minority opinion. The full Board has 

the option to arrive at different conclusion and reject the committee recommendation. 

The purpose of this recommendation is to clarify committee procedures and prerogatives for 

completing recommendations. 

Background 

During the NOSB Fall 2010 Meeting, procedural questions arose over the prerogative of a 

Committee to withdraw a proposed recommendation. Withdrawing a recommendation is not an 

uncommon practice, occurring at least once during the same Board Meeting. However in this 

case, the majority of the Board objected to the action of the Committee. During the insuring 

discussions, it became obvious that the PPM needed clarification on the subject. 

Relevant areas in the Rule 

OFPA provides the authority for the NOSB. Operating procedures were left to Board’s 

discretion. 

Discussion 

Standing Committees develop recommendations based on the best information available, 

including public comment and the Committees own expertise. 

At the Board Meeting additional information may be presented that may cause the Committee 

to reconsider its recommendation. This may be done during the Board meeting. However, the 

new information may be so complex, technical or controversial, that the Committee needs 

additional time or third party evaluation of the information. In such situations, the Committee 

needs to be able to take back its recommendation. 
Policy & Procedures Manual Section V: 

Procedures for Completing Committee Recommendations 

April 29, 2011

Page 2 of 2

Recommendation 

Revision of Section V, PPM: Procedures for Completing Committee Recommendations 

Developing committee recommendations follows these broad steps: 

1. The committee prepares a recommendation or discussion document as agreed to in 

the committee work plan (see p. 32 PPM). 

2. The recommendation or discussions document is posted for public comment. 

3. During the Board meeting, the committee presents its recommendation for 

discussion by the full Board. 

4. At any point in the process prior to the Board’s vote on the status of the 

recommendation, the presenting committee may convene and vote to withdraw its 

recommendation, based on approval of this action by the majority of the members of 

the committee. 

5. Once presented, the Board votes on the committee recommendation. 

 Note: all language following #4 on p.20 remains unchanged and should be included. 

Committee Vote 

Motion: to accept the proposed amendment to the Policy and Procedures Manual 

Motion by: Barry Flamm Second: Calvin Walker 

Yes: 4 No: 0 Absent: 1 Abstain: 0 Recuse: 0